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- Board of State and Community Corrections
- Kern County Probation Department
- County of Los Angeles Probation Department
- Mendocino County Probation Department
- San Joaquin County Probation Department
- County of Santa Barbara Probation Department
Board of State and Community Corrections
March 25, 2020
Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 200
Sacramento, CA 95814
Linda Penner, Chair
Board of State and Community Corrections
2590 Venture Oaks Way 200
Sacramento, CA 95833
Dear Honorable Ms. Howle,
The Board of State and Community Corrections (BSCC) has received the California State Auditor’s (CSA) recommendations on the Juvenile Justice Crime Prevention Act. We have provided the responses to your recommendations below.
Each header will summarize the recommendations from the CSA and we have numbered the referenced question on the audit report:
SUMMARY OF RECOMMENDATIONS – RESULTS IN BRIEF - (PAGES 7 – 8)
5. BSCC should revise its comprehensive plan template to require Coordinating Councils to specify plan components the county is changing and what those changes are. If the county is making no changes, the template should require Coordinating Councils to explain why no changes to the plan are necessary.
BSCC’s Response: BSCC agrees and has implemented this recommendation for the upcoming 2020 reporting period.
6. BSCC should review the information counties submit to it and follow up with them to obtain missing information or to clarify information that seems incorrect.
BSCC’s Response: On a limited basis, BSCC will follow up with counties to clarify information that seems incorrect.
RECOMMENDATIONS CHAPTER 1: COUNTY OVERSIGHT OF THE JJCPA IS WEAK - (PAGES 31 – 32)
4. To ensure that counties’ comprehensive plans are informative and up to date, BSCC should revise its plan template to require Coordinating Councils to specify plan components the county is changing and to describe those changes. If the county is making no changes, the template should require Coordinating Councils to explain why no changes to the plan are necessary.
BSCC’s Response: BSCC agrees and has implemented this recommendation for the upcoming 2020 reporting period.
RECOMMENDATIONS CHAPTER 2: THE STATE HAS NOT PROVIDED SUFFICIENT OVERSIGHT OF THE JJCPA (PAGES 46 – 48)
3. To ensure that counties include accurate information in their comprehensive plans and year-end reports, BSCC should review the information counties submit to it and follow up with them to obtain missing information or to clarify information that seem incorrect.
BSCC’s Response: On a limited basis, BSCC will follow up with counties to clarify information that seems incorrect.
4. To better promote effective local efforts related to the JJCPA, BSCC should include on its website the capability for stakeholders, counties, and other interested parties to review and easily compare the JJCPA information of multiple counties. Specifically, its website should allow users to be able to select a specific type of JJCPA-funded program and easily review information the counties submitted for all programs associated with the program type.
BSCC’s Response: BSCC believes that the information about programs is readily available in the individual county reports that are posted. Although there may be value in providing searchable capability by program type, the BSCC does not currently have the resources for this work.
5. BSCC should determine the cost of providing this additional service and, if necessary, request additional resources.
BSCC’s Response: In the event of a statutory change to require this additional reporting, BSCC would cost out the resources that would be needed.
If you have questions, please contact Juanita Reynaga at Juanita.Reynaga@bscc.ca.gov.
Thank you,
LINDA PENNER
Chair
Cc:Vance Cable, Senior Auditor Evaluator I
Kathleen T. Howard, Executive Director
Aaron Maguire, General Counsel
Ricardo Goodridge, Deputy Director
Juanita Reynaga, Senior Management Auditor
Adam Lwin, Associate Governmental Program Analyst
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE Board of State and Community Corrections
To provide clarity and perspective, we are commenting on the response from Community Corrections. The numbers below correspond to the numbers we have placed in the margin of Community Corrections’ response.
We look forward to reviewing Community Corrections’ 60‑day response to the audit recommendations to assess its progress in implementing them.
Community Corrections plan to follow up with counties only on a limited basis to clarify information that seems incorrect is not sufficient. As we describe in Chapter 2, we found several instances in which counties did not report information correctly in their year‑end reports to Community Corrections. Further, we state in Chapter 2 that these issues would be relatively simple for counties to correct if Community Corrections reviewed the information they submit to ensure that they have accurately reported and appropriately categorized their programs. Thus, we stand by our recommendation that Community Corrections should review all of the information counties submit to it and follow-up with them to obtain missing information or to clarify information that seems incorrect.
