Colorado Department of Corrections
Administrative Segregation and Classification Review
Technical Assistance # 11P1022

Prepared by
James Austin, Ph.D.
and
Emmitt Sparkman

National Institute of Corrections

Prisons Division
500 First St. NW, 7th Floor

Washington, DC 20534
October 2011

Disclaimer

RE:

NIC Technical Assistance No. 11P1022

This technical assistance activity was funded by the Prisons Division of the National
Institute of Corrections. The Institute is a Federal agency established to provide
assistance to strengthen state and local correctional agencies by creating more
effective, humane, safe and just correctional services.
The resource person who provided the on site technical assistance did so through a
cooperative agreement, at the request of the Colorado Department of Corrections, and
through the coordination of the National Institute of Corrections. The direct onsite
assistance and the subsequent report are intended to assist the agency in addressing
issues outlined in the original request and in efforts to enhance the effectiveness of the
agency.
The contents of this document reflect the views of James Austin and Emmitt Sparkman.
The contents do not necessarily reflect the official views or policies of the National
Institute of Corrections.




1


Background
The Colorado Department of Corrections (CDOC) made formal request to the National
Institute of Corrections (NIC), U.S. Department of Justice, to have an external review of
its offender classification system and its administrative segregation policies and
practices. Once the request was received, the NIC selected two consultants (James
Austin and Emmitt Sparkman) to complete the TA assignment.
The primary reasons for this request can be summarized as follows;
1. With respect to the offender classification system, there had not been a full revalidation of the offender classification for several years. It is recommended that
all risk assessment systems be re-tested at least every five years to ensure the
system is both reliable and valid. Further, there was the need to determine if the
systems are equally effective for male and female offenders.
2. With respect to administrative segregation, there have been a number of
important changes in the overall structure and procedures associated with
administrative segregation within the CDOC. Here again, a comprehensive
assessment of the current system was desired to determine if further changes
were warranted.
Once the two consultants had been designated by NIC and agreed to by the CDOC, a
three-day onsite visit was scheduled for August 8-10, 2011. In advance of the on-site
activities a wide array of documents were forwarded to the consultants to help them
become acquainted with the classification and administrative segregation systems.
Although both consultants worked as a team, Emmitt Sparkman spent most of his time
focused on the administrative segregation issued and Dr. Austin focused on the
offender classification systems. However, this report’s findings and recommendations
represent the consensus of both consultants.
Some of the key documents and data files that were provided to the consultants were
as follows:
1. A CCF/CSP power point describing the Quality of Life component of the
Administrative Segregation system;
2. A detailed data file that listed all persons currently assigned to administrative
segregation;
3. A detailed data file of the entire prison population containing the current
classification record and disciplinary records;
4. A 2005 study completed by Maureen L. O'Keefe, Director of Research for the
CDOC (Analysis of Colorado’s Administrative Segregation);
5. All CDOC administrative regulations, policies and facility memorandums




2


regarding administrative segregation;
6. Current classification forms (both male and female);
7. .Current Administrative Regulations regarding Security Threat Group
Identification and Management; and
8. CDOC FY2011 Statistical Annual Report
What follows is a description of the on-site activities followed by analysis and
recommendations regarding administrative segregation and the offender classification
system. The short-term nature of this assignment (on-site for three days covering two
complex subject matters) limits the extent of the analysis and subsequent
recommendations. Additional analysis and review would be required to complete the
level of work needed to make a complete assessment. However, the findings presented
here are sufficiently grounded regarding the work completed under NIC.
On-Site Activities
During the three-day site visit the following major meetings and activities were
completed.
Introductory Meeting
An introductory meeting was held the morning of August 8, 2011, with Colorado
Department of Corrections officials; Tony Carochi Director of Prisons, Karl Spiecker,
Director of Finance and Administration, Maureen O’Keefe, Director of Planning and
Research, Lou Archuleta, Assistant Director of Offender Services, Paul Hollenbeck,
Associate Director of Offender Services, Larry Reid, Deputy Director Prisons, and Kevin
Milyard, Deputy Director of Prisons. The overall scope of the TA was discussed and a
tentative agenda for the on-site activities was agreed upon by the CDOC officials and
NIC Consultants. The procedures for administrative segregation placement were
discussed and the differences between administrative and disciplinary segregation
reviewed by the meeting participants (There are approximately 1,500 offenders in
administrative segregation and another 670 offenders designated for punitive
segregation including state and private facilities.
In the discussion that follows it will be useful to refer to Table 1 which lists number of
persons assigned to administrative segregation by each facility and by the Quality of
Life (QOL) that an offender can be assigned to. This report describes in some detail the
QOL system which basically allows offenders to receive higher and lower levels of
privileges while confined to administrative segregation. One should note that the vast
majority of the population is assigned to Levels 2 and 3.



