PREA AUDIT: AUDITOR’S SUMMARY REPORT
ADULT PRISONS & JAILS

Name of facility:

Metro-Davidson County Detention Facility

Physical address:

5115 Harding Place, Nashville, TN 37211

Date report submitted:

August 18, 2014

Auditor Information

Rodney P. Bivens

Address:

P.O. Box 392 Sweetwater, TN 37874

Email:

bivens.rodney@yahoo.com

Telephone number:

865-659-2424

Date of facility visit:

July 14-16, 2014

Facility Information
Facility mailing
address: (if different from

N/A

Telephone number:

615-831-7088

above)

Military

The facility is:

County

X Private for profit

Federal

Municipal

State

Private not for profit
X Jail

Facility Type:

Name of PREA Compliance Manager:
Email address:

Prison
Frederick Perry

Title:
Telephone
number:

fredrick.perryii@cca.com

Chief of Unit
Management
615-831-7088

Agency Information
Name of agency:

Corrections Corporation of America

Governing authority or
parent agency: (if

N/A

Physical address:

10 Burton Hills Boulevard Nashville, TN 37215

applicable)

Mailing address: (if

different from above)

Telephone number:

N/A
615-263-3000

Agency Chief Executive Officer
Name:

Damon Hininger

Email address:
damon.hininger@cca.com

Title:

President and Chief Executive Officer

Telephone
number:

615-263-3301

PREA AUDIT: AUDITOR’S SUMMARY REPORT

1

Agency-Wide PREA Coordinator
Name:
Lisa Hollingsworth
Email address:
lisa.hollingsworth@cca.com

Title:

Senior Director PREA Compliance

Telephone
number:

615-263-6915

AUDIT FINDINGS
NARRATIVE:

The PREA audit of the Metro-Davidson County Detention Facility was conducted on July 14-16,
2014 by Rodney P. Bivens, Certified PREA Auditor. Prior to the audit the facility provided to the
auditor policies, procedures and facility documentation related to each standard for review.
Ongoing communication was held with the facility PREA Manager and the PREA Coordinator in
preparation for the on-site visit. The evening prior to the audit, the auditor was supplied with a
list of inmates sorted by housing units, lists of inmates with special needs and special
designations as well as a list of facility staff. The auditor selected at random inmates and staff
to be interviewed during the on-site visit from these list. The first day of the audit began with
an entrance meeting which included the following staff:
Blair Leibach (Warden)
Frederick Perry (Chief of Unit Management)
Yolanda Pittman (Chief of Security)
Lisa Hollingsworth, Senior Director, PREA Programs and Compliance, CCA Facility
Support Center
Yesenia Bermudez (Unit Manager)
Takiyah Cooper (Unit Manager)
Charlton Dethrow (Unit Manager)
Katanga Taylor (Quality Assurance Manager)
Darrell Jones (Assistant Shift Supervisor)
Following the entrance meeting the entire facility was toured from 8:40 a.m. – 11:00 a.m.
During the tour the auditor reviewed camera placement, blind spots, staff placement and
documentation to assist in determining standard compliance. The following staff accompanied
the auditor on the facility tour:
Blair Leibach (Warden)
Frederick Perry (Chief of Unit Management)
Yolanda Pittman (Chief of Security)
Lisa Hollingsworth, Senior Director, PREA Programs and Compliance, CCA Facility
Support Center
Yesenia Bermudez (Unit Manager)
Takiyah Cooper (Unit Manager)
Charlton Dethrow (Unit Manager)
Katanga Taylor (Quality Assurance Manager)
Darrell Jones (Assistant Shift Supervisor)
PREA AUDIT: AUDITOR’S SUMMARY REPORT

2

All housing units, day rooms, inmate program areas, work areas and all other inmate accessible
areas were toured. While touring several inmates and staff were questioned about their
knowledge of PREA standards and their responsibilities. All staff and inmates informally
interviewed during the tour acknowledged receiving training and procedures for reporting a
sexual abuse, sexual harassment and/or retaliation for reporting. A total of 22 staff members
were interviewed during the course of the audit. This number includes one volunteer who was
interviewed by telephone and one contract employee interviewed on site. A random selection
of 9 correctional officers from all shifts as well as intermediate and higher level supervisors
were interviewed and affirmed compliance with the applicable standards. There is no SAFE or
SANE staff at the facility; they are available by contract at the local hospital. Staff interviewed
were well versed in their responsibilities in reporting sexual abuse, sexual harassment, staff
negligence and retaliation for reporting. When questioned about evidence preservation, all
staff responses reflected knowledge of agency policies and confirmed standard compliance.
A total of 15 general population inmates, three non-English proficient inmates and two inmates
housed in the Special Housing Unit (SHU) were interviewed. The majority of the Inmates
interviewed acknowledged receiving PREA training, pamphlets and handbooks; as well as other
written materials being provided, in their language, detailing numerous methods for reporting
incidents of sexual abuse, sexual assault, sexual harassment and/or retaliation for reporting
such incidents.
In the 12 months preceding the audit, Metro-Davidson County Detention Facility received a
total of fifteen PREA complaints broken down as follows:







