Audit of Offender Population Management

Internal Audit Report

378-1-272

January 11, 2013

Table of Contents

EXECUTIVE SUMMARY

Background

The Audit of Offender Population Management was conducted as part of Correctional Service Canada's (CSC) Internal Audit Sectors 2011-2014 Risk-Based Audit Plan. This audit links to a number of CSC's corporate priorities, which include: Safety and security of staff and offenders in our institutions and in the community; Safe transition to and management of eligible offenders in the community; and Efficient and effective management practices that reflect values-based leadership. Additionally, the audit of population management links to CSC's corporate risk: "The required level of safety and security within operational sites cannot be maintained."

This audit is material because population management encompasses most of the daily activities completed within the institution, including security reclassifications, segregation, double bunking, and transfers. Managing the offender population is of particular interest to CSC management in light of the anticipated increase in offenders resulting from legislative changes such as the Truth in Sentencing Act and the Safe Streets and Communities Act.

The purpose of this audit is to provide reasonable assurance that the controls in place support the effective management of the offender population and are adequate to ensure compliance with relevant sections of the Conditional and Correctional Release Act, its accompanying regulations, and relevant CSC policies and procedures.

The objectives of this audit were:

  • to provide reasonable assurance that the management framework in place, including the Population Management Strategy, supports the effective management of the offender population; and
  • to provide reasonable assurance that CSC is complying with relevant legislation and policy directives related to offender population management.

To achieve these objectives, the audit team reviewed key documentation and policies, conducted interviews with institutional, regional and national staff, and performed file reviews. The audit was national in scope and focused on compliance with CSC's Commissioner's Directives.

Conclusion

Overall, the audit found that a management framework to support population management was in place. Commissioner's Directives related to population management are consistent with the Correctional and Conditional Release Act (CCRA), and the Correctional and Conditional Release Regulations and policies are generally considered to be clear. A population management strategy has been created, institutional population management committees have been established and reporting and monitoring of population management is taking place at all levels of the organization. Lastly, plans have been put in place to support the infrastructure needs associated with growth of the offender population.

However, there are areas where additional work can be done to improve the management framework. These include:

  • defining and communicating what population management is;
  • communicating the population management strategy and providing more direction to the institutional population management committees;
  • providing more direction to sites on who is responsible for completing the double bunking placement assessments;
  • ensuring that population forecasts are more widely distributed; and
  • communicating plans to address infrastructure concerns that are anticipated to arise due to the increasing offender population.

Moreover, CSC was complying with CCRA requirements when placing an offender in segregation, and with policy requirements for approving security reclassifications and security overrides. However, CSC's compliance with many other areas of the Commissioner's Directives related to population management could be improved.

These include:

  • keeping the Offender Management system up to date when offender cell changes occur;
  • completing double-bunking placement assessments for all offenders prior to placing them in a double-bunked cell;
  • ensuring that all incompatibles are properly cross-linked and managed according to the policy;
  • completing security reclassifications within the established timeframes;
  • ensuring that conflict resolution attempts are properly documented in the offender's file; and
  • addressing concerns regarding the length of transfer times.

Recommendations have been made in the report to address these areas for improvement. Management has reviewed the report and agrees with its findings. A Management Action Plan has been developed to address the recommendations.


Office of Primary Interest Response

The Correctional Operations and Programs Sector agrees with the audit findings and the recommendations as presented in the report. We have prepared a detailed action plan to address the issues raised in the audit. More details on the actions to be taken have been provided for each recommendation. All actions to address recommendations are to be implemented by April 2013. It is important to note that, as a result of the Deficit Reduction Action Plan, some of the Correctional Operations and Programs Sector will need to be reviewed. At this time, this review is not anticipated to have an impact on the implementation of the recommendations within this audit. Nonetheless, Correctional Operations and Program Sector will monitor the impact of DRAP on offender population management activities and update the Audit Committee accordingly as a regular part of the MAP review process.

STATEMENT OF ASSURANCE AND CONFORMANCE

This engagement was conducted at a high level of assurance. i

In my professional judgment as Chief Audit Executive, sufficient and appropriate audit procedures have been conducted and evidence gathered to support the accuracy of the opinion provided and contained in this report. The opinion is based on a comparison of the conditions, as they existed at the time, against pre-established audit criteria that were agreed on with management. The opinion is applicable only to the area examined.

The audit conforms to the Internal Auditing Standards for Government of Canada, as supported by the results of the quality assurance and improvement program. The evidence gathered was sufficient to provide senior management with proof of the opinion derived from the internal audit.

__________________________________ Date: __________________
Sylvie Soucy, CIA
Chief Audit Executive

1.0 INTRODUCTION

1.1 Background

The Audit of Offender Population Management was conducted as part of Correctional Service Canada's (CSC) Internal Audit Sectors 2011-2014 Risk-Based Audit Plan. This audit links to a number of CSC's corporate priorities. These include: Safety and security of staff and offenders in our institutions and in the community; Safe transition to and management of eligible offenders in the community; and Efficient and effective management practices that reflect values-based leadership. Additionally, the audit of population management links to CSC's corporate risk "The required level of safety and security within operational sites cannot be maintained."

In 2007, the CSC Independent Review Panel presented a report titled A Roadmap to Strengthening Public Safety, which reviewed CSC's operational priorities, strategies, and business plans. One of the items included in the mandate of this panel was to review "current challenges with respect to safety and security in institutions…"1 The panel found that "when the Act [Correctional and Conditional Release Act (CCRA)] was drafted there was a single, homogeneous general population, but this has not been the case for some time…It is not uncommon to find four or five distinct subpopulations that cannot intermingle in a penitentiary, and two or three groups of offenders who for their own safety must be physically separated from other populations, either through administrative segregation or special units that separate them."2

The number of offenders affiliated with criminal organizations has grown substantially, which has contributed to the growing number of incompatible populations within the institutions.3 It is estimated that "9% of incarcerated offenders are involved in gang activity. Within our institutions, 24% of major institutional incidents and 14% of major incidents in the community involve gang members."4

Moreover, as a result of many legislative changes, CSC has seen its offender population increase. It is anticipating that its population will continue to increase over the next few years. The specific legislative changes, and the anticipated increases as a result of these changes, are discussed below. To address these increases CSC has installed or is planning to install a total of 2,378 additional beds into cells which were designed as single bunk cells. In the majority of the institutions, these double bunks are considered temporary measures until new units are built. It has been announced that a total of 53 sites will receive 2,702 new single cells by the end of 2014, of which 58 cells have been completed to date.

This audit is material because population management encompasses most of the daily activities completed within the institution and is part of CSC's core business. Based on CSC's 2012-2013 Report on Plans and Priorities, CSC's forecasted spending for 2011-2012 on Custody related activities was $1.92 billion out of a total budget of nearly $3 billion.

Risk Identification and Analysis

A risk analysis was completed by the audit team based on interviews and a review of past audits, policies and strategy documents.

Some of the concerns raised with the audit team during the risk analysis process included the following:

  • the management of incompatibles;
  • security level classifications;
  • the establishment of a population management committee at each site;
  • timely transfer of inmates;
  • the use of segregation; and
  • the quality of the double-bunking placement assessments.

These risks were considered in establishing the audit objectives and developing supporting audit tools for testing and gathering evidence.

2.0 AUDIT OBJECTIVES AND SCOPE

2.1 Audit Objectives

The audit objectives were:

  • to provide reasonable assurance that the management framework in place including the Population Management Strategy, supports the effective management of the offender population; and
  • to provide reasonable assurance that CSC is complying with relevant legislation and policy directives related to offender population management.

Specific criteria related to each of the objectives are included in Annex A.

2.2 Audit Scope

The Audit of Offender Population Management was national in scope and focused on the management of federal offenders while they are within the confines of an institution. All security levels were included within the scope of this audit. Visits took place in all regions. A total of 16 institutions were visited and an additional three sites were interviewed via video conference.

The audit covered the period from April 1, 2011 until fieldwork was substantially completed in April 2012. However, the files reviewed varied in terms of the time period covered. The number of files selected for this audit was based on ensuring sufficient audit coverage. Annex B provides a detailed summary of the number of files reviewed.