Administrative Segregation Unit Visits
Following the introductory meeting, the NIC Consultants and CDOC officials; Tony
Carochi, Director of Prisons, Larry Reid, Deputy Director of Prisons, and Kevin Milyard,
Deputy Director of Prison traveled to Canon City, Colorado for site visits to the Colorado
State Prison, Centennial North Prison and Centennial South Prison. Susan Jones is the




3


Chief Administrative Officer/Warden for the Colorado State Prison (CSP), Centennial
North Prison (CCF North) and Centennial South Prison (CCF South) Complex.



Table 1. Summary of Administrative Segregation Populations By Facility By
Quality of Life Levels
Quality of
Level

Total CCF
Sterling
and CSP

Denver
Women

Totals

5

2

30

340

61

13

414

427

725

69

12

806

0

0

0

55

2

57

0

146

146

0

9

155

0

51

51

90

0

90

477

757

1,234

280

38

1,552

CCF

CSP

Level 1

10

13

23

Level 2

169

171

Level 3

298

Level 4
OMI
OMI Waitlist
Totals

Source: CDOC Facility Reports
A meeting was held with Warden Jones and her staff to review the use of administrative
segregation at the complex. Upon the conclusion of the overview, all three sites were
toured. At each housing unit the consultants completed brief interviews with offenders
assigned to the unit.
Colorado State Penitentiary
The Colorado State Penitentiary (CSP) is a prison designated for administrative
segregation with a capacity of approximately 756 offenders. The CSP has two types of
administrative segregation; regular administrative segregation and mentally ill offenders
in administrative segregation (OMI). Offenders in the regular administrative segregation
unit participate in a behavior system with three levels. An offender begins in Level 1 and
with positive behavior after 7 days can progress to Level 2. After 90 days with
acceptable behavior at Level 2, the offender can progress to Level 3 the highest level.
Progression in levels corresponds with an increase in privileges.
The consultants discovered that level progression was not related to an offender being
released from administrative segregation. The behavior level system dictates the
privileges of an offender, and the completion of cognitive learning and other programs is
the means for an offender to be released from administrative segregation. In general,
each program takes at least 90 days to complete and a male offender must successfully



4


complete three such programs (this is not a requirement for the female administrative
segregation units). This amounts to a offender having an indeterminate sentence in
administrative segregation. Once the offender completes required cognitive learning
programs he is transferred to the Sterling Correctional Facility for review and transition
to Level 4 and release to Close Custody-General Population (PRO Unit).
The CSP Behavior Level System for regular administrative segregation does not
provide a reduction in security procedures to allow offenders to congregate with other
offenders and/or participate in activities outside the cell without restraints. Interestingly,
the majority of the CSP Administrative Segregation offenders were at the highest
behavior level (Level 3 – 427 offenders). Only 13 were in Level 1; however, security
procedures reducing use of restraints and congregating out of cell activities are not
incorporated in the program. Almost all programs and activities are provided by staff at
the cell side without removal of the offender from the cell. Offender assessments are
limited to paper reviews without offender participation or conducted by staff at the cell
side with the offender present.
The CSP OMI Administrative Segregation is an eight level behavior system that
provides an increase in privileges and with a corresponding reduction in security
procedures. The OMI Program allows group congregating and outside of the cell
activities without restraints at the highest behavior level of the behavior program. The
CSP OMI Program has 146 offenders participating with the majority in the higher levels;
Level 1-1, Level 2-1, Level 3-28, Level 4-26, Level 5-20, Level 6-34, Level 7-34, Level
8-2. Security module tables have been constructed enabling OMI offenders to
participate in group activities in restraints that reduce offender isolation.
The CSP physical plant has space for group activities including a multipurpose
gymnasium that is minimally utilized by OMI offenders. There is program and noncontact visitation space available for assigned offenders. CSP regular administrative
segregation offenders are not allowed access to the multipurpose gymnasium. The
individual exercise areas for regular and OMI administrative segregation offenders are
inside with direct sunlight only through windows.
A debriefing was held with the prison after the tour of CSP. The debriefing included a
file review of selected offenders interviewed by the NIC Consultants during the tour.
Centennial Correctional Facility-South
CCF-South is located adjacent to CSP. CCF-South is the CDOC’s newest prison
utilized for administrative segregation. Warden Susan Jones is also the Chief
Administrative Officer for the CCF-South, a prison with a capacity for approximately 948
offenders with 632 beds open. The other 632 beds have not been opened for budget
reasons. CCF-South is a high tech prison with almost all services provided the offender
in his cell using a kiosk. The CSP three level behavior system for regular administrative
segregation and eight level behavior system for OMI administrative segregation is
utilized at CCF-South. CCF-South administrative segregation offenders completing the




