Report 2010-124 All Recommendation Responses

Report 2010-124: Department of Corrections and Rehabilitation: The Benefits of Its Correctional Offender Management Profiling for Alternative Sanctions Program Are Uncertain (Release Date: September 2011)

Recommendation #1 To: Corrections and Rehabilitation, Department of

To ensure that the State does not spend additional resources on COMPAS while its usefulness is uncertain, Corrections should suspend its use of the COMPAS core and reentry assessments until it has issued regulations and updated its operations manual to define how Corrections' use of COMPAS will affect decision making regarding inmates, such as clarifying how COMPAS results will be considered when sending inmates to different prison facilities, enrolling them in rehabilitative programs to address their criminal risk factors, and developing expectations for those on parole.

Agency Response*

Revisions to DOM were necessary to incorporate updated Casework Supervision guidelines for both CPSRM and SOMP. Labor negotiations are still in progress. DAPO will continue with the revision of regulations to California Code of Regulations, Title 15, Division 3, Subsection 6, Article 1, Parole Supervision, incorporating the COMPAS Re-Entry Assessment and Case Plan. Once negotiations with CCPOA are complete, the regulations will be routed to the DAPO Director for approval. The regulations will then be sent to RPMB for the required public comment period and to the Office of Administrative Law for final approval. This process is anticipated to take several more months for completion.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: June 2018
  • Response Date: November 2017

California State Auditor's Assessment of Status: Pending


Agency Response*

CDCR's Division of Adult Parole Operations (DAPO) has incorporated the COMPAS Re-Entry Assessment and Case Plan into the 08/24/16 revision of the Department Operations Manual, Chapter 8, Article 49, Pre-Release Re-Entry Case Planning, Sections 86040.1 - 86040.10.

In addition, DAPO is in the process of revising the California Code of Regulations, Title 15, Division 3, Subsection 6, Article 1, Parole Supervision, to incorporate the COMPAS Re-Entry Assessment and Case Plan, with an anticipated completion date of June 2017.

(See provided proof of practice: Notice of Change to Department Operations Manual, #16-08.)

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: June 2017
  • Response Date: October 2016

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

CDCR's Division of Rehabilitative Programs developed emergency regs adding a new section to the CCR, Title 15 Section 3375.6, Automated Needs Assessment which was adopted into law effective 2/25/13. Title 15, Section 3375.6 amendment filed 10/29/13 added Subsection (a)(3), which specified the criminogenic needs indicated by the COMPAS assessment. Additional established regulations include: Title 15 Section 3375(b) which states that the classification process shall take into consideration an inmate's needs, interests and desires, behavior, and placement score. Section 3375(l) states that an automated risk and needs assessment tool that identifies criminogenic needs shall be administered pursuant to Section 3375.6. Section 3375.6(b) states that the results of the automated needs assessment tool shall be evaluated during committee actions to assist determining the inmate's placement and sequencing into rehab programs. Section 3375(f)(7) states that Classification committee decisions shall be based on evaluation of available information. Reentry Hubs regs were put in place 10/29/13. In addition, the SOMS Case Plan which is under development will allow the Department to draw a direct line connecting an offender's program assignments to assessed criminogenic needs, providing a complete continuum of care throughout the lifecycle of incarceration.

CDCR's Division of Adult Parole Operations has decided not to promulgate regulations until a determination can be made on an appropriate re-entry needs assessment tool to use for parole case plan development. The criterion for considering an alternative is that it must ensure that the case plans will effectively address the parolee's needs and build upon the parolee's in-custody program achievements.

Due to character limitations, additional detail can be found in CDCR's submitted proof of practice.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: December 31, 2015
  • Response Date: September 2015

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

CDCR's Division of Rehabilitative Programs has developed regulations in response to this recommendation. California Code of Regulations, Title 15, section 3375.6, Automated Needs Assessment was adopted into law effective February 25, 2013. An amendment added subsection (a)(3), which specified the criminogenic needs indicated by the COMPAS assessment.