A number of Commissioner's Directives have been promulgated that relate to offender population management. Portions of various Commissioner's Directives were examined as part of the audit and are listed in Section 3.0 of this report.

Due to the large number of topics that fall under population management, the areas included in this audit were those considered to pose a higher risk to the organization or that have not been previously audited. The audit did not include offenders in the community and inmate movement, since the Internal Audit Sector has planned specific audits for these topics in its three-year risk-based audit plan.

Additionally, the case management process, which includes the intake assessment process, the institutional supervision framework and pre-release decision-making, were also excluded because these areas were recently audited.

Two additional areas, CSC's Anti-Drug Strategy and Employment, Programming and Leisure Activities were, also excluded from the scope of the audit. At this time, only employment is listed on our audit plan. These other areas will be considered during the next review of the risk-based audit plan.

3.0 AUDIT APPROACH AND METHODOLOGY

The audit team reviewed policies, procedures and legislation in place related to offender population management; the roles and responsibilities of the institution; resources; and monitoring and reporting.

The audit team also assessed compliance with key policies related to population management, such as Commissioner's Directive 550 Inmate Accommodation, Commissioner's Directive 710-6 Review of Offender Security Classification; Commissioner's Directive 568-7 Management of Incompatibles; Commissioner's Directive 568-3 Identification and Management of Criminal Organizations; and a small portion of Commissioner's Directive 709 Administrative Segregation and Commissioner's Directive 710-2 Transfer of Offenders. This assessment was completed through file reviews and interviews with staff at the national, regional and institutional levels.

Annex B lists and describes the techniques used to gather evidence to complete this audit.

4.0 AUDIT FINDINGS AND RECOMMENDATIONS

4.1 Management Framework for Population Management

We assessed the extent to which the management framework supporting the effective management of the offender population has been put into place. This included an examination of legislation, Commissioner's Directives, strategies, roles and responsibilities, monitoring and reporting, and resources.

4.1.1 Policy and Legislative Framework

We expected to find that Commissioner's Directives, policies and strategies existed, supported the offender population management process, and were consistent with the Correctional and Conditional Release Act and the Correctional and Conditional Release Regulations.

Commissioner's Directives related to Offender Population Management were consistent with the Correctional and Conditional Release Act (CCRA) and the Correctional and Conditional Release Regulations (CCRR).

CSC does not have a Commissioner's Directive specific to managing the offender population because this covers a large spectrum of CSC's mandate. Instead, there are a number of policies that relate to population management.

The audit team compared a number of Commissioner's Directives related to population management to the requirements of the CCRA and CCRR to ensure that they were consistent. We found that there was consistency between the CCRA, CCRR and applicable Commissioner's Directives. Annex B contains a complete list of Commissioner's Directives that were reviewed during the audit.

Overall, institutional staff felt that the policies surrounding population management were clear.

Of the institutional staff interviewed, 84% (132 of 157) felt that the policies surrounding population management were clear. Some of the areas identified as not being clear within the policies include the process to follow when offenders would like to disassociate themselves from a security threat group; criteria for formally recognizing offenders as incompatibles; and who should complete double-bunking assessments. This last point will be discussed further in Section 4.1.4.

CSC has created a population management strategy to assist with offender population management; however, half of the staff interviewed had not read the strategy.

CSC has developed a strategy entitled CSC's Population Management Strategy-It's Everybody's Business (the Strategy). This document was intended to provide "strategic operational direction and support to the regions in their efforts to effectively and efficiently manage the offender population."5 In May 2011, the Strategy was updated to include a sub-strategy on Gang Management. In addition to the gang management sub-strategy, there are sub-strategies that focus on Anti-Drug, Women Offenders, and Community.

As part of the Strategy and sub-strategies, a number of indicators (levers) have been created to help CSC identify operational priorities, enable strategic decision making and ultimately improve results. Additional information on CSC's levers will be presented in Section 4.1.5 of this report.

The 2012-2013 CSC Report on Plans and Priorities states that to achieve its planned results, "CSC will continue implementing its Population Management Strategy to provide strategic operational direction and support to regions as they work to manage the offender population, in order to protect the safety of inmates, staff and the public."6

When staff were asked during interviews if they had read the Strategy, only 53% (79 of 148) said that they had. A number of staff indicated that they were familiar with the Strategy in general but had not fully read it and were not familiar with all of its content. A number of staff who had not read the Strategy indicated that they were unable to locate the Strategy on CSC's internal information network.

For those staff who had read the strategy, their views of the document were mixed. Some felt the Strategy was too high level and did not provide enough specific guidance, while others felt it provided a good base from a strategic standpoint. For CSC to achieve its plans and priorities, it is critical that staff be familiar with the Strategy and understand how it relates to the job they perform, so that they can all work consistently towards the same goals.

4.1.2 Population Management Defined

We expected to find that CSC had defined population management and had clearly communicated the definition to its key stakeholders.

Although population management was described in many of CSC's documents, no single definition of population management has been established.

All staff interviewed were able to describe how they believe their role fits into offender population management. However, when asked whether CSC had defined population management only 62% (40 of 65) of senior management in the institutions and 56% (46 of 82) of the institutional staff interviewed felt that CSC had fully defined population management.

A review of CSC documentation did not reveal any official definition of population management. However, as discussed in the previous section, the Strategy provides a framework detailing what is included in population management. As such some staff interviewed use the Strategy to define population management. One reason given for not having an official definition is that population management encompasses most of CSC's daily activities.

Guidelines 005-1 Institutional Management Structure: Roles and Responsibilities, Annex A, provides a description of population management at a local level. This includes: "… an ongoing analysis of offender profiles, security intelligence and offender movements (i.e. internally between units or ranges, and transfers between institutions). The management of criminal gang affiliations/disaffiliations and management of incompatibles are also critical elements."7

Although these guidelines exist, they have not been updated to reflect the requirements of the Strategy and do not include the case management component of population management.

Without an officially approved and communicated definition there is a risk that CSC's approach to population management may become fragmented, making it increasingly difficult for CSC to carry out its plans and priorities.

4.1.3 Population Management Management

We expected to find that population management committees were in place, had a clear mandate, and understood their roles and responsibilities.

All but one site visited had established a population management committee. However, the roles and expectations of these committees are not always clear to the members.

The Strategy requires each institution to establish a population management committee chaired by the deputy warden. We found that all sites visited except one had established a population management committee. The Strategy does not indicate how often the committee is required to meet. However, we found that half of the sites were holding meetings at least monthly, while the other sites were holding meetings every two months or more.

During the interviews, we were informed that the expectations of the institutional population management committee are not always clear. As a result, sites are holding meetings to talk about what they think they should be discussing. Some sites questioned the value of having population management meetings at the site level. They do not feel that they are adding value, since many of the items discussed during these meetings are part of their day-to-day work and are discussed in other forums.

We found that there are a number of unique challenges in the Prairies region because it encompasses the Northwest Territories, Alberta, Saskatchewan, Manitoba and a portion of Ontario. As a result, additional population management meetings are held within each of the provinces. These meetings bring together all of the institutions in the province and CSC staff who work in the community, to discuss population management concerns specific to the province.

Good Practice

The Prairies region had sent a template to the institutions in their region, to help provide additional structure and guidance for the population management meetings.

4.1.4 Roles and Responsibilities

We expected to find that roles and responsibilities specific to the areas8 being audited have been clearly defined in the Commissioner's Directives.

Roles and responsibilities specific to the areas being audited have been clearly defined in policy. However, clarification is required related to who is responsible for completing the double-bunking assessments.

The audit team compared the areas being audited to the related Commissioner's Directives to determine whether responsibilities for each of the areas being audited were identified. We found that in all but one area related to the audit, a position had been identified as being responsible for each of the key areas reviewed.