5


program are transferred to Sterling Correctional Facility the same as CSP. Visitation,
programs, case management, etc. for offenders is via the kiosk inside the offender cell.
The kiosk allows an offender easier access to communication based services; however,
it increases his isolation from human contact. The tour of CCF-South revealed the
prison was designed with the intent for almost all services to be provided by kiosk in the
cell. Program, visitation and recreation space is extremely limited. The physical plant is
not conducive for an offender to receive programs and activities outside his cell
because space was not included in the prison design. CCF South offenders are
allowed outside their cells for showers three times per week and exercise five times per
week. Outside exercise areas are not truly outside the building, but do offer outside
views and indirect sunlight. The consultants interviewed offenders during the tour of the
prison and selected several for file review for administrative segregation
appropriateness.
Centennial Correctional Facility-North
CCF-North is located in the perimeter with CCF South and is the older of the two
facilities. NIC consultants toured the prison and interviewed a small number of
offenders. Warden Jones is also the Chief Administrative Officer for the CCF-North that
has a capacity for 336 offenders. The three level behavior system for regular
Administrative Segregation and four level behavior transitional system for OMI program
offenders is utilized at CCF-North. CCF-North Administrative Segregation offenders
completing the program are transferred to Sterling Correctional Facility the same as
CSP and CCF-South.
Unlike CCF-South, CCF North has significant program space and the exercise area is
outside the building. The CCF North physical plant has program and outside exercise
areas that promote out of cell activities for offenders. The CCF-North OMI Close
Custody has an additional four levels (9 through 12) where offenders are in a step down
program and are classified as OMI Close Custody general population.
San Carlos Correctional Facility
Mr. Sparkman toured the San Carlos Correctional Facility (SCCF) and interviewed staff
the afternoon of August 8, 2011. San Carlos serves the CDOC by providing specialized
treatment and programming for male offenders that exhibit the most severe and
persistent mental health issues. CDOC has 6100 offenders that are diagnosed mentally
ill and SCCF has a capacity for 255 offenders, with 24 cells designated as
Administrative Segregation. CDOC Associate Director of Clinical Services Kellie Wasko
and Associate Warden Laurie Tafoya guided the tour of the 24 bed Mental Health
Administrative Segregation Unit.
The SCCF Administrative Segregation is operated on a three level behavior system;
Level 1-2 weeks, Level 2-2 weeks, and Level 3-indeterminate.
SCCF OMI
Administrative Segregation Level 3 offenders are permitted to participate in group
activities outside the cell without restraints. The SCCF Administrative Segregation




6


exercise area is outside the building. Once SCCF OMI Administrative Segregation
offenders become stable they are moved to the general population to participate in
treatment programs at SCCF or other CDOC prisons. A small number because of
severe mental illness remain in the SCCF OMI Administrative Segregation Program.
CDOC Mental Health officials at headquarters determine what offenders will be placed
at SCCF. Assessment of offenders in Administrative Segregation with mental illness is
standardized throughout CDOC by Clinical Standards and Procedures “Mental Health
Evaluations of Offenders classified as Administrative Segregation 700-3.840.
Denver Women’s Correctional Facility-DWCF
Both consultants toured the DWCF with CDOC officials Tony Carochi, Director of
Prisons, Larry Reid, Deputy Director of Prisons, and Kevin Milyard, Deputy Director of
Prison on August 9, 2011. The tour was guided by Warden Dona Zavislin and her staff.
DWCF has 32 regular administrative segregation beds and 32 punitive segregation
beds. The offenders in regular administrative segregation participate in four level
behavior system. An offender can reach level 4 in one year with positive behavior.
Most programs are provided the offender at cell side. Administrative Segregation
offenders are given out of cell behavior level reviews; however, CDOC Administrative
Regulations do not require out of cell reviews. Case Managers have weekly contacts
with the offender at the cell and monthly reviews are paper without offender
participation. DWCF has 24 bed housing unit designated for OMI offenders; 12 beds
administrative segregation and 12 beds special needs. OMI offenders in this program
have programming activities two days per week outside the cell. Additional outside of
cell time is provided five days per week for showers, dayroom and telephone.
Sterling Correctional Facility-SCF
Mr. Sparkman met with SCF Acting Warden John Chapdelaine and his staff the
afternoon of August 9, 2011. Acting Warden Chapdelaine and his staff provided an
overview of SCF. The prison has an interior of 75 acres with a capacity of 2545
offenders. The SCF East housing is dormitories with a capacity of 1056 offenders. The
SCF West has cells and a capacity of 1201. Administrative Segregation is located in
SCF West 6,7, and 8 housing units and has a 192 bed capacity. Punitive Segregation is
in SCF 5 and has a 92 bed capacity.
SCF Administrative Segregation has 4 behavior levels. The Case Manager ratio is one
to approximately 96 offenders. Case Managers contact with offenders is primarily at
cell side. Those offenders who are within 6 months of release at SCF receive PreRelease staff services from one staff member half a day a week. It was reported other
program positions for the administrative segregation offenders were vacant. This is a
concern because SCF was designated as the transition point for offenders released
from administrative segregation to the general population or community.
SCF administrative segregation offender’s typical day is one hour out of cell for showers
and exercise. This is five days per week and does not include weekends. Eligible