Additional established regulations include Title 15 section 3375(b), the inmate classification process; section 3375(l), automated risk and needs assessment tool; section 3375.6(b), automated needs assessment results; and section 3375(f)(7), basis of Classification Committee decisions. The Office of Administrative Law is currently reviewing regulations regarding the Reentry Hubs Emergency regulations which add section 3379(a)(10)(A), in part, "An inmate with the following case factors shall be given priority for placement at a Reentry Hub: ...3. A medium or high need for one or more rehabilitative treatment programs as indicated by a validated automated needs assessment tool."

CDCR's Division of Adult Parole Operations has developed the text of The Proposed Regulations (TPR) for the COMPAS Re-Entry Assessment and the Initial Statement of Reason (ISOR) for California Code of Regulations, Title 15, section 3502, Pre-Parole Referral and section 3503, Automated Needs Assessment (See supporting TPR and ISOR documents dated October 2014).

The regulation file has been submitted for CDCR Stakeholder Review and to initiate the public notice/comment period. CDCR intends to submit the regulation package to the Office of Administrative Law for review within 90 - 120 days and it is anticipated that the regulations will be adopted in 2015.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: December 31, 2015
  • Response Date: October 2014

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

California Code of Regulations, Title 15, Section 3375.6, Automated Needs Assessment was adopted into law effective January 15, 2013.

  • Response Type†: Annual Follow Up
  • Completion Date: January 2013
  • Response Date: October 2013

California State Auditor's Assessment of Status: Not Fully Implemented

Corrections' regulations lack specificity as to how its staff will use COMPAS when making decisions about inmates who are going through the classification process. Draft regulations defining how Corrections staff will use COMPAS on inmates going through the re-entry process also lack specificity and Corrections' operations manual does not discuss how its employees should use COMPAS. Although Corrections did provide guidance to its staff in a March 2013 memo explaining what factors should be considered when transferring inmates to a rehabilitative hub to address their COMPAS-identified rehabilitative needs, our recommendation was for Corrections to solidify and clarify its process through regulation and the public rulemaking process.

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Agency Response*

Partially Implemented:

Emergency regulations were filed with the Office of Administrative Law to promulgate the new section into California Code of Regulations, Title 15, § 3375.6, Automated Needs Assessment Tool, operative May 10, 2012. The emergency regulations were re-filed and operative on

October 17, 2012.

Plan for full implementation:

The CDCR is in negotiations with the COMPAS software developer to make necessary changes. Once the necessary software updates have been completed, the department will complete the process of revising the regulations and filing the revision in accordance with the Administrative Procedures Act. Full regulatory requirements will be met no sooner than June 30, 2013.

Current Status:

Completion of the final regulatory requirements are on hold. Ongoing negotiations with the software vendor will define the scope and terms of the contract for necessary software changes to the COMPAS tool. Once completed, the CDCR will then be able to determine the time frame for completing the regulatory requirements based on the release of the updated software.

Upon completion of the Regulations, the new section of the Department Operations Manual

will be developed accordingly.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: June 2013
  • Response Date: November 2012

California State Auditor's Assessment of Status: Not Fully Implemented


Recommendation #2 To: Corrections and Rehabilitation, Department of

To ensure that the State does not spend additional resources on COMPAS while its usefulness is uncertain, Corrections should suspend its use of the COMPAS core and reentry assessments until it has demonstrated to the Legislature that it has a plan to measure and report COMPAS's effect on reducing recidivism. Such a plan could consider whether inmates enrolled in a rehabilitative program based on a COMPAS assessment had lower recidivism rates than those provided rehabilitative programming as a result of non-COMPAS factors.