During the interviews, we found that the policy surrounding who is responsible for completing the double-bunking assessments was not clear. Commissioner's Directive 550 Inmate Accommodation states that "the Institutional Head may designate a person responsible for accommodation management within each unit. This person shall normally not be in a position lower than a Correctional Supervisor."9 A further section within the policy indicates that "the staff member responsible for placing an offender in double occupancy shall ensure that a double occupancy assessment has been conducted prior to each placement."10

The responsibility for completing the double-bunking assessments was not consistent from site to site. At some sites, the correctional manager completed the assessments while at other sites, they were completed by the correctional officer II. This lack of clarity has caused conflicts at some sites.

One reason we were given for institutional management wanting the correctional officer II to complete the assessments was that they have more interaction with the offenders and are in a better position to know if an issue may arise if specific offenders are placed together. Additional direction should be provided to sites that have double bunking to ensure that the assessment responsibilities are clear.

4.1.5 Reporting and Monitoring

We expected to find that monitoring of the Strategy, including its levers, was taking place and that the data was being used to assist CSC in managing its offender population.

Reporting and monitoring of the strategy was taking place at the national, regional and site levels through the population management levers. However, there were concerns at the regional and site levels related to the usefulness of some levers.

As discussed previously, CSC has developed a number of levers to be used to identify issues, challenges and gaps. There are 15 levers in the main part of the Strategy, in addition to levers in each of the sub-strategies. Some examples of the core-strategy levers include:

  • comparison between the Custody Rating Scale recommended security level and Final Offender Security Level decision (Initial security level decisions only);
  • the number of admissions (Warrant of Committal, Revocation) in relation to the number of releases;
  • bed capacity; and
  • amount of double bunking.

Overall, the reporting that takes place at the institutional level consists of sending their population management meeting minutes to Regional Headquarters (RHQ). Through interviews, we also found that there was a significant amount of information reporting taking place at the site level, which includes the information shared at the morning briefings.

At the regional level, data on population management was being collected and analyzed. Once this was completed, sites are informed of the analysis and asked to provide explanations/action plans if the data showed a change in one or more of the levers. Regions were also submitting a quarterly report to National Headquarters (NHQ) detailing the region's population statistics and an analysis of regional.

Data related to population management is also analyzed at the National level. The lever information as well as population trends are reviewed to determine where CSC should focus its attention and resources. When positive or negative trends were identified, additional analysis was conducted to determine the reasons behind the identified trends and what actions (if any) needed to be undertaken to address the concern. Nationally, bed space availability was also being monitored regularly to help CSC further manage its population pressures.

Although the levers have been a key tool used to monitor population management, both RHQ and the sites expressed concerns to the audit team related to the levers. One concern is that there are too many levers, making it difficult to focus ones attention. It was suggested that there be fewer levers or that they be prioritized to allow for a more focused approach when analyzing the information.

Another concern related to the applicability of all levers at some sites. Depending on the security level and the purpose of a given site (i.e. treatment and reception centres), not all of the levers carry the same importance. However, sites felt they were expected to show positive results in some areas that are not a priority (i.e. day parole releases from a treatment centre).

4.1.6 Population Forecasting

We expected to find that CSC was preparing and providing accurate and useful population forecasts to all levels, to assist with the decision-making process.

Regional population forecasts by security level were being prepared by NHQ; however, forecasts were not consistently being provided to the institutions on a regular basis.

Forecasts are prepared annually by the Corporate Services Sector as part of the National Capital, Accommodation, and Operations Plan (NCAOP) Treasury Board submission. Moreover, in September 2012, CSC produced an Accommodation Plan covering the years 2013 to 2018. This accommodation plan presents population growth forecasts as well as quantity and location of new living units to accommodate the increase in the inmate population. The accommodation plan also states that "the unit build program includes ancillary projects to upgrade institutional elements such as: expanded food services, expanded parking space, increased program space, additional space for staff and core utilities such as water, sewer, electrical, emergency generators, heating plants, etc." The accommodation plan further states that "the most recent population forecasts suggest that after completion of the new units, CSC should have sufficient overall capacity until the end of fiscal year 2018-19."

These forecasts are broken down by region and security level but not by individual institution. They are prepared based on past growth and take into account events that are specific to a region. They could include recent operations targeting a specific criminal organization or a police focus on an activity that is anticipated to increase the federal prison population.

As per CSC's 2013-2018 Accommodation Plan, CSC has committed to continue to monitor offender population growth, revisit forecast assumptions, and revise hiring plans and review staff to offender ratios as needed. Given that it typically takes four to five years to bring major new infrastructure elements on line, CSC has committed to return to Cabinet in fiscal year 2014-2015 with a report on population trends and to seek approval of its post 2017-2018 Accommodation Plan.

The Correctional Operations and Programs Sector (COPS) also prepares 30-, 60- and 90- day forecasts that are based on past trends and the number of forecasted releases and admissions. As with the Corporate Services forecasts, this data is broken down by region and security level but is not institutional-specific. We were informed that these forecasts have not been widely distributed. When asked, sites were still anticipating that there would be an increase in the offender population as a result of the Truth in Sentencing Act and the Safe Streets and Communities Act and did not seem to be aware of the revisions to the population forecasts.

Among institutional management interviewed, 60% (29 of 48) stated that they had received population forecasts from either NHQ or RHQ. Forty percent (two out of five) of the Assistant Deputy Commissioners, Institutional Operations (ADCIO) (or delegates) stated that they received population forecasts. In discussions with institutional staff who received forecasts, we were told that the usefulness could be improved if they were more accurate and site-specific instead of couched at the regional level. Sites indicated that without site-specific forecasts, it is difficult to adequately prepare for population changes.

4.1.7 Resources

We expected to find that CSC had plans in place to ensure it meets the needs of the anticipated growing offender population.

CSC has established plans to address the needs of a growing offender population; however, institutional staff felt that CSC was not fully prepared to deal with the impact of the population changes.

As discussed previously, there have been a number of recently enacted legislative changes that are predicted to result in an increase in the offender population and have given rise to a number of policy changes for CSC staff.

There have been a number of initiatives undertaken at a national level to address several concerns associated with an increasing offender population. Since 2010, an Infrastructure Renewal Committee has been created to monitor and provide advice to the Executive Committee (EXCOM) of Correctional Service Canada on the effective implementation of measures in response to legislation, trends, and best practices. This committee is supported by a team, headed by senior officials, whose role is to work with operational sites, regions and sectors at National Headquarters to ensure appropriate levels of staff, accommodation space and other resources are in place to allow for effective case management, program delivery and community supervision as the population increases.

As well, to address site specific resource requirements, a process of resource allocation based on a business case approach has been devised to meet pressures associated with new legislation. Additionally, in late 2011, CSC Commissioner in a general communication to the staff spoke of various initiatives that the CSC had underway to meet the growing population. Specifically, he referred to:

  • hiring of additional staff across the country;
  • through this hiring, the delivery of correctional, education and work programs was being expanded to assist offenders in their rehabilitation, and guidelines were in place to ensure the right offenders are assigned to the most appropriate programs;
  • construction work was now underway at some sites as part of the plan to expand many of the existing penitentiaries.

Finally, as discussed under 4.1.6, in September 2012, following the completion of the fieldwork for this audit, CSC released an accommodation plan which has been developed to address the anticipated population increases, the infrastructure renewal requirements and the need to operate and maintain its infrastructure for the foreseeable future.

During interviews with institutional staff on the subject of legislative changes, the audit team found that 38% of Senior Management (23/60) and 57% of staff had concerns that CSC might not be ready yet for the impact of all these changes. With respect to the predicted growth in the offender population, 61% of Wardens and Deputy Wardens had concerns.

The main areas of concern identified by staff at the time of the audit included insufficient infrastructure, such as a lack of office space when the number of staff increases; kitchen facilities that are not being large enough to handle the additional offenders; insufficient space for programming; and too few amenities for offenders. Many of the institutions were built on the assumption that there would only be one offender per cell but with double bunking this is no longer the case. As a result, many of the common areas are unable to comfortably accommodate the additional demand. Many of the sites visited have undertaken projects or have devised plans to address several of the above-noted concerns.

