STATE OF TENNESSEE
COMPTROLLER OF THE TREASURY

DEPARTMENT OF CORRECTION
Performance Audit Report
November 2017

Justin P. Wilson, Comptroller

Division of State Audit
Sunset Performance Section

DEBORAH V. LOVELESS, CPA, CGFM, CGMA
Director
JOSEPH SCHUSSLER, CPA, CGFM
Assistant Director
DENA W. WINNINGHAM, CGFM
Audit Manager
Vincent Finamore, CFE
David Wright, CFE
In-Charge Auditors
Fonda Douglas
Greg Spradley
Jafar Ware
Staff Auditors
Amy Brack
Editor
Amanda Adams
Assistant Editor

Comptroller of the Treasury, Division of State Audit
Suite 1500, James K. Polk State Office Building
505 Deaderick St.
Nashville, TN 37243-1402
(615) 401-7897
Reports are available at
www.comptroller.tn.gov/sa/AuditReportCategories.asp
Mission Statement
The mission of the Comptroller’s Office is
to make government work better.
Comptroller Website
www.comptroller.tn.gov

STATE OF TENNESSEE

COMPTROLLER OF THE TREASURY
DEPARTMENT OF AUDIT
DIVISION OF STATE AUDIT

PHONE (615) 401-7897
FAX (615) 532-2765

SUITE 1500, JAMES K. POLK STATE OFFICE BUILDING
505 DEADERICK STREET
NASHVILLE, TENNESSEE 37243-1402

November 3, 2017
The Honorable Randy McNally
Speaker of the Senate
The Honorable Beth Harwell
Speaker of the House of Representatives
The Honorable Mike Bell, Chair
Senate Committee on Government Operations
The Honorable Jeremy Faison, Chair
House Committee on Government Operations
and
Members of the General Assembly
State Capitol
Nashville, Tennessee 37243
and
The Honorable Tony Parker, Commissioner
Tennessee Department of Correction
320 Sixth Avenue North
Nashville, Tennessee 37243-0465
Ladies and Gentlemen:
Transmitted herewith is the sunset performance audit of the Department of Correction.
This audit was conducted pursuant to the requirements of the Tennessee Governmental Entity
Review Law, Section 4-29-111, Tennessee Code Annotated.
This report is intended to aid the Joint Government Operations Committee in its review to
determine whether the department should be continued, restructured, or terminated.
Sincerely,
Deborah V. Loveless, CPA
Director
17275

State of Tennessee

Audit Highlights
Comptroller of the Treasury

Division of State Audit

Performance Audit
Department of Correction
November 2017
_________

FINDINGS
Trousdale Turner Correctional Center and Whiteville Correctional Facility, managed by
Core Civic, operated with fewer than approved correctional officer staff, did not have all
staffing rosters, did not follow staffing pattern guidelines, and one left critical posts unstaffed
Shortages in correctional officer staff may have prevented two Core Civic facilities (Trousdale
Turner Correctional Center and Whiteville Correctional Facility) from meeting staffing obligations
and may have limited their ability to effectively manage the inmate populations assigned to them.
Correctional officer staffing was often less than operationally planned, and Trousdale Turner had
unstaffed critical posts on several days. Both facilities had rosters that did not match stateapproved staffing patterns, and both facilities were consistently short-staffed (page 7).
Core Civic staffing reports for two facilities (Trousdale Turner Correctional Center and
Hardeman County Correctional Center) contained numerous errors, so information about
hires, terminations, and vacancies may not be reliable
Our review of staffing reports revealed inconsistencies regarding hires, terminations, and
vacancies for two of the four Core Civic facilities. We found the following reporting issues for
Trousdale Turner Correctional Center and Hardeman County Correctional Center: missing
position numbers for vacancies; vacancies carrying over to subsequent months without additional
vacant days; vacancies listed with more than 30 days not listed for the previous month; different
job titles with the same position number; the number of hires and terminations not reconciling to
the number of vacancies; and reports missing the number of filled positions, inmate population,
and officer-to-inmate ratio (page 15).
Trousdale Turner Correctional Center management’s continued noncompliance with
contract requirements and department policies challenges the department’s ability to
effectively monitor the private prison
After nearly two years in operation, Trousdale Turner Correctional Center still did not comply
with some of the Department of Correction’s policies and contract requirements. While the
department’s contract monitoring efforts regularly report the facility’s shortcomings, cuts in
monitoring staff may have reduced the department’s ability to effectively monitor key contract

requirements. This lack of effective monitoring has resulted in situations that may undermine the
department’s ability to achieve its stated mission and could result in harm to inmates (page 22).
Probation and parole officers did not always meet supervision requirements
As noted in the 2012 and 2014 performance audits, probation and parole officers did not always
meet supervision standards. We determined that the department has not fully corrected probation
and parole issues identified in the previous two performance audits and must continue to improve
its monitoring capabilities (page 26).
Probation and parole supervisors did not always meet oversight requirements
As noted in the 2012 and 2014 performance audits, supervisors did not always meet the
requirements for reviewing the work of probation officers. We found that 2 of the 5 case files had
been reviewed by a supervisor within 60 days, while 2 did not contain the required initial case file
review code indicating the date when the file had been reviewed, and 1 was not performed within
the required time frame (page 28).

OBSERVATION
The audit also discusses the following issue: the department should annually publish the
correctional officer turnover rate and clearly identify which classifications are included in its
annually published correctional officer series turnover rate (page 18).

Performance Audit
Department of Correction
TABLE OF CONTENTS

Page
INTRODUCTION

1

Purpose and Authority for the Audit

1

Organization and Statutory Responsibilities

1

AUDIT SCOPE

6

OBJECTIVES, METHODOLOGIES, AND CONCLUSIONS

6

Staffing Levels—Private Prison Review

6

Finding 1 −

Finding 2 −

Trousdale Turner Correctional Center and Whiteville Correctional
Facility, managed by Core Civic, operated with fewer than
approved correctional officer staff, did not have all staffing rosters,
did not follow staffing pattern guidelines, and one left critical posts
unstaffed

7

Core Civic staffing reports for two facilities (Trousdale Turner
Correctional Center and Hardeman County Correctional Center)
contained numerous errors, so information about hires,
terminations, and vacancies may not be reliable

15

Staffing—State Facilities

18

Observation 1 − The department should annually publish the correctional officer
turnover rate and clearly identify which classifications are
included in its annually published correctional officer series
turnover rate

18

Private Prison Monitoring

21

Finding 3 −

Trousdale Turner Correctional Center management’s continued
noncompliance with contract requirements and department
policies challenges the department’s ability to effectively monitor
the private prison

Community Supervision Division
Finding 4 −
Finding 5 −

22
25

Probation and parole officers did not always meet supervision
requirements

26

Probation and parole supervisors did not always meet oversight
requirements

28

Performance Audit
Department of Correction
INTRODUCTION

PURPOSE AND AUTHORITY FOR THE AUDIT
This performance audit of the Department of Correction was conducted pursuant to the
Tennessee Governmental Entity Review Law, Title 4, Chapter 29, Tennessee Code Annotated.
Under Section 4-29-239(a)(13), the department is scheduled to terminate June 30, 2018. The
Comptroller of the Treasury is authorized under Section 4-29-111 to conduct a limited program
review audit of the department and to report to the Joint Government Operations Committee of the
General Assembly. This audit is intended to aid the committee in determining whether the
Department of Correction should be continued, restructured, or terminated.

