Tn Doc Performance Audit Probation Parole Board Sept 2012

• Topics: Misconduct/Corruption, Corrections Audits

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Board of Probation and Parole
September 2012

Justin P. Wilson
Comptroller of the Treasury

State of Tennessee
Comptroller of the Treasury
Department of Audit
Division of State Audit

Arthur A. Hayes, Jr., CPA, JD, CFE
Director

Deborah V. Loveless, CPA, CGFM
Assistant Director

Diana Jones, CGFM

Jennifer M. Garoutte, CGFM, CFE

Audit Manager

In-Charge Auditor

John Dunne, CPA
Stacey Green, JD
Kimberly White

Amy Brack
Editor

Staff Auditors

Comptroller of the Treasury, Division of State Audit
1500 James K. Polk Building, Nashville, TN 37243-1402
(615) 401-7897
Performance audits are available online at www.comptroller.tn.gov/sa/AuditReportCategories.asp.
For more information about the Comptroller of the Treasury, please visit our website at
www.comptroller.tn.gov.

STATE OF TENNESSEE

COMPTROLLER OF THE TREASURY
DEPARTMENT OF AUDIT
DIVISION OF STATE AUDIT
SUITE 1500
JAMES K. POLK STATE OFFICE BUILDING
NASHVILLE, TENNESSEE 37243-1402
PHONE (615) 401-7897
FAX (615) 532-2765

September 18, 2012
The Honorable Ron Ramsey
Speaker of the Senate
The Honorable Beth Harwell
Speaker of the House of Representatives
The Honorable Mike Bell, Chair
Senate Committee on Government Operations
The Honorable Jim Cobb, Chair
House Committee on Government Operations
and
Members of the General Assembly
State Capitol
Nashville, Tennessee 37243
Ladies and Gentlemen:
Transmitted herewith is the performance audit of the Board of Probation and Parole.
This audit was conducted pursuant to the requirements of Section 4-29-111, Tennessee Code
Annotated, the Tennessee Governmental Entity Review Law.
This report is intended to aid the Joint Government Operations Committee in its review to
determine whether the Board of Probation and Parole should be continued, restructured, or
terminated.
Sincerely,

Arthur A. Hayes, Jr., CPA
Director
AAH/dj
12-036

State of Tennessee

Audit Highlights
Comptroller of the Treasury

Division of State Audit

Performance Audit
Board of Probation and Parole
September 2012
_________

AUDIT OBJECTIVES
The objectives of the audit were to determine whether probation and parole officers are
monitoring offenders as required; determine whether probation and parole officers with a
Global Positioning System (GPS) caseload are monitoring and following up on alarms as
required by policy; determine the level of review of offender case files being completed by
the probation and parole officers’ supervisors; determine how the board ensures offenders
have been notified of their appeal rights; determine the timeliness of notifications of parole
decisions; determine the risk factors included in technical violation decision-making and
whether decisions made by the Administrative Case Review Committee (ACRC) are
consistent; determine the requirements of the fee collection Request for Proposal and its
status; determine whether the divisions of Internal Audit and Research, Policy, and Planning
duplicate efforts in reviewing all activities of the board; determine whether the board
complies with state laws regarding open meetings and provides adequate public notice
regarding meetings; determine whether board staff and members are receiving all required
training and sign a conflict of interest statement annually; determine if employees are
provided training on topics including time management and prioritizing caseloads; determine
the number of offenders who have participated in Victim Impact and Courage to Change
training, then (if possible) determine the number of offenders participating in these programs
who have reoffended within one year of completing the programs; determine the status of the
Justice Assistance Grant through the American Recovery and Reinvestment Act; and gather
and report Title VI information, staff demographic information, and performance measures
data.