Agency Response*

Research conducted by CDCR indicates offenders who participate in Substance Abuse Treatment (SAT) and complete aftercare have a substantially lower return-to-prison rate (15.3%) than offenders who do not participate in SAT or receive aftercare (46.5%). Interventions such as SAT, are shown to be effective in lowering rates of return among substance abusers, who are shown through empirical research to return to prison at higher rates. Offenders that were assessed with COMPAS that were shown to have an SAT need, and completed SAT, returned to prison at a rate of 17.6%. Offenders who were not assessed with COMPAS and received SAT, returned to prison at a rate of 31.2%. Offenders that were assessed with COMPAS and shown to have an SAT need, but did not receive SAT, returned to prison at a rate of 51.5%. Offenders who were shown to have a treatment need through COMPAS, but did not receive treatment, have a substantially higher rate than those who did receive treatment. The use of COMPAS to assess offenders most in need of SAT has largely attributed to lowering recidivism rates. It is clear that participation in SAT is an important component in reducing recidivism and COMPAS is needed to identify those most in need of treatment.

CDCR has maintained since the implementation of the COMPAS automated and needs assessment tool, that COMPAS is not capable of reducing recidivism in a vacuum. It is a tool for determining the most effective rehabilitative programming to address an offender's criminogenic needs. CDCR is also investigating commissioning a study by UCI comparing the COMPAS assessment against a new assessment tool developed by Dr. Farabee at UCLA.

(See provided proof of practice documentation.)

  • Response Type†: Annual Follow Up
  • Completion Date: December 2014
  • Response Date: October 2016

California State Auditor's Assessment of Status: Fully Implemented

Although Corrections does not indicate that it suspended the use of COMPASS for any period of time, Corrections does appear to have conducted the type of COMPASS assessment we envisioned when we first made this recommendation.


Agency Response*

Offenders participating in substance abuse treatment (SAT) consistently have lower return to prison rates than offenders who do not participate in SAT. Offenders that were determined to have a substance abuse need by the COMPAS tool and participated in SAT had a return to prison rate of 43.3% while offenders who did not receive a COMPAS assessment and did not participate in SAT had a rate of 52.1%. The return to prison rate for offenders that were identified as having a substance abuse need by COMPAS but did not participate in SAT is the highest among all categories. Offenders assessed with the COMPAS tool with a substance abuse need, but did not receive SAT, had a return to prison rate of 59.4%, which is 5.1% points higher than the state-wide return to prison rate of 54.3% and 16.1 percentage points higher than the rate of offenders who had an identified substance abuse need and received SAT, indicating that SAT participation is effective in reducing the recidivism.

Due to character limitations, please see CDCR's submitted proof of practice for additional information.

  • Response Type†: Annual Follow Up
  • Completion Date: December 2013
  • Response Date: September 2015

California State Auditor's Assessment of Status: Will Not Implement

The California Department of Corrections and Rehabilitation (Corrections) could not provide any evidence that it is monitoring COMPAS' effectiveness as a screening tool when compared to other potential methods for identifying inmates who have rehabilitative needs. Although Correction's 2014 Outcome Evaluation Report had a section devoted to COMPAS, the analysis in that section only concluded that inmates who receive treatment are less likely to return to prison.


Agency Response*

The 2012 Outcome Evaluation Report noted that offenders with a substance abuse need, as identified by the COMPAS assessment, who participated in in-prison SAP and completed aftercare had a lower recidivism rate than offenders with a substance abuse need who only completed aftercare or in-prison SAP, or offenders without a substance abuse need identified.

Offenders who participated in in-prison substance abuse programming, regardless of COMPAS identified need showed a 62.2% recidivism rate, while those who did not participate had a 63.9% recidivism rate.

It is very important to emphasize that the COMPAS assessment is not capable of reducing recidivism by itself. COMPAS is a tool that provides CDCR with information on an offender's individual needs. This information can then be used to place the offender into a program that can meet the offender's specific criminogenic needs. It is the combination of the COMPAS assessment with appropriate and well-implemented evidence based programming that can reduce recidivism.

The 2014 Outcome Evaluation plans to add a comparison of recidivism rates for individuals with a COMPAS need who received substance abuse treatment vs. those who received treatment but did not have a COMPAS need to the recidivism report, which is compiled after we transition our data to SOMS.