7


administrative segregation offenders are delayed release from Housing Unit 6, 7, and 8
due to unavailable PRO Unit bed space in the general population. SCF is not
designated for Administrative Segregation OMI offenders; however, there are 90 OMI
offenders in Housing unit 5, 6, 7, and 8 waiting CSP or CCF placement. SCF Housing
Unit 6, 7, and 8 only have one out of cell exercise area for 16 offenders which is
insufficient. For example, it would take 16 hours to provide required out of cell exercise
and showers if requested by all the 16 offenders. The out of cell exercise area is inside
the building with a view to the outside.
SCF Unit 1 has two of three pods designated for the STAR and IMP Programs. Both
programs would be defined as diversion prior to placement into Administrative
Segregation or general population. The STAR and IMP Programs are not managed by
CDOC Administrative Regulations.
They are managed by SCF Operation
Memorandums. The STAR Program provides offenders one hour out of cell a day five
days a week for showers and exercise without restraints. Offenders are double bunked
and typically are overflow from punitive segregation and identified security threat group
members. The STAR Program is typically 90 days in length. The IMP Program is six
months to one year and allows an offender four hours per day out of cell seven days a
week; 1 hour in the a.m., 1 ½ hours in the afternoon and 1 ½ hours in the evening.
Offenders meet with their Case Manager monthly in an office setting.
SCF Unit 2 Pod C is designated for the PRO Unit. The unit has a 102 capacity and the
population for the PRO is approximately 65-70 offenders. PRO Unit offenders are Close
Custody-General Population mixed with other Close Custody General Population.
Offenders assigned to PRO attend the “Thinking for Change” program two hours a day
two times per week.
Other Site Activities
Advocates Opposed to Administrative Segregation Meeting
Following the tour of the DWCF a meeting was held with invited advocates opposed to
the CDOC use of Administrative Segregation (see attendee list). The advocates voiced
their concerns and were encouraged to submit comments to CDOC officials for
inclusion in the NIC Consultant Report (see attachments). The primary concerns
presented were;
•
•
•
•




The number of CDOC offenders in Administrative Segregation is considerably
higher than the national average;
Numbers in Administrative Segregation are actually even higher if you include
the Sterling Correctional Facility STAR and IMP Programs;
About 40% of offenders are released directly to the community from CDOC
Administrative Segregation (verified with CDOC);
Placement is arbitrary (vague and subjective) and needs to be more restrictive
reducing the numbers in Administrative Segregation;

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•
•
•
•
•
•
•
•
•
•

•

Offenders with mental illness by default are placed in administrative segregation
due to dwindling treatment resources;
Administrative Segregation Placement Committees needs to include a Mental
Health Professional;
Mentally Ill offenders in Administrative Segregation has increased from 10
percent in 1999 to 41% in 2010 (verified with CDOC);
Mental Health Offenders need thorough assessments prior to and after
placement in Administrative Segregation to determine appropriateness or
continued confinement in the status;
Administrative Segregation does not have acceptable step down programs;
Programs for Administrative Segregation offenders that are out of cell time and
congregate activities need to be increased; and,
The use of force by staff is excessive.
Offenders should not be released from Administrative Segregation straight to the
streets without some sort of step-down, assimilation program.
Administrative Segregation should not be used as a permanent placement for
offenders. An 18-month average length of stay is unacceptable.
Providing treatment services to those in Administrative Segregation seems
promising, but also seems an odd incentive. Do offenders who are not in
Administrative Segregation receive as robust treatment services as they do while
in Administrative Segregation? If so, great. If not, it seems that in order to get
treatment, one would actually want to be placed in Administrative Segregation.
It is concerning to hear that mental health assessments are conducted as a
simple pass through and only consist of some basic questions… A mental health
assessment should be conducted in person and with some level of
confidentiality, so that others do not hear what the offender is saying.



Reception Center
After this meeting, Dr. Austin met with the CDOC Reception staff to review the intake
process. The intake process is quite comprehensive and efficient. The average time
spent in the center is about two weeks during which comprehensive education, drug
use, mental health and medical screening and assessments are completed. There
were only two areas of concern regarding the intake process that were noted.
First, the CDOC has been implementing a commercially available risk assessment
system commonly known as the LSI-R (Level of Service Inventory- Revised). That
system consists of a 54 item rating system to measure a offender’s risk to recidivate
and a number of “criminogenic” factors believed to be associated with the risk level
(e.g., substance abuse, use of leisure time, etc.).
To its credit, the CDCOC conducted three initial studies of the LSI-R starting in 1998 on
a limited number of offenders. The evaluations found the LSI overall scale was
predictive of various measures of recidivism. However, the evaluations did not report
the level of predictiveness for each of the 54 items or the major domains. Other studies
have found that only a limited number of the LSI have strong associations with