Seven allegations for intentional touching of the genitalia, anus, groin, breast, inner
thigh, or buttocks of another was reported. Three were inmate on inmate and the other
four was employee on inmate. All employee on inmates were unfounded as well as one
inmate on inmate. The other two inmate on inmate were found unsubstantiated.
Six complaints of sexual harassment was reported. Four of which were inmate on inmate
and the other two were employee on inmate. Both employee on inmate allegations were
unsubstantiated, two of the inmate on inmate allegations were unsubstantiated, one was
unfounded and the other was substantiated.
One complaint of voyeurism, employee on inmate, was received and was determined to
be unfounded during the investigation.
One complaint of sexual abuse, employee on inmate was reported and determined to be
unsubstantiated by the investigator during the investigation.

All investigative files of each incident were reviewed during the onsite audit. It is the opinion of
this auditor that proper procedures were followed regarding each investigation. All incident
appeared to be thoroughly investigated and properly referred for possible criminal prosecution
as indicated.
At the conclusion of the on-site visit an exit meeting was held to discuss the audit findings.
The following people were in attendance:
Blair Leibach (Warden)
Frederick Perry (Chief of Unit Management)
Yolanda Pittman (Chief of Security)
Lisa Hollingsworth, Senior Director, PREA Programs and Compliance, CCA Facility
Support Center
PREA AUDIT: AUDITOR’S SUMMARY REPORT

3

Yesenia Bermudez (Unit Manager)
Takiyah Cooper (Unit Manager)
Charlton Dethrow (Unit Manager)
Katanga Taylor (Quality Assurance Manager)
Darrell Jones (Assistant Shift Supervisor)
The auditor explained the process that would follow the on-site visit and the facilities
responsibility to make the final report available to the public on their website. This auditor also
acknowledged the willingness of all staff involved to accomplish PREA compliance as a team.
DESCRIPTION OF FACILITY CHARACTERISTICS:
The Corrections Corporation of America’s Metro-Davidson County Detention Facility is located in
Davidson County, just south of the city of Nashville. The facilities physical plant is
approximately 244,451 square feet covering several acres of land. In 1990, the Metropolitan
Government of Nashville and Davidson County contracted with Corrections Corporation of
America to design, build and manage the Metro-Davidson County Detention Facility. The facility
houses locally sentenced male and female inmates serving one to six year sentences. The
custody level of the inmates being housed ranges from minimum to medium. The facility is
comprised of six celled units, five dormitory units, two multi-occupancy units and a segregation
unit. There is a seven bed medical observation unit and handicapped access is provided
throughout the facility. The facility provides 14 small recreation yards attached to each housing
unit and a large gymnasium for inmate exercise. The entire perimeter is surrounded by a nonlethal stun fence and twenty-four hour perimeter patrol to enhance security.
Metro-Davidson County Detention Facility Administrative and Support Buildings consist of a
Master Control Center, Administrative Offices, Food Services, Dining Area, Medical, Visitation,
Chapel, Intake and Property Storage, Laundry, Library, and Education and Vocational
Classrooms.
Corrections Corporation of America by signed contract with Davidson County, agrees to house
their inmates and meet all related PREA standards. The Corrections Corporation of America’s
stated mission is “advancing corrections through innovative results that benefit and protect all
we serve” Their values are “having PRIDE in all we do”. It was evident the staff at MetroDavidson County Detention Facility were committed to excellence in corrections, by providing a
dedicated team of professionals whose focus is on the enhancement of the quality of life
through self-improvement opportunities for the inmates entrusted to their care.
SUMMARY OF AUDIT FINDINGS:

Number of standards exceeded: 2
Number of standards met:
39
Number of standards not met:
0
Non-applicable:
2

§115.11 - Zero tolerance of sexual abuse and sexual harassment
PREA AUDIT: AUDITOR’S SUMMARY REPORT

4

Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
The agency has a written policy mandating zero tolerance toward all forms of sexual
abuse and sexual harassment which outlines the agency’s approach to preventing,
detecting and responding to such conduct. This policy was clearly outlined in
Corrections Corporation of America policy 14-2.
The agency employs an upper-level, agency-wide PREA coordinator and a PREA
compliance manager. Based on interviews and the documentation provided, they
both appear to have sufficient time and authority to develop, implement, and oversee
agency efforts to comply with the PREA standards.

§115.12 - Contracting with other entities for the confinement of inmates
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
X Not-applicable Standard
Based on documentation provided the Corrections Corporation of America does not
contract with other facilities to house inmates assigned to their custody. Therefore, this
standard was found to be non-applicable to this facility.