  • Response Type†: Annual Follow Up
  • Completion Date: December 2013
  • Response Date: October 2014

California State Auditor's Assessment of Status: Not Fully Implemented

Although Corrections compared the recidivism rates of certain inmates who had received a COMPAS assessment to those who had not, Corrections has yet to define a performance standard to evaluate the tool's effectiveness at placing the right inmate in the right rehabilitative program to reduce recidivism. We also noted that the recidivism rates for those inmates receiving a COMPAS assessment were not significantly different than the rates for those that did not.

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Agency Response*

In the 2012 Outcome Evaluation Report, CDCR reported recidivism rates for the following groups: 1) those who received substance abuse treatment in prison, 2) those who received substance abuse treatment in aftercare, 3) those who received both in-prison and aftercare substance abuse treatment, 4) those who did not receive substance abuse treatment, 5) those who had a COMPAS substance abuse need and received substance abuse treatment in prison, 6) those who had a COMPAS substance abuse need and received substance abuse treatment in aftercare, 7) those who had a COMPAS substance abuse need and received substance abuse treatment in prison and aftercare, 8) those who had a COMPAS substance abuse need and did not receive substance abuse treatment, and 9) those who did not have a COMPAS substance abuse need or were not assessed.

CDCR plans to add a comparison of recidivism rates for individuals with a COMPAS need who received substance abuse treatment vs. those who received treatment but did not have a COMPAS need to the recidivism report which is compiled after we transition our data to SOMS.

  • Response Type†: Annual Follow Up
  • Completion Date: December 2013
  • Response Date: October 2013

California State Auditor's Assessment of Status: Not Fully Implemented

Although Corrections compared the recidivisim rates of certain inmates who had received a COMPAS assessment to those who had not, Corrections has yet to define a performance standard to evaluate the tool's effectiveness at placing the right inmate in the right rehabilitative program to reduce recidivism. Finally, we note that the recidivism rates for those inmates receiving a COMPAS assessment were not significantly different than those that did not.

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Agency Response*

CDCR's 2012 Outcome Evaluation Report included recidivism rates by COMPAS needs categories (pp. 52-54).

  • Response Type†: Annual Follow Up
  • Response Date: November 2012

California State Auditor's Assessment of Status: Not Fully Implemented

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Recommendation #3 To: Corrections and Rehabilitation, Department of

Once Corrections resumes its use of COMPAS core and reentry assessments, it should provide ongoing training to classification staff representatives, parole agents, and others that may administer or interpret COMPAS assessment results to ensure that COMPAS is a valuable inmate assessment and planning tool.

Agency Response*

CDCR has stressed to users that COMPAS assessment results are intended to drive programming decisions. During training sessions, all COMPAS users were trained in the correlation of COMPAS scales to rehabilitative programs and was included in the 6/26/13 memo titled "Reentry Hub Inmate Assignment Process", which provides direction and a matrix to assist with programming decisions.

The Division of Adult Parole Operations completed training for field staff and parole agents in 2013. Follow-up training was provided to Unit Supervisors and District Administrators in 2014-2015, reinforcing best practices including the use of COMPAS within the CPSRM. All new parole agents receive COMPAS training in the CPSRM curriculum while attending the Parole Agent Academy. On-going training occurs in unit meetings held on a regular basis to discuss relevant issues and reinforce training at the unit level. The field Unit Supervisors have the responsibility of identifying the need for remedial training if a field agent does not understand or does not follow the proper procedures for the use of the COMPAS assessments and case plans.

Due to character limitations, please see CDCR's submitted proof of practice for additional information.

  • Response Type†: Annual Follow Up
  • Completion Date: April 2013
  • Response Date: September 2015

California State Auditor's Assessment of Status: Fully Implemented


Agency Response*

CDCR's Division of Rehabilitative Programs implemented statewide T4T training in April 2013 that included the California Logic Model which illustrates the rehabilitative process used by CDCR, including the assessment and placement into programs appropriate to an offender's criminogenic needs. The training provided designated staff the required knowledge to administer additional training to new classification staff, and to serve as a local subject matter expert.

This training also included a review of the Reentry Hub and October 4, 2012 memos regarding the Classification Committee Chairpersons review of an inmate's needs identified on the COMPAS assessment when making program placement determinations.