9


recidivism but many of the other items are either not associated or have a weak
association. The reliability study done with mixed results. The reliability study also did
not show the individual item reliability results which again could have pinpointed those
specific items that are problematic.
It’s fair to say that many of the LSI-R risk items are also generally covered or addressed
by the other aspects of the CDOC reception center process. And, the current LSI needs
to have a more current evaluation both in terms of its reliability and validity. Such
studies should assess each item and the major domains as well as the overall scale.
The current process provides a very complete assessment of the offender’s needs.
Specifically, the Diagnostic Narrative Summary provides a very adequate assessment
of the person’s employment, academic/vocational (with IQ and TABE testing results),
mental health, substance abuse, sexual adjustment, anger, medical, prior correctional
conduct, social summary, current and prior offense history and leisure activities.
For sex offenders, a very complete psychosexual evaluation is completed by a licensed
SOMB evaluator. That assessment uses numerous assessment instruments including
the Static-99, SORAG, and VRAG. It’s not clear how the LSI-R can enhance this
already thorough assessment.
What the LSI-R does or should provide is a risk assessment score that would help
prioritize the need for the offender to participate in and complete meaningful programs
that would serve to reduce risk and enhance the offender’s chances for parole at the
time of his/her parole eligibility date.
Secondly, and on a more minor level, the recommendation for substance abuse
treatment cannot be made unless a licensed substance abuse worker can complete the
assessment. Since there is not a sufficient number of such professionals available at
the Reception Center, many offenders who clearly have a drug abuse problem do not
receive such a diagnosis. This gap between assessment and treatment is further
aggravated by the lack of treatment resources.
Exit Briefing with Executive Director Tom Clements
The NIC consultants held an exit briefing with CDOC Executive Director Tom Clements
and Management staff on August 10, 2011. Prior to the meeting a summary of the
major findings and recommendations were drafted. During the meeting these findings
and recommendations were discussed with Executive Director Clements and his
management team. It was explained that a draft of the report would be forwarded to
him within two weeks and that a final draft would be submitted to NIC and the CDOC
shortly thereafter. There are no substantial differences between the
findings/recommendations presented in this report and the ones presented to the CDOC
during this meeting.




10


Administrative Segregation Placement and Review Policies
In this section of the report, we attempt to summarize the key official policies and
regulations that govern the use of administrative segregation by the CDOC.
CDOC Administrative Regulation (AR) 600-02 Offender Classification-Administrative
Segregation establishes the guidelines for segregating high security risks offenders and
members of security threat groups from facility general population offenders.
Factors and evidence relied upon to recommend administrative segregation must be
clearly documented in a “Notice for Administrative Segregation”. Placement in
administrative segregation is justified for only the following reasons:
1. Conduct that poses a serious threat to security of a facility;
2. To prevent imminent injury to an offender(s) or an employee(s)
3. To contain or prevent or quell a riot;
4. To prevent serious property damage; and,
5. To prevent escape and/or 6) other (must be specified).
While these five reasons have “face” validity they can be hard to apply to specific
offenders and their behavior. For example, just what constitutes “serious threat” or
“serious property damage”. How does one know that placement in administrative
segregation has prevented an escape or “imminent injury”?
The official process for initiating placement in administrative segregation typically begins
when a CDOC employee completes the “Notice for Administrative Segregation”. This
document includes a summary report setting forth the facts relied upon and reason(s)
why the offender should be considered for placement into administrative segregation.
The notice is served to the offender by a CDOC employee with a copy to the facility
Classification Committee. The Classification Committee then conducts a hearing and
the offender has the right be present unless security precludes presence. The offender
is given 48 hours notice prior to the hearing. The Facility/Prison Administrative Head
designates the Classification Committee, which is defined in AR 600-02 Section III. E.
AR 600-02 specifies the chairperson of the committee will be a CDOC employee at or
above the level of Correctional Officer III.
The Classification Committee hearing for administrative segregation is held no later
than five days after the “Notice of Administrative Hearing“ and is served unless good
cause is documented in the record. A delay in the hearing cannot exceed 30 days. The
CDOC has the burden of proof to demonstrate the offender should continue placement
in Segregation and requires the standard of proof to be “substantial”. The offender is
provided the opportunity to offer an explanation or rebuttal of the circumstances and any
additional information related to the incident as documented in the “Notice for
Administrative Segregation”.