Additionally, staff noted concerns related to finding meaningful employment for offenders within the institution and having insufficient space for inmate activities when they are not in programming or working. The last major area of concern identified by staff was bed space. However, this concern was not consistent from site to site, or from region to region. For those regions that have not seen large increases in their offender population, bed space was not of great concern. CSC is currently in the process of building an additional 2,700 beds11 throughout the country, which is meant to address the bed space concerns.

Nine of the 18 sites indicated that they have been in a situation where offenders arrived on site and they did not have a bed for them. Eight of these sites were either a reception/assessment site or a temporary detention site, which means they must take all offenders who arrive. At sites where contingency plans were discussed, all but one site had developed a contingency plan in the event there were too many offenders. Examples of the plans include using Private Family Visit houses; using health care beds; and creating dormitory style accommodations in the gymnasium. Generally, these plans have not been well documented at most sites.

Corporate Services has provided a number of documents to senior management both at the NHQ and regionally. Some of the documents detailed resource allocations based on business cases for the implementation of the Truth in Sentencing Act. Moreover, there have been plans made to address the growing offender population, such as building additional units as discussed previously and adding additional general-purpose buildings at a number of institutions once all of the new units have been completed. These general-purpose buildings are intended to address many of the infrastructure concerns identified by staff during the audit. Staff interviewed felt that they were not being fully informed of the plans developed to address many of the concerns raised.

Conclusion

Overall, the management framework in place supported the effective management of the offender population.

We found that:

  • the policies in place at the time of the audit were consistent with the CCRA and CCRR;
  • monitoring of population management was taking place and the results were being used to assist with managing the population;
  • for the most part, policies surrounding population management were clear, as were the roles and responsibilities, although, it is not clear who is responsible for completing the double-bunking placement assessments;
  • a population management strategy has been created, although it has not been widely distributed or read at the institutions;
  • population management committees have been established at the national, regional and site levels; however, the expectations of the institutional committees were not always clear;
  • CSC has initiated plans and other initiatives to support the growth in the offender population. However, these plans and initiatives have not been well communicated at site level.

Although the areas mentioned above met or partially met the audit expectations, we found that:

  • CSC's definition of population management has not been clearly communicated; and
  • population forecasting could be distributed more broadly and frequently.

Recommendation 1 12

The Assistant Commissioner, Correctional Operations and Programs, should update, communicate and create awareness surrounding the Population Management Strategy.

Office of Primary Interest Response

We agree with this recommendation. By the end of the fiscal year, NHQ will develop and implement a communication strategy to create awareness of the National Population Management Strategy. As part of this awareness process CSC's definition of population management will be made more visible and additional information will be provided to the Institutional committees which will help provide additional structure to their meetings.

4.2 Compliance with Policy

We assessed the extent to which CSC was compliant with relevant legislation and policy directives related to offender population management.

4.2.1 Cell Assignments

We expected to find that the processes related to inmate cell assignments were in compliance with applicable Commissioner's Directives.

Offender cell changes are not being updated in a timely manner in the Offender Management System (OMS).

Commissioner's Directive 550 Inmate Accommodation requires that inmate placements be recorded in OMS in a timely manner. Updating OMS on a timely basis is important as it ensures CSC can quickly access to up-to-date information, use it to verify the cell location of an incompatible by someone who is not at the institution, and determine the cell location of an individual during a security incident.

A comparison was made between the on-site inmate location records (count boards) and OMS records, to determine whether OMS was being updated in a timely manner. We found that only 29% of the sites visited had updated OMS in a timely fashion.13

Sites indicated that updating OMS was not always a priority for staff when there were significant temporary cell movements taking place, because they can consult the on-site documentation when determining the cell location of an offender.

Overall, single-cell waitlists existed. However, a conclusion cannot be made on whether CSC is following policy when assigning single cells.

As per Commissioner's Directive 550 Inmate Accommodation, when double bunking is in place, a single-cell waitlist should be established and single-occupancy accommodation should normally be assigned on a first come, first served basis through a unit-based or institution-wide waiting list.14 At each of the sites with double bunking, the audit team requested a copy of the current single-cell waitlists as well as a copy of the previous month's wailists. Sites that had waitlists were not able to provide the requested documentation, as the waitlists are updated on an ongoing basis. As a result, we were unable to verify whether single-accommodation cells are being assigned on a first come, first served basis. However, we were told at some sites that the priority is given to offenders serving a life sentence.

We found no evidence that offenders were being inappropriately transferred from a single cell to double-bunked cell.

The audit team reviewed a list of all offenders who were double-bunked at the time of the audit to determine which of these offenders were in a single-bunked cell the previous month. This information was used to determine which offenders had been moved from a single cell to a cell where they were double-bunked.

For those offenders identified, the sites were asked to provide the reason for the cell change. All sites were able to provide sufficient justification to support the movement. Some of the reasons for the offenders moving from a single to a double-bunked cell included: the offenders requested to be moved off the range or to a house that is double-bunked; the offenders were moved from segregation back into general population; or the offenders were in a temporary location because they had just arrived at the institution.

All offender placements in segregation were in compliance with the requirements of the CCRA/Commissioner's Directive.

Administrative segregation is "the involuntary or voluntary separation, when specific legal requirements are met, of an inmate from the general population, other than pursuant to a disciplinary decision."15 Per section 31(3) of the CCRA:

"The institutional head may order that an inmate be confined in administrative segregation if the institutional head is satisfied that there is no reasonable alternative to administrative segregation and he or she believes on reasonable grounds that

  1. the inmate has acted, has attempted to act or intends to act in a manner that jeopardizes the security of the penitentiary or the safety of any person and allowing the inmate to associate with other inmates would jeopardize the security of the penitentiary or the safety of any person;
  2. allowing the inmate to associate with other inmates would interfere with an investigation that could lead to a criminal charge or a charge under subsection 41(2) of a serious disciplinary offence;
  3. allowing the inmate to associate with other inmates would jeopardize the inmate's safety."16

The audit team found that 100% (166 of 166) of the segregated offender files reviewed had a reason for segregation on file that was in compliance with the requirements of the CCRA.

For security reasons, segregation is used within the institution to help manage the offender population. This could comprise offenders who are unable to integrate into the population for various reasons, including identified incompatibles in the population. In these cases the offender cannot re-enter the general offender population until their incompatibles have been transferred or until they themselves have been transferred.

Prior to placing an offender in segregation, there are three alternatives that must be considered and documented: 1) Confinement to cell; 2) Mediation and 3) Change of cell/range/unit.17 Our file review found that 64% of the files contained evidence to demonstrate that all three alternatives were considered. As segregation is considered to be a last resort, it is important to look at all alternatives first.

As the offender population increases and institutions start to reach capacity, it may become more difficult to move offenders between cells/ranges/units. While visiting some sites, we were told that, due to limited bed space, incoming offenders are being placed in units where there is an available bed instead of the unit that would be best for the offender. Over time, there is potential for increased conflicts, resulting in more offenders requiring placement in segregation and eventually, a transfer to another institution.

We found no evidence of offenders being double-bunked in segregation at the institutions visited.

Commissioner's Directive 550 Inmate Accommodation does not allow two offenders to be placed in a segregation cell under 23-hour confinement unless approved by the Commissioner.18 We found no evidence that offenders were being double-bunked in segregation at the sites visited as part of the audit.

Policies related to housing incompatible and co-convicted offenders separately cannot always be followed.

Commissioner's Directive 550 Inmate Accommodation and Commissioner's Directive 568-7 Management of Incompatibles state that "Inmates identified as co-convicted and under current sentence for an offence resulting in serious harm or death shall not be accommodated in the same range or in the same unit, or in the same institution, unless the Institutional Head approves such accommodation..."19 and "Incompatible offenders shall not normally be transferred to the same institution unless the risk can be managed...[and] incompatible offenders shall not be housed in the same unit, range or cell."20

During the course of the audit, we found that this area of the policy was not always being followed. We found four co-convicted offenders living in the same institution, only one of which had evidence of appropriate approvals. As well, we found 15 offenders living in an institution with at least one identified incompatible. Of these 15, six had an identified incompatible already at the institution when the transfer took place. Three of these offenders were residing at either a treatment centre or a reception site. As each region has one treatment centre, an inter-regional transfer would be required to keep incompatible offenders apart. Of the three remaining offenders, one was living in the same range/unit with an identified incompatible, while the remaining two offenders were in the same institution but in a different range/unit.