CDCR's Division of Adult Parole Operations completed deployment of the California Parole Supervision Reintegration Model (CPSRM) statewide; founded on the premise of successful reintegration by addressing each offender's specific criminogenic needs. A core component of the CPSRM is the automated assessment tool (COMPAS Reentry Assessment) with the results in the form of the COMPAS Case Plan, providing recommended programs available that address the criminogenic needs identified by the tool. The COMPAS Case Plan is used to further develop a comprehensive plan including incremental goals that lead to the offender's success on parole.

Six-hours of the CPSRM training included understanding criminogenic needs, treatment dosages, and using available assessment tools to identify the offender's criminogenic needs. Additionally, six-hours of training was provided on the use of the COMPAS Reentry Assessment Tool, interpreting the results, and using the COMPAS Case Plan. (See Sign-In sheets for the COMPAS Training.) Refresher training will be provided upon request.

  • Response Type†: Annual Follow Up
  • Completion Date: April 2013
  • Response Date: October 2014

California State Auditor's Assessment of Status: Not Fully Implemented

Although Corrections indicated in its response that it has trained staff on the use of COMPAS, it did not provide evidence that this training includes information regarding how COMPAS-generated reports should be interpreted or used to make decisions about inmates and their rehabilitative needs. Additionally, although it did provide evidence that training had been provided to parole agents, it did not provide evidence that it had been provided to others who may use COMPAS results.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

In April 2013, statewide T4T training was provided to designated institutional staff who provide periodic training at the institutional/unit level.

  • Response Type†: Annual Follow Up
  • Completion Date: April 2013
  • Response Date: October 2013

California State Auditor's Assessment of Status: Not Fully Implemented

Although Corrections provided evidence that it has trained certain staff on the use of COMPAS, this training simply focused on how to navigate the software as opposed to discussing how COMPAS-generated reports should be interpreted or used to make decisions about inmates and their rehabilitative needs.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

CDCR is certainly in the process of developing a program placement model outlined in the “The Future of California Corrections, CDCR Blueprint,” that will include enhanced training and messaging to Classification Staff Representatives and staff within the institutions on the value and importance of the COMPAS assessment.

  • Response Type†: Annual Follow Up
  • Response Date: November 2012

California State Auditor's Assessment of Status: Not Fully Implemented

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Recommendation #4 To: Corrections and Rehabilitation, Department of

Once Corrections resumes its use of COMPAS core and reentry assessments, it should develop practices or procedures to periodically determine whether its staff are using COMPAS core or reentry assessments as intended. Such a process might include performing periodic site visits to corroborate that COMPAS is being used as required.

Agency Response*

The Division of Adult Parole Operations (DAPO) Community Transition Program (CTP) conducts the COMPAS Re-entry Needs Assessments on the offender population paroling to DAPO. These Assessments are the foundation for developing each parolee's Re-entry Case Plan and provides the proper identification of each parolee's needs for appropriate parole supervision under the CPSRM and in relation to SOMS data collection capabilities. Furthermore, DAPO is working with the Division of Rehabilitative Programs to integrate the new SOMS Case Planning module to further enhance the use of the COMPAS Re-entry Assessment in parolee case planning. The DAPO CTP supervisors conduct regular quality assurance audits of the COMPAS Re-entry Assessments to ensure that parolee Case Plans incorporate the appropriate elements for field parole agents' use in parolee supervision. Additionally, CTP staff collaborate with the DAPO field parole agents and assist with the direct placement of parolees into community-based programs based upon the outcomes identified in the COMPAS Reentry Assessment, and in correlation to each individual parolee's needs.

  • Response Type†: Annual Follow Up
  • Completion Date: September 2016
  • Response Date: October 2016

California State Auditor's Assessment of Status: Fully Implemented

Corrections provided us with procedures that it disseminated in 2014 for supervisors to periodically review COMPAS assessments. In previous responses, Corrections indicated that these supervisory reviews had been put on hold due to budget cuts. However, Corrections indicated that these reviews have been restored and provided examples of recently completed supervisory reviews as evidence.