We acknowledge in Chapter 2 that Community Corrections views its statutory responsibility to post a description or summary of JJCPA information narrowly and that Community Corrections has not calculated the cost of organizing and displaying JJCPA information on its website in more useful ways. We also point out in Chapter 2 that Community Corrections has the capability to develop a more robust presentation of JJCPA information because it currently presents other statewide information using the same software that we used to create our interactive graphic.To view a display of program budgets and information for all counties that participate in the JJCPA, visit our interactive dashboard in the online version of this report at www.auditor.ca.gov/reports/2019-116/supplementalgraphic.html. Further, as we explain in Chapter 2, some of the counties we visited expressed that it would be helpful if Community Corrections improved the information it displays about the programs that other counties are funding with their JJCPA allocations. Thus, we stand by our recommendation that Community Corrections should improve its website related to JJCPA information and we believe the minimal cost to implement the recommendation would help Community Corrections further satisfy its duty to identify and promote evidence-based and innovative programs.
Community Corrections incorrectly implies that our recommendation is contingent on a statutory change. It is not. We believe that Community Corrections should be proactive and determine the cost of providing the additional services on its website and, if necessary, request additional resources.
Kern County Probation Department
April 3, 2020
Elaine M. Howle
California State Auditor
621 Capitol Mall Suite 1200
Sacramento, CA 95814
Re: JJCPA Audit Response
Dear Ms. Howle:
Kern would like to thank the State Auditor’s staff. During the course of this audit, they were attentive and responsive, and we appreciate their professionalism. The County has received and reviewed the report. While we concur with some of its findings and comments, we disagree with others which will be discussed below. Regardless, we understand the importance of the audit process and will continue to strive to best serve the people of Kern County.
The section titled, “[Kern’s] Comprehensive Plan [Is] Outdated” discusses how Kern’s plan rarely changed and therefore was outdated. This does not take into account the significant changes outside of JJCPA funded programs. It is true that the JJCPA funded programs (Aftercare and GIST “Gang Intervention and Suppression Team”) continued to be JJCPA funded without much alterations since 2009. However, after a series of modifications to the plan in earlier years, we settled on a strategy concept that focused on those youth identified as moderate to high risk based on the PACT (Positive Achievement Change Tool – an evidence-based assessment), significantly gang involved, and released directly from long-term commitment programs (which made up Aftercare and GIST caseloads). Despite other changes made in our juvenile system unrelated to the plan, the number of youths requiring services through Aftercare and GIST justified the continued use of JJCPA funds dedicated to those programs.
There have been significant changes in our overall approach to juvenile justice in Kern over the same period of time. Examples include but are not limited to the following: Kern created the Juvenile Programs Unit, a unit of non-sworn staff who directly deliver multiple evidence-based treatment programs to youth both in and out of custody. Kern expanded services at our Bridges Academy; a school program operated in conjunction with the Superintendent of Schools. Increased mental health, educational and vocational programs have been offered to at risk youth. The Probation Department implemented use of an evidence-based assessment tool (PACT) that drives much of the decisions to divert youth out of the juvenile justice system, as well as determination of supervision level and needed programming in order to address criminogenic needs. Furthermore, Kern has focused on best practices and emerging trends through staff development through trainings and implementation of trauma informed care, motivational interviewing and evidence-based practices.
By focusing on JJCPA funded programs the report fails to paint the full picture of the changes and evolution to the continuum of services offered by Kern. While the JJCPA funded programs are a very important part of that continuum they are not exclusive of our overall approach and response. It was determined by the JJCC (Juvenile Justice Coordinating Council) that the JJCPA funded programs continued to be needed. The JJCC was fully informed and presented information regarding the other changes to the overall juvenile justice system.
The section titled “[Kern’s] Plan Would Benefit from Defining At-Risk Youth” states that Kern should define “at-risk youth” as part of its plan. While the County would concede that technically this is correct, it disagrees that the County has not, in practice, complied with this requirement. The entire way the County addresses its juvenile justice system is based on evidence-based assessments that determine risk level to re-offend. The County uses this information to make decisions on diversion or formal Court action. It drives how and to what level we supervise youth on probation. It helps dictate individual case plans to ensure that they focus on the top criminogenic needs of the youth. It drove the creation of the Juvenile Programs Unit by identifying the largest gaps in service to address criminogenic needs.