During the interviews, we were told that at reception sites and treatment centres, it is not always possible to keep co-convicted and/or incompatible offenders in different units. One reason for this is that reception sites are not able to control when offenders arrive. This is of particular concern when large police operations are undertaken and a number of offenders are convicted at the same time. In light of the offender profiles at certain institutions, there are times when co-convicted/incompatible offenders will be housed at the same institution because there is no other location that would be able to accept them (unless they were put into segregation).

Although an inter-regional transfer is an option available to staff, it can take a significant amount of time to transfer an offender out of the region, as discussed in section 4.2.5 of this report.

4.2.2 Double Bunking

We expected to find that offenders were placed in double-bunked and double-occupancy cells in compliance with Commissioner's Directive 550 and policy bulletin 315.

Just over half of the double-bunking assessments were completed prior to an inmate being placed with another offender in a double-bunked cell.

Commissioner's Directive 550 Inmate Accommodation requires that, when an offender is being considered for double bunking, a double-bunking placement assessment must be completed prior to each placement.21

Of the 216 double-bunked offenders' files we reviewed, 56% (120 of 216) had a double-bunking placement assessment on file for their current cellmate.

In addition to the requirement that an assessment be made, the individual completing the assessment must consider the following criteria when completing the assessment:

  • compatibility
  • vulnerability
  • predatory/permissive behaviour
  • preventative security considerations
  • medical information
  • criminal profile
  • psychological information.22

We found that 73% (94 of 120) of the files with a current assessment on file showed evidence that all of the criteria were considered prior to the offender being double bunked. While reviewing the templates developed by each site, it became evident that additional guidance is needed to ensure that staff evaluates each of the criteria in a consistent manner. We found that at some sites, the template being used for the double-bunking assessment was missing one or more of the required criteria and, as a result, their assessments were considered incomplete.

The completion of a double-bunking assessment for each offender when new cellmates are being considered is critical to ensuring that all relevant information is evaluated prior to placing two offenders in the same cell. Although it is not possible to predict all conflicts and violence between double-bunked offenders, completing the assessments will help identify potential areas of concern.

In discussions with sites that had double-bunked offenders, we were informed that a standard double-bunking assessment form has not been provided by NHQ. As a result, it has been left to the regions and/or each site to create its own form. For example, the Ontario region completed a review of double bunking and subsequently developed and provided a standard double-bunking assessment template to each site in the region.

As many of the sites visited have created their own templates, we found that each of the sites had elements of a good template. These elements include the names of all offenders being considered for double bunking; the date each offender being considered for double bunking was interviewed; all seven criteria identified, with points to consider for each criteria; and questions on whether the offender has any identified incompatibles or has been co-convicted, since both of these situations require additional attention when considering an offender's cell placement.

Double bunks installed at all sites visited were properly approved.

Commissioner's Directive 550 Inmate Accommodation and policy bulletin 315 require that approval be obtained prior to a site increasing its double-bunking capacity. In regions where less than 20% of the overall rated capacity is double-bunked, the RDC is required to approve any increases to the number of double bunks, while in regions where more than 20% of the offender population is double-bunked, the Commissioner's approval is required. All nine sites visited where double bunking was being used had proper approvals in place.

4.2.3 Gangs, Incompatibles and their Management

We expected to find that processes in place that relate to incompatibles and criminal organizations were in compliance with Commissioner's Directives.

Listed incompatibles were not consistently being cross-referenced in the OMS.

Incompatibles are defined as "offenders who, for whatever reason or situation, pose a threat to the safety and well-being of each other and hence may pose a safety risk to the institution and to others."23 When an incompatibility is entered on one offender's file, policy requires that the corresponding offender's name be listed on the other offender's file.24 Through file review, we found that 13% (14/109) of the offenders' files we reviewed did not have all incompatibles properly cross-referenced. We were told that cross-referencing is a manual process that can be overlooked or forgotten. This is of significant concern as an identified incompatibility may be missed when a file review is taking place, particularly when a transfer is being considered, thus threatening the safety of the offender and the institution.

Incompatible reviews were not taking place on a yearly basis, as required by policy.

At the time of the audit, Commissioner's Directive 568-7 Management of Incompatibles required that all incompatibilities be reviewed at least annually to determine the validity and continued relevance of the incompatibility. Shortly after the completion of our fieldwork,Commissioner's Directive 568-7 Management of Incompatibles was revised to remove the yearly review requirement. The security intelligence officer is now required to "review the validity of offender incompatibilities for their continued relevance prior to any significant decisions being made."25

We found that only 16% (20 of 127) of the offenders with incompatibles had evidence in their file that the required yearly review had taken place. Staff indicated that based on the number of identified incompatibles, it would be very difficult and time consuming to review all incompatibles on a yearly basis. One specific concern staff expressed was related to situations where one offender may not know he/she has been identified as an incompatible to another offender. Determining whether this incompatibility still exists becomes more difficult when staff are unable to talk to both offenders regarding the incompatibility.

Although all incompatibles are not being formally reviewed, we were informed by the security intelligence officers that when they are consulted for transfers and security reclassifications, they look to see if an offender has any incompatibles and may review the validity of incompatibles, depending on the situation. As well, when offenders first arrive at an institution, they are encouraged to disclose any incompatibilities.

During the interviews we heard that there was a lack of consistency when it came to the amount of support required before an incompatible would be listed. At the time of the audit, there was no set process or established criteria for listing incompatibles. It is therefore was up to each individual security intelligence officer to determine how much support is required before listing an incompatible. Staff felt that this has resulted in a number of incompatibles being listed that are not true incompatibles. If an offender has too many incompatibles listed, it can become difficult to transfer that offender to another institution, or can prevent another offender from being transferred to the institution since policy discourages sites from housing incompatibles at the same institution.26

Information sharing with outside agencies was based on working relationships the intelligence staff have developed.

With the exception of the Québec region, where information sharing and gathering with outside agencies such as provincial jails and police is centrally located, information sharing was based on relationships that staff at each of the sites have developed. Sites indicated that information concerning offenders known by outside agencies, such as incidents while in provincial jails, incompatibilities and gang involvements, can at times be difficult to obtain unless they have established relationships with individuals in these organizations.

Conflict resolution was being offered but not documented.

When a conflict arises between offenders "conflict resolution shall normally be considered to allow the incompatible offenders to resolve their conflict."27 A review of recently added incompatibles was completed to determine if there was evidence in the offender's file that conflict resolution was offered and/or took place. We found evidence of mediation in only 21% (19 of 92) of the files reviewed. However, 95% (61 of 64) of the staff interviewed stated that mediation was offered to offenders to resolve the incompatibility issues.

As discussed previously, it is not possible to mediate all incompatibilities, particularly when one offender does not know that he/she is considered an incompatible to another offender. Staff expressed that identifying this information could further jeopardize the safety of the offender.

As with other sections of this policy, the requirements for when conflict resolution should be offered recently changed. The policy now reads "conflict resolution will be considered where appropriate to allow the incompatible offenders to resolve the reasons for their incompatibilities."28 Successful mediation helps to reduce the number of incompatibles, giving sites more options when managing their population.

Staff felt they received timely updates regarding gangs and incompatibles.

Gangs and incompatibles have a large impact on how staff manage the offender population. As such, it is critical that staff receive timely information on gangs and incompatibles. Of the staff interviewed, 81% (39 of 48) felt that they received timely updates on gangs and incompatibles from the intelligence staff. Many of the staff felt this information was extremely useful as it provided them with more information when dealing with the offenders.

4.2.4 Security Classification

We expected to find that the management of offender security classification reviews were completed and in compliance with the applicable Commissioner's Directive.

Offenders' security reclassifications were not always being completed within the required timeframes.