Agency Response*

Within the Division of Rehabilitative Programs, business rules included in the SOMS Classification and Programs module provide an automated check against eligibility criteria prior to moving an offender from a waiting list to a program. For in-prison programs, regulations are in place and memoranda have been distributed instructing classification staff to use the COMPAS needs scores to determine an offender's program placement and sequencing. CDCR currently issues a quarterly report on goal 1.2 of the Strategic Plan, which indicates the number and percentage of offenders paroling who have received rehabilitative programming consistent with their identified needs. CDCR reporting indicates the number of offenders who have been assessed as having a criminogenic need and are currently enrolled in a rehabilitative program versus enrolled offenders without the required need. These reports are possible due to the implementation of the SOMS Classification and Program modules, which occurred on 4/25/14.

For the Division of Adult Parole Operations (DAPO), ongoing staffing issues prevent DAPO from being able to provide a more specific target date for the reinstatement of QA reviews.

Due to character limitations, please see CDCR's submitted proof of practice for additional information.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: December 31, 2015
  • Response Date: September 2015

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

Business rules included in the recently implemented SOMS Classification and Programs module provide an automated check against eligibility criteria prior to moving an offender from a waiting list to a program.

For in-prison programs, regulations are in place and memoranda have been distributed instructing classification staff to use the COMPAS needs scores to determine an offender's program placement and sequencing. CDCR currently issues a quarterly report on goal 1.2 of the Strategic Plan, which indicates the number and percentage of offenders paroling who have received rehabilitative programming consistent with their identified needs.

CDCR is currently developing reports to indicate the number of offenders who have been assessed as having a criminogenic need and are currently enrolled in a rehabilitative program versus enrolled offenders without the required need.

CDCR's Division of Adult Parol Operations (DAPO) has initiated the review and enhancement of the assessment methods used in the QA review process, further increasing the scope of the assessment tools to evaluate the extent of which the COMPAS case plan components are being utilized in the supervision of offenders on State supervised parole.

DAPO anticipates reinstating QA reviews with the enhanced procedures within the coming year.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: October 2015
  • Response Date: October 2014

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

With the implementation of the latest release of COMPAS version 8 on May 10, 2013, CDCR is able to monitor staff activity within the Northpointe Software Suite including the number of assessments, completion of assessments, timeliness of assessments, and adherence to departmental directives.

Currently, CDCR distributes a weekly report to each institution, indicating the number of completed COMPAS Core assessments during the week and the percentage of eligible offenders who have received an assessment. Additionally, CDCR distributes a monthly report to each institution listing all eligible offenders who have not received a COMPAS Core assessment.

With the implementation of this new technology, CDCR is able to conduct "virtual" site visits and able to corroborate COMPAS is being used as required. Also, CDCR, in partnership with the University of California San Diego, is developing a fidelity tool which will include a site review. Part of the fidelity tool will evaluate the administration of the assessment and its adherence to established protocols.

CDCR will continually monitor and evaluate the data as we continue to move forward with rehabilitative efforts.

  • Response Type†: Annual Follow Up
  • Completion Date: May 2013
  • Response Date: October 2013

California State Auditor's Assessment of Status: Not Fully Implemented

Corrections did not provide evidence of any meaningful monitoring of its staff's use of the COMPAS core assessment. Although Corrections did provide support that it tracked-by institution- the number of COMPAS-assessed inmates, Corrections did not provide evidence that it is monitoring how its staff are making decisions based on COMPAS-generated results.

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Agency Response*

The Department is currently developing a proposed site visit process that will include a review of the assessment process and a follow-up report that outlines any issues found during the visit. The Department has begun publishing a monthly report to Executive Staff ranking institutions by percentage of eligible offender assessments completed. The Department is expecting to make use of a variety of new utilization monitoring options which will become available in COMPAS version 8.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: April 2013
  • Response Date: November 2012

California State Auditor's Assessment of Status: Not Fully Implemented


Recommendation #5 To: Corrections and Rehabilitation, Department of

Once Corrections resumes its use of COMPAS core and reentry assessments, it should develop practices or procedures to periodically compare the demand for certain rehabilitative programs, as suggested by a COMPAS core assessment, to the existing capacity to treat such needs.

