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Policy 115.316, PREA Residents with Disabilities/Limited English Proficient, outlines
the facility's procedures for providing reasonable accommodations and
communication assistance to residents with disabilities or limited English
proficiency. The policy provides for the use of qualified interpretive services, medical
staff, Community Services staff, and other appropriate resources, including the
American Red Cross when applicable, to ensure residents receive PREA-related
information and services in a manner they can understand.
According to the Pre-Audit Questionnaire and information provided by the PREA
Coordinator, NNJDC did not house any residents with hearing, vision, or speech
disabilities during the previous 12-month audit period. Although the facility had not
needed to implement these accommodations during that time, policies and
resources are in place to ensure effective communication should the need arise.
During the facility tour, the auditor observed PREA informational posters displayed
prominently throughout the facility in both English and Spanish. Spanish-language
versions of the Resident's Guide to Sexual Misconduct and the PREA brochure are
also readily available for residents who require them. The PREA Coordinator
explained that Spanish is the most common non-English language encountered at
the facility and that telephonic language interpretation services are available
through a language line whenever interpretation is needed for residents who speak
other languages.
Policy 115.316 further prohibits the routine use of resident interpreters, resident
readers, or other resident assistants for PREA-related communications. The policy
permits their use only in limited exigent circumstances when an extended delay in
obtaining a qualified interpreter could compromise resident safety, the performance
of first responder duties, or the investigation of a resident's allegation of sexual
abuse.
The Pre-Audit Questionnaire reported, and the PREA Coordinator confirmed, that
there were no instances during the previous 12 months in which resident
interpreters, readers, or other resident assistants were used for PREA-related
matters.
Interviews with staff demonstrated a clear understanding of the facility's
requirements regarding interpretation services. Staff consistently stated that
qualified interpreters would be utilized whenever possible and that resident
interpreters would only be used in emergency circumstances where delaying
communication would jeopardize resident safety or the integrity of an investigation.
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