11


The
Classification
Committee
recommends
specific
actions
to
the
Warden/Administrative Head. The Warden/Administrative Head is required to review
the Classification Committee’s decision within five days of receipt.
The
Warden/Administrative Head may confer with the Offender Services Associate Director
to affirm, deny or reverse the decision of the Classification Committee to place the
offender in Administrative Segregation. It was reported the Offender Service Associate
Director rarely rejected the recommendation of the Warden/Chief Administrative Head.
In cases where the Warden/Administrative Head denies Administrative Segregation
placement, the documentation is forwarded to the Offender Services Associate Director
stating whether the offender can be managed at the facility or should be transferred to
another facility and/or security level.
A offender with known mental health problems (P3 or higher) for whom the
Classification Committee recommends administrative segregation receives a mental
health evaluation by the mental health staff to determine where the offender will serve
administrative segregation. But the Mental Health staff is not involved in the initial
decision to place an offender in administrative segregation.
The Offender may appeal the administrative segregation recommendation to the
Warden/Administrative Head. The appeal must be in writing and submitted within seven
days after receipt of the decision. The Warden/Administrative Head must respond to
the offender’s appeal within 30 days.
An offender in administrative segregation receives a review every seven days for the
first two months of confinement and every thirty days thereafter. The reviews are
conducted by the Case Manager. Such reviews are primarily done cell side or by paper
without the offender present. Rarely is the offender given a review in an office setting.
Toevs v Reid et al: 2011 WL 2437782 (C.A. 10 (Colo.)), found the CDOC did not
provide meaningful periodic reviews for administrative segregation offenders. However,
the Court ruled the CDOC defendants were entitled to qualified immunity because it was
not clearly established in 2005 though 2009 that the review process was inadequate.
We reviewed Administrative Segregation confinement at CSP, Centennial North,
Centennial South, San Carlos Correctional Facility, Denver Women’s Facility, and
Sterling Correctional Facility. All the sites were found to have Quality of Life (QOL)
Programs for offenders in Administrative Segregation. QOL Programs varied from
regular administrative segregation offenders participating in three level behavior based
programs with graduated privileges at each level to offenders with significant mental
health problems (OMI) in administrative segregation participating in an eight level
behavior based program.
Offenders with severe mental illness in administrative segregation at San Carlos
participate in a three level behavior based program. Variations to the regular and OMI
Quality of Life Programs were found at all of the facilities. Regular Administrative
Segregation offenders do not receive lessened security procedures with the progression
in behavior levels. Even at the highest privilege level, an Administrative Segregation
offender must be in restraints and escorted by staff outside his/her cell. A regular



12


administrative segregation offender is not allowed at any stage of the QOL Program to
participate in congregate activities with other offenders. OMI Administrative Segregation
offenders’ security procedures do lessen with progression through behavior levels and
allow group activities at the highest level. The variation in the QOL Programs at the
facilities was confusing to the us and could be confusing to staff and offenders.
CDOC QOL Programs has minimal bearing on the offender release from Administrative
Segregation and is primarily associated with privileges. An offender can become
eligible for release only by completing designated cognitive learning programs.
Completion of the programs does not guarantee the offender his release from
administrative segregation and resources prevent required treatment programs from
being offered and completed by offenders. Time frames for administrative segregation
release eligibility are not defined as they are in the CDOC QOL Programs. Essentially,
an offender placed in CDOC Administrative Segregation can be held for an
indeterminate period with strict security procedures although his positive behavior has
warranted maximum privileges.



Offender
Classification

The CDOC has been operating an objective prison classification system for a number of
years. That system consists of an initial and reclassification process and forms.
Separate classification forms have been established for the male and female
populations. The items used on the initial and reclassification forms are fairly typical of
the items used on other state prison classification systems. Over-rides are also
available to over-ride the scored custody level and must be properly documented. In
terms of classification structure, the entire classification process is governed and
monitored by the centralized classification unit that is staffed with experienced CDOC
personnel. So in terms of the basic structure and design of the CDOC system it is
basically sound. However, there are several areas where the system can be improved
upon and modified to enhance its current operations.

Under
and
Over‐Classification

Table 2 summarizes the current custody levels of the female and male populations for
the current prison population. The CDOC uses a four level custody system for the
general population. For the males, there is a fairly even distribution for all four levels
with the smallest percentage being for Close custody (15%). This % in close is fairly
typical for the male population as found in other states. However, the same percentage
exists for females which is highly unusual. Most states either have no or very few
women in the close custody category.
For the males, there is only 23% in the medium custody level but a combined 50% in
the Minimum and Minimum Restricted levels. The Minimum Restricted group seems to
be a mixture of true mediums and true minimums. The small number of “unclassified”
offenders verifies that the reception process is being conducted in a timely manner.




13


Table 2. Current Colorado Custody Classification Levels

Custody Level

Males

Females

Total

Administrative Segregation

7.3%

2.1%

6.8%

Close

14.8%

14.0%

14.7%

Medium

23.4%

11.4%

22.4%

Minimum Restricted

26.2%

27.8%

26.3%

Minimum

27.7%

43.8%

29.1%

Unclassified

0.7%

1.0%

0.7%

Source:

CDOC

For this report there is not sufficient time to conduct a formal validation study. This will
be conducted later in the year. However, there is some preliminary analysis that
suggests the system is working well but for which there could be some improvements.
As noted earlier, the classification system allows for over-rides. As shown in Table 3,
the level of over-rides is quite low for most categories (2-4%). The highest is 8% for
cases that are in minimum restrictive but are over-ridden to minimum. The
recommended standard is that the over-rides be between 5% and 15% so the 4% is a
bit low. There should be an audit of the very few cases (3) that are scored as close but
have been placed in minimum custody. Similarly, and audit should be made of cases
that are scored minimum but are assigned to Close custody.