§115.13 – Supervision and Monitoring
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy the agency has developed,
documented and made its best efforts to comply on a regular basis with a staffing plan.
The staffing plan provides for adequate levels of staffing and uses video monitoring to
enhance the protection of all inmates against sexual abuse and sexual harassment.
Based on the documentation provided and staff interviews there have been no
PREA AUDIT: AUDITOR’S SUMMARY REPORT

5

incidences where the staffing plan has not been complied with during this audit period,
resulting in a not applicable finding with 115-13 (b).
Documentation provided and staff interviews also revealed an Annual PREA Facility
Assessment was conducted by the Warden, PREA Manager and the PREA
Coordinator. The annual review provided to the auditor documented the need for
additional cameras. The auditor agrees and strongly recommends that additional
cameras be placed in all areas identified in this annual PREA assessment. The agency
head was interview prior to this audit and confirmed that a five year capital
expenditure plan had been approved to enhance camera coverage at all Corrections
Corporation of America facilities.
In review of the Corrections Corporation of America’s policy along with intermediatelevel or higher level staff interviews it was determined the facility has a policy in
place and intermediate-level and higher level staff practice conducting unannounced
rounds on all shifts. The logs were reviewed providing documentation of
unannounced rounds being conducted on each shift.

§115.14 – Youthful Inmates
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Not Applicable
The documentation provided, staff interviews and observation revealed that the
Corrections Corporation of America’s Metro-Davidson County Detention Facility
houses youthful inmates being tried and sentenced as an adult by the court system
due to the nature of the crime committed. The facility has designated two areas in
the facility where youthful inmates may be house when necessary. During this audit
there was one youthful female inmate being housed. The facility provided
documentation as well as the auditor inspected the housing unit, interviewed staff
and interviewed the youthful inmate confirming compliance with all aspects of this
standard.

§115.15 – Limits to Cross-Gender Viewing and Searches
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
PREA AUDIT: AUDITOR’S SUMMARY REPORT

6

Does Not Meet Standard (requires corrective action)
There have been no incidences of cross-gender strip searches or cross-gender visual
body cavity searches. Corrections Corporation of America’s policy outlines the
procedures to be followed if these type of searches were to occur. A training outline
for cross-gender viewing and searches was reviewed and addressed all elements of
the standard including transgender and intersex inmates.
The facility has policies and procedures that enable inmates to shower, perform bodily
functions and change clothing without non-medical staff of the opposite gender viewing
their breasts, buttocks or genitalia. Corrections Corporation of America’s policy was
reviewed and required staff of the opposite gender announce their presence prior to
entering the housing units. The facility also had stenciled above the entry to each
housing unit a reminder for the staff to announce. Inmate and staff interviews revealed
that this was common practice at this facility. The inmates did confirm also during
interviews they had privacy when showering, using the toilets and while changing their
clothes.

§115.16 – Inmates with Disabilities and Inmates
who are Limited
English
Proficient
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
The agency takes appropriate steps to ensure that inmates with disabilities and inmates
that are limited English proficient have an opportunity to participate and benefit from
all aspects of the agency’s efforts to prevent, detect and respond to sexual abuse and
harassment. Corrections Corporation of America policy and procedures related to this
standard require that all PREA training materials in the form of posters, inmate
handbooks, videos and pamphlets be available in both English and Spanish.
Corrections Corporation of America Policy prohibits the use of inmate interpreters,
inmate readers or other types of inmate assistants, except in limited circumstances
where an extended delay in obtaining an effective interpreter could compromise the
inmate’s safety, the performance of first-response duties or the investigation of an
inmate’s allegations. Staff and inmate interviews confirmed this was common practice.

§115.17 – Hiring and Promotion Decisions
Exceeds Standard (substantially exceeds requirement of standard)
PREA AUDIT: AUDITOR’S SUMMARY REPORT

7

X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
In review of Corrections Corporation of America policy and based on Human Resource
staff interviews the agency does not hire or promote anyone who may have contact
with inmates, and does not enlist the services of any contractor or volunteer who may
have contact with inmates, who has engaged in sexual abuse in a prison, jail, lockup,
community confinement facility, juvenile facility, or other institution, has been
convicted of engaging or attempting to engage in sexual activity in the community
facilitated by force, overt or implied threats of force, or coercion, or if the victim did
not consent or was unable to consent or refuse; or has been civilly or administratively
adjudicated to have engaged in the activity described above. The agency considers all
incidents of sexual harassment in determining whether to hire or promote anyone, or
to enlist the services of any contractor or volunteer, who may have contact with
inmates.
In interview with the Human Resources Manager and review of five random personnel
files the agency performs extensive criminal background records checks before hiring
new employees. In review of three personnel files of employees who have been
employed by the facility for at least five years, five-year background checks are being
performed, including contractors and volunteers as required.
Corrections Corporation of America policy imposes upon all employees, contractors and
volunteers a continuing affirmative duty to disclose any such misconduct in writing
during the hiring process.

§115.18 – Upgrades to Facilities and Technology
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy requires that when installing or updating a
video monitoring system, electronic surveillance system, or other monitoring
technology, the agency shall consider how such technology may enhance the
agency’s ability to protect inmates from sexual abuse.
During this audit cycle there have been no facility upgrades or enhancements to the
technology at this facility.