FINDINGS
Comparison of Offender Social Security
Numbers to the Department of Health
Death Records Found 82 Offenders Were
Still Actively Monitored After Their
Death
After comparing the offender’s social
security numbers to the Tennessee
Department of Health death records, we
conducted simple Google searches and
reviewed the social security death master
file available online to obtain additional
evidence of the offenders’ death. The 82
offenders we were able to find additional
evidence for had been deceased from less
than 6 months to over 19 years. In addition,
we found 2 instances where probation and
parole officers entered information into the
Tennessee
Offender
Management
Information System (TOMIS) indicating the
offender was alive after the offender died.
While 82 is a small number compared to the
over 60,000 offenders monitored each year,
the board (and now the Department of
Correction) should consider regularly
comparing offender information to either
state or social security administration death
records (page 10).
As Noted in the May 2006 Audit, the
Board’s Probation and Parole Officers
Are Still Not Completing All Supervision
Requirements Resulting in Increased
Risk That the Board Will Not Achieve Its
Mission of Minimizing Public Risk and
Maximizing Lawful Behavior
During the current audit, we found 8 of 70
GPS-monitored offender files and 69 of 120
regular offender files that were in
compliance with all board supervision
requirements during calendar year 2011.
While board policy allows for entries in
TOMIS when an offender fails to arrive for
a face-to-face meeting or an attempted home
visit found no one home, etc., we still found

many instances where there was no evidence
of an attempt at supervision by the probation
and parole officers. The board and the
Department of Correction (TDOC) should
develop a formal corrective action plan
which ensures information in TOMIS is
complete and accurate (page 11).
The Board’s Disaster Recovery Plan
Lacks the Elements Necessary to Ensure
Resumption
of
Functioning
and
Performing Essential Duties in the Event
of an Emergency
State law requires each agency to have an
emergency services coordinator who is
responsible for a disaster preparedness plan.
The plan should be reviewed by the local
emergency management agency and
approved by the Tennessee Emergency
Management Agency (TEMA).
The
wording of this finding does not identify
specific vulnerabilities because disclosing
these vulnerabilities could present a security
risk by providing readers with information
that might be confidential pursuant to
Section 10-7-504(i), Tennessee Code
Annotated. The board should thoroughly
document specific disaster recovery
procedures and actions to be taken, from the
declaration of a disaster until the time that
normal business operations are resumed.
The plan should contain adequate detailed
information to permit staff to use it as a
stand-alone field manual. The plan should
be reviewed, updated, tested, and
reapproved as processes change and, at a
minimum, on an annual basis. The plan
should be submitted to TEMA and made
readily available to board employees (page
30).

The Board Should Reevaluate Current
Procedures for Posting Meeting Notices,
to Better Ensure Compliance With Public
Meetings Law
Currently the board only posts meeting
notices in the elevator lobby at the central
office on the 13th floor of the Parkway
Towers Building in downtown Nashville
and on the Public Meetings area of the state
website less than 48 hours prior to the
meetings; however, state law stipulates that
all meetings of any governing body are
public meetings and open to the public at all
times. State law also requires adequate
public notice of both regularly scheduled
and special meetings. The board should
strengthen policies and procedures regarding
public meeting notices to better ensure
compliance with state law and ensure that
board personnel and the general public are
aware of the meetings of the board. Further,
the board should ensure its notices are
posted at a time sufficiently in advance of
the actual meeting in order to given citizens
both an opportunity to become aware of and
to attend the meeting (page 32).
In Some Instances, the Board Still Fails to
Comply With State Law Regarding
Hearing Decisions; Further, Letters
Denying Parole Omit Appeal Rights
(Repeated from May 2006 and June 2001
Performance Audits)
In reviewing files for this audit, we found no
problems with timeliness for sending out the
notifications for scheduled hearings to
offenders, but problems still exist for
sending out notifications of hearing
decisions to offenders and interested parties.
State law requires notices of decisions be
sent within 30 days of the finalized
decisions. Of the 48 files we reviewed, 15
hearing decision notifications were sent
more than 30 days after the board’s decision
was finalized. We also determined that
information related to appeal rights was not

included in the letters to offenders whose
parole was denied or revoked. The board
needs to strengthen existing parole hearing
notification procedures to ensure compliance
with statute. The board should also revise
the notification of hearing decision letters to
include appeal rights for the offender to
ensure the board’s communication of appeal
rights to the offender is documented (page
34).
Weaknesses in the Tennessee Offender
Management Information System could
result in inaccurate analysis of some
programs
We found instances in two separate
programs where offenders were allowed to
participate in programs without first being
referred to the program as required by board
policy.
This means TOMIS lacks
appropriate edit checks to help PPOs ensure
they are completing all required steps for
getting offenders into programs. It also
negatively affects the board’s ability to
analyze and rely on the information in
TOMIS. The board and TDOC should work
together to ensure that appropriate edit
checks and data validation tools are
developed and implemented for TOMIS
(page 37).
Approximately Half of the Cases in Our
Sample Were Not Reviewed by PPO
Supervisors During Calendar Year 2011
A March 2010 Directive established
guidelines for supervisory reviews to ensure
that 100% of cases received a review each
year.
We reviewed TOMIS and
documentation of supervisory reviews
provided by PPO supervisors and found that
only 50% of the 230 files in our sample
received at least one review during calendar
year 2011. The board and TDOC should use
all available tools for monitoring to
determine if supervisory reviews are being
completed. The board and TDOC should