Commissioner's Directive 710-6 Review of Inmate Security Classification requires that an inmate's security classification be reviewed at least every 12 months except for inmates classified as minimum security; inmates classified as medium or maximum security and serving a life sentence for first or second degree murder; and women offenders classified as maximum security who are not serving a life sentence for first or second degree murder.29

In the case of offenders serving a life sentence, a security review must take place every two years. Maximum security women who are not serving a life sentence are to have a review every six months.30 In the February 2010 version of this Commissioner's Directive, minimum security offenders were to be reviewed when there was reason to believe the classification needed to be changed.31

The audit team found that only 68% (124 of 182) of the security reviews were completed within the established timeframes. For those reviews that were late, some were a few days late while others were late by a few months. It is important that security reviews take place within the established timeframes to help encourage offender reintegration, since a security level change is generally required prior to an offender being approved for transfer to a different security level institution. Although an offender's security level will not change with every review, completing the review within the required timeframe helps to ensure that offenders are being housed at an appropriate institution (i.e. proper security level and proper amount of security).

Overall, the staff member approving the security reviews had the appropriate level of authority.

Policy requires that the Institutional Head authorize an offender's security classification. However, this may be delegated to the deputy warden, except in cases where the offender is convicted of first or second degree murder or if the offender is female.32 We found that in 97% (177 of 182) of the files reviewed, the individual approving the security review was at the appropriate level. In all five cases where the incorrect position approved the classification, the deputy warden approved the security review when the offender was convicted of first or second degree murder.

Security Rating Scale overrides were being completed as per policy.

As part of the security review process, a Security Reclassification Scale (SRS) for men and a Security Reclassification Scale for Women (SRSW) are completed. The SRS and SRSW are "research-based tools developed to determine the most appropriate level of security at key points throughout an offender's sentence."33 These scales produce a security rating of maximum, medium or minimum. Using this information, the parole officer recommends a security level.

Of the files reviewed, 25% had a security level approved that was different from the SRS/SRSW results. In all cases, there was appropriate justification in the file to support the decision not to follow the SRS/SRSW results. We were told at the sites that the override/under-ride34 process was used when the SRS/SRSW did not account for certain information thus allowing for a more appropriate placement and a more accurate evaluation of the offender's security needs.

4.2.5 Transfers

We expected to find that transfer warrants were executed within a reasonable length of time.

The average length of time for transfers to take place was 6.8 days for penitentiary placements and 7.5 days for non-penitentiary placements.

Penitentiary placements35 typically take place when an offender enters the federal justice system or when an offender has had his/her parole revoked and has been brought back to a federal institution. Commissioner's Directive 710-2 Transfer of Inmates does not specify how long it should take to transfer an offender once the decision has been approved. However, 49% (28 of 57) of the staff interviewed had concerns regarding the length of time between transfer approval and the actual move to a new institution.

Staff members did not have a consistent answer when asked how long they felt the transfer should take. Some felt it should take a week or two while others said a month or more. Through interviews, we found that there was not a consistent approach to when a transfer approval was signed. At some sites, the approval was signed once it was confirmed that the offender was leaving while at other sites, the approval was signed as soon as the offender transfer was approved, regardless of when the offender was actually being moved. This difference in approach helps to explain the disconnect between the length of time it takes for a transfer to take place and the concerns expressed by the institutional staff.

During the interviews, we heard that there are a number of factors that can slow down the movement of an offender. These factors can include a lack of bed space at the receiving institution; the offender starting a program at the sending institution resulting in the transfer being delayed until the program is completed; incompatibility issues between the offender being sent to an institution and an offender already at the institution; and a lack of space on the intra-regional transfer bus or inter-regional flight. It was explained to the audit team that intra-regional bus transfers and inter-regional flight seats are based on space and priority. Women offenders,36 mental health offenders, offenders with pending court dates and offenders who are in segregation at the sending institution take priority and can move non-priority offenders down the wait-list.

Transfers that take a long time to occur have a number of impacts on an institution and its offenders. In some cases where offenders have been in segregation for a significant length of time, the only way to safely move them out of segregation is to transfer them to another institution. However, if this cannot happen in a timely manner, the institution has one less bed available in their segregation range to assist with managing the population. As well, in some cases, an offender will be held in segregation until his/her incompatible can be moved to another institution. When these transfers do not take place, the offender may remain in segregation. As previously discussed, segregation is only to be used as a last resort.

As not all institutions have the same offender programming available, a transfer may be the only way that an offender can take the programming needed to assist with his/her re-integration. If the transfer does not take place and the offender does not participate in the required programming, this could delay his/her release on day or full parole.

In addition, for offenders who are waiting for a transfer to a lower security level, there are concerns that some of these offenders may be influenced by the higher security offenders and undertake actions resulting in an increase in their security classification. Concerns were also expressed that offenders waiting for transfer may become demoralized, resulting in behavioural changes and possibly jeopardizing the safety of both the offender and the institution.

Offenders have been sent to institutions that did not have the best re-integration potential.

Eighty percent (20 of 25) of the wardens and deputy wardens interviewed said that they have had to send an offender to an institution that they felt may not have offered the best re-integration potential for the offender. As discussed previously, there are a number of factors that can delay a transfer and there were a number of concerns that could arise if a transfer takes too long.

Conclusion

We found that overall, CSC was complying with relevant legislation but not with some policy directives related to offender population management.

Throughout the audit, we found the following:

  • timeliness of transfers was a concern;
  • conflict resolution was being offered but not documented in the offenders file;
  • security reclassifications were properly authorized, but were not being completed within the required timeframe;
  • offenders' incompatibilities were not being reviewed on a yearly basis;
  • cell assignment changes were not being updated in a timely manner.

Since our audit, a number of policy changes have occurred that could assist in resolving many of the above-noted compliance issues. However, two areas have not been addressed by these policy changes:

  • incompatibilities were not being properly cross-referenced between offender files; and
  • double-bunking placement assessments were not being completed for each new cell assignment.

Recommendation 2 37

The Regional Deputy Commissioners should ensure that the policies surrounding incompatibles are being followed.

Office of Primary Interest Response

We accept this recommendation. By December 2012 a review of all incompatibles will be undertaken to ensure that incompatibles lists are accurate and current. As well, security policies will be reviewed to ensure that there is clear direction regarding the management and record-keeping of co-located incompatibles. Lastly, compliance with policy requirements will be monitored semi-annually by the regions.


Recommendation 338
The Assistant Commissioner, Correctional Operations and Programs, should clarify who should be completing the double-bunking placement assessments and support the Regional Deputy Commissioners in having a process in place to ensure that double-bunking assessments are completed.

Office of Primary Interest Response

We agree with this recommendation. To address this recommendation policy will be reviewed to ensure that the responsibilities for double-bunking assessments are clarified. In the interim we have issued a security bulletin to provide direction to correctional staff. To ensure double-bunking assessments are completed, a standardized tool will be developed and regional and local managers will be provided with Query reports to confirm the completion of double occupancy assessments. The recommendation will be fully addressed by December 2012.

5.0 OVERALL CONCLUSION

Overall, the audit found that a management framework to support population management was in place. Commissioner's Directives related to population management are consistent with the Correctional and Conditional Release Act (CCRA) and the Correctional and Conditional Release Regulations, and the policies are generally considered to be clear. A population management strategy has been created, institutional population management committees have been established and reporting and monitoring of population management is taking place at all levels of the organization. Lastly, plans have been put in place to support the infrastructure needs associated with growth of the offender population.

However, there are areas where additional work can be done to improve the management framework. These include:

  • defining and communicating what population management is;
  • communicating the population management strategy and providing more direction to the institutional population management committees;
  • providing more direction to sites on who is responsible for completing the double bunking placement assessments;
  • ensuring that population forecasts are more widely distributed; and
  • communicating plans to address infrastructure concerns which are anticipated to arise due to the increasing offender population.

Moreover, CSC was complying with CCRA requirements when placing an offender in segregation, and with policy requirements for approving security reclassifications and security overrides. However, CSC's compliance with many other areas of the Commissioner's Directives related to population management could be improved.