Agency Response*

The Division of Rehabilitative Programs utilizes the overall criminogenic need and risk to reoffend (COMPAS and CSRA scores) of an inmate in placement of programs. While COMPAS alone is not used, COMPAS scores related to those with a high to moderate need, combined with CSRA scores for a high to moderate risk to recidivate, are what drives placement of programming in the division. To help facilitate programming placement, the Division is currently working on SOMS data-driven, web-based tools that expediently allow the aforementioned combination assessments to be displayed by CDCR institutions/facilities to appropriately and accurately facilitate placement of programming slots when comparing to the Division's target population. These tools and assessments, both at the local facility, and at the Executive level, provide information on contract/capacity placement and target needs by location.

  • Response Type†: Annual Follow Up
  • Completion Date: February 2014
  • Response Date: October 2016

California State Auditor's Assessment of Status: Fully Implemented

As evidenced by the Corrections' Blueprint, and subsequent updates to the Blueprint, Corrections is tracking the available program placements and the demand for these services. Based on these assessments, it has set goals to increase capacity in certain programming areas.


Agency Response*

In April 2013, statewide T4T training was provided to designated institutional staff who provide periodic training at the institutional/unit level. In-prison programming capacity decisions are based on the Master Offender List, a comprehensive list of currently incarcerated offenders. This list includes COMPAS and TABE scores, as well as current assignment and housing information. Due to both the size of this file, and the sensitive nature of its content, this document cannot be offered as proof of practice. There are programs in prison, and the Day Reporting Center community programs which have contracts utilizing this methodology. The Blueprint indicates annual capacity figures which correlate to COMPAS needs scores. For example, CIW shows a planned capacity of 288 for the Substance Abuse program, and a review of offender COMPAS scores show 266 offenders with a substance abuse need who are eligible for the Substance Abuse program. ASP also shows 288 for planned capacity and 285 eligible offenders.

When renewing the Reentry Hub contracts, the Department reviews the Master Offender List to determine if any modifications in the annual capacity for a specific modality, is warranted. The Master Offender List contains multiple case factors which include, but are not limited to, COMPAS and TABE scores, as well as current assignment and housing information.

In addition, CDCR utilizes the above referenced list to help guide transfers in order to facilitate offender programming. CDCR also uses documents like the "Target Population versus Program Capacity FY 15-16 16-17 and 17-18" to determine transfer of offenders and capacities of programs.

  • Response Type†: Annual Follow Up
  • Completion Date: September 2013
  • Response Date: September 2015

California State Auditor's Assessment of Status: Partially Implemented

  • Auditee did not substantiate its claim of full implementation

Agency Response*

The current contract capacities for Cognitive Behavioral Treatment were developed using the criminogenic needs that were identified through the COMPAS assessment results.

On March 20, 2013, and September 20, 2013, CDCR revised the COMPAS exclusionary criteria to include more inmates in the assessment process. The Division of Rehabilitative Programs reviews the COMPAS needs results to determine adjustment in the statewide capacities for Substance Abuse Treatment, Criminal Thinking, Anger Management, and Family Relationships. CDCR has programs in all institutional levels and will be able to adjust program capacities based on identified needs by specific levels of inmates.

CDCR also uses COMPAS assessment results in the development of other treatment programs beyond the Blueprint requirements. The Blueprint indicates annual capacity figures which correlate to COMPAS needs scores.

In-prison programming capacity decisions are currently based on the Master Offender List, a comprehensive list of currently incarcerated offenders. This list includes COMPAS and TABE scores, as well as current assignment and housing information. Due to both the size of this file, and the sensitive nature of its content, this document cannot be offered as proof of practice. There are currently programs in prison, and the Day Reporting Center community programs which have contracts utilizing this methodology.

When renewing the Reentry Hub contracts, the Department reviews the Master Offender List to determine if any modifications in the annual capacity for a specific modality, is warranted. The Master Offender List contains multiple case factors which include, but are not limited to, COMPAS and TABE scores, as well as current assignment and housing information.