ORGANIZATION AND STATUTORY RESPONSIBILITIES
The Department of Correction was established in 1923 under Title 4, Chapter 3, Part 6,
Tennessee Code Annotated, to operate the correctional system for the State of Tennessee (Section
41-1-102). The department’s mission is to operate safe and secure prisons and provide effective
community supervision in order to enhance public safety. In July 2012, duties including probation
and parole supervision and community correction grant program functions were transferred to the
department from the Board of Parole.
The department houses nearly 21,000 inmates at 10 adult prisons; contracts with a private
prison management company for the operation of one prison; and contracts with several counties
for the operation of three other private correctional facilities that are owned and operated by private
contractor Core Civic (formerly known as Corrections Corporation of America). All facilities
housing Department of Correction prisoners are located on the map on page 5. The Tennessee
Prison for Women and the Women’s Therapeutic Residential Center (located at the West
Tennessee State Penitentiary site) exclusively house female offenders, and the Bledsoe County
Correctional Complex houses both male and female offenders. The other 11 facilities house only
male offenders. The department’s Community Supervision unit supervises nearly 78,000
offenders on probation, on parole, or in a community correction program. Table 1 illustrates the
offender population under the department’s jurisdiction as of July 2017.

1

Table 1
Number of Offenders Under Department of Correction Oversight
July 2017
Type of Oversight

Number of Offenders

Incarcerated Felons

30,185

Probation and Community Corrections

66,148

Parole

11,553

Total Population

107,886

Source: Tennessee Felon Population Update, July 2017.

The department employs more than 6,500 staff members at the correctional facilities, at
administrative offices in Nashville, and at Community Supervision offices throughout the state.
The department trains staff members and criminal justice professionals from other government
agencies at the Tennessee Correction Academy in Tullahoma.
The department’s Commissioner is supported by a Deputy Commissioner/Chief of Staff,
who also oversees Title VI and Grant Management; a Deputy Commissioner
Administration/General Counsel; four Assistant Commissioners (Operational Support, Prisons,
Community Supervision, and Rehabilitative Services); and the Chief Financial Officer. Executive
Operations, also under the Commissioner’s purview, includes the Office of Investigations and
Compliance; Legal Services; Communications; Decision Support; Research and Planning; and the
department’s Legislative Liaison. The department recently added a Chief Interdiction Officer who
answers directly to the Commissioner and focuses on combatting the introduction of prohibited
items (drugs, cell phones, etc.) into correctional facilities. Various divisions operate under each
Deputy and Assistant Commissioner, as follows:
Deputy Commissioner of Administration/General Counsel
Staff Attorneys; the Policy Development Manager; Human Resources; Offender
Administration (including Offender Sentence Management and Offender Records Management);
and Talent Management operate under the supervision of the Deputy Commissioner of
Administration/General Counsel.
Assistant Commissioner of Operational Support
Support divisions under this Deputy Commissioner include Facilities Planning and
Construction; Facilities Management and Maintenance; Mission Support; and Statewide Training,
which oversees the Tennessee Correction Academy.
Assistant Commissioner of Prisons
Under the Assistant Commissioner of Prisons, the correctional administrators in the East,
Middle, and West regions oversee the operation of all state-owned and operated correctional
facilities, while one correctional administrator for Core Civic facilities oversees contract monitors
2

at the four Core Civic facilities housing prisoners. The Assistant Commissioner of Prisons also
oversees the Local Jails Resource Office, Transportation, Classification, and Inmate Grievances.
Assistant Commissioner of Community Supervision
The Assistant Commissioner of Community Supervision supervises three Field Services
Administrators, who in turn oversee correctional administrators in charge of probation, parole, and
specialized caseload operations in the East, Middle, and West regions of the state. This unit also
oversees the department’s Community Correction Programs and the Criminal Conviction Records
unit.
Assistant Commissioner of Rehabilitative Services
This Assistant Commissioner oversees Offender Development and Rehabilitation; Quality
Assurance; Clinical/Behavioral Services; Women’s Programs/Services; and four Day Reporting
Centers.
Chief Financial Officer
Accounting and Payroll; Budget Services; Procurement; Local Jail Payments/State
Prosecutions Accountant; Contract Administration; and Fleet Management operate under the Chief
Financial Officer.
The department’s organizational chart is presented on the next page.

3

4

Tennessee Department of Correction
Facility Locations

Tennessee Prison for Women
Riverbend Maximum Security Institution
Lois M. DeBerry Special Needs Facility
Nashville

West Tennessee
State Penitentiary
Henning

Trousdale Turner
Correctional Center
Hartsville

Northwest Correctional Complex
Tiptonville

Morgan County
Correctional Complex
Wartburg

Northeast Correctional Complex Annex
Roan Mountain
Northeast Correctional Complex Main
Mountain City

Women’s
Therapeutic
Residential
Center at West
Tennessee
Penitentiary

Bledsoe County
Correctional Complex
Pikeville

Mark H. Luttrell
Correctional Center
Memphis

Hardeman County
Correctional Facility
Whiteville
Correctional Facility
Whiteville

South Central
Correctional Facility

Turney Center Industrial
Complex Main
Only

Turney Center
Industrial Complex
Annex
Clifton

Source: Information provided by the Department of Correction.

5

Tennessee Correction Academy
Tullahoma

AUDIT SCOPE

We audited the Department of Correction’s activities for the period July 1, 2014, through
August 31, 2017. Our audit scope included a review of internal controls and compliance with
laws, regulations, and provisions of contracts or grant agreements that are significant within the
context of the audit objectives. Management of the department is responsible for establishing and
maintaining effective internal controls and for complying with applicable laws, regulations, and
provisions of contracts and grant agreements.
For our sample design, we used nonstatistical audit sampling, which was the most
appropriate and cost-effective method for concluding on our audit objectives. Based on our
professional judgment, review of authoritative sampling guidance, and careful consideration of
underlying statistical concepts, we believe that nonstatistical sampling provides sufficient,
appropriate audit evidence to support the conclusions in our report. Although our sample results
provide reasonable bases for drawing conclusions, the errors identified in these samples cannot be
used to make statistically valid projections. We present more detailed information about our
methodologies in the individual report sections.
We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.

OBJECTIVES, METHODOLOGIES, AND CONCLUSIONS

STAFFING LEVELS—PRIVATE PRISON REVIEW
Background Information
Core Civic (formerly Corrections Corporation of America) is a private prison contractor
based in Tennessee and operates four prisons in the state (Hardeman County Correctional Center,
South Central Correctional Center, Trousdale Turner Correctional Center, and Whiteville
Correctional Facility). South Central is owned by the state and is operated under direct contract
with the state; the other three are subcontracted through the counties in which they are located.
Trousdale Turner began accepting state prisoners on January 4, 2016, with an assigned capacity of
2,512 inmates; as of July 5, 2017, it housed 2,483 inmates, which is 99% of capacity. Whiteville
began accepting state prisoners in 2002, with an assigned capacity of 1,505 inmates; as of July 5,
2017, it housed 1,497 inmates, which is 99% of capacity.

