Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.212
Contracting With Other Entities for the Confinement of Residents
Policy:
CPA is a private, non-profit agency. CPA does not contract for the confinement of its HTH or WRP residents with other private agencies or entities.
Procedures:
Not applicable.
Date of Last Revision: 6-7-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-7-13
Cross References: ____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.214
Reserved
Policy:
CPA’s HTH and WRP do not conduct strip searches, pat down searches, or visual body cavity searches.
Procedure:
Not applicable.
Date of Last Revision: 6-6-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-6-13
Cross References: 115.215
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.215
Limits to Cross Gender Viewing and Searches
I. Policy:
CPA’s HTH and WRP do not conduct strip searches, pat down searches, or visual body cavity searches.
It is prohibited for staff to search or physically examine a transgender or intersex resident for the sole purpose of determining the resident’s genital status.
The HTH and WRP shall enable residents to shower, perform bodily functions, and change clothing without staff of the opposite gender viewing such activity.
II. Procedures:
If the resident’s genital status is unknown, it may be determined during conversations with the resident or by reviewing records from the referral source(s), if deemed necessary by the Program Manager.
Staff of the opposite gender will announce their presence when entering an area where residents are likely to be showering, performing bodily functions, or changing clothing.
Transgender and intersex residents will be given the opportunity to shower separately from other residents.
Date of Last Revision: 6-7-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-7-13
Cross References: 115.214
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.216
Residents with Disabilities and Residents who are LEP
Policy:
CPA shall take appropriate steps to ensure residents who are LEP or have disabilities (including, for example, residents who are deaf or hard of hearing, those who are blind or have low vision, or those who have intellectual, psychiatric, or speech disabilities), have an equal opportunity to participate in or benefit from all aspects of the agency’s efforts to prevent, detect, and respond to sexual abuse and sexual harassment.
Procedures:
- To ensure effective communication with residents who aredeaf or hard of hearing, the program shall provide access to interpreters who can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.
- The program shall ensure written materials are provided in formats or through methods that ensure effective communication with residents with disabilities, including residents who have intellectual disabilities, limited reading skills, or who areblind or have low vision.
- The program shall take reasonable steps to ensure meaningful access to all aspects of the agency’s efforts to prevent, detect, and respond to sexual abuse and sexual harassment to residents who are LEP, including steps to provide interpreters who can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.
- The program shall not rely on resident interpreters, resident readers, or other types of resident assistants except in limited circumstances where an extended delay in obtaining an effective interpreter could compromise the resident’s safety, the performance of first-response duties, or the investigation of the resident’s allegations.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References: LEP Policy____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.218
Upgrades to Facilities and Technologies
Policy:
CPA shall ensure PREA standards are considered when designing or acquiring or upgrading facilities and technologies.
Procedures:
- Facilities: When designing or acquiring any new facility and in planning any substantial expansion or modification of existing facilities, CPA shall consider the effect of the design, acquisition, expansion, or modification upon the agency’s ability to protect residents from sexual abuse.
- Technologies:When installing or updating a video monitoring system, electronic surveillance system, or other monitoring technology, CPA shall consider how such technology may enhance the agency’s ability to protect residents from sexual abuse.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References: ____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.221
Evidence Protocol and Forensic Medical Examinations
Policy:
CPA shall contact local authorities to investigate allegations of sexual abuse. CPA shall offer all victims of sexual abuse access to forensic medical examinations without financial cost. CPA shall attempt to make available to the victim a victim advocate.
Definitions:
Rape Crisis Center: an entity that provides intervention and related assistance to victims of sexual assault.
Qualified Agency Staff/Community Based Staff: an individual who has been screened for appropriateness to serve in this role and has received education concerning sexual assault and forensic examination issues in general.
Procedures:
- Access to Forensic Medical Examinations: CPA shall offer victims of sexual abuseaccess to forensic medical examinations via Hartford Hospital, without financial cost where evidentiary or medically appropriate. Such examinations shall be performed by Sexual Assault Forensic Examiners (SAFEs) or Sexual Assault Nurse Examiners (SANEs) where possible. If SAFEs or SANEs cannot be made available, the examination will be performed by other qualified medical practitioners. CPA shall document its efforts to provide SAFEs or SANEs.
- Victim Advocate: CPA shall attempt to make available to the victim a victim advocate from a rape crisis center. If a rape crisis center is not available to provide victim advocate services, CPA shall attempt to make such services available through a qualified staff member from a qualified community based organization. The program shall document efforts to secure services from rape crisis centers.