These include:

  • keeping the Offender Management system up to date when offender cell changes occur;
  • completing double-bunking placement assessments for all offenders prior to placing them in a double-bunked cell;
  • ensuring that all incompatibles are properly cross-linked and managed according to the policy;
  • completing security reclassifications within the established timeframes;
  • ensuring that conflict resolution attempts are properly documents in the offender's file; and
  • addressing concerns regarding the length of transfer times.

Recommendations have been made in the report to address these areas for improvement. Management has reviewed this report and agrees with the findings. A Management Action Plan has been developed to address the recommendations.

Office of Primary Interest Response

The Correctional Operations and Programs Sector agrees with the audit findings and the recommendations as presented in the report. We have prepared a detailed action plan to address the issues raised in the audit. More details on the actions to be taken have been provided for each recommendation. All actions to address recommendations are to be implemented by April 2013. It is important to note that, as a result of the Deficit Reduction Action Plan, some of the Correctional Operations and Programs Sector will need to be reviewed. At this time, the plans presented in the management action plan are not anticipated to have an impact the implementation of the recommendations within this audit. Nonetheless, Correctional Operations and Program Sector will monitor the impact of DRAP on offender population management activities and update the Audit Committee accordingly as a regular part of the MAP review process.

ANNEX A

AUDIT OBJECTIVES AND CRITERIA

OBJECTIVES CRITERIA
1.To provide reasonable assurance that the management framework in place including the Population Management Strategy supports the effective management of the offender population. 1.1 Commissioner's Directives, policies and strategies exist, support the offender population management process and are consistent with the Correctional and Conditional Release Act (CCRA) and Correctional and Conditional Release Regulations (CCRR).
1.2 CSC has defined population management and has clearly communicated it to key stakeholders.
1.3 Population management committees are in place, understand their role and responsibilities, and have a clear mandate.
1.4 Roles and responsibilities specific to the areas being audited have been clearly defined in the Commissioner's Directives.
1.5 Monitoring of the strategy and its levers is taking place and the data is being used to assist CSC in managing its offender population.
1.6 CSC is preparing and providing accurate and useful population forecasts to all levels to assist with the decision-making process.
1.7 CSC has plans in place to ensure it meets the needs of a growing offender population that is anticipated as a result of legislative changes (i.e. case management staff, intervention staff, correctional staff, institutional services, etc.).
2. To provide reasonable assurance that CSC is complying with relevant legislation and policy directives related to offender population management. 2.1 Processes related to inmate cell assignments are in compliance with Commissioner's Directives.
2.2 Offenders are placed in double bunks and double-occupancy cells in compliance with CD 550 and Policy Bulletin 315.
2.3 Processes undertaken which relate to incompatibles and criminal organizations are in compliance with applicable Commissioner's Directives.
2.4 Management of the offender security classification review are completed in compliance with the applicable Commissioner's directive.
2.5 Transfer warrant executions are completed within a reasonable length of time.

ANNEX B

AUDIT APPROACH, METHODOLOGY AND POLICY SUMMARY

Audit evidence was gathered through a number of techniques.

Interviews: 178 interviews with staff were conducted either in person, by videoconference or by teleconference. An additional 16 interviews with inmate committees were conducted. Interviews took place across all five regions, including National Headquarters, Regional Headquarters and selected institutions (see Annex D for a list of interviewees).

Review of Documentation: Relevant documentation such as legislation, policy documents, strategy documentation, procedure manuals, quarterly lever reports and meeting minutes including Population Management Committee minutes were reviewed.

Commissioner's Directives reviewed included:

  • CD 550 Inmate Accommodation (including Policy Bulletin 315)
  • CD 568-3 Identification and Management of Criminal Organizations
  • CD 568-7 Management of Incompatibles
  • CD 709 Administrative Segregation
  • CD 710-2 Transfer of Offenders
  • CD 710-6 Review of Offender Security Classification.

File Review: A computer program was used to randomly select files at each site. Judgment was used to determine the number of files to be reviewed.

File reviews were conducted at each of the sites visited to determine whether policies were being followed.

  • 347 files were reviewed on-site to determine whether the information was consistent between OMS and the offender's preventative security files as it relates to incompatibles; whether policies related to housing co-convicted offenders and incompatible offenders separately were being followed; and whether listed incompatibles were being reviewed on a yearly basis.
  • Simultaneously, 127 files were reviewed to assess if mediation was offered prior to an incompatible being recorded.
  • Additionally, 335 OMS files were examined to determine whether policies were being followed relative to the timeliness of security classification reviews, whether the proper position approved the classification; and whether policies related to the override process were followed.
  • Furthermore, 167 files of segregated offenders were reviewed to determine whether they were in compliance with legislation. As well, the timeliness of 304 transfers (96 penitentiary placement and 208 transfers) was reviewed.
  • Finally, a review of 216 double-bunking placement assessments was conducted to determine whether they were on-file and contained all required information.

Analytical Review: An analytical review was conducted throughout the audit, to determine trends for the management of the offender population.

ANNEX C

LOCATION OF SITE EXAMINATIONS

REGION SITES
NHQ
  • Correctional Operations and Programs
  • Corporate Services
Atlantic
  • Nova Institution for Women
  • Springhill Institution
Quebec
  • Cowansville
  • Federal Training Centre
  • Regional Reception Centre
Ontario
  • Bath Institution
  • Collins Bay Institution
  • Joyceville Institution
  • Kingston Penitentiary
  • Millhaven Institution
Prairies
  • Edmonton Institution (Video Conference)
  • Edmonton Institution for Women (Video Conference)
  • Pê Sâkâstêw Centre (Video Conference)
  • Regional Psychiatric Centre
  • Saskatchewan Penitentiary
  • Willow Cree Healing Centre
Pacific
  • Fraser Valley Institution for Women
  • Matsqui Institution
  • RTC - Pacific

ANNEX D

LOCATION OF INTERVIEWEES

REGION SITES
NHQ
  • Associate Assistant Commissioner Correctional Operations
  • Manager, NCAOP
  • Manager, Corporate and Interdepartmental Relations
RHQ Atlantic
  • Assistant Deputy Commissioner, Institutional Operations
  • District Director
  • Regional Transfer Coordinator
Québec
  • Assistant Deputy Commissioner, Institutional Operations
  • Regional Transfer Coordinator
Ontario
  • A/ Director, Interventions
  • Regional Transfer Coordinator
  • Regional Administration Assessment and Intervention
Prairies
  • Assistant Deputy Commissioner, Institutional Operations
  • Regional Transfer Coordinator
Pacific
  • Assistant Deputy Commissioner, Institutional Operations
  • Regional Transfer Coordinator
Institutions
  • Warden/Executive Director
  • Deputy Warden
  • Assistant Warden Operation
  • Assistant Warden Intervention
  • Manager Assessment Intervention
  • Security Intelligence Officer
  • Correctional Manager, Unit
  • Correctional Manager, Assessment
  • Correctional Officer, Unit
  • Correctional Officer, Assessment
  • Parole Officer
  • Grievance Coordinator
  • Inmate Grievance Analyst
  • Administrative Assistant
  • Chief of Administrative Services
  • Inmate Committee

MANAGEMENT ACTION PLAN

AUDIT OF OFFENDER POPULATION MANAGEMENT

Recommendation: Recommendation 139
The Assistant Commissioner, Correctional Operations and Programs, should update, communicate and create awareness surrounding the Population Management Strategy
Management Response / Position: __x__ Accepted ___ Accepted in Part ___ Rejected
Action(s) Deliverable(s) Approach Accountability Timeline for Implementation

What action(s) has / will be taken to address this recommendation?

Expected deliverable(s) / indicator(s) to demonstrate the completion of the action(s)

How does this approach address the recommendation?

Who is responsible for implementing this action(s)?

When will action(s) be completed to fully address the recommendation?

A communication strategy will be implemented to create awareness on the National Population Management Strategy.

Develop and launch a centralized INFONET page dedicated to population management providing easy access to information and resources on population management (reports, decks, best practices).

The communication objectives of the NPMS are to:

  • effectively communicate the PM initiatives and highlight successes and results achieved
  • to report key findings and recommendations on PM
  • to highlight CSC's ongoing commitment to enhancing public safety and security within CSC institutions and communities across Canada.

