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
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:
- the momentum of the audit continues the focus on the negative results and creates grass-roots solutions that can be implemented quickly in most cases to achieve operational excellence
- the local compliance staff has the attention and support of facility leadership to focus the department heads on the creation of good CAPs
- there is ownership on every level to solve any findings and the workshop creates a forum for discussion of tough or recurring issues
- the facility receives the benefit of the Contract Compliance Department’s expertise, perspective, and shares the best practices from other GEO locations
- with department heads and staff present during the Workshop, if the issue involves staff work, the information from the auditors is relayed directly to the staff responsible for making change
- the facility staff can move directly ahead to implement CAPs with increased likelihood of successful compliance
Training of Facility Compliance Administrators
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, Reentry Services, and Youth Services facilities travel to GEO’s Corporate Headquarters for a week of intensive training.