Pre-Onsite Review
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Contract/Site
SOW (ask COR for most recent version, as well as any waivers given
to the site)
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Review
the contract/SOW and, if applicable, relevant waivers:
Follow
up notes:
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Past
monitoring trip reports or corrective actions issued by COR or
other ORR staff (See S:\ drive)
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Dates
of past monitoring trips:
Findings/Corrective
Actions from monitoring trip reports and/or COR/FFS:
Follow
up notes:
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Site’s
website (if applicable) (Use the internet)
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Are
there pictures of UC pictures on the site’s website?
Is
the site’s address available to the public? (See Policy
Guide Section 5.1.1)
If
there is information about the UC Program on the site’s
website, is it accurate and in-line with public information on
ORR’s website?
Follow
up notes:
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Review
SIRs submitted in the UC Portal (use the UC Portal Events tab or
Tableau to search for reports)
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Review
recent SIRs (e.g.,
past 3 months):
Review
notable SIRs (e.g., abuse allegations, medical emergency, etc.)
for required follow-up and notifications
Review
SIRs for compliance (e.g., timely submission, accuracy of dates,
fact-based narrative and/or addendums to correctly document the
incident, required notifications, etc.)
Note
any UC case files to request from the program
Follow
up notes:
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Review
of completed Site Visit Guide (SVG) and attachments
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Identify
any areas that require follow up (e.g., discrepancy between the
site’s P&P and ORR P&P, unique challenges posed at
this site, items to add to the facility walkthrough, concerns with
service delivery, any recent inspections from local/State
authorities, any relevant licenses/permits/certifications, etc.):
Follow
up notes:
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Review
Prevention of Sexual Abuse and Harassment materials
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Review
and confirm the site has the following in place:
Zero
Tolerance Policy
Staff
Reporting Policies and Procedures
Coordinated
Response and Sexual Abuse
Attorney
Client Visitation Rules
Follow
up notes:
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Site’s
Staffing Plan and Organizational Chart
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Does
the staffing plan meet the ORR and SOW minimum requirements for
client to staff ratio requirements?
Does
the organizational structure promote effective chain of command
and communication?
Follow
up notes:
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UC
Orientation and Discharge Packets
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Are
all ORR required topics covered, in both the orientation and
discharge information?
Is
the information in line with ORR policies and procedures?
Are
language access services used as needed for youth?
Is
it child friendly?
Follow
up notes:
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Behavior
Management Plan
|
Review
the Behavior Management Plan. Does the behavior management plan
meet the Flores requirements i.e. “Program
rules and discipline standards shall be formulated with
consideration for the range of ages and maturity in the program
and shall be culturally sensitive to the needs of alien minors.
Minors shall not be subjected to corporal punishment, humiliation,
mental abuse, or punitive interference with the daily functions of
living, such as eating or sleeping. Any sanctions employed shall
not: (1) adversely affect either a minor's health, or physical or
psychological well-being; or (2) deny minors regular meals,
sufficient sleep, exercise, medical care, correspondence
privileges, or legal assistance”?
Follow
up notes:
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Background
Checks for Staff, Volunteers, and Contractors
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Review
the entire list to ensure staff, volunteers, and contractors are
receiving the ORR required background checks (ORR Guide 4.3.3):
A
FBI fingerprint check of national and state criminal history
repositories;
A
Public Records Criminal Background Check
A
child protective services check with the staff’s State(s)
of U.S. residence for the last five years; and
Background
investigation updates at a minimum of every five years of the
staff/contractor/volunteer’s start date or last background
investigation update.
Check
to ensure that the facility is following their supervision plan
(as reported in the ICF Site Visit Guide) for any staff whose
background checks are still pending. Monitors
should observe, not just ask, that the supervision plan is being
followed during both day and night shifts.
Have
you identified any background discrepancies to discuss with the
site?
Are
there specific files you plan to pull on-site?
Follow
up notes:
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Educational
Services
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Does
the program have an educational assessment tool to assess
individual needs?