ACCOP

March 2013

 

Definition of population management will be clearly visible on all documents and sub-strategies.

Routinely defining what population management is will strengthen overall awareness and communications.

 

 

 

An Information package on the role of Institutional Population Management Committees has been prepared and sent to the RDCs.

Provides guidance and structure to IPM committees.

ACCOP

2012-08-31
Completed

 

Regional and local population management committees will review the Strategy with their members.

The strategy will be discussed at relevant meetings.

ADCIO and Wardens

2012-09-30 to 2013-03-31


Recommendation: Recommendation 240
The Regional Deputy Commissioners should ensure that the policies surrounding incompatibles are being followed.
Management Response / Position: __x__ Accepted ___ Accepted in Part ___ Rejected
Action(s) Deliverable(s) Approach Accountability Timeline for Implementation

What action(s) has / will be taken to address this recommendation?

Expected deliverable(s) / indicator(s) to demonstrate the completion of the action(s)

How does this approach address the ecommendation?

Who is responsible for implementing this action(s)?

When will action(s) be completed to fully address the recommendation?

A review of all incompatibles will be undertaken to ensure that incompatibles are accurate and current.

Listed incompatibles that are no longer current due to death and/or release will be reviewed and archived accordingly. Existing archives will be reviewed and records expunged when appropriate.

This will streamline unnecessary records to simplify the review, maintenance and cross-referencing of relevant incompatibilities.

ACCOP

December 2012

 

Incompatibilities that involve staff, contractors and other non-offenders will be reviewed, deleted and directed to other appropriate mechanisms (i.e. Employee Protection).

This will streamline unnecessary records to simplify the review, maintenance and cross-referencing of relevant incompatibilities.

ACCOP

December 2012

 

Records of "Other/Unknown" will be assessed, replaced and/or deleted and this availability of this option will be removed from OMS.

This will streamline unnecessary records to simplify the review, maintenance and cross-referencing of relevant incompatibilities.

ACCOP

December 2012

Compliance with policy requirements will be monitored on a semi-annual basis regionally.

Direction will be issued to ensure that local managers are aware of policy requirements and accountabilities.

Results of semi-annual reporting compliance and accountability to be discussed at RMC and Regional PM committee meetings.

RDCs

October 2012

 

Monitoring of overall national compliance to ensure improvements.

 

 

ONGOING

Security policies will be reviewed to ensure that clear direction about the management and record-keeping related to co-located incompatibilities is in place.

Review of security policies and consultation with the regions.

This will ensure that in addition to tracking incompatibilities, strong management processes are in place for managing these offenders.

ACCOP

December 2012


Recommendation: Recommendation 341
The Assistant Commissioner, Correctional Operations and Programs, should clarify who should be completing the double-bunking placement assessments and support the Regional Deputy Commissioners in ensuring that double-bunking assessments are completed.
Management Response / Position: __x__ Accepted ___ Accepted in Part ___ Rejected
Action(s) Deliverable(s) Approach Accountability Timeline for Implementation

What action(s) has / will be taken to address this recommendation?

Expected deliverable(s) / indicator(s) to demonstrate the completion of the action(s)

How does this approach address the ecommendation?

Who is responsible for implementing this action(s)?

When will action(s) be completed to fully address the recommendation?

Policy is being reviewed to ensure the responsibilities for double-bunking assessments are clarified.

The revised policy CD 550 on Inmate Accommodation clearly identifies that the Correctional Officer normally completes the assessments and the Correctional Manager will quality control and approve the final placement.

Addresses the recommendation as it will ensure compliance and accountability thereby strengthening the MCF on PM.

ACCOP

December 2012

 

Until policy changes are complete, a security bulletin (202-09) was issued on June 6, 2012, providing interim instructions that the Correctional Manager will ensure that a double-bunking assessment (DBA) is completed for each double occupancy situation.

 

 

Security bulletin issued
June 6, 2012.

Standardized tools will be developed to support completion of the assessments. Regional and local managers will be provided with RADAR Query reports to confirm completion of double occupancy assessments.

Monitoring reports are being designed for RADAR and will be put in place.

Reports obtained from RADAR to ensure compliance will be shared with units and by videoconference with the Directors to monitor compliance with the policy.

ACCOP

Mid-September 2012 - Completed

 

 

 

ACCOP

Once received from NHQ

i Amendment made on June 10, 2013 to reflect proper assurance level.

1 A Roadmap to Strengthening Public Safety, Executive Summary, Page iv

2 A Roadmap to Strengthening Public Safety, Page 20

3 A Roadmap to Strengthening Public Safety, Page 20

4 CSC's Population Management Strategy-It's Everybody's Business, Page 16

5 CSC's Population Management Strategy-It's Everybody's Business, Page 3

6 2012-13 Report on Plans and Priorities, Page 12

7 Guideline 005-1 INSTITUTIONAL MANAGEMENT STRUCTURE: Roles and Responsibilities, Annexe A, page 7

8 See Section 3.0 for a list of areas audited

9 Commissioner's Directive 550 Inmate Accommodation, Paragraph 15

10 Commissioner's Directive 550 Inmate Accommodation, Paragraph 16

12 Recommendation requires management's attention, oversight and monitoring.

13 The policy does not define "timely". For the purposes of the audit, "timely" was considered to be the next day following the comparison.

14 Commissioner's Directive 550 Inmate Accommodation, Paragraph 23

15 Commissioner's Directive 709 Administrative Segregation, Paragraph 12

16 Correctional and Conditional Release Act, Section 31(3)

17 Commissioner's Directive 709 Administrative Segregation, Annex B (2007-11-09)

18 Commissioner's Directive 550 Inmate Accommodation, Paragraphs 17a and 29 (2001-03-15)

19 Commissioner's Directive 550 Inmate Accommodation, Paragraph 22 (2001-03-15)

20 Commissioner's Directive 568-7 Management of Incompatibles, Paragraphs 11a and 11b (2003-01-03)

21 Commissioner's Directive 550 Inmate Accommodation, Paragraph 16

22 Commissioner's Directive 550 Inmate Accommodation, Paragraph 20

23 Commissioner's Directive 568-7 Management of Incompatibles, Paragraph 3 (2003-01-03)

24 Commissioner's Directive 568-7 Management of Incompatibles, Paragraph 11f (2003-01-03)

25 Commissioner's Directive 568-7 Management of Incompatibles, Paragraph 10 (2012-06-13)

26 Commissioner's Directive 568-7 Management of Incompatibles, Paragraph 11a (2003-01-03)

27 Commissioner's Directive 568-7 Management of Incompatibles, Paragraph 10 (2003-01-03)

28 Commissioner's Directive 568-7 Management of Incompatibles, Paragraph 14 (2012-06-13)

29 Commissioner's Directive 710-6 Review of Inmate Security Classification, Paragraph 23 (2010-02-10)

30 Commissioner's Directive 710-6 Review of Inmate Security Classification, Paragraphs 25 and 26 2010-02-10)

31 Commissioner's Directive 710-6 Review of Inmate Security Classification, Paragraph 24 (2010-02-10)

32 Commissioner's Directive 710-6 Review of Inmate Security Classification, Paragraphs 5 and 6 (2010-02-10)

33 Commissioner's Directive 710-6 Review of Inmate Security Classification, Paragraph 28 (2010-02-10)

34 The term override is often used when the offender is being recommended for a security level higher than the SRS/SRSW results, while under-ride is commonly used when the offender is being recommended for a security level lower than the SRS/SRSW results.

35 A transfer is considered to be a penitentiary placement when the offender is not assigned to a specific institution.

36 Women offenders are not transferred on the intra-regional transfer bus in the Prairies region; however, they are transferred on the inter-regional plane with male offenders.

37 Recommendation requires management's immediate attention, oversight and monitoring.

38 Recommendation requires management's immediate attention, oversight and monitoring.

39 Recommendation requires management's attention, oversight and monitoring.

40 Recommendation requires management's immediate attention, oversight and monitoring.

41 Recommendation requires management's immediate attention, oversight and monitoring.