14


Table 3. Final and Scored Custody Levels – Current Prison Population

Missing
Scored
Close
Medium
Minimum Restrict
Minimum
Total

106
169
305
161
741

Close
2,946
58
29
37
3,070

Medium
75
4,515
20
10
4,620

Minimum
Restrict

Minimum

5
74
5,139
23
5,241

3
44
267
3,494
3,808

Total
3,135
4,860
5,760
3,725
17,480

Over-Ride
NA
4%
2%
2%
8%
4%
Source:
CDOC
Data
File,
Administrative
Segregation
Cases
are
Deleted.
If
there
was
no
final
custody
level,
the
case

is
deleted
from
the
analysis.


In terms of the scoring items and their influence on the overall score, Tables 4 and 5
show the results for the male population. First, it should be noted that the vast majority
of the current prison population is under the reclassification instrument (13,243
offenders) as opposed to the initial instrument (1,801 offenders). Second, four items on
the initial classification form drive the total average point score (13.59 points) – severity
of current offense, detainer, prior felony record, and parole eligibility date.
Table 4. Initial Classification Scoring Results – Males
Items
Total Score
History of Inst Violence
Severity of Current Offense
Multiplier
Death Involved
Severity Prior Offense
Escape History
Alcohol/Drug
Detainer
Prior Felony Convictions
Current Age
Education
Employment Status
PED
Source:
CDOC
Data
File.


Data
Code
Total
A01
A02
A03
A04
A05
A06
B01
B02
B03
B04
B05
B06
B07

Ave.
Score
13.59
0.08
3.68
0.19
0.05
1.01
0.52
2.53
2.03
3.34
1.44
0.39
0.11
2.10

Std.
Deviation
7.301
0.588
2.316
0.593
0.319
1.967
1.219
1.038
2.943
2.411
0.900
0.487
0.313
5.401













15


Table 5 Reclassification Scoring Results – Males
Items
Total Score
History of Inst Violence
Last 12 Months
Severity Current Offense
Multiple Convictions
Involved Death
Severity Prior Offense
Prior Felony Convictions
1 or more at highest
Involving Death
Detainer
Escape History
Disciplinaries
Last 12 Months - Class I
Last 12 Months - Class II
Hist of Disciplinaries
PED

Data
Code
Total
A01
A02
A03
A04
A05
A06
B01
B02
B03
B04
B05
B06
B07
B08
B09
B10

Ave.
Score
20.06
0.16
0.02
4.99
0.52
0.2
1.2
2.54
0.73
0.02
1.28
0.57
1.26
2.87
1.24
2.92
5.39

Std.
Deviation
22.752
0.871
0.255
2.164
0.88
0.6
1.63
1.764
0.963
0.192
3.343
1.302
4.308
7.184
4.085
2.852
18.398

For the reclassification instrument, the driving factors are offense severity, prior felony
convictions, PED and several measures of disciplinary infractions (past and current).
This emphasis on offender conduct is as designed and consisted with objective
classification systems. Offenders move to higher or lower custody levels largely based
on their conduct.
What is unusual for today’s systems is the use of the PED and detainer for scoring
purposes (emphasis added). Most states are now using PED or time left to serve or
detainer as mandatory over-rides to restrict placement in minimum security facilities.
Removal of these two items in the scoring process may reduce the extent of overclassification for people now in the Close and Medium custody levels.
Related to this issue, there is some degree of placing “true” close custody offenders at
the four major Level 3 facilities that needs to be addressed immediately. By “true” close
we mean offenders who have become close custody through their disciplinary
infractions and are being housed in a close security unit within a multi-level security
(Level 3) prisons. As much as possible, these “true” close custody offenders should be
transferred to a pure Level 4 prison.
Finally, unlike all other states, there is no dedicated protective custody unit nor are
offenders called Protective Custody. Offenders who require such protection are either
transferred out of state or are handled internally using special management flags. The
CDOC should undertake an assessment to determine how many offenders would
qualify for a dedicated PC unit.




16


Major
Findings
and
Recommendations

Based on the documents received, the data collected while on-site and follow-up
information the following major findings and recommendations are being made to the
CDOC.
Administrative Segregation Findings
1. Prison population is declining slightly but not as fast as projected. Despite the
decline in the prison population, the administrative segregation population is
increasing as well as the proportion listed as having a significant mental health
condition.
2. In 1999, 22% were P3 or higher; by 2010 it had increased to 40%; 15% had
serious mental illness in 1999; by 2010 it had increased to 22%.
3. Currently about 7% (1,427) of the prison population is in administrative
segregation, which is significantly above the national average of 1-2 %.
4. This does not include the Intensive Management Pod (100 beds), PRO (70
beds), and STAR (100 beds) programs which are not GP offenders. Further
there another 670 some offenders in punitive segregation.
5. Most of the administrative segregation population is in Quality of Life Level 3 and
have been at that level for some time. Very few are in Level 1 which suggests
that most are not being disruptive and have not been disruptive for some time.
6. There is considerable confusion in the operational memorandums and
regulations on how the administrative segregation units are to function.
7. The vast majority (about 80%) of administrative segregation offenders do not
return to administrative segregation within two years of release.
8. About 25% are in administrative segregation for injury to other offenders and/or
staff with most being injury to other offenders.
9. The decision to refer an offender to administrative segregation is largely
controlled at the various facilities with some oversight by Central Office.