6

Objective and Methodology for Staffing Review (Finding 1)
The contracts for the Trousdale Turner, Whiteville, and Hardeman County facilities require
each facility to submit an operations plan, subject to the state’s approval, that addresses all areas
of the contract, including but not limited to the following:


Staffing patterns list the designated posts and the number of officers the contractor will
use per shift per post. The department approves the contractor’s proposed staffing
pattern.  



Staffing rosters are daily shift logs that show the active officer posts, the officers
scheduled per post, and the officer attendance.  



Critical posts are shown in bold on the staffing rosters and are based on what facility
management determines to be critical to its operations. According to the department’s
Policy 506.22, critical posts must be staffed regardless of institutional circumstances;
if the posts were left unstaffed, it would jeopardize the security or safety of the facility,
staff, offenders, or community.  

These operations plans establish the policies and procedures the facilities are required to
follow in all areas covered by the contract. The terms also state that the “plan shall not be altered,
amended, modified, revised or supplemented without the prior written approval by the State.”
We analyzed correctional officer staffing by comparing a sample of daily facility staffing
rosters to the currently approved staffing patterns.
We randomly selected 3 days per month over the 9-month period between October 2016
and June 2017, for a total of 27 days. We selected a separate sample of days for each facility and
asked facility staff for copies of the completed daily staffing rosters for the selected days. We also
reviewed the department’s contract monitoring reports and monitoring tools related to the
evaluation of staffing patterns and rosters for both the Trousdale Turner and Whiteville facilities.
Finding
1.

Trousdale Turner Correctional Center and Whiteville Correctional Facility,
managed by Core Civic, operated with fewer than approved correctional officer staff,
did not have all staffing rosters, did not follow staffing pattern guidelines, and one left
critical posts unstaffed

Shortages in correctional officer staff may have prevented two Core Civic facilities
(Trousdale Turner Correctional Center and Whiteville Correctional Facility) from meeting staffing
obligations and may have limited their ability to effectively manage the inmate populations
assigned to them. Correctional officer staffing was often less than operationally planned, and
Trousdale Turner had unstaffed critical posts on several days. Both facilities had rosters that did
not match state-approved staffing patterns, and both facilities were consistently short-staffed.

7

Sample Collection Results
The number of staffing rosters we expected to receive varied for the facilities, depending
on the number of shifts per day during the time under review. For Trousdale Turner, we expected
a total of 72 signed rosters and for Whiteville, a total of 54 signed rosters. We received only 51%
of the requested signed rosters from Trousdale Turner, but we received 100% from Whiteville (see
Table 2).
Table 2
Daily Shift Rosters Requested From Core Civic Facilities
October 2016 – June 2017
Shift Rosters
Not Received
We received
blank rosters
from Trousdale
Turner for each
shift in both
October and
November 2016.

Facility
Trousdale Turner
Whiteville

Number of Rosters Expected
72*
54**

Percentage Received
51%
100%

* Between October 2016 and March 2017, Trousdale Turner operated on three 8-hour shifts, so
we expected to receive 54 staffing rosters ([3 rosters per day x 3 sampled days per month] x 6
months). Between April and June, the facility operated two 12-hour shifts per day. For this
period, we expected to receive 18 staffing rosters ([2 rosters per day x 3 sampled days per month]
x 3 months). In total, we expected 72 (54 + 18) staffing rosters.
** Whiteville operated with two 12-hour shifts during the entire sampled period, so we expected
to receive 54 staffing rosters ([2 shifts per month x 3 sampled days per month] x 9 months).

From the rosters, we judgmentally chose to review 16 officer posts for Trousdale Turner
and 17 posts for Whiteville. The selected posts consisted of housing units; segregation; recreation;
transportation; central control; perimeter; medical; and utility, search, and escort. The majority of
the posts were designated as critical on the rosters.
Trousdale Turner Correctional Center Review
Trousdale Turner operated with less than the number of security staff listed on the approved
staffing pattern. Our analysis revealed instances of officers working consecutive shifts (16 hours
in a row); critical and non-critical posts closed because officers were moved to cover other posts;
and posts designated as closed on the roster with no staff assigned when the staffing pattern
indicated the posts should be staffed. On April 1, 2017, Trousdale Turner management
implemented a new staffing pattern that changed the number of critical posts and the number of
shifts for security staff; however, the department did not approve the new plan until June 2017.
The new staffing pattern changed certain security and unit management posts from three 8-hour
shifts to two 12-hour shifts and reduced the total number of correctional officer staff needed to
cover operations. See Table 3.

8

Table 3
Trousdale Turner Correctional Center’s Staffing Patterns
Date of Staffing Pattern

Required Officers

October 2016 to March 2017
April 1, 2017, and onward

196
183

Officer-toInmate Ratio
1:13
1:14

Source: TTCC TDOC approved staffing patterns provided by TDOC.

Between the months of December 2016 and March 2017, some correctional officers worked
extended hours because of staffing shortages, which may have motivated the staffing pattern change.
The rosters show that on one day in March, 11 officers worked 16-hour shifts to cover posts.
A sample of 3 different days in 3 months revealed 44 critical posts unstaffed. We might
have identified more unstaffed posts, but our review was limited by the blank staffing rosters. We
received only 10 of the 18 rosters we expected between April and June 2017 ([2 rosters per day x
3 sampled days] x 3 months). See Table 4.
Table 4
Trousdale Turner Correctional Center’s Critical Posts Unstaffed
Three Selected Days in Each Month
April – June 2017
Month
April
May
June

Sampled Days
Day 1
Day 2
Day 3
Blank Rosters
7
11
12
Blank Rosters
6
Blank Rosters
Blank Rosters
8
Review Period Total

Source: Daily rosters provided by Trousdale Turner Correctional Center.

Total
18
18
8
44

Critical Posts
Unstaffed
Although there
were 8 blank rosters
(2 shifts per day x 4
days), we still
identified 44
unstaffed critical
posts.

Whiteville Correctional Facility Review
Whiteville operated with fewer staff than allowed by the approved staffing pattern.
According to our analysis of 17 correctional officer positions, the staffing pattern’s combined shift
total need for the positions reviewed was 79 officers. We observed, on average, a shift total of 57
officers, a difference of 21 officers. Most critical posts were staffed on the sampled days, but 1
critical post (the front gate) was often unstaffed for approximately 6 hours out of the 12-hour
second shift.
Recreation and Transportation Posts
In some cases, staffing rosters for both facilities had fewer posts than the approved staffing
patterns required. Recreation and transportation posts were consistently under-staffed, underposted, and closed. These positions are designated as non-critical; however, if these positions are

9

not properly manned, the facilities may not be able to properly provide offenders with
programming and services like yard time or transportation to and from medical appointments.
The Trousdale Turner staffing pattern requires 5 recreation posts to be manned for 8 hours
during the 1st and 2nd shifts, 5 days a week. The Whiteville staffing pattern requires 5 recreation
posts to be manned for 12 hours during the 1st shift, 7 days a week. For the sampled days in April
through June 2017, Trousdale Turner’s rosters only list 3 posts and the Whiteville rosters only list
4 posts, instead of 5 as in the staffing pattern. Neither facility’s roster showed that the posts were
manned to the level the staffing patterns require. (See Tables 5 and 6.)
Table 5
Trousdale Turner Correctional Center – Recreation Posts Filled (April – June 2017)
Note: 1st Shift | 2nd Shift
Staffing Pattern = 5 | 5, 5 Days per Week

Month
Staffing Pattern
April Rosters
May Rosters
June Rosters

Posts per Shift
5|5
3|3
3|3
3|3

Day 1
- | -*
0|0
Blank Roster

Sample Day
Day 2
Day 3
- | -*
0|0
Blank Roster
0|0
- | -*
1|1
Period Total

Total
0
0
2
2

* Weekend.
Summary: Trousdale Turner lists only 3 of the 5 required posts on the daily rosters. In our sample, 34 out 36 roster
posts were unfilled. The staffing pattern recommends 60 posts.