also ensure that the supervisory reviews are
discussed with PPOs as required by board
policy (page 40).
The Board’s Field Services Division Does
Not Adequately Document and Monitor
Administrative Case Review Committee
(ACRC) Actions for Offenders Who
Commit Technical Violations and, in
Some Instances, Fails to Administer
Proper Sanctions
State law allows the board to use
intermediate administrative sanctions when
appropriate to better manage offenders.
Board policy establishes the ACRC as a
means of dealing with “technical
violations,” failures to comply with
supervision conditions which do not amount
to criminal offenses. Through the ACRC, a

system of progressive interventions and
sanctions has been established based on the
severity of the technical violation. For 2 of
the 13 regular supervision offenders and 1 of
3 GPS-monitored offenders, PPOs did not
document that appropriate sanctions had
been imposed. For 1 of 4 IOT offenders
there were no sanctions documented.
Additionally, PPOs are not consistently
using the appropriate TOMIS code to
indicate when an offender has participated in
ACRC. The board and TDOC should ensure
adequate records of ACRC activities are
maintained, appropriate sanctions are
imposed for all violations, and that staff
enter TOMIS codes and thoroughly
document sanctions imposed.
ACRC
sanctions should be considered during
supervisory reviews of case files (page 43).

OBSERVATIONS AND COMMENTS
The audit discusses the following issues: the board’s Information Systems Division does not

maintain an adequate record of source code changes; conflict of interest disclosures do not
adequately document compliance with policy; board policy regarding pre-service orientation is
not consistent with practice but most employees received training required by board practice;
over 80% of GPS-monitored offenders’ alarms appear unmonitored; the Division of Internal
Audit and the Division of Research, Policy, and Planning duplicate efforts in completing reviews
of all board activity; the board’s Office of Victim Liaison Services does not have an effective
system for evaluating or even measuring completion or success rates for the offenders referred to
the Victim Impact and Courage to Change classes; weaknesses in the fee collection process
previously noted in the June 2001 and May 2006 performance audits and the 2007 financial and
compliance audit still need to be rectified (page 49).

Performance Audit
Board of Probation and Parole
TABLE OF CONTENTS
Page
INTRODUCTION

Purpose and Authority for the Audit

Objectives of the Audit

Scope and Methodology of the Audit

Organization and Responsibilities

Revenues and Expenditures

FINDINGS AND RECOMMENDATIONS

1. Comparison of offender social security numbers to Department of Health death
records found that 82 offenders were still actively monitored after their death

3. The board’s disaster recovery plan lacks the elements necessary to ensure
resumption of functioning and performing essential duties in the event of an
emergency

4. The board should reevaluate current procedures for posting meeting notices, to
better ensure compliance with public meetings law

5. In some instances, the board still fails to comply with state law regarding hearing
decisions; further, decision letters denying parole omit appeal rights

6. Weaknesses in the Tennessee Offender Management Information System could
result in inaccurate analysis of some programs

7. Approximately half of the cases in our sample were not reviewed by probation and
parole officer supervisors during calendar year 2011

TABLE OF CONTENTS (CONT.)
Page
OBSERVATIONS AND COMMENTS

The Board’s Information Systems Division Does Not Maintain an Adequate
Record of Source Code Changes, Increasing the Risk of Unauthorized
Changes and Interruptions of Service

Conflict of Interest Disclosures Do Not Adequately Document Compliance with
Policy

Over 80% of GPS-Monitored Offenders’ Alarms Appear Unmonitored

The Division of Internal Audit and the Division of Research, Policy, and
Planning Duplicate Efforts in Completing Reviews of All Board Activity

Weaknesses in the Fee Collection Process Previously Noted in the June 2001
and May 2006 Performance Audits and the 2007 Financial and Compliance
Audit Still Need to Be Rectified