  • Response Type†: Annual Follow Up
  • Completion Date: September 2013
  • Response Date: October 2014

California State Auditor's Assessment of Status: Not Fully Implemented

Corrections' response claims that its current capacities for treating inmates were developed using COMPAS results. However, Corrections provided no evidence that this is the case.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

The current contract capacities for Cognitive Behavioral Treatment were developed using the criminogenic needs that were identified through the COMPAS assessment results.

On March 20, 2013, and September 20, 2013, CDCR revised the COMPAS exclusionary criteria to include more inmates in the assessment process. The Division of Rehabilitative Programs will review the COMPAS needs results to determine adjustment in the statewide capacities for Substance Abuse Treatment, Criminal Thinking, Anger Management and Family Relationships when developing the new contracts which will begin on July 1, 2015. CDCR has programs in all institutional levels and will be able to adjust program capacities based on identified needs by specific levels of inmates.

CDCR shall also use COMPAS assessment results in the development of other treatment programs beyond the Blueprint requirements.

  • Response Type†: Annual Follow Up
  • Completion Date: September 2013
  • Response Date: October 2013

California State Auditor's Assessment of Status: Not Fully Implemented

Corrections' response claims that its current capacities for treating inmates were developed using COMPAS results. However, Corrections provided no evidence that this is the case. Further, the rest of Corrections' response discussed things it plans to do in the future, as opposed to what it has already done to address our recommendation.

  • Auditee did not substantiate its claim of full implementation

Agency Response*

COMPAS data was utilized in developing the CDCR Blueprint, which was approved by the Legislature in May 2012, to determine program capacity and location based on criminogenic need profiles, as well as other factors. The Department's goal is to provide programming to 70 percent of the target population prior to release. CDCR does not have resources to plan program space for all inmates with a need at any given period of time, but will ensure sufficient capacity is available within its resources based upon correlating inmate needs and their scheduled release. Annual assessments will be done to reevaluate during normal budget development processes.

  • Response Type†: Annual Follow Up
  • Response Date: November 2012

California State Auditor's Assessment of Status: Not Fully Implemented

  • Auditee did not substantiate its claim of full implementation
  • Auditee did not address all aspects of the recommendation

Recommendation #6 To: Corrections and Rehabilitation, Department of

To ensure transparency and accountability for costs associated with information technology projects such as COMPAS, Corrections should disclose that it lacks accounting records to support certain COMPAS expenditure amounts it reported to the Technology Agency and seek guidance on how to proceed with future reporting requirements for its deployment of the COMPAS core to its adult institutions.

Agency Response*

Corrections' staff met with the California Technology Agency in October 2011 and disclosed that it lacked accounting records to support certain COMPAS expenditures that Corrections has been submitting to the California Technology Agency. The California Technology Agency stated that Corrections' reporting of COMPAS costs were appropriate. (See 2013-406, p. 225)

  • Response Type†: 1-Year
  • Response Date: September 2012

California State Auditor's Assessment of Status: Fully Implemented


Recommendation #7 To: Corrections and Rehabilitation, Department of

To ensure transparency and accountability for costs associated with information technology projects such as COMPAS, Corrections should develop policies to ensure that accounting or budget management personnel are involved in the project planning phase of future information technology projects so that appropriate accounting codes are established for reporting actual project costs.

Agency Response*

Corrections has modified its project management manual to require those responsible for information technology projects to obtain an accounting code—referred to as a functional area code—from Corrections' budget and accounting staff. Corrections provided the state auditor with revisions to its policy manuals and cost-tracking tools to demonstrate it had implemented the recommendation. (See 2013-406, p. 225)

  • Response Type†: 1-Year
  • Response Date: September 2012

California State Auditor's Assessment of Status: Fully Implemented


All Recommendations in 2010-124

Response Type refers to the interval in which the auditee is providing the State Auditor with their status in implementing recommendations made in an audit report. Auditees must submit a response regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year or subsequent to one year.

*Agency responses received after June 2013 are posted verbatim.


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