§115.21 – Evidence Protocol and Forensic Medical Examinations
PREA AUDIT: AUDITOR’S SUMMARY REPORT

8

Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy, as well as an interview with the facility
Investigator revealed the agency complies with all elements of this standard.
To the extent the agency is responsible for investigating allegations of sexual abuse;
the agency follows a uniform evidence protocol that maximizes the potential for
obtaining usable physical evidence for administrative proceedings and criminal
prosecutions. The Metro Nashville Police Department conducts all criminal
investigations at this facility.
The agency offers all victims of sexual abuse access to forensic medical examinations,
at the Nashville General Hospital, without financial cost, where evidentiary or medically
appropriate. Such examinations is performed by Sexual Assault Forensic Examiners
(SAFEs) or Sexual Assault Nurse Examiners (SANEs) at the hospital.
The agency makes available to the victim a victim advocate by a Memorandum of
Understanding between the agency and Nashville General Hospital to provide advocacy
services if requested by the victim. The victim advocate will accompany and support
the victim through the forensic medical examination process and investigatory
interviews and shall provide emotional support, crisis intervention, information and
referrals.

§115.22 – Policies to Ensure Referrals of Allegations for Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy as well as interviews with the
Warden and investigative staff, the agency ensures that an administrative and a
criminal investigation is completed for all allegations of sexual abuse and sexual
harassment. Referrals of allegations are first investigated by the facility. If the
allegation involves potentially criminal conduct, it is referred to Metro Nashville Police
Department for criminal investigation and prosecution when warranted.

§115.31 – Employee Training
PREA AUDIT: AUDITOR’S SUMMARY REPORT

9

Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy and the facility PREA Training Curriculum
was reviewed and confirmed all employees were provided the required PREA training
at this facility. The policies as well as the training curriculum reviewed address all
elements of this standard. The training is tailored to the gender of the inmates at the
facility. All staff interviewed at the facility, formally and informally was very
knowledgeable about PREA, the agency’s zero-tolerance policy and how to
report/respond to allegations of sexual abuse and sexual harassment. All staff at this
facility are trained as first responders. Random employee training records were
reviewed and revealed documented training had being conducted. All employees
acknowledged by signature they had received and understood the training provided.

§115.32– Volunteer and Contractor Training
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy outlines the requirements for training of all
volunteers and contractors who have contact with inmates. The curriculum was
reviewed and outlined comprehensive training, with the objectives of the training
ensuring volunteers and contractors are notified of the agency’s zero-tolerance policy
regarding sexual abuse and sexual harassment as well as how an to whom they are
to report such incidents.
A random review of volunteer and contractor training records and by interviews with
a volunteer and a contractor confirmed this training was being provided. Volunteers
and contractors acknowledged by signature they have received and understood the
training being provided.

§115.33 – Inmate Education
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period
PREA AUDIT: AUDITOR’S SUMMARY REPORT

10

Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy requires that all inmates receive PREA
education as part of the Admission and Orientation program and shall be provided by
the staff at the facility. The inmates receive information explaining the zero-tolerance
policy regarding sexual abuse and sexual harassment and how to report incidents or
suspicions of sexual abuse, sexual harassment and retaliation for reporting such
incidents.
The inmate handbook was reviewed as well as the PREA Admission and Orientation
training materials and pamphlets for content and compliance with this standard. The
training being provided was adequate and provided in both English and Spanish. This
information was also provided to inmates with disabilities such as low vision, low
hearing and/or limited reading skills in a manner they could understand. The agency
provided more comprehensive education to the inmates in person and/or by video less
than 30 days after intake. The additional education being provided covered all aspects
of reporting PREA incidents and the inmate’s freedom from retaliation for reporting.
A random review of inmate records showed that inmates acknowledge through
signature they have received and understood the training. Formal and informal
interviews with inmates indicated an understanding of the training received. Posters
about being free from sexual abuse as well as how to report were displayed throughout
the facility.

§115.34 – Specialized Training: Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy as well as the PREA Specialized
Investigator Training curriculums provided, Investigators training file review and
investigative staff interviews revealed in addition to general training provided to all
employees, the agency provided specialized training to all its investigators. This
training includes techniques for interviewing sexual abuse victims, proper use of
Miranda and Garrity warnings, sexual abuse evidence collection in confinement settings
and the criteria and evidence required to substantiate a case for administrative action
or prosecution referral.

§115.35 – Specialized training: Medical and mental health care
Exceeds Standard (substantially exceeds requirement of standard)
PREA AUDIT: AUDITOR’S SUMMARY REPORT

11

X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy as well as the PREA Specialized
Medical/Mental Health training video and curriculum provided, training file review and
staff interviews revealed in addition to general training provided to all employees, the
agency provided specialized training to all its medical and mental health staff.
The agency ensures all medical and mental health practitioners have additional training
on how to detect and assess signs of sexual abuse and sexual harassment, how to
preserve physical evidence, how to respond effectively and professionally to victims of
sexual abuse and sexual harassment and how to report allegations of sexual abuse and
harassment. The agency maintains documentation that all medical and mental health
practitioners have received this training. Training records reflected all medical and
mental health staff had received this specialized training.
The facility medical staff does not conduct forensic examinations. These are conducted
by contract at the area hospital. Therefore, section (b) of this standard is not applicable
to this facility.