Table 6
Whiteville Correctional Facility – Recreational Posts Filled (April – June 2017)
Note: 1st Shift | 2nd Shift
Staffing Pattern = 5 | 0, 7 Days per Week

Month
Staffing Pattern
April Rosters
May Rosters
June Rosters

Posts per Shift
5|0
4|0
4|0
4|0

Day 1
1|0
1|0
1|0

Sample Day
Day 2
3|0
2|0
0|0

Day 3
Total
4|0
8
0|0
3
2|0
3
Period Total
14

Summary: Whiteville lists only 4 of 5 required posts on the daily rosters. In our sample, 22 out of 36 roster posts
were unfilled. The staffing pattern recommends 45 posts.

10

Table 7
Trousdale Turner Correctional Center – Transportation Posts Filled (April – June 2017)
Note: 1st Shift | 2nd Shift
Staffing Pattern = 3 | 1, 5 Days per Week

Month
Staffing Pattern
April Rosters
May Rosters
June Rosters

Posts per Shift
3|1
4|0
4|0
4|0

Day 1
- | -*
4|0
Blank Roster

Sample Day
Day 2
Day 3
- | -*
4|0
Blank Roster
1|0
- | -*
1** | 0
Period Total

Total
4
5
1
10

*Weekend.
**Posts without staff assigned 3 of the 4.
Summary: Trousdale Turner lists 4 posts on 1st shift and 0 on 2nd shift. Rosters show 1st-shift posts are 8 hours,
from 7:00 a.m. to 3:00 p.m. In our sample, 10 out of 24 posts were unfilled. The staffing pattern recommends 24
posts; however, 6 of these are to be on 2nd shift.

Whiteville did not have designated transportation posts on its roster. The staffing pattern
provides that there should be 2 posts on the 1st shift for 8 hours, 5 days a week.
Department of Correction Monitoring
We reviewed Whiteville’s April, May, and June monitoring reports; its March, May, and
June noncompliance summaries; and its April and August noncompliance reports. For Trousdale
Turner, we reviewed its June noncompliance report, as well as its April and June monitoring report.
In these reports, the department did not cite unstaffed posts or staffing pattern inconsistencies for
these two prisons for the reviewed period. The department’s annual inspections for Whiteville and
Trousdale Turner did not address these areas either. The staffing reports we reviewed indicated
compliance with staffing rosters and staffing levels. We found, however, that the rosters did not
match the approved staffing patterns, and both facilities were experiencing problems filling posts
consistently.
The contract monitor for Trousdale Turner did include unstaffed critical posts in the most
recent noncompliance report dated August 11, 2017, we feel in part due to the observations we
shared. As a result of the noncompliance report, Trousdale Turner created a plan of action to
address these issues.
We visited both Trousdale Turner and Whiteville facilities and spoke with the wardens and
other facility staff, as well as the contract monitors. Historically, staffing has been a concern for
correctional facilities statewide. According to Trousdale Turner management, they continue to
recruit new officers and have increased correctional officer salaries (see Table 8). The newly
appointed warden (as of July 1, 2017) informed us that they conduct pre-service training for new
recruits every two weeks.

11

Table 8
Trousdale Turner Correctional Center
Correctional Officer Salary
2015

6/12/2016

12/11/2016

6/25/2017

$11.75

$13.75

$15.75

$16.50

Source: The Human Resources Director at the Trousdale Turner
Correctional Center.

The facilities have changed their training programs by emphasizing more on-the-job
training within the facilities, including exposing new recruits to inmates earlier in the curriculum.
Whiteville management mentioned that providing exposure upfront helps new officers to more
quickly determine if the job will be a fit for them or not. Whiteville has also increased salaries for
its officers, as shown in Table 9.
Table 9
Whiteville Correctional Facility
Correctional Officer Salary
2015

6/12/2016

12/11/2016

6/25/2017

$11.75

$11.75

$12.50

$13.25

Source: The Human Resources Manager at the Whiteville Correctional Facility.

Whiteville management mentioned during our visit that the overall nature of inmates and
the characteristics of newly hired correctional officers create new challenges for recruiting and
keeping correctional officers. The younger inmates are more disrespectful and less cooperative.
Young correctional officers no longer view the position as a career, but rather as a temporary
paycheck on the path to a different job, or perhaps to earn money while in school. Management
stated that younger officers take less pride in the job, but, more importantly, they lack the required
human interaction skills to properly interact with
the inmates.
“Staffing is arguably the most
Facilities that fail to maintain consistent
crucial element to safety inside our
staffing levels of correctional officers can be
prisons” and “the total interaction
limited in their ability to provide staff and inmates
between staff and inmates is what
determines the level of safety
with a safe environment and to meet inmate needs
within the facility.”
like recreation and transportation. A March 2017
article, “Impacts of Understaffing,” published by
—American Correctional Officer
Intelligence Network, “Impacts
the American Correctional Officer Intelligence
of Understaffing”
Network, states, “Staffing is arguably the most
crucial element to safety inside our prisons” and
“the total interaction between staff and inmates is
what determines the level of safety within the
facility.” Staffing rosters and staffing patterns are strong indicators of operational performance,
and they should be analyzed routinely. Not following approved staffing patterns can undermine

12

the department’s ability to provide a safe prison environment and to reduce recidivism. It can also
lead to increased violence, escapes, forced overtime, staff sick leave, staff turnover, and cases of
post-traumatic stress disorder.
Recommendation
To ensure critical posts are staffed, the department’s contract monitors should identify
unstaffed critical posts, write noncompliance reports documenting these contract violations,
document when staffing levels are below the approved staffing requirements, and document the
actions Core Civic management takes to address staff shortages. The contract monitors also should
ensure that department management approve any staffing change before it is implemented. Core
Civic should ensure that facilities are operating with enough staff to provide necessary services
and should complete staffing reports for all shifts.
Management’s Comment
We concur in part with the finding. The Department of Correction has issued multiple
noncompliance reports to Core Civic for understaffing at both Trousdale Turner Correctional
Center (TTCC) and Whiteville Correctional Facility (WCFA). Both facilities have submitted
corrective action plans and have been proactive with regard to recruitment and retention, as
illustrated by significantly increasing staff pay. For instance, TTCC has increased their officer
pay by more than $4.00 per hour and is also providing an additional $1.00 to $2.00 per hour for
any correctional staff with previous years of correctional experience. Immediate signing bonuses
and relocation bonuses are also being offered by Core Civic as a means of resolving staff
vacancies.
We do not concur in part with the finding. The Department of Correction works daily with
Core Civic to support consistent staffing patterns and gives thoughtful consideration to any
proposed staffing changes. As a point of clarification, approved staffing patterns list how many
people are required to be working at the facility based on their inmate population. However, this
is not the amount of people required to be at the facility on a shift by shift basis. Various shifts
across a twenty-four hour period are characterized by staff being distributed differentially based
upon the movement (or lack of movement) associated with inmate activities. For instance, the
pattern of staff placement overnight is not identical to staff placement during the daytime.
Similarly, most facilities remove the front gate officer after traffic stops in the area. And finally,
some posts by function are only necessary when offenders are present, such as a utility/yard officer
position that is required if inmates are on the yard, but these officers are frequently redirected to
other functions when inmates are no longer present in that area.