The “Introduction” section of the report discusses the Pew-McArthur Results First Initiate and Clearinghouse Database and its effectiveness and importance. It should be noted that Kern was one of the first four counties in California to implement Results First. This was done in our adult criminal justice system, however, much of what we learned was translated into our Juvenile system as well, resulting in the creation of new programs such as our Juvenile Programs Unit. This program, and others, focus on proven best practices in community corrections in order to reduce recidivism.
Ultimately, Kern will continue to strive for improvement in order to best serve our youth and our community. We will work diligently to address those areas where we concur changes should be made. However, based on the above stated reasons, we do not concur with several conclusions reach in the report.
Recommendation #1: To determine the effectiveness of their use of JJCPA funds, Kern…should include in its year-end reports to Community Corrections descriptions or analyses of how its JJCPA-funded programs influenced the county’s juvenile justice trends, as required by law.
Response to Recommendation #1: Kern agrees with this recommendation and will increase its descriptions and analyses of how its JJCPA-funded programs influenced the county’s juvenile justice trends in its year-end reports.
Recommendation #2: To accurately assess the effectiveness of their programs, Kern…should determine how to accurately identify in its case management system the JJCPA programs and services in which each individual participated or enhance these systems to provide this capability.
Response to Recommendation #2: Kern agrees with this recommendation. Our current case management system (CMS) is an older, home-grow system with limited data tracking capabilities. The County has attempted to upgrade its CMS capabilities; however, a new system has not yet been implemented. However, the County will implement alternative solutions to track the needed data to comply with the recommendation until a fully competent CMS solution is online.
Sincerely,
TR Merickel
Chief Probation Officer
Kern County Probation Department
merickelt@kernprobation.org
(661) 868-4102
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM The KERN county probation department
To provide clarity and perspective, we are commenting on the response from Kern. The numbers below correspond to the numbers we have placed in the margin of Kern’s response.
Although Kern asserts that it has made significant changes to its juvenile justice strategy, its comprehensive plans often did not reflect any changes. As we describe in the Introduction, the JJCPA requires counties to include four components in their comprehensive plans that generally summarize their holistic efforts to reduce juvenile crime. Additionally, we state in Chapter 1 that according to Community Corrections, the comprehensive plans should describe how JJCPA‑funded programs fit within the context of counties’ overall juvenile justice strategies. Therefore, to meet the requirements of the JJCPA related to preparing comprehensive plans, Kern should have communicated in its comprehensive plan any significant changes to its approach to juvenile crime and delinquency, including changes to its JJCPA‑funded programs. However, as shown in Figure 2, Kern made no changes to its comprehensive plan in 14 of the 18 years since the inception of the JJCPA. Consequently, we concluded that Kern’s comprehensive plans were outdated and do not accurately reflect the county’s strategies for addressing juvenile crime and delinquency.
We acknowledge in a text box in the Introduction that in addition to describing the JJCPA‑funded programs, the JJCPA requires counties to assess the existing services for juvenile offenders, at‑risk youth, and their families and to describe their local action strategies for providing a continuum of responses to juvenile crime and delinquency. As noted in Appendix B, the Audit Committee directed us to evaluate the spending, reporting, and evaluation of JJCPA funds by five counties, including Kern, and to evaluate their decision‑making processes related to these funds. While we were aware of other juvenile justice activities that the five counties performed, these activities were outside of the audit’s scope.
Although Kern asserts that it complied with this requirement in practice, Kern’s comprehensive plan did not formally define at‑risk youth or identify risk factors, as we indicate in Table 3. We acknowledge in Chapter 1 Kern’s efforts to revise its method for assessing whether juveniles are at risk of reoffending, but without specific, documented definitions of at‑risk youth in Kern’s comprehensive plans, parents and stakeholders may not know where to turn for services to assist the youth in their care. Likewise, without this definition, Kern cannot demonstrate that it has complied with state law requiring it to develop comprehensive plans that assess existing services for and includes responses to juvenile offenders and at‑risk youth.
We look forward to reviewing Kern’s 60‑day response to the audit recommendations to assess its progress in implementing our recommendations.
