GEO devotes considerable resources to assuring total compliance with contractual requirements and that integrity, professionalism, and quality are maintained. To this end, an independent compliance division, established in early 2012, is responsible for monitoring operations to ensure compliance with the various standards and contractual requirements for each agreement.
The Contract Compliance Department is an independent, corporate department reporting directly to the Chairman, Founder and Chief Executive Officer. GEO’s Contract Compliance Department reviews all operational aspects of GEO’s domestic operations. The Contract Compliance Department performs audits for GEO Secure Services and GEO Care’s BI, and Reentry Service divisions. The Contract Compliance Department is managed by an Executive Vice President. The Executive Vice President and a Contract Compliance Vice President lead approximately 42 highly-skilled quality assurance personnel who implement GEO’s robust Quality Control Program (QCP). This plan includes systematic monitoring, facility audits, review of healthcare programs, and the development of corrective action plans (CAP). The QCP, and its implementing procedures, improve operational performance and compliance with GEO policies, client contracts, and accreditation standards. The Contract Compliance staff perform approximately 324 audits each calendar year.
Since GEO is responsible for the provision of health care at many of its facilities, the Contract Compliance Department requires an expert team of heath care professionals to perform this specialized audit work. The Contract Compliance Department has a team of five medical compliance specialists with medical degrees and compliance expertise. The team’s Director and one Manager are medical doctors with a combined operational experience with the U.S. Bureau of Prisons of over 50 years. Both doctors have extensive experience in The Joint Commission’s Standard requirements. Another Manager is a licensed practical nurse with years of experience in National Commission on Correctional Health Care standards and working at a GEO-contracted facility for U.S. Immigration and Customs Enforcement. Another Manager is a registered nurse (RN) with corrections, military, and outside medical experience along with compliance work. The fourth manager is also a RN with both operational and compliance experience in health care delivery.
The Contract Compliance team has developed meaningful audit tools based on GEO's Corporate and Divisional policies and our government partners’ policies and standards. Using those tools, a team auditors travel to facilities across the country, conducting 3-4 day annual reviews using a team of 3-8 operational, subject matter experts and reviewing all standards applicable to each specific facility or site. This annual review is conducted at all GEO facilities every year. In addition, follow-up reviews are performed as well. Findings from government-conducted audits or monitoring are also monitored and tracked for sustained compliance.
GEO’s Quality Control Program (QCP) is the comprehensive auditing and monitoring plan that includes field and remote audits, corrective action plans, accreditation, and verification activity. The QCP is designed to prevent errors, detect gaps in operational excellence, and mitigate performance deficiencies by bringing programs into compliance as quickly as possible through CAPs. GEO’s QCP makes compliance every employees’ responsibility. The QCP creates a two-part process of compliance activity. The first part is the external audit activity conducted by the Contract Compliance Department staff. These audits are led by the Contract Compliance Department staff and field-based Subject Matter Experts (SME). The second part of the QCP audit plan is the internal audit activity conducted by the facility’s Compliance Administrator or program director personnel. The Compliance Administrator, who reports to the Facility Administrator, is the person at each facility monitoring the day-to-day activities to ensure the facility’s compliance with GEO policies, contract requirements, and accreditation standards.
For both internal and external audits, audit questions include specific questions from GEO policy and procedures, contract requirements, applicable ACA and PREA standards, client audit findings, and every audit question that GEO’s contracting client uses in its own audit activity. Both corporate and facility-level sets of audit results are entered in the Contract Compliance Department’s database to ensure all audit data is captured, analyzed, and shared with all levels of GEO leadership. At year’s end, all applicable Contract Compliance audit tools will have been tested against each facility’s operations. In response to each year’s audit activity, audits results are used to develop effective corrective actions, where needed, and to inform daily monitoring to ensure sustained and thorough compliance.
Similarly, Contract Compliance’s Medical team audits GEO Secure Services facilities in the medical areas to provide an objective view of the quality of a facility’s health care program. After identifying problem areas, the team assists in the drafting of effective CAPS. The Contract Compliance medical team’s work allows for an additional and independent review by skilled practitioners.