13

Objective and Methodology for Staffing Reports (Finding 2)
We obtained staffing reports from each of the four Core Civic facilities for January through
June 2017 to determine if staffing information (new hires, terminations, and vacancies) was
accurately communicated. Contract terms require the state to develop reporting requirements for
staff turnover and vacancies and that each
month each contracted facility submit a
report to the contract monitor. The report
must include names and position numbers
for employees hired, the name of each
employee terminated including the reason
for termination, and any vacant positions
on the staffing pattern including the
number of days vacant. Department
contract monitors located on-site at each
contracted facility use these reports to
monitor staffing and identify contract
violations, such as when a position is
vacant for more than 45 days.
Contract monitors provided the
audit team staffing reports that are in the
form of a memo, except for the Whiteville
Correctional Facility, which provided a
Staffing Legend spreadsheet. The memos
are divided into three sections:
1. Total Number of Employees Hired for
Reporting Period,
2. Total Number of Employees
Terminated for Reporting Period, and
3. Vacant Positions in Staffing Pattern.
In each section of the memo, the
number of items in the list should equal
the total number at the top of the list.
For section 1, Employees Hired, the employee name and position title are provided; for
section 2, Employees Terminated, the employee name, position title, and reason for termination
are provided; for section 3, Vacant Positions, the position title, position number, and number of
days vacant are provided. The Staffing Legend provided by Whiteville is a spreadsheet which lists
each position in the facility and provides detailed information concerning position numbers,
employee names, hiring dates, termination dates, and vacancy designations.

14

Finding
2.

Core Civic staffing reports for two facilities (Trousdale Turner Correctional Center
and Hardeman County Correctional Center) contained numerous errors, so
information about hires, terminations, and vacancies may not be reliable

Our review of staffing reports revealed inconsistencies regarding hires, terminations, and
vacancies for two of the four Core Civic facilities. We found the following reporting issues for
Turner Trousdale Correctional Center and Hardeman County Correctional Center:


missing position numbers for vacancies;



vacancies carrying over to subsequent months without additional vacant days;



vacancies listed with more than 30 days not listed for the previous month;



different job titles with the same position number;



the number of hires and terminations not reconciling to the number of vacancies; and



reports missing the number of filled positions, inmate population, and officer-to-inmate
ratio.

We elaborate on two of the more significant problems below.
Not Providing Position Numbers
In the April, May, and June 2017 staffing reports, staff at Trousdale Turner listed
“Correctional Officer, 64 Positions” and “Senior Correctional Officer, 9 positions” as vacancies
(see Exhibit 1). Without position numbers for each unique position, the contract monitor has a
limited ability to track positions over time and the report does not meet contract requirements. We
also observed that reports we reviewed did not include position numbers with the lists of hires and
terminations, but did include this information for vacancies. This means monitors could not easily
compare lists and locate discrepancies.

15

Exhibit 1
Vacant Positions in Staffing Pattern for Trousdale Turner Correctional Center

Carrying Over Recurring Vacancies Without Adding Additional Vacant Days
We found that the department did not cite at least two 45-day violations at Trousdale Turner
because of not verifying the staffing report information. The contract monitor issued a
noncompliance report for March 2017 that cited Trousdale Turner for having 2 positions vacant
for more than 45 days. These positions both showed 152 days vacant. We identified 3 additional
positions that could have also needed citing (at least 2 should have been cited). Trousdale Turner
reported 2 of these positions in the March 2017 staffing report as 24 and 29 days vacant, with
another reported as 41 days vacant. However, these same positions were listed in the January and
February reports as 24 and 29 days vacant, and the third as 8 days vacant. Because the positions
had carried over 2 months without additional vacant days added (31 days between the January and
February report + 25 days between the February and March report), they appeared on the March
report as under the 45-day threshold (see Exhibit 2). Positions 4714351 and 4714131 should have
been cited in February with 60 days and 55 days vacant; and in March, with 85 days and 80 days
vacant. Because 4714094 is listed in March as having 41 days, it was likely filled during the
month, which is why 41 days vacant is listed. Without positions numbers in the Hires section of
the report, it is difficult to confirm.

16

Exhibit 2
Trousdale Turner Correctional Center’s Staffing Reports
January Through March 2017
January 2017 Staffing Report

February 2017 Staffing Report

March 2017 Staffing Report

Recommendation
The department’s monitoring staff should ensure that the information they receive from
Core Civic is complete and accurate, and they should verify information, including vacancies and
the length of time positions are vacant. If the reports are not accurate, monitors should cite this in
noncompliance reports until the issues are corrected. Additionally, the department may wish to
require the number of filled positions and inmate population to be included in each report, so it
can better determine the officer-to-inmate ratio, staff turnover rates, and vacancy rates.
Management’s Comment
We concur with the finding. Trousdale Turner Correctional Center (TTCC) has been
instructed to use the format identified by the Comptroller’s Office audit staff as the best mechanism
for reporting vacancies. Using the suggested format will improve the accuracy of information
being provided to the monitor and more readily reveal any noncompliance.
17

STAFFING—STATE FACILITIES
Observation
1.

The department should annually publish the correctional officer turnover rate and
clearly identify which classifications are included in its annually published correctional
officer series turnover rate

Department of Correction management acknowledges that the turnover rate for
correctional officers is high in state-operated correctional facilities. The department operates 10
correctional facilities, and the average correctional officer salary was $28,389.61 between fiscal
years 2014 and 2017 (see Chart 1).
Chart 1
Average Correctional Officer Salary
FY 2014-FY 2017

$29,918

$28,620
$27,732

FY2014

$27,288

FY2015

FY2016

FY2017

Source: State of Tennessee’s employment management system, EDISON.
We obtained Correctional Officer employee data for each fiscal year and
averaged the salaries.

