The Policy and Audit Division (PAD), under the supervision of Commissioner of Prisons, and Chief Counsel, has been given the responsibility of providing the Philadelphia Prison System (PPS) staff guidance by developing comprehensive policies and procedures and assisting in training programs. The PAD assists correctional administrators by identifying organizational lapses and deficiencies. In addition, the PAD assists managers in planning, developing, implementing and constantly improving operational strategies and protects the public by conducting security audits and unannounced system checks.
The Division conducts frequent audits that systematically examines the operation of the PPS to provide the following:
- Identify instances of non-compliance
- Identify applicable standards
- Discover inconsistencies and conflicts between policies and practices
- Expose and document facility deficiencies
- Perform follow-up audits to ensure deficiencies are corrected
- Collect and compile input from PPS staff regarding the policies, noting changes and suggestions for later inclusions
The Division’s goals are to avoid costly litigation by conducting internal audits, updating policies and procedures to meet current correctional standards.
To develop, distribute, put into effect, continually update and maintain the policies and procedures of the Philadelphia Prison System (PPS) to meet current correctional standards.
To provide correctional staff guidance and assistance in understanding and complying with the approved policies and procedures of the PPS.
Organizational lapses often remain undetected; therefore, the PAD will develop and maintain a proactive and effective internal audit system that can provide administrators an extension of their own eyes and ears to systematically monitor the operation and management of each of the institutional operations, which includes the facilities, units, functions and shift.
To monitor key components that are necessary for an effective system.
To help determine whether institutional practices comply with PPS policies and procedures and assess whether security resources are being used efficiently and effectively.
To develop and maintain a follow-up system, which is the final step in the audit process. The follow-up audit allows the PPS to measure the facility’s progress and ensure it has taken adequate steps to strengthen security and is in compliance with policies and procedures.
To protect the public by identifying weaknesses and deficiencies in facility operations so that corrective action can be taken.
Policy development begins with the review of the PPS Operational Physical Standards, relevant American Correctional Association (ACA) standards, Pennsylvania Title 37 standards (Minimum Standards for County Jails, the National Commission on Correctional Health Care (NCCHC) Standards, current practices within the PPS, and other available relevant information. The policy is then sent to the Executive Review Committee for review and comments. After all comments are received, the policy is then submitted to the Chief Counsel and to the Commissioner for final review and approval. Once the Commissioner approves the policy, the policy is eligible for implementation.
Dissemination of Written Policy and Procedure Materials
The Policy and Audit Division issues a Master Binder with all PPS policies and procedures to the appropriate executive staff. The PAD tracks the location and recipients of particular policies so that the appropriate staff will receive updates and revisions as necessary.
Implementation of Policies and Procedures
After the Commissioner has approved a policy, the responsibility of implementation rests on the Director for Policy and Audit Division, and the facility Deputy Wardens for Administration (Facility Implementation Officers) and the Department Heads. The Policy and Audit Division facilitates policy implementation training by preparing post instructions for specific policies, lesson plans for the scheduled policies being taught and developing training codes for the implementation training. The PAD will also review monthly statistical data to determine the progress being made of the number of staff trained on specific scheduled policies. In addition, the PAD will collect and compile input from PPS facility/department trainers regarding the policy, noting changes and suggestions for later inclusions.
Auditing Policies and Procedures
The monitoring of policies is the responsibility of the Policy and Audit Division. After the PPS has begun implementing a policy, members of the PAD will conduct an audit of the relevant facility or area for compliance with the policy and its procedures. After conducting an audit, the auditors will conduct an exit interview concerning the findings of the audit with the appropriate administrator. The PAD assists staff in understanding and complying with the requirements of the approved PPS policies and procedures. Throughout the monitoring of a policy and its procedures, the PAD continues to collect and compile input from PPS staff regarding the policy, noting changes and suggestions for later inclusions. The PAD continuously audits approved PPS policies and procedures on a periodic basis as a means of ensuring continual compliance.
Revising and Updating Policies
The Policy and Audit Division continually generates, gathers, and explores ideas, suggestions, and comments of staff regarding the operations and administration of the PPS. Auditors will identify areas where new policies and procedures need to be developed, and make recommendations for policy development. The group will develop revisions, which are then reviewed and approved by PPS Chief Counsel and the Commissioner.
The PAD conducts unannounced security and other applicable inspections of the PPS consistent with ACA or other applicable standards.
Administrative Segregation Monitoring Report
The PAD thoroughly reviews the special management paperwork from the facilities in order to prepare the weekly Administrative Segregation Monitoring Report for the PPS.