RESULTS OF OTHER AUDIT WORK

JAG/ARRA Grant Agreement Implementation Status

RECOMMENDATIONS

Administrative

APPENDICES

Appendix 1 - Title VI and Other Information

Appendix 2 - Performance Measures Information

Appendix 3 - Finding 2 Testwork Results by Grand Division

Performance Audit
Board of Probation and Parole
INTRODUCTION

PURPOSE AND AUTHORITY FOR THE AUDIT
This performance audit of the Board of Probation and Parole was conducted pursuant to
the Tennessee Governmental Entity Review Law, Tennessee Code Annotated, Title 4, Chapter
29. Under Section 4-29-234, the board is scheduled to terminate June 30, 2013. The
Comptroller of the Treasury is authorized under Section 4-29-111 to conduct a limited program
review audit of the agency and to report to the Joint Government Operations Committee of the
General Assembly. The audit is intended to aid the committee in determining whether the board
should be continued, restructured, or terminated. (Prior to the end of our fieldwork, the General
Assembly passed legislation that transferred supervision of probationers and parolees to the
Department of Correction, with full implementation to be accomplished by January 1, 2013;
however, our reviews focused on instances that had occurred or were occurring with the board
and its supervision of probationers and parolees prior to the beginning of this transition.) As of
July 1, 2012, the board’s name changed to the Board of Parole.

OBJECTIVES OF THE AUDIT
The objectives of the audit were to
1. determine whether probation and parole officers are monitoring offenders as required;
2. determine whether probation and parole officers with a Global Positioning System
(GPS) caseload are monitoring and following up on alarms as required by policy;
3. determine the level of review of offender case files being completed by the probation
and parole officers’ supervisors;
4. determine how the board ensures offenders have been notified of their appeal rights;
5. determine the timeliness of notifications of parole decisions;
6. determine the risk factors included in technical violation decision-making and
whether decisions made by the Administrative Case Review Committee (ACRC) are
consistent;
7. determine the requirements of the fee collection Request for Proposal and its status;

8. determine whether the divisions of Internal Audit and Research, Policy, and Planning
duplicate efforts in reviewing all activities of the board;
9. determine whether the board complies with state laws regarding open meetings and
provides adequate public notice regarding meetings;
10. determine whether board staff and members are receiving all required training and
sign a conflict of interest statement annually;
11. determine if employees are provided training on topics including time management
and prioritizing caseloads;
12. determine the number of offenders who have participated in Victim Impact and
Courage to Change training, then (if possible) determine the number of offenders
participating in these programs who have reoffended within one year of completing
the programs;
13. determine the status of the Justice Assistance Grant through the American Recovery
and Reinvestment Act; and
14. gather and report Title VI information, staff demographic information, and
performance measures data.

SCOPE AND METHODOLOGY OF THE AUDIT
The activities of the Board of Probation and Parole were reviewed for the period January
2011 to May 2012. We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objectives. Methods used
included
1. review of applicable legislation, rules, and board policies and procedures;
2. examination of board files, documents, and offender information in the Tennessee
Offender Management Information System (TOMIS), the GPS monitoring system
Veritracks, and the Board Operations Application Suite;
3. review of reports, and information summaries from other states; and
4. interviews with the board chairman, board members, board staff, vendors, and staff of
other state and local agencies that interact with the board.

ORGANIZATION AND RESPONSIBILITIES
The Board of Probation and Parole is a full-time board composed of seven members
appointed by the Governor, charged with deciding which eligible felony offenders will be
granted parole and released from incarceration. The board is then responsible for the supervision
of parolees granted release and of felony offenders who are placed on probation by the Criminal
Courts. See organization chart on page 4.
The administrative duties of the board include setting criteria for granting and revoking
parole and developing a strategic plan, an annual budget and staffing plan, and policies and
procedures.
The board’s executive director is responsible for the day-to-day functioning of the agency
and for assisting the board in the development and implementation of policies, procedures,
strategic plans, budgets, and reports. The executive director also has responsibility for
recruitment and supervision of staff and for developing and maintaining communication and
cooperation between the Department of Correction and the board.
Two probation and parole administrators assist the executive director and, along with the
directors of Field Services, Communications, and General Counsel, provide the senior level of
management for the board. Each administrator is responsible for several of the divisions. The
two probation and parole administrators are responsible for the following divisions:


Fiscal Services;



Budget;



Research, Policy, and Planning;



Information Systems;



Human Resources;



Board Operations;



Community Corrections;



Parole Hearing Officers; and



Training.