§115.41 – Screening for Risk of Victimization and Abusiveness
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy was reviewed along with the objective Initial
PREA Intake Screening Assessment and the 30-day PREA Reassessment Screening
instrument demonstrating compliance with the requirements of this standard. Upon
intake to the facility all inmates are screened using the objective screening instrument.
The screening instrument was thorough and covered all required criteria for
assessment of inmates to be at risk of sexual victimization as well as those potential
sexual predators. Based on interview with the staff responsible for completing the
screening the information gathered on the screening instrument was restricted to staff
making housing, work and program assignments. Inmates are not disciplined for
refusing to answer, or for not disclosing complete information in response to the
questions being asked.
Within 30 days of the inmate’s arrival at the facility, all inmates are reassessed for their
risk of victimization or abusiveness based upon any additional, relevant information
received since the initial intake screening. An inmate’s risk level is also reassessed due
PREA AUDIT: AUDITOR’S SUMMARY REPORT

12

to a referral, request, and incident of sexual abuse or upon receipt of additional
information that may have bearing on the inmate’s risk of sexual victimization or
abusiveness.

§115.42 – Use of Screening Information
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policies were utilized to verify compliance with this
standard along with interviews of the Case Manager and the Classification staff
responsible for risk screening. The information gathered during this audit showed
consistency in how the information from the risk screening is used to determine
housing, bed, work, education and program assignments to better enhance the safety
of each inmate.
The agency has developed and will be releasing a system which automates the
screening tool and automatically assigns the classification and/or alerts which will be
used to determine housing, work, education and program placement.
Placement and programming assignments for each transgender or intersex inmate is
reassessed at least twice each year per policy reviewing all threats to their safety.
Transgender and intersex inmates are given the opportunity to shower separately from
other inmates.
The agency does not place lesbian, gay, bisexual, transgender, or intersex inmates in
dedicated facilities, units or wings solely on the basis of such identification or status,
unless such placement is in a dedicated facility, unit or wing established in connection
with a consent decree, legal settlement or legal judgment for the purpose of protecting
such inmates.

§115.43 – Protective Custody
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy prohibits the facility from placing inmates at
high risk of victimization in involuntary segregation unless there is no alternative
available. If no available alternative can be reached the inmate must be provided
program, privileges, education and work opportunities. If these opportunities are
PREA AUDIT: AUDITOR’S SUMMARY REPORT

13

withheld the facility documents the reasons for withholding the opportunity to
participate. It was confirmed during interviews with the Warden and staff who
supervise segregated inmates that segregation has not been used during the past 12
months to house any inmate at high risk for victimization.

§115.51 – Inmate Reporting
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy, the Inmate Handbook and the PREA
pamphlets and posters provided to inmates were utilized to verify compliance with this
standard. Staff and inmate interviews verified the inmates have multiple internal ways
to report incidents of abuse or harassment. They can report verbally, in writing, dialing
the hotline provided and/or through report of a third party.
The facility provides the inmate’s access to the National Sexual Abuse Hotline on the
inmate phone system which provides the inmates with a confidential and private way
of reporting sexual abuse and harassment to an outside entity.
During the tour in one of the housing units the auditor made contact with the
National Sexual Abuse Hotline using the information posted above the telephones in
every housing unit. The phone line was found to be in-service with no problems
being reported by the inmates or staff.

§115.52 – Exhaustion of Administrative Remedies
Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
X Not Applicable (Exempt)
Based on Corrections Corporation of America policy the agency does not require
inmates, filing a report of sexual abuse, sexual harassment or retaliation, to exhaust
administrative remedies through the standard grievance process. If an inmate chooses
to report an incident by filing a grievance he or she may do so and it will be fully
investigated.
PREA AUDIT: AUDITOR’S SUMMARY REPORT

14

The policy requires no timelines for filing regardless of when the alleged incident
occurred. The agency ensures that an inmate who alleges sexual abuse by filing a
grievance, can do so without having to submit the grievance to a staff member who is
the subject of the complaint.
The agency may discipline an inmate for filing a grievance related to alleged sexual
abuse only when the agency demonstrates that the inmate filed the grievance in bad
faith. Inmates are informed of grievance procedures in the inmate handbook.
During the past twelve months there have been no grievances received alleging sexual
abuse or sexual harassment.

§115.53 – Inmate Access to Outside Confidential Support Services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy was reviewed and verifies inmates have
access to confidential support services. A Memorandum of Understanding with the
Nashville Sexual Assault Center provides for victim advocacy for emotional support
services related to sexual abuse. The Memorandum of Understanding describes the
services to be provided which includes confidential support services 24 hours a day,
seven days a week. Inmates are given information through signage in housing units
and other places throughout the facility. The inmates also receive a pamphlet in
Admissions and Orientation detailing this service and how to access it. Inmate
interviews revealed that inmates are aware of these outside resources.