County of Los Angeles Probation Department
March 24, 2020
Ms. Elaine Howle
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Ms. Howle,
Attached is the Los Angeles County response to the draft report titled, “Juvenile Justice Crime Prevention Act: Weak Oversight Has Hindered Its Meaningful Implementation,” an audit that was the result of a Joint Legislative Audit Committee Request.
Our County has a history of prioritizing the utilization of our JJCPA funding for direct services to our youth and families. We will continue to work together with our decision makers and stakeholders to implement strategies that positively impact programming for our youth in Los Angeles County.
Additionally, I appreciate the process and time your Audit staff spent with my Department so that we could provide requested information and respond to this audit. Please direct any additional questions to Felicia Cotton, Deputy Director, Juvenile Field Services at (562) 940-2526 or via email at Felicia.Cotton@probation.lacounty.gov.
Sincerely,
Ray Leyva
Interim Chief Probation Officer
Attach.
c: Sheila E. Mitchell, Chief Deputy – Juvenile Services
Tom Faust, Acting Chief Deputy – Juvenile Services
Felicia Cotton, Deputy Director – Juvenile Field Services
The following includes the County of Los Angeles’ detailed response, by Chapter and Recommendation, to the Auditor of the State of California’s draft report titled, “Juvenile Justice Crime Prevention Act: Weak Oversight Has Hindered Its Meaningful Implementation.”
Overview
Overall, Los Angeles County’s JJCPA funding has been a part of our Juvenile Justice continuum for program and services provision to our youth and families since inception. As mentioned in the draft report, recent efforts to update our County’s comprehensive plan expanded and included additional stakeholders in the development process. Revisions throughout the years were based on strategies, which thereby impacted programs. Additionally, Los Angeles County went above and beyond by having our contracted JJCPA evaluator produce an annual report utilized to inform decision makers and stakeholders about promising program results.
Chapter 1: County Oversight of the JJCPA
Recommendation: To determine the effectiveness of its use of JJCPA funds, Los Angeles should include in its year-end reports to Community Corrections descriptions or analyses of how its JJCPA funded programs influenced the county’s juvenile justice trends, as required by law.
Response: Agree. Los Angeles County included the intended outcomes in the year-end reports, however there was a rich body of information from the evaluator and other researchers that could have been included as a supplement. This supplemental information has been utilized to inform decision makers and established policies throughout the juvenile justice community in the County of Los Angeles. The RAND Corporation, our JJCPA program evaluator during a portion of the audit period (Fiscal Years 2013-14, 2014-15, 2015-16) and Resource Development Associates (published evaluation in April 2018 for FYs 2012-13, 2013-14, 2014-15 and 2015-16) published reports on their public websites that affirmed such efforts
Recommendation: Los Angeles should collect data on all participants in each JJCPA program and service to adequately assess the effectiveness of those programs at reducing juvenile crime and delinquency.
Response: Agree.
Recommendation: To accurately assess the effectiveness of its programs, Los Angeles should determine how to accurately identify in its case management systems the JJCPA programs and services in which each individual participated or enhance these systems to provide this capability.
Response: Agree. Los Angeles utilizes several source systems to track the various youth and families who receive services through JJCPA funding. Our case management system is utilized for case information related to Probation youth.
Chapter 2: State Oversight of the JJCPA
Recommendation: None.
Appendix A – Program Descriptions, Expenditures, and Demographics of JJCPA Program Participants at the Five Counties We Reviewed, Fiscal Years 2013-14 through 2017-18
Comments: Table A.4, titled, “Percentages of Certain Demographics for Los Angeles JJCPA-Funded Programs During Fiscal Years 2013-14 through 2017-18,” includes our Base-Funded Programs and only one (1) identified One-Time Projects Program (the Early Intervention and Diversion Program). Additionally, the Table A.4 footnote mentions that “Los Angeles does not track demographic data for its Early Intervention and Diversion Program or its One-Time Projects Program. To clarify, the Early Intervention and Diversion Program is a One-Time Projects Program. Los Angeles has various One-Time funded programs for which we may collect participant or demographic information where applicable; some funded projects included system enhancements, transportation and other programs.
Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM the county of Los Angeles probation department
To provide clarity and perspective, we are commenting on the response from Los Angeles. The numbers below correspond to the numbers we have placed in the margin of Los Angeles’s response.