Department Correctional Officer Turnover Rate
As the department does not annually publish the correctional officer turnover rate, when
we asked them to provide the rates, the department’s human resources management said it would
take some time to calculate the turnover rate to provide to us. Furthermore, the department’s
human resources management was unable to provide us with a standardized method for calculating
the correctional officer turnover rate. The turnover rate for correctional officers eventually
provided to us is higher than the turnover rate the department published in its annual statistical
abstract reports for fiscal years 2013 through 2016.
We calculated correctional officer turnover rates, because this is an entry-level position
whose adequate staffing is critical to the security of correctional facilities. We calculated officer
rates for fiscal years 2014, 2015, 2016, and 2017. Our calculated correctional officer turnover rate
and the department’s human resources management-provided turnover rate are similar. Chart 2
illustrates that both of the calculated turnover rates for correctional officers (only) are higher than
18

the correctional officer series turnover rates published in the department’s statistical abstract
reports. This shows the mitigating effects of including supervisory and managerial classifications
in the calculation of turnover, instead of reporting the officer rate independently.
Chart 2
Turnover Rates
FY2014 - 2017
Reported by department in Statistical Abstracts (Correctional Officer Series)
Calculated by Comptroller's Office (Correctional Officer)
Provided by department during the audit (Correctional Officer)
62%
56%
50%

37% 37%

48%

48%

45%

40%
36%

30%

2014

2015

2016

2017

Not publishing the correctional officer turnover rate may provide stakeholders with
incomplete data. We recommend that the department publish the correctional officer turnover rate
in its statistical abstracts in addition to the series rate. The department should also clearly
communicate which positions are included in the series rate it publishes and the rationale for
providing a combined series rate.
Staffing Concerns
The percentage of correctional officer separations in the first three years of employment
has increased to 93% from an average 86% for the prior three fiscal years. On average, the bulk
of these separations are a combination of job abandonments and resignations (63%), which is 3
times higher than the next category (dismissals or qualifications not met). See Charts 3 and 4.

19

Chart 3
Breakout of Separations
2014-2017 Averaged
Retirement 5%

Cancellation of
Appointment 4%
Death 0%

Chart 4
Correctional Officer Separations
Within 3 Years or Less
93%

Dismissals/ Qualifications
Not Met 21%

86%

86%

87%

FY2014

FY2015

FY2016

Job Abandonment/
Resignation 63%

FY2017

To better prepare new correctional
officers for the position, the department has recently modified its training to include two weeks of
on-site training at state-operated correctional facilities.
Overtime Policy
In 2014, the department adopted a 28-day period for staff scheduling, citing advantages
such as improved departmental communication and flexibility in scheduling. However, (1) the
length of time between working and being paid for overtime, and (2) not accruing overtime pay
(time and a half) until after working 171.1 hours in those 28 days may be factors in the increase in
turnover between 2014 and 2015. The American Correctional Association recommended, in its
October 2015 report, that the department change the work period from 28 days to 14 days. In
2017, the department moved to implement the 14-day work period.
According to the department, for the 14-day period to be successful, correctional officers
will be required to work 12-hour shifts, which will reportedly allow for complete shift coverage in
the state-operated facilities. In addition, the 12-hour shift, the department says, will allow
correctional officers to be off every 4th day. However, according to facility staffing, some
correctional officers may still be required to work a schedule outside of the 12-hour shift, 14-day
work period schedule, but this is a facility choice.
Under the 14-day period, the department pays correctional officers premium overtime pay
after 80 hours worked within the 14 days. The department cites advantages for correctional
officers such as a reduced amount of time between working and being paid for overtime; not being
required to work more than three days in a row; and getting a three-day weekend every other week,
via a rotating schedule.
The department will pilot the new scheduling system beginning in September 2017 at
Bledsoe County Correctional Complex, Turney Center Industrial Complex, and West Tennessee
20

State Penitentiary, and in late November or early December 2017 at the other seven state-operated
correctional facilities. Once the new system is fully implemented at all state-operated correctional
facilities, the department will be the only state agency utilizing the 12-hour shift, 14-day work
period scheduling system.

PRIVATE PRISON MONITORING
Objective and Methodology
Our objective was to evaluate the Department of Correction’s monitoring of the state’s
private prisons. To accomplish that, we conducted inspections and file reviews at two Core Civic
facilities housing Tennessee inmates. We identified several of the department’s operational
policies, and facility standards, and contract requirements and tested each facility’s compliance
with these and with records management. Our work at each facility included observing, reviewing
paper files, and checking records in the Tennessee Offender Management Information System
(TOMIS). For the file reviews and record checks, we generated a random sample of inmates from
each of the facilities’ roster reports and reviewed information for those selected. For Trousdale
Turner Correctional Center, we randomly selected 248 inmates from a roster of 2,483. Once onsite, we determined that after a review of 93 inmate files and 87 medical files, we had a sufficient
understanding of the identified problems and would not benefit from further review. Based on our
experience at Trousdale Turner, we randomly selected 50 inmates from 1,497 at the Whiteville
Correctional Facility. We reviewed all 50 inmate and medical files. Our sampling methodology
is nonstatistical; therefore, our conclusions are not statistically generalizable to the entire
population. We decided that 50 files from Whiteville would be sufficient to identify if the same
types of issues found at Trousdale Turner were also occurring at Whiteville.
We reviewed compliance with facility standards, including unimpeded inmate access to
sick call and grievance forms; instructions for obtaining health care posted in housing units;
grievance procedures accessible in the facility’s library; locked depositories for collection of
grievance forms; sign-in sheets to record attendance at classes or jobs within the facility; and
secure storage of incident reports and video recordings that are clearly labeled to match written
reports.
We also examined a sample of inmate files and medical files for items required by
departmental policy, including documentation of inmate health screenings upon arrival at each
facility and inmate-signed facility orientation forms, which communicate instructions for
obtaining medical care. We also reviewed charge sheets, which inmates are required to sign when
disciplined, or their refusal to sign must be noted.
Finally, we checked TOMIS records for documentation of inmate activities, analyzing
whether disciplinary investigations had been completed within seven days of the incident; whether
appropriate fines were assessed against inmates guilty of disciplinary infractions; whether
documentation of disciplinary reports was signed by both the inmate (or their refusal noted) and
the reporting staff member; and whether inmate grievances were documented and resolved within
appropriate time periods. Our work resulted in the following finding.

21

Finding
3.

Trousdale Turner Correctional Center management’s continued noncompliance with
contract requirements and department policies challenges the department’s ability to
effectively monitor the private prison

After nearly two years in operation, Trousdale Turner Correctional Center still did not
comply with some of the Department of Correction’s policies, facility standards, and contract
requirements. While the department’s contract monitoring efforts regularly report the facility’s
shortcomings, cuts in monitoring staff may have reduced the department’s ability to effectively
monitor key contract requirements. This lack of effective monitoring has resulted in situations
that may undermine the department’s ability to achieve its stated mission, and could result in harm
to inmates.
Our facility visits and file reviews (see the above Objectives and Methodology section for
sampling information) revealed multiple instances of noncompliance at Trousdale Turner. One
issue, unimpeded access to sick call and grievance forms, appeared to be an issue at both Trousdale
Turner and Whiteville. Issues of noncompliance identified during our tour at Trousdale included
the following:


One housing pod did not have grievance forms in the unit, and two pods did not have
sick call request forms. Inmates were required to request these forms from the
correctional officer on duty. The officer in one of those units reported being out of sick
call forms for approximately four hours and waiting for copies. Access to grievance
forms, according to the department’s Policy 501.01, is required to be “unimpeded.”
Access to health care is governed by the department’s policies and terms of the contract.