§115.54 – Third-Party Reporting
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
The agency provides multiple methods for receiving third-party reports of sexual
abuse and sexual harassment on the agency website at: www.correctionscorp.com.
The information available on the website explains how to report sexual abuse and
sexual harassment on behalf of an inmate. The facility takes all reports seriously no
matter how they are received and thoroughly investigates each reported incident.
PREA AUDIT: AUDITOR’S SUMMARY REPORT

15

§115.61 – Staff and Agency Reporting Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy was reviewed to verify compliance with this
standard. Policies requires all staff to report immediately any knowledge or
information regarding an incident of sexual abuse, sexual harassment or retaliation.
Tennessee reporting laws for vulnerable persons as well as the training curriculum for
staff reporting was reviewed. Random interviews with staff revealed that staff is very
aware of their responsibilities to report incidents of sexual abuse and/or sexual
harassment.
The staff was also aware of the policy requiring them not to reveal any information
about a sexual abuse incident to anyone other than to the extent necessary. The
facility reports all allegations of sexual abuse and sexual harassment to the facility’s
designated investigator.

§115.62 – Agency Protection Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy, when the agency learns an
inmate is subject to a substantial risk of imminent sexual abuse, the staff shall take
immediate action to protect the inmate. The Warden confirmed there have been no
incidents in the past 12 months, where it was necessary for the facility to take any
action in regards to an inmate being at substantial risk of sexual abuse.

§115.63 – Reporting to Other Confinement Facilities
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
PREA AUDIT: AUDITOR’S SUMMARY REPORT

16

Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy, requires all sexual abuse allegations
reported by another facility regarding any inmate that was confined at the MetroDavidson County Detention Facility be fully investigated.
The policy also requires the Warden of Metro-Davidson County Detention Facility to
report all allegations of sexual abuse, reported by an inmate while confined at
another facility, to the Warden of the facility where the alleged abuse occurred as
soon as possible, but no later than 72 hours after receiving the allegation.
Interviews with the Warden and the PREA Manager confirmed knowledge of the
policies regarding their duty to report.

§115.64 – Staff First Responder Duties
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy outlines the responsibilities of all staff
members receiving an allegation of sexual abused to follow these guidelines:
(1) Separate the alleged victim and abuser;
(2) Preserve and protect any crime scene until appropriate steps can be taken to
collect any evidence;
(3) If the abuse occurred within a time period that still allows for the collection of
physical evidence, request that the alleged victim not take any actions that could
destroy physical evidence, including, as appropriate, washing, brushing teeth,
changing clothes, urinating, defecating, smoking, drinking, or eating; and
(4) If the abuse occurred within a time period that still allows for the collection of
physical evidence, ensure that the alleged abuser does not take any actions that
could destroy physical evidence, including, as appropriate, washing, brushing teeth,
changing clothes, urinating, defecating, smoking, drinking, or eating.
If the first staff responder is not a security staff member, the responder shall advise
the alleged victim not to take any actions that could destroy physical evidence, and
then notify security staff immediately.
The auditor confirmed compliance based on interviews with security staff who are
first responders and review of training documents provided.

PREA AUDIT: AUDITOR’S SUMMARY REPORT

17

§115.65 – Coordinated Response
X Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America’s Response Plan outlines a very comprehensive
written plan to coordinate actions taken in response to an incident of sexual abuse,
among staff first responders, medical and mental health practitioners, investigators
and facility leadership. The plan clearly defines the responsibilities of each and the
procedures to follow in detail. Interviews with SART members confirmed their
knowledge of the response plan. Part of the response plan is a detailed check off list
which ensures all steps in the plan are carried out in a timely manner.

§115.66 – Preservation of ability to protect inmates from contact with

abusers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on interview with agency head and the facility Warden. The Metro-Davidson
County Detention Facility does not participate in collective bargaining.

§115.67 – Agency protection against retaliation
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy describes the procedures and practice to be
followed to detect and prevent all retaliations against any inmate or staff member
who report sexual abuse or sexual harassment. The agency has assigned a staff
member to carry out the responsibilities of monitoring for retaliation. The retaliation
PREA AUDIT: AUDITOR’S SUMMARY REPORT

18

monitoring staff member was interviewed and explained his role in preventing
retaliation and the measures he takes to protect inmates and staff from retaliation.

§115.68 – Post-Allegation Protective Custody
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy, involuntary segregated housing
may be used only after an assessment of all available housing alternatives has shown
there are no other means of protecting the inmate. As indicated in standard 115.43,
use of protective custody to protect alleged victim is only used as a last resort for a
very short time. Interviews with the Warden and segregation staff showed that
segregation has not been used during the last 12 months to protect any alleged
victims.

§115.71 – Criminal and Administrative Agency Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
In review of Corrections Corporation of America policy, the facility investigators conduct
investigations immediately when notified of an allegation of abuse. Interview with the
investigator and review of his training records confirmed he had received special
training. If the investigation supports criminal prosecution, the case is referred to the
Metro Nashville Police Department.

§115.72 – Evidentiary Standard for Administrative Investigations
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
PREA AUDIT: AUDITOR’S SUMMARY REPORT

19

According to Corrections Corporation of America policy, the agency shall impose no
standard higher than a preponderance of the evidence in determining whether
allegations of sexual abuse or sexual harassment are substantiated. When the
investigator was asked what standard of evidence was used in determining if an
allegation is substantiated, the agencies policy was recited confirming compliance
with the standard.