In Chapter 1 of our report we acknowledge Los Angeles’s contract with an external evaluator to assess the effectiveness of its JJCPA-funded programs. However, we disagree with the county’s characterization that it went “above and beyond” because Los Angeles did not include the key findings from its evaluator in its 2018 year-end report that it submitted to Community Corrections. As we note in Chapter 1, by not including its evaluator’s key findings in its year-end report, Los Angeles missed an opportunity to inform decision makers, stakeholders, and other counties about the effectiveness of its use of JJCPA funds.
Although Los Angeles indicates that it included the intended outcomes in its year-end reports, we found it did not report the measures of effectiveness required by state law. As we describe in Chapter 1, Los Angeles did not include in its year-end reports descriptions or analyses of how its JJCPA-funded programs may have contributed to or influenced countywide juvenile justice trends, such as declining arrests.
Los Angeles incorrectly states that Table A.4 includes only one identified One-Time Projects program—the Early Intervention and Diversion program. In fact, Table A.4 includes information for all of the programs Los Angeles reported that it operated from fiscal years 2013–14 through 2017–18, including the Early Intervention and Diversion program and the One‑Time Projects program. Further, Los Angeles’s assertion that the Early Intervention and Diversion program should be classified as a One-Time Projects program contradicts what it reported to Community Corrections. Specifically, in its year-end reports to Community Corrections, which was the source of the information presented in Appendix A, Los Angeles did not indicate that the Early Intervention and Diversion program was a One-Time Projects program. Thus, we expected Los Angeles to provide demographic data separately for both the Early Intervention and Diversion program and the One-Time Projects program.
Mendocino County Probation Department
March 19, 2020
Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
Please accept this letter as the County of Mendocino’s response to the California State Auditor’s draft, redacted report entitled, “Juvenile Justice Crime Prevention Act: Weak Oversight Has Hindered Its Meaningful Implementation”. As stated in our response, Mendocino County is committed to the goal of reducing crime and delinquency among young people.
We appreciate the professionalism of your audit team and look forward to seeing the final report.
Should you have any questions, please contact me at (707) 234-6911.
Sincerely,
Izen Locatelli
Chief Probation Officer
Attachment
cc: Carmel Angelo, Chief Executive Officer
Christian Curtis, Acting County Counsel
Brina Blanton, Deputy County Counsel
March 19, 2020
Mendocino County submits this response to the recommendation and statements made in the draft, redacted State Audit Report 2019-116, “Juvenile Justice Crime Prevention Act: Weak Oversight Has Hindered Its Meaningful Implementation”.
Overview of the Report
Mendocino County is committed to the goal of reducing crime and delinquency among the young people in our communities. We appreciate the thoroughness with which this audit was conducted. While the scope of the audit was focused on the Juvenile Justice Crime Prevention Act (JJCPA) funding, Mendocino County wanted to highlight other fund expenditures in the area of juvenile justice. It was mentioned within the report that Mendocino County had not contracted with Community Based Organizations (CBO’s) and other agencies for JJCPA funds. It should be noted, however, that Mendocino utilized a significant amount of its Youthful Offender Block Grant (YOBG) expenditures towards CBO’s. Specifically, during the 5 years that covered this audit, Mendocino County spent 64% of total YOBG expenditures in those years with a CBO for a community-based Drug and Alcohol Treatment program. This program supports two out-patient, community-based programs to address substance abuse. The Foundations program provides early intervention services to youth with low-level drug and alcohol offenses and juvenile probationers with drug or alcohol-related probation violations. The Passages program provides treatment to youth on probation who have a dual diagnosis (mental health and substance abuse). These programs service not only youth currently in the juvenile justice system, but also serves youth in a pro-active and prevention method through direct referrals from schools and also through diversion alternatives. In the development of our updated Comprehensive Multi-agency Juvenile Justice Plan, this program will now be funded with JJCPA funding.
Also mentioned in the report is the Comprehensive Multi-agency Juvenile Justice Plan being outdated and incomplete. As was noted in the report, this plan has been in place in its current form since 2009-2010. While we continued to operate the same program since that year with no substantive modifications, Mendocino County, in conjunction with stakeholders, acknowledge the need to update our plan. While this is not a recommendation of the report, Mendocino County has taken additional steps beyond the recommendations of the audit report to complete an extensive and in-depth CMJJP which will be presented at our newly reconvened Juvenile Justice Coordinating Council this month.