- Staff Support: As requested by the victim, the victim advocate, qualified CPA staff member, or qualified staff from a community based agency shall accompany and support the victim through the forensic medical examination process and investigatory reviews and shall provide emotional support, crisis intervention, information, and referrals.
- Qualifications of Investigating Agency: CPA shall request that the investigating agency abide to PREA requirements/standards.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References: ____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.222
Policies to Ensure Referrals of Allegations for Investigations
Policy:
CPA shall ensure that an administrative or criminal investigation is completed for all allegations of sexual abuse and sexual harassment.
Procedures:
- Sexual Abuse/Harassment Allegations: CPA maintains policies to ensure that allegations of sexual abuse or sexual harassment are referred for investigation to local authorities to conduct criminal investigations, unless the allegation does not involve potentially criminal behavior. This policy is maintained on the CPA website ( CPA shall document all such referrals.
- Conducting Criminal Investigations: Local authorities shall be responsible for conducting criminal investigations, not CPA. CPA shall attempt to secure the publication describing the responsibilities of the local authorities and publish it on the agency’s website.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References: ____
Community Partners in Action - CPA
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.232
Volunteer and Contractor Reporting
Policy:
CPA shall ensure that all volunteers and contractors who have contact with residents have been trained on their responsibilities under the agency’s sexual abuse and sexual harassment prevention, detection, and response policies and procedures.
Procedures:
A. Zero Tolerance:
All volunteers and contractors who have contact with residents will be notified and provided a copy of the agency’s zero tolerance policy regarding sexual abuse and sexual harassment and informed how to report sexual abuse.
B. Training:
The level and type of training provided to volunteers and contractors will be based on the services they provide and the level of contact they have with residents.
C. Documentation:
The agency will maintain documentation confirming that volunteers and contractors understand the training they have received.
Date of Last Revision: 6-19-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-19-13
Cross References: ____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.233
Resident Education
Policy:
CPA shall ensure HTH and WRP residents receive information explaining the agency’s zero-tolerance policy regarding sexual abuse and sexual harassment, how to report incidents or suspicions of sexual abuse or sexual harassment, their rights to be free from sexual abuse and sexual harassment and to be free from retaliation for reporting such incidents, and regarding agency policies and procedures for responding to such incidents.
Procedures:
- Duringtheintakeprocess, staffmust notifyall HTH and WRP residentsthat CPA:
Has zero tolerance for allforms ofsexual abuse and sexual harassment;
Has multiplewaysfor residents to privatelyreport sexual abuse and sexual harassment, retaliation byother residents or staff forreportingsexual abuse and sexual harassment and staffneglect orviolation of responsibilities that mayhave contributed to such incidents;and
Has awayto report sexual abuseorsexual harassment to authorities,allowing the reporting residenttoremain anonymous.
- During intake, staff must complete the required form foreach residentwhich indicates the residenthas received therequired notices. This form will be signed by the resident, along with the staff conducting the intake, and retained in the resident’s file.
Oncea residenthas received the noticesthat residentdoes notneed to acknowledge receipt ofnoticeagain, foraperiod ofoneyear, so longas heremains inthe HTH or WRP.
- During intake, the resident must be referred to signageposted in the facility statingthe zero tolerance policy.
- CPA must utilizelanguageassistanceservices toobtain atranslation ofthis signage, ifnecessary. CPA must not relyon theservices of residents to provide assistanceto other residents with disabilities orwho are limited English proficient.
- CPA must provide refresher information whenever a resident is transferred to a different facility.
- HTH and WRP must provide resident education in formats accessible to all residents, including those who are limited English proficient, deaf, visually impaired, or otherwise disabled as well as residents who have limited reading skills. The programsmust maintain documentation of resident participation in these education sessions.
- In addition to providing such education, the HTH and WRP must ensurekey information is continuously and readily available or visible to residents through posters, resident handbooks, or other written formats.
Date of Last Revision: 6-28-13
Positions Responsible: HTH and WRP staff
Effective Date: 6-28-13
Cross References: PREA Overarching Policy___
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.234
Specialized Training: Investigations
Policy:
CPA will rely on local and/or state authorities to investigate sexual abuse.
Procedures:
- Allegation ofSexual Abuse: upon learninga resident was sexually abused, the first staffmemberto respond must:
Not leavethevictim alone;
Call the Person in Charge to request assistance from the Residential Supervisor, Program Manager, or senior management staff;
Call 911 to obtain transportation for the resident to Hartford Hospital for care and examination. Hartford Hospital is PREA compliant.