§115.73 – Reporting to Inmate
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy, interview with Warden and the
investigator it was confirmed that following an investigation into an inmate’s
allegation he/she suffered sexual abuse in the facility, the investigator informs the
inmate as to whether the allegation has been determined to be substantiated,
unsubstantiated, or unfounded in writing.
When the agency refers the investigation to the authorities for criminal prosecution,
the facility investigator shall request information regarding the progress of the
investigation, from the investigative agency in order to inform the inmate.
Following an inmate’s allegation that a staff member has committed sexual abuse
against the inmate, the agency shall subsequently inform the inmate (unless the
agency has determined that the allegation is unfounded) whenever:
(1) The staff member is no longer posted within the inmate’s unit;
(2) The staff member is no longer employed at Metro-Davidson County Detention
Facility;
(3) The agency learns that the staff member has been indicted on a charge related to
sexual abuse within Metro-Davidson County Detention Facility; or
(4) The agency learns that the staff member has been convicted on a charge related
to sexual abuse within Metro-Davidson County Detention Facility.
Following an inmate’s allegation that he has been sexually abused by another inmate,
the agency shall subsequently inform the alleged victim whenever:
(1) The agency learns that the alleged abuser has been indicted on a charge related
to sexual abuse within Metro-Davidson County Detention Facility; or the agency
learns that the alleged abuser has been convicted on a charge related to sexual
abuse within Metro-Davidson County Detention Facility. All such notifications or
attempted notifications are documented.
The agency’s obligation to report under this policy shall terminate if the inmate is
released from the agency’s custody.
PREA AUDIT: AUDITOR’S SUMMARY REPORT

20

§115.76 – Disciplinary sanctions for staff
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy states that staff shall be subject to
disciplinary sanctions up to and including termination for violating agency sexual
abuse policies. Policy also states that termination shall be the presumptive
disciplinary sanction for all staff who engage in sexual abuse of the inmates.

§115.77 – Corrective action for contractors and volunteers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy states any contractor or volunteer who
engages in sexual abuse shall be prohibited from contact with inmates and shall be
reported to law enforcement agencies. In interview with the Warden, there have
been no incidences of sexual abuse by contractors or volunteers. If it were to occur,
appropriate remedial actions would be taken immediately. Interviews with a
contractor and volunteer confirmed they knew the punishment for engaging in sexual
abuse or sexual harassment of inmates.

§115.78 – Disciplinary sanctions for inmates
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America policy and a review of the Inmate
Handbook, the inmates are subject to disciplinary sanctions pursuant to a formal
PREA AUDIT: AUDITOR’S SUMMARY REPORT

21

disciplinary process following an administrative finding that the inmate engaged in
inmate-on-inmate sexual abuse or following a criminal finding of guilt for inmate-oninmate sexual abuse.
Sanctions are commensurate with the nature and circumstances of the abuse
committed, the inmate’s disciplinary history, and the sanctions imposed for
comparable offenses by other inmates with similar histories.
The disciplinary process considers whether an inmate’s mental disabilities or mental
illness contributed to his behavior when determining what type of sanction, if any,
should be imposed.
The agency disciplines an inmate for sexual contact with staff only upon a finding
that the staff member did not consent to such contact.
A report of sexual abuse made in good faith based upon a reasonable belief that the
alleged conduct occurred shall not constitute falsely reporting an incident or lying,
even if an investigation does not establish evidence sufficient to substantiate the
allegation.
The agency prohibits all sexual activity between inmates and may discipline inmates
for such activity.

§115.81 – Medical and mental health screenings; history of sexual abuse
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
As outlined in Corrections Corporation of America policy all new arrivals see a Mental
Health provider. If the screening indicates the inmate has experienced prior sexual
victimization, whether it occurred in an institutional setting or in the community, staff
shall ensure the inmate is offered a follow-up meeting with the medical and/or
mental health staff within 14 days of the intake screening.
If the screening indicates an inmate has previously perpetrated sexual abuse/prior
sexual victimization, whether it occurred in an institutional setting or in the
community, staff shall ensure the inmate is offered a follow-up meeting with mental
health staff within 14 days of the intake screening.
Any information related to sexual victimization or abusiveness that occurred in the
facility is strictly limited to medical and mental health practitioners and other staff, as
necessary, to inform treatment plans and security and management decisions,
including housing, bed, work, education, and program assignments, or as otherwise
required by Federal, State, or local law.
PREA AUDIT: AUDITOR’S SUMMARY REPORT

22

Medical and mental health practitioners obtain informed consent from inmates before
reporting information about prior sexual victimization that did not occur in the facility,
unless the inmate is under the age of 18.

§115.82 – Access to emergency medical and mental health services
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Corrections Corporation of America Policy and the Memorandum of
Understanding with Nashville General Hospital inmate victims of sexual abuse receive
timely, unimpeded access to emergency medical treatment and crisis intervention
services, the nature and scope of which are determined by medical and mental
health practitioners according to their professional judgment.
If no qualified medical or mental health practitioners are on duty at the time a report
of recent abuse is made, security staff first responders takes preliminary steps to
protect the victim and shall immediately notify the appropriate medical and mental
health practitioners.
Inmate victims of sexual abuse while incarcerated are offered timely information
about and timely access to emergency contraception and sexually transmitted
infections prophylaxis, in accordance with professionally accepted standards of care,
where medically appropriate.
Treatment services are provided to the victim without financial cost and regardless of
whether the victim names the abuser or cooperates with any investigation arising out
of the incident.