Response to Recommendations Made in the Draft Audit Report for Mendocino County
Recommendation 1: To ensure that its Coordinating Council meets statutory requirements and is transparent to stakeholders, Mendocino County should reinstate its Coordinating Council, and should develop and implement bylaws for its Coordinating Council.
Response 1: Mendocino County agrees with this recommendation and has taken the necessary steps in reinstating our Juvenile Justice Coordinating Council (JJCC). We have developed a draft updated Comprehensive Multi-agency Juvenile Justice Plan (CMJJP) by contacting key stakeholders and those required to be a part of the JJCC as defined by 749.22 of the Welfare & Institutions Code. Additionally, draft bylaws have been prepared. At this time our new reinstated JJCC is scheduled to meet on March 27, 2020 at which time the JJCC will be presented with both the CMJJP and bylaws for review, comment and approval. Once the JJCC has approved both the CMJJP and the bylaws, both documents will be presented to the Mendocino County Board of Supervisors for final approval, tentatively scheduled for April 20, 2020.
Recommendation 2: To determine the effectiveness of their use of JJCPA funds, Mendocino should include in its year-end reports to Community Corrections descriptions or analyses of how its JJCPA-funded program influenced the county’s juvenile justice trends, as required by law.
Response 2: Mendocino County agrees and will take steps to implement this recommendation.
Recommendation 3: Mendocino should collect data on all participants in each JJCPA program and service to adequately assess the effectiveness of those programs at reducing juvenile crime and delinquency.
Response 3: Mendocino County agrees and will take steps to implement this recommendation. As the updated CMJJP includes new JJCPA funded programs, Mendocino plans to commence data collection on the funded programs at the on-set of these programs. A critical part of this recommendation which Mendocino County will address involves the definition and parameters of the data to be collected. As mentioned in the report, Mendocino County does have limitations in our current case management system to collect all necessary data in a method that will allow effective data extraction and, thus, analysis. We will be working with our system vendor to identify and make system modifications, where possible, to allow for the effective collection and extraction of data through the system. Where the system is unable to support necessary data collection needs, Mendocino County will work on developing alternative data collection methods.
Mendocino County believes the responses above will effectively address the recommendations addressed in the draft audit report.Comments
CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM the Mendocino County Probation Department
To provide clarity and perspective, we are commenting on the response from Mendocino. The number below corresponds to the number we have placed in the margin of Mendocino’s response.
Mendocino asserts that it used funding from the Youthful Offender Block Grant to support a drug and alcohol treatment program operated by a CBO. As we describe in the Introduction, state law currently requires counties to include information about the JJCPA and the Youthful Offender Block Grant in their comprehensive plans. However, the Audit Committee did not ask us to audit expenditures of the Youthful Offender Block Grant and therefore, we cannot comment on Mendocino’s assertion.
San Joaquin County Probation Department
March 16, 2020
Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
RE: State Audit Report – Juvenile Justice Crime Prevention Act
Dear Ms. Howle,
On behalf of the San Joaquin County Probation Department, this letter provides a response to the draft redacted State Audit report titled, “Juvenile Justice Crime Prevention Act: Weak Oversight Has Hindered Its Meaningful Implementation.”
In response to the draft audit report recommendation, the Probation Department provides the following:
Recommendation #1: To ensure that it’s Coordinating Council meet statutory requirements and are transparent to stakeholders, San Joaquin should develop and implement bylaws for its Coordinating Council.
Response #1: While not required by legislation, the San Joaquin County Probation Department acknowledges that it is a best practice and will implement the recommendation.
Recommendation #2: To determine the effectiveness of its use of JJCPA funds, San Joaquin should include in its year-end reports to Community Corrections descriptions or analyses of how its JJCPA-funded programs influenced the county’s juvenile justice trends, as required by law.