Immediately at the close of an annual external audit, the Annual Corporate Audit Chair, assisted by other members from the Contract Compliance Department, conducts a Post Audit Workshop at the facility. The Workshop consists of meetings to focus on non-compliant findings, if any, and to ensure the facility’s leadership has a clear understanding of the audit’s results. The team also immediately begins drafting CAPs to bring non-compliant programs into compliance. The benefits of the Post Audit Workshop include:
Each year, the Contract Compliance Department holds an annual Quality Assurance (QA) Conference for GEO compliance professionals for a week of intensive training that includes workshops like Critical Thinking, Performance Improvement, Standard Operating Procedures, Prison Rape Elimination Act (PREA) Auditing, Health Insurance Portability and Accountability Act (HIPAA), Record Retention, Occupational Safety and Health (OSHA), and American Correctional Association (ACA) accreditation.
Compliance and Quality Assurance Administrators from all GEO Secure Services and Reentry Services facilities travel to GEO’s Corporate Headquarters for a week of intensive training.
GEO subscribes to operational standards promulgated by a number of different certifying organizations and opens its facilities to inspection and accreditation by these associations, commissions and councils. Accreditation serves as added protection for the client agency against claims and litigation. As a matter of corporate policy, all GEO facilities are designed and operated in general accordance with the recommendations of one or more of the following organizations:
Under the leadership of the Director of Accreditation in the Contract Compliance Department, GEO has attained and maintained accreditation of most of its facilities through the leading correctional accreditation organization. Each facility undergoes a rigorous audit every three years by a team of independent auditors using 350-550 standards, depending on the type of facility and applicable standards. The Contract Compliance Department initiates, organizes, and manages these audits through mock audits, regular review of standards through auditing, and works with the facility’s ACA manager and ACA leaders.
Each GEO facility undergoing an American Correctional Association (ACA) certification audit will prepare for the review in coordination with the Contract Compliance Department. Both the Director of Accreditation and the Compliance Directors work with the facility to train on the process and to review progress through regular contact and support. Two months prior to the actual audit, a team of compliance and operational SMEs conduct a Mock ACA audit, going through every step that the actual auditors will do in certification. After the audit, the auditors’ notes on each standard file are compiled in a final working report for the facility. If the facility is using the electronic files described below, the on-site visit is accomplished with one auditor over 1-2 days.
GEO has created an electronic system which allows all documentation to be stored and viewed remotely. The auditors and the facility find that it is a marked improvement on the storage demands and costs of the paper system. In addition, the electronic storage of files allows for the Contract Compliance Department to conduct remote reviews of files on an ongoing basis prior to the ACA audit. ACA auditors are very impressed with this method and its user-friendly approach.
View GEO facilities and their most recent ACA Accreditation scores
As required by rules issued by the U.S. Department of Homeland Security (DHS) and U.S. Department of Justice (DOJ), GEO has appointed a Contract Compliance Director as GEO’s PREA Coordinator. The GEO PREA Coordinator is responsible for implementation of PREA monitoring systems and policies as well as developing, implementing, and overseeing GEO’s compliance with the National PREA Standards in all its required Secure Service and Reentry Services Facilities. In addition, the GEO PREA Coordinator provides guidance and resources in all matters related to PREA training, reporting, compliance, allegations, and investigations.
In addition to the PREA Coordinator, there is one Contract Compliance Senior Manager and one Contract Compliance Manager with extensive investigative experience who are all responsible with reviewing and assisting in investigations of PREA incidents as well as operating as a resource to all facilities. An additional Contract Compliance Manager is dedicated to conducting Mock Audits and providing assistance when needed. A Contract Compliance Specialist is dedicated to collecting and analyzing PREA data and preparing required reports.
GEO’s operations comply with the Prison Rape Elimination Act of 2003, 42 U.S.C. §§ 15601-15609, Public Law 108-79-September 4, 2003 and with client-specific policy and procedures, such as U.S. Immigration and Customs Enforcement’s Sexual Abuse and Assault Prevention and Intervention Directive. GEO’s operations comply with DOJ National Standards to Prevent, Detect, and Respond to Prison Rape Elimination Act (PREA), 28 C.F.R. Part 115, in required Adult Prisons and Jails, Community-Based Reentry Services, Lock-up , and DHS’ Sexual Abuse and Assault Prevention Standards, 6.C.F.R. Part 115 (2014).
GEO completed the first three-year audit certification cycle for PREA with 62 facilities audited and 57 of those being certified by November 16, 2016.