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Policy 115.331, Employee Training, requires that all applicable staff be trained on
key PREA concepts, including the facility’s zero-tolerance policy for sexual abuse
and sexual harassment; staff responsibilities for prevention, detection, reporting,
and response; resident rights to be free from sexual abuse and retaliation; dynamics
and common reactions of juvenile victims; recognizing and responding to signs of
abuse; maintaining professional boundaries; appropriate communication with
residents; mandatory reporting obligations; and relevant laws regarding age of
consent.
The PREA Coordinator confirmed that NNJDC provides PREA training primarily
through structured presentations, including the monthly PREA Refreshers offered
through PowerDMS training software and the Maintaining Appropriate Boundaries
and Professional Relationships PowerPoint. The PREA Coordinator provided
documentation confirming that all current employees received required annual PREA
training.
Interviews with a random sample of staff demonstrated consistent understanding of
PREA requirements and facility expectations. All staff interviewed confirmed that
they had received PREA training upon hire and participate in annual refresher
training. Staff were able to articulate key PREA concepts, including reporting
obligations, resident rights, and appropriate professional boundaries.
The auditor verified through review of personnel training files that PREA training
documentation is maintained for all staff. Each employee’s training record includes
documentation of training topics, completion dates, and required certifications. For
specialized staff, including investigators, medical personnel, and mental health
staff, additional training is provided through the National Institute of Corrections
online platform, PowerDMS, and The Moss Group. Certificates of completion for
these specialized trainings were reviewed and confirmed in the applicable personnel
files.
Training records further confirmed that PREA training is provided during the
onboarding process, typically within the first month of employment, and is
reinforced through annual refresher training. Staff interviews corroborated this
training schedule, with personnel consistently reporting regular PREA training
participation through PowerDMS software.
The auditor also determined that NNJDC’s training curriculum is tailored to the
juvenile population and includes instruction relevant to both male and female
residents. Staff demonstrated an understanding of how PREA principles apply to the
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