Ensure
all required classes, per Flores/ORR Guide, are covered (Science,
SS, Math, Reading, Writing, and PE)
Ensure
UC are receiving 6 hours of structured education daily
Ensure
there are different level curriculums to address the various UC
educational levels:
Follow
up notes:
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Map
of facility
|
Helpful
for getting oriented to campus and to identify the amount of time
needed for the facility walkthrough
Follow
up notes:
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Emergency
Plan
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Does
the site have a current evacuation plan(s) in place for relevant
natural disasters?
Does
the site have an emergency response plan in place (e.g., health
emergencies, fires, behavioral disruptions, intruders, active
shooters, etc.?
Does
the evacuation plan include a list of agencies and individuals to
notify in the event of an evacuation, including ORR contacts, DHS,
and local law enforcement (UC MAP Section 3.3.4)?
Follow
up notes:
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Quality
assurance procedures and internal monitoring resources
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Review
the site’s quality assurance procedures
How
often do they review UC case files, and other site documents for
compliance?
Follow
up notes:
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Internal
Procedures
|
Code
of Conduct – should include employee’s obligations
with respect to interactions and interventions with UC, staff, and
external stakeholders. Must include respecting boundaries, zero
tolerance for sexual abuse and harassment, not providing legal
advice to UC, therapeutic counseling only if properly licensed and
authorized, maintaining professional standards, not discriminating
against any person, employing strength-based behavior management
approaches, cooperating with official investigations, reporting
any criminal or inappropriate conduct, and protecting staff and UC
from retaliation if they disclose or threaten to disclose the
existence of an illegal or unsafe practice. (See Cooperative
Agreement p. 16-18 for full description and also ORR Guide 4.3.5.)
Grievances
– should include procedures on handling time-sensitive
incidents reported as a grievance that involve an immediate
threat, include issuing a written decision to a grievance within 5
days of receipt, and that youth may obtain assistance from another
youth, care provider staff, family members, or legal
representative to prepare a grievance.
Conflict
of Interest – should identify and define conduct that
creates a conflict of interest, prohibit employees form having any
direct or indirect financial interests in services of the program,
require staff to recuse themselves from decision-making if there
is a conflict of interest, require staff to disclose conflicts of
interest, state that failure to disclose conflicts of interest may
result in discipline or termination. (See Cooperative Agreement
p. 19 for full description.)
Follow
up notes:
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Food
services/menus and employee food safety certifications
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Are
meals prepared
in accordance with nutritional guidelines as defined by DOA
guidelines?
Are
meals prepared with sensitivity to cultural dietary practice when
possible?
Are
the employee food safety certifications current?
Follow
up notes:
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CPS
Reports
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Have
there been any CPS reports or investigations?
If
yes, were any of the allegations substantiated? If so, review
reports.
Follow
up notes:
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Vehicle
Inspections
|
Are
inspections required in the State? If so, how often and is the
site in compliance?
How
often does the site’s complete internal vehicle
reviews/walkarounds?
Any
deficiencies found? If so, when were they corrected?
Follow
up notes:
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Personnel
Training
|
Review
the list of personnel trainings
Are
the annual trainings in line with ORR required trainings?
Are
trainings offered frequently enough for staff to comply with
requirements?
Follow
up notes:
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Safety,
health and sanitation certificates, fire inspections
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Are
the certificates current?
When
was the last fire inspection conducted? Were any violations cited?
Follow
up notes:
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UC
Daily Activity Schedule
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Does
the daily activity schedule account for adequate recreation and
leisure activity, both on the weekend and weekdays?
Does
the daily activity schedule account for religious services?
Follow
up notes:
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Personnel
File Checklists
|
Complete
the Personnel File checklist for all selected files
Note
any additional personnel file documents to spot-check while
on-site
Follow
up notes:
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UC
Case Files Checklists (UC Portal and hard file documentation)
|
Complete
the UC Case File checklist for all selected files
Follow
up notes:
|
Consult
with ORR Staff, COR, PSA, Intakes, Medical, FFS, CFS, etc.
|
Recent
emergency SIRs
Potential
issues to research
Name
of specific personnel and UC to interview and/or files to review
Follow
up notes:
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Legal
Service Provider Interview
|
Were
there any issues/concerns raised by the LSP?
Follow
up notes:
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GDIT
Case Coordinator Interview
|
Were
there any issues/concerns raised by the Case Coordinator(s)?
Follow
up notes:
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