17


10. The average length of stay (LOS) in administrative segregation is about two
years with a median LOS of 14 months.
11. However, about 40% of the offenders are released from administrative
segregation directly to the community.
12. The current units are exceptionally clean, quiet, and safe as compared to other
state administrative segregation units.
13. Access to outdoor recreation is deficient at all of the units except for CCF-North,
SCF, and SCCF.
14. The kiosk communication system (with cameras) at CCF-South is excellent but
the absence of program and recreation space is extremely problematic.
15. The requirement (only at CCF/CSP) that they complete 3 programs of
questionable value and of limited availability is extending the time unnecessarily
in administrative segregation.
16. The only programming presently received at the Sterling Administrative
Segregation Unit is one half day pre-release services provided by a Pre-Release
Specialist.
17. Administrative Segregation Level 4 offenders at Sterling are delayed release to
the PRO Unit due to lack of bed space.
18. Sterling has a backlog of Administrative Segregation OMI offenders
(approximately 90) awaiting transfer to CSP or Centennial.
Administrative Segregation Recommendations
1. The criteria for which a person can be admitted to Administration Segregation is
basically sound but needs to be narrowed to reflect recent developments in Ohio
and Mississippi.
2. Require offenders to first complete Punitive Segregation and then be reviewed
for placement in Administrative Segregation rather than using Ad Seg to serve as
a substitute for Disciplinary Segregation.




18


3. Require a mental health review before placement in Administrative Segregation
and monthly reviews thereafter. The mental health review must be an out of cell
interview.
4. Require at a minimum a 30 minute out of cell contact with the offender each
month with his caseworker.
5. Create a simplified four level system that has specific rules and privileges
associated with each phase. This would be a substitute for the current 3 Level
Quality of Life system.
6. The four level system would have (in general) 90-day periods, which would allow
the offender to be returned to GP within 9 months if compliant with the program
(Offenders would start at Level 2).
7. The current practice of automatic review to administrative segregation for
persons re-admitted to prison should be discontinued. These cases should be
decided on a case-by-case basis.
8. Strengthen Central Office role and influence on who is admitted and released
from administrative segregation.
9. The above changes would significantly reduce the current administrative
segregation population.




10. The reduction in the administrative segregation population would allow the
agency to re-configure the use of Sterling, CSP and CCF.
11. One scenario would be to concentrate the administrative segregation units at
CCF South and North and have CSP and Sterling function as close custody
general population facilities.
12. The responsibility for setting regulations and policies governing administrative
segregation should rest with Offender Services.
Classification Findings
1. The current system consists of an initial and reclassification instruments. These
have been separately developed for males and females.




19


2. The system also provides for a number of discretionary and management overrides. Further analysis of the scoring process including the application of overrides will be done once the requested data files are received.
3. In terms of current custody levels, the percent of male offenders in close custody
is about 15%, which is comparable to other states.
4. However, this number would increase slightly if the Administrative Segregation
population is reduced as recommended above.
5. Conversely, about 30% are minimum, which is comparable to other states as
well. There is a large percentage (26%) in the “minimum restricted” which could
also be defined as “Low Medium”.
6. There appears to be a higher proportion of females classified as close custody
than one would expect (14% -the same as males).
7. As observed previously, the use of PED and Detainers as scoring items is
producing some level of over-classification.
8. There is some degree of placing “true” close custody offenders at the four major
Level 3 facilities that needs to be addressed immediately.
9. Unlike other states, there is no dedicated protective custody unit nor are
offenders called PC.
Classification Recommendations
1. Eliminate PED and detainers and use them as mandatory over-rides.
2. This should “purify” and reduce the close custody population thus allowing the
Level 3 facilities to not hold “true” close custody offenders.
3. Make other appropriate changes to the male and female systems based on the
validation study to be completed in October.




20


4. A Colorado risk and case management system can be easily engineered using
current assessment procedures.
5. Develop a new risk and assessment system that is based on various
components of the current system but anchored in a standardized case
management plan that follows the offender from prison admission through
release from parole supervision.
6. Such a seamless system would be coordinated with the Parole Board decision
making process so that offenders are compliant with the case management plan
have a high probability of being paroled at the PED.
7. Eliminate the need for a clinician to certify a offender as having a substance
abuse problem.
8. Evaluate the need to establish a small but much needed PC unit.

























21