Only one pod out of four had instructions for obtaining medical care posted in the pod.
Facility management reported that inmates often tore down items posted in pods or tore
off small pieces to write notes, eventually destroying the posted item. Facility
managers reported that they were planning to install closed-circuit television screens
high on the walls of the pods, with rotating screens displaying information inmates
need to know.

Impeded access to sick call forms may reduce inmates’ ability to receive timely medical
examinations and treatment. Impeded access to grievance forms may reduce inmates’ willingness
to file grievances against the same staff members they have to ask to provide them with grievance
forms.
We did not find issues with locked depositories at housing units, available grievance
handbooks, appropriate sign-in sheets at inmate job locations, classrooms with assigned inmate
signatures, proper segregation unit records, and properly stored incident report records and videos.
Departmental policies also require certain paperwork to be included in inmate files or inmate
medical files. Inmates must sign a form indicating they received facility orientation and instructions
for obtaining medical care. Below are the results of our file reviews for Trousdale Turner:

22



Of 87 medical files, 11 (13%) did not include documentation of a health screening
conducted upon arrival at the facility.



Of 93 inmate files, 27 (29%) did not include documentation that inmates had been
instructed on how to obtain medical care.

We also checked the sampled files for appropriate notations in TOMIS regarding
grievances, fines assessed to inmates found guilty of disciplinary infractions, and attendance at
assigned jobs or classes. Results of our review at Trousdale Turner include the following:


Of 29 inmates with grievances noted in TOMIS, 1 (3%) had a grievance that was not
logged in TOMIS.



Of 80 inmates assigned to either a job or class, 20 (25%) had no attendance recorded.
Of those 20, 18 were assigned to classes, not jobs.



Of 80 inmates assigned to either a job or class, 16 (20%) had inaccurate information
recorded. Inaccuracies included long periods of time where no attendance was
recorded; instances of an inmate assigned to one job or class, but attendance recorded
for something different; or an inmate assigned to a class, but attendance at a job
recorded. Supervisors of facility school staff are responsible for entering inmate
attendance. The department monitor noted problems with verifications of class
attendance in the March 2017 internal compliance audit.

These issues at Trousdale Turner could have been caused by relatively new staff members
and a lack of experience and training on TOMIS data entry, or by the inmates not attending
assigned classes. Notably, from the sampled files at Trousdale Turner, we found no instances of
fines not assessed for inmates found guilty of disciplinary infractions.
Reduction in Department Monitoring Staff
We found that the department reduced its monitoring staff and increased the
responsibilities of contract monitors at private prisons. Contract provisions include both a contract
monitor and a liaison from the department located on-site, with their salaries reimbursed by the
private contractor. In July 2015, as a part of the state’s Voluntary Buyout Program (VBP), the
department eliminated the liaison positions at all private facilities, leaving one contract monitor at each
facility to do both jobs. The department also created a single correctional administrator position to
oversee monitoring and to provide a layer of administrative oversight for the four private facilities.
According to TDOC’s justification for this restructuring, this additional layer of administrative
oversight would both increase accountability and ensure consistency in operational policies and
procedures. However, the liaison’s duties were to be absorbed by the contract monitors, adding such
additional duties as attending disciplinary and grievance hearings, approving inmate segregation, and
being available 24/7 to receive incident reports from the prisons. Contract monitors’ original task was
to ensure facilities complied with policies, contract provisions, and the Commissioner’s directives in
all areas of facility operation. Under the structure in place after the VBP, contract monitors are not
only responsible for the liaison duties described above, but also for completing each of the monitoring
instruments below on a quarterly basis:

23

Commissary
Disciplinary Procedures
Facility and Property
Inmate Jobs
Policies and Procedures
Safety
Security Equipment
Staffing (monthly)

Counts
Drug Testing
Grievances
Personal Property
Records and Reports
Searches
Special Management Inmates
Use of Force

Having only one individual responsible for both monitoring and (former) liaison duties at
Trousdale Turner may have contributed to that facility’s continued noncompliance. Other possible
significant factors are the following:


Trousdale Turner is a relatively new facility.



Instability in leadership could be a factor—during our review, the facility was on its
third warden in two years.



A mix of inmates transferred from other prisons into Trousdale Turner, a newly
established correctional setting and population. For example, wardens at other facilities
asked to transfer inmates to Trousdale Turner might move those with disciplinary
issues, inmate compatibility issues, or security threat group (gang) affiliation.



Compared to Whiteville, which we found to be largely in compliance with policies and
contract provisions, Trousdale Turner is significantly larger, housing 2,483 inmates
compared to 1,497 at Whiteville at the time we visited. A larger facility, with nearly
1,000 more inmates, would likely also have more disciplinary problems, grievances,
incidents, and staffing challenges. When we visited Trousdale Turner, the department
was in the process of transferring approximately 40 inmates per day in and out of the
facility to reduce the percentage of confirmed gang-affiliated inmates at the facility.



A larger facility adds to the responsibilities of the single on-site contract monitor, likely
reducing the overall effectiveness of monitoring to enforce compliance.

The conditions identified in this finding could undermine the department’s ability to
prepare offenders for successful reentry into society. Not enforcing class attendance; inaccurate
recordkeeping; limited access to grievance, medical, and sick call forms; and unperformed health
screenings may prevent the facility from meeting the department’s goal of providing a successful
correction system.
Recommendation
The department should address any monitoring deficiency resulting from its decision to
eliminate the department liaison position from private prison contract monitoring staff. The
department and Core Civic should ensure that staff properly record class attendance and job
assignments in TOMIS and should ensure inmates attend their assignments. The department and
Core Civic should provide inmates with unimpeded access to grievance and sick call forms. The

24

department should enforce compliance with policies, standards, directives, and contract terms, and
should consider imposing civil monetary penalties allowed in the contract.
Management’s Comment
We concur with the finding. Aptly noted by the Comptroller’s Office auditors, Trousdale
Turner Correctional Center (TTCC) is a relatively new facility that has been operating for less than
two years. As such, considerable oversight has been required at the Correctional Administrator
level. Many noncompliance issues have been documented on the contract monitoring reports,
annual audits, and quarterly medical and mental health audits.
At the direction of the Correctional Administrator, the facility Contract Monitor has
submitted 36 noncompliance reports in the last 18 months that relate to nearly every area of the
facility. This past March, the annual audit contained 66 deficiencies and resulted in the decision
to double the number of audits being conducted at TTCC to ensure continuous forward progress
in meeting compliance expectations. The department has also submitted a breach of contract
requesting liquidated damages due to continued noncompliance on a critical operational issue.

COMMUNITY SUPERVISION DIVISION
The Community Supervision Division monitors offenders placed on either parole or
probation. Offenders on parole have been incarcerated and released to the community. Offenders
on probation have been found guilty of a crime but have not been imprisoned. Parole and probation
officers monitor offenders to ensure compliance with supervision requirements specified by the
offender’s assigned supervision level.
The 2012 performance audit and the 2014 follow-up audit identified two findings, one
regarding offender supervision by parole and probation officers, and the other pertaining to
supervisory review. To determine whether the department resolved the two findings, we tested a
sample of 60 probation and parole offenders from the 70,438 offenders the department is
responsible for monitoring. The sample consisted of


12 offenders (6 on parole and 6 on probation) who were assigned to Interactive
Offender Tracking for noncompliance with the conditions of their supervision;  



12 offenders (6 on parole and 6 on probation) who were placed on Global Positioning
System (GPS) monitoring due to a sex offense conviction or having attributes of a
violent nature; and  



36 regular offenders (18 on parole, and 18 on probation).  