Response #2: The San Joaquin County Probation Department is committed to evaluating its JJCPA programs. As such, we have been under contract with an outside evaluator, the San Joaquin Community Data Co-Op (Data Co-Op) since 2001. The Data Co-Op prepares an annual evaluation report that they present annually to the Juvenile Justice Coordinating Council. The report includes a wide range of findings on program outcomes. However, the California State Auditor is correct and we have not been including these findings on our annual report to the Board of State and Community Corrections. The San Joaquin County Probation Department will begin doing so with our next report.
Recommendation #3: San Joaquin should collect data on all participants in each JJCPA program and service to adequately assess the effectiveness of those programs at reducing juvenile crime and delinquency.
Response #3: The San Joaquin County Probation Department has consistently collected data for the two primary JJCPA Probation Department programs: Probation Officers on Campus and Reconnect Day Reporting Center. The Neighborhood Service Centers provides their data directly to the Data Co-Op for evaluation purposes. However, when we began funding the Family Focused Intervention Team in 2017-2018 and the Positive Youth Justice Initiative in 2018-2019, the Department inadvertently forgot to have the Data Co-Op evaluate those programs. We have since increased our contract with the San Joaquin Community Data Co-Op and will include this information in our next report. It is important to note, the San Joaquin County Probation Department recently entered into a contract to replace its Juvenile Justice Case Management System. It is expected to go live during the 2020-2021 fiscal year.
The Probation Department would like to thank you and your staff for their professionalism and diligence during this audit process. We look forward to seeing the final report.
Thank you,
Stephanie L. James
Chief Probation Officer
County of Santa Barbara Probation Department
March 19, 2020
Elaine M. Howle
State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
The County of Santa Barbara submits this response to the recommendations and statements made in the draft audit report 2019-116, entitled “Juvenile Justice Crime Prevention Act: Weak Oversight Has Hindered Its Meaningful Implementation.” This audit was conducted at the direction of the Joint Legislative Audit Committee (JLAC) of the California Legislature.
Recommendation 1: To determine the effectiveness of the use of its JJCPA funds, Santa Barbara should include in its year-end reports to Community Corrections descriptions or analyses of how its JJCPA-funded programs influenced the county’s juvenile justice trends, as required by law.
County of Santa Barbara Response: We agree that descriptions of how our JJCPA-funded programs influenced juvenile justice trends could be more robust in our year-end reports. Enhanced data collection and program monitoring is key to this analysis. In FY 2018-19, in response to the issues which emerged from the Probation Department’s comprehensive data mining, the Department asked our local providers to embrace new models of programming, and introduced the idea of evidence-based practices in our services. In FY 2019-20, the Department introduced very basic performance measures, to help providers understand the concepts of program evaluation and begin the transition to more comprehensive evaluation measures. In FY 2020-21, the Department is implementing robust performance measures for each provider, which include a set of measures standardized across all programs, as well as a set of program-specific measures tailored to the services each provider is contracted to perform. These measures will be incorporated into each provider contract and will be reported on quarterly. The Department has also created a department business specialist position to perform program and contract analysis; that position will be responsible for ongoing evaluation of performance measures, and conducting fidelity checks to ensure evidence-based programs are provided according to the program models.
With more comprehensive program/contract monitoring and better performance outcome data, combined with continued scrutiny of our internal data (risk assessment and recidivism information, in particular), we will be able to provide stronger analysis over time of the nexus between funded programs and the county’s juvenile justice trends.
Recommendation 2: To accurately assess the effectiveness of its programs, Santa Barbara should determine how to accurately identify in its case management systems the JJCPA programs and services in which each individual participated or enhance these systems to provide this capability.
County of Santa Barbara Response: Many changes have been made to the County’s JJCPA-funded services and programs over the last 20 years. Unfortunately, the electronic tracking mechanisms for those programs and services did not always change concurrently, which has led to inaccuracies in the historical JJCPA data. As program names changed and service models shifted, this was not always reflected in the case supervision types used to indicate youth receiving JJCPA services in our case management system. In some cases, supervision types were removed from the system or disabled when a program was renamed or terminated, but without a clear replacement which would enable continuous tracking of those cases assigned under JJCPA-funded programs. This reflects a disconnect between the service and supervision being provided daily, and the electronic tracking components associated with the case management system. Our electronic case management system has the capability we require; the Department has begun exploring solutions to the problem of tracking and identification.
Sincerely,
Tanja Heitman
Chief Probation Officer
County of Santa Barbara Probation Department