§115.83 – Ongoing medical and mental
health care for sexual
abuse
victims and abusers
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)

PREA AUDIT: AUDITOR’S SUMMARY REPORT

23

Based on Corrections Corporation of America policy and interviews with
medical/mental health staff. Metro-Davidson County Detention Facility offers medical
and mental health evaluation and, as appropriate, treatment to all inmates who have
been victimized by sexual abuse in the facility.
The evaluation and treatment of such victims include, as appropriate, follow-up
services, treatment plans, and, when necessary, referrals for continued care following
their transfer to, or placement in, other facilities, or their release from custody.
Metro-Davidson County Detention Facility provides such victims with medical and
mental health services consistent with the community level of care. Inmate victims of
sexual abuse while incarcerated are offered tests for sexually transmitted infections
as medically appropriate. Treatment services are provided to the victim without
financial cost and regardless of whether the victim names the abuser or cooperates
with any investigation arising out of the incident.

§115.86 – Sexual abuse incident reviews
X Exceeds Standard (substantially exceeds requirement of standard)
Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Based on Correction Corporation of America policy and on interviews with the Warden,
PREA compliance manager and members of the incident review team.
Metro-Davidson County Detention Facility conducts a sexual abuse incident review at
the conclusion of every sexual abuse investigation, including where the allegation has
not been substantiated, unless the allegation has been determined to be unfounded.
This review ordinarily occurs within 30 days of the conclusion of the investigation. The
review team includes upper-level management officials, with input from line
supervisors, investigators, and medical and/or mental health practitioners.
The review team considers whether the allegation or investigation indicates a need to
change policy or practice to better prevent, detect, or respond to sexual abuse;
whether the incident or allegation was motivated by race; ethnicity; gender identity;
lesbian, gay, bisexual, transgender, or intersex identification, status, or perceived
status; or gang affiliation; or was motivated or otherwise caused by other group
dynamics at Metro-Davidson County Detention Facility; and they examine the area in
Metro-Davidson County Detention Facility where the incident allegedly occurred to
assess whether physical barriers in the area may enable abuse; assess the adequacy
of staffing levels in that area during different shifts; assess whether monitoring
technology should be deployed or augmented to supplement supervision by staff.
PREA AUDIT: AUDITOR’S SUMMARY REPORT

24

The agency has deployed an excellent PREA after action review form which
addresses all elements of the standard. Metro-Davidson County Detention Facility
conducts an incident review for all cases and reviews all findings telephonically with
the agency wide PREA Coordinator for additional clarification and guidance.

§115.87 – Data Collection
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy requires the agency to collect accurate,
uniform data for every allegation of sexual abuse at facilities under its direct control
using a standardized instrument and set of definitions. The agency must aggregate
the incident-based sexual abuse data at least annually per policy.
The incident-based data collected shall include, at a minimum, the data necessary to
answer all questions from the most recent version of the Survey of Sexual Violence
conducted by the Department of Justice.
The agency maintains, reviews, and collects data as needed from all available
incident-based documents, including reports, investigation files, and sexual abuse
incident reviews.
Upon request, the agency shall provide all such data from the previous calendar year
to the Department of Justice no later than June 30.

§115.88 – Data Review for Corrective Action
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
According to Corrections Corporation of America policy and interview with the PREA
Coordinator, the agency reviews data collected and aggregated in order to assess
and improve the effectiveness of its sexual abuse prevention, detection and response
to policies, practices and training. The report includes a comparison of the current
year’s data and corrective actions with those from prior years. The Annual PREA
PREA AUDIT: AUDITOR’S SUMMARY REPORT

25

Report is made available on the Corrections Corporation of America website at:
www.correctionscorp.com.

§115.89 – Data Storage, □ Publication, and
Destruction □
Exceeds Standard (substantially exceeds requirement of standard)
X Meets Standard (substantial compliance; complies in all material ways with the
standard for the relevant review period)
Does Not Meet Standard (requires corrective action)
Corrections Corporation of America policy was reviewed to verify compliance with this
standard. The agency ensures that data collected pursuant to standard 115.87 is
securely retained for at least 10 years after the initial date of collection or longer if
required by state statute. All aggregated sexual abuse data is available annually on
the Corrections Corporation of America website at: www.correctionscorp.com.
Before publishing aggregated sexual abuse data, the agency removes all personal
identifiers.

AUDITOR CERTIFICATION:

The auditor certifies that the contents of the report are accurate to the best of his/her
knowledge and no conflict of interest exists with respect to his or her ability to conduct an audit
of the agency under review.

____Rodney P. Bivens______
Auditor Signature

___August 18, 2014____
Date

PREA AUDIT: AUDITOR’S SUMMARY REPORT

26