Separatethealleged victim and abuser, if applicable;
Preserveand protect thecrimescene, if applicable;
Ifthe abuseoccurredwithin atimeperiod that would still allow for the collection ofphysicalevidence,request that the alleged victim not take anyaction that could destroyphysical evidence, including washing, drinkingor eating, unless medicallyindicated. Iftoileting needs to takeplace, the resident should beinstructed to not wipe.
As soon as practical, CPA shall contact the CT Sexual Assault Crisis Center Services to arrange for a sexual assault advocate to go to the hospital where the resident is being transported.
- CPA shall ensure the local and/or state authorities investigating the abuse have completed the required specialized training in conducting sexual abuse investigations and maintain documentation of such.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References: PREA Overarching Policy____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.235
Specialized Training: Medical and Mental Health Care
Policy:
CPA’s HTH and WRP do not employ medical and mental health care staff.
Procedure:
Not applicable.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References:
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.241
Screening for Risk of Victimization and Abusiveness
Policy:
CPA must ensure all residents arescreened to assess their riskofbeingsexually abused orbeingsexuallyabusivetoward other residents using an objective assessment/screening instrument.
Procedures:
- Assessment: staff must follow theinstructions on the assessment form formakingthis assessment byaskingeach residentquestions about theirperceived risk ofbeingabused. Staff mayalso considertheirown assessment of risk factors. Completed assessments must beretained with the program’s dailypaperwork as well as in the resident’s file.
- Assessment Timeframe: residents shall be assessed during the intake process or upon transfer to another facility. The assessment must take place within 72 hours of arrival at the facility.
- Assessment Content: the screening shall consider, at a minimum, the following criteria to assess residents for risk of sexual victimization:
Whether the resident has a mental, physical, or developmental disability;
The age of the resident;
The physical build of the resident;
Whether the resident has previously been incarcerated;
Whether the resident’s criminal history is exclusively nonviolent;
Whether the resident has prior convictions for sex offenses against an adult or child;
Whether the resident is or is perceived to be gay, lesbian, bisexual, transgender, intersex, or gender nonconforming;
Whether the resident has previously experienced sexual victimization; and
The resident’s own perception of vulnerability.
The assessment screening shall consider prior acts of sexual abuse, prior convictions for violent offenses, and history of prior institutional violence or sexual abuse, as known to the agency, in assessing residents for risk of being sexually abusive.
- Re-assessment: within a set time period, not to exceed 30 days from the resident’s arrival at the facility, the facility will reassess the resident’s risk of victimization or abusiveness based upon any additional, relevant information received by the facility since the intake screening.
A resident’s risk level shall be reassessed when warranted due to a referral, request, incident of sexual abuse, or receipt of additional information that bears on the resident’s risk of sexual victimization or abusiveness.
- Failure to Answer Assessment Questions: residents must not be disciplined for refusing to answer, or for not disclosing complete information in response to assessment questions.
- Confidentiality: CPA shall implement appropriate controls on the dissemination within the facility of responses to questions asked pursuant to this PREA Standard to ensure sensitive information is not exploited to the resident’s detriment by staff or other residents.
Date of Last Revision: 6-28-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 6-28-13
Cross References: PREA Overarching Policy____
Community Partners in Action
Hartford Transitional Housing - HTH
Work Release Program - WRP
PREA Standard: 115.242
Use of Screening Information
Policy:
CPA is responsible for ensuring the safety of each resident in HTH or WRP.
Procedures:
- Risk Screening Information: CPA shall use information from the risk screening required in PREA Standard 115.241 to inform housing, bed, work, education, and program assignments with the goal of keeping separate those residents at high risk of being sexually victimized from those at high risk of being sexually abusive.
- Individualized Determinations: CPA shall make individualized determinations about how to ensure the safety of each resident.
- Transgender or Intersex Residents:
In deciding whether to assign a transgender or intersex resident to HTH or WRP and in making other housing and programmatic assignments, CPA shall consider on a case – by – case basis whether the placement would ensure the resident’s health and safety, and whether the placement would present management or security problems.
A transgender or intersex resident’s own views with respect to his safety shall be given serious consideration.
Transgender and intersex residents shall be given the opportunity to shower separately from other residents.
- Residential Placement: CPA shall not place lesbian, gay, bisexual, transgender, or intersex residents in dedicated facilities, units, or wings solely on the basis of such identification or status, unless such placement is in a dedicated facility unit, or wing established in connection with a consent decree, legal settlement, or legal judgment for the purpose of protecting such residents.
Date of Last Revision: 7-1-13
Positions Responsible: PODs, HTH and WRP staff
Effective Date: 7-1-13
Cross References: ____
Community Partners in Action