We reviewed both TOMIS records and paper files over a six-month period, November 2016 to
April 2017, to assess the department’s compliance. We used this sample for both Findings 4 and
5.

25

Finding
4.

Probation and parole officers did not always meet supervision requirements

As noted in the 2012 and 2014 performance audits, probation and parole officers did not
always meet supervision standards. We noted the following problems during our current review:


3 of 48 required arrest checks (6%) were not performed and 1 (2%) was not performed
within the required time frame;



1 of 48 required drug tests (2%) was not performed within the required time frame;



1 of 12 Vermont Assessment of Sex Offender Risk checks (8%) was not performed
within the required time frame;



3 of 48 offenders tested (6%) did not have matching addresses in TOMIS and the paper
file;



1 of 12 offenders (8%) was missing sex offender treatment monitoring checks;



4 of 48 offenders (8%) were missing required face-to-face checks; and



7 of 48 special condition monitoring checks (15%) were not conducted in the required
time frame.

We determined that the department has not fully corrected probation and parole issues
identified in the previous two performance audits and must continue to improve its monitoring
capabilities.
Recommendation
We recommend that the department ensures probation and parole officers conduct all
required monitoring activities and enter all information into TOMIS.
Management’s Comment
We concur with the finding. The Department of Correction has significantly changed how
offenders are being managed in the community since assuming responsibility for them in 2012.
The goals for the transfer of community supervision included the creation of a seamless
supervision model that would foster consistency in how offenders were being managed, focus on
increased accountability for offenders, provide cohesive, assessment driven prevention and
intervention strategies, and streamline services that would enhance public safety.

26

To date, the agency has


Updated the Probation Parole Standards of Supervision to better align with best
practices;



Established felony offender individualized case management plans;



Implemented a validated risk /needs assessment that is utilized throughout the criminal
justice community;



Effectively enacted a swift, certain and proportionate system of graduated sanctions to
hold offenders on community supervision accountable;



Successfully leveraged partnerships that support enforcement both within and outside
the agency;



Invested heavily in staffing, training, and equipping Probation/Parole Officers to
improve felon risk management in the community;



Expanded transitional programming and treatment availability across the state;



Focused on workforce development and employable skills training through the opening
of the Mark Luttrell Transition Center in Shelby County;



Partnered with the Department of Safety and Homeland Security to issue drivers
licenses to offenders preparing for release to the community; and



Achieved ACA accreditation of the Community Supervision division.

These accomplishments have resulted in a more robust system of accountability in both how
offenders are being supervised in the community and the overall level of offender compliance with
conditions of supervision. Given these improvements, it is safe to say that, despite the occasional
human error, the day-to-day supervision of more than 78,000 offenders is better managed now than
at any previous time.
As it relates to the specific audit finding, the department continues to seek improvements
in the monitoring capabilities of parole and probation officers tasked with ensuring that offenders
in the community are meeting supervision requirements. One example of enhancing officer
monitoring capabilities involves recent changes to the Standards Due Report that have been made
since the audit follow-up period concluded. The report is a weekly summary of supervision
standard compliance requirements and the frequency of the requirement for each offender under
parole or probation supervision. Using the new Standards Due Report has enhanced the ability of
our community supervision officers and managers to monitor the timeliness of completion of
compliance standards, such as arrest checks, drug screens, and special conditions checks,
throughout the month (rather than at the end of the month).
To further strengthen offender monitoring, by 2018 a compliance rating scale will be
assigned to each standard in the Standard Due Report. The result will be a compliance score
automatically calculated for each offender every time the report is generated. This modification
will allow officers, managers and other members of leadership to quickly review the compliance
requirements and status for each offender under supervision in the community.
27

Finding
5.

Probation and parole supervisors did not always meet oversight requirements

As noted in the 2012 and 2014 performance audits, supervisors did not meet the
requirements for reviewing the work of probation officers.
According to the department’s Policy 706.02, “Supervisory Review of Caseloads,”


supervisors shall review all offender case records within 60 days of the
offender’s supervision start date, and



closing case records reviews shall occur no later than 90 days prior to the
offender’s projected expiration date.

To determine if supervisors reviewed the files within the required time frames, we tested
60 probation and parole files. Within the sample of 60 case files, we identified 5 files initiated
after November 1, 2016, thus requiring review by the officer’s supervisor within 60 days. We
found that 2 of the 5 case files had been reviewed by a supervisor within 60 days, while 2 did not
contain the required initial case file review code indicating the date when the file had been
reviewed, and 1 was not performed within the required time frame.
Closing Reviews
Supervisors are required to review case files no later than 90 days prior to an offender’s
projected expiration date. Within the same sample of 60 offender files reviewed, we identified 47
cases closed or projected to close after November 1, 2016. Of these cases, 37 had expiration dates
beyond the time frame where we could assess compliance with six of these cases having lifetime
supervision because they were sex offenders. Of the remaining case files, 3 did not have a closure
review, 4 cases with closure reviews were conducted after the expiration date, and 3 complied with
the criteria.
Annual Reviews
To determine if case files were annually reviewed as required, we tested a sample of 10
active case files out of the 961 cases TOMIS selected for supervisory review in April 2017. We
found that 6 of the 10 sampled files had an initial case review code, indicating that they had been
reviewed in April as required. Three of the 10 case files had not been reviewed. The 10th file had
a supervisor closing code for the month reviewed.
We determined that the department has not fully corrected the issues and must continue to
improve its supervisory review of parole and probation officers.

28

Recommendation
The department should ensure probation and parole officers and supervisors complete case
file reviews as required.
Management’s Comment
We concur with the finding. The department is currently implementing a Case
Management Review (CMR) process to facilitate improvements in probation and parole managers’
ability to meet oversight requirements. The goal is to support effective and efficient use of time
and assets to ensure the completion of mandatory case records reviews while maintaining a robust
role in supervising probation and parole officers. An integral part of the CMR process is the
Standards Due Report discussed in Management’s Comment for Finding 4.
Access to the weekly Standards Due Report is now providing managers with information
that allows them to quickly assess the status and compliance for each officer’s caseload and
promptly work with officers to appropriately schedule and manage their outstanding requirements
for the month. In addition, the district directors can easily discern their district’s compliance at
any given time during the month and follow up as appropriate with managers.
Quicker assessments of caseload status and the ability to streamline the management of
outstanding caseload requirements increase the time available to perform the mandatory case
records reviews. However, even a successful time saving process isn’t a sufficient substitute for
much needed staff increases. Consider this example. Caseload sizes are high (frequently more
than 100 offenders) and managers supervising 8 or more officers may have review responsibilities
for almost 1,000 offenders. The 3% casefile review protocol means that a manager is expected to
complete about 360 case records reviews per year while actively managing their parole and
probation officers. This is in addition to the required initial case records reviews and all closing
case records reviews.

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