The Fiscal Services Division provides a variety of services to agency staff including
general accounting and payables for the board and the Community Corrections agencies;
offender fee accounting; purchasing; contract management; facility and property management;
and printing, communications, records management, and other miscellaneous responsibilities.
The Budget Division, in conjunction with the board and senior management, is
responsible for the continual process of budget development, budget training, and monitoring.

Board of Probation and Parole
Organization Chart
June 2011
Chairman and
Board Members

Victim Services
Director

Executive Director

Internal Auditor

Communications Director

Research, Policy, and
Planning Director

Probation/Parole
Administrator

Field Services
Director

General Counsel

Probation/Parole
Administrator

Field Services Deputy
Director

Board Operations
Director

Fiscal Services
Director
Assistant Director
Parole

Community
Corrections Director

Human Resources
Director
Assistant Director
Probation

Hearing Officers
Director

Information Systems
Director
Assistant Director
Treatment Services

Training Director

Budget Director
District Directors (8)

Source: Board of Probation and Parole Annual Report 2010-2011.

The Research, Policy, and Planning Division provides internal and external compliance
reviews of all board offices, including the central office and the Community Corrections
programs. These reviews include analysis of program activities and fiscal management. In
addition to compliance reviews, the division also provides statistical information to the agency,
researches a variety of criminal justice topics, oversees other research conducted by external
parties that involves the board, and has responsibility for policy and forms development and
grant writing and administration.
The Information Systems Division is composed of two teams: Technical Support and
Development. The Technical Support Team assists board staff in carrying out their duties. The
Development Team provides business process analysis and modeling, and application design,
development, and implementation for the agency.
The Human Resources Division administers, monitors, and processes employee programs
that involve payroll, civil service transactions, and retirement. This includes position and staff
job classifications and compensation, attendance, sick leave, the sick leave bank, the Family
Medical Leave Act, donated leave, workers compensation, employee assistance programming,
Americans with Disabilities Act compliance, insurance, regular and disability retirement,
performance evaluations, disciplinary and grievance actions, and human rights and EEOC issues.
Board Operations is responsible for scheduling parole hearings, issuing parole and
determinate release certificates, maintaining the board offender files, obtaining psychological
evaluations for offenders prior to parole hearings, processing requests for executive clemency,
and responding to agency correspondence.
The Community Corrections Program was created by the passage of the Tennessee
Community Corrections Act of 1985. The intent was to provide services and programs in local
jurisdictions for eligible felony offenders in lieu of incarceration in state penal institutions or
local jails. The Board of Probation and Parole provides broad oversight of independent local
agencies who deliver these short-term community residential treatment options and
individualized evaluation and treatment services.
The Parole Hearing Officers Division is responsible for conducting parole granting and
revocation hearings. Parole hearing officers are appointed by the board chairman to conduct
parole hearings at state penal institutions and local jails to gather information, take testimony,
and make non-binding recommendations that assist board members in determining which
eligible offenders will be granted parole and placed under community supervision. Hearing
officers also conduct parole revocation hearings. The hearing officers are assigned to four
hearing regions, and as of January 2012, there were 18 parole hearing officers in the state.
The Training Division is responsible for developing and implementing training at a
district/local level that will ensure adherence to policy, give staff the knowledge and techniques
to effectively perform their assigned job task, seek the input of line staff and supervisors in
training issues, and aid staff in personal and professional development. Each new full-time
employee is to participate in 40 hours of pre-service orientation. Full-time employees are to
receive annual training: 40 hours for specialized staff and 16 hours for support staff.

Field Services
The Field Services Division has a district director in each of its eight district offices, each
serving a designated number of counties. In addition to the district offices, there are 49 field
offices. Probation and parole officers (PPOs) supervise and monitor the conduct, behavior, and
progress of probationers and parolees assigned to them. They also report to the court and to the
board on the progress of probationers and parolees. Violation of any of the conditions of parole
is a potential cause for revocation or other sanctions ordered by the board. PPOs report
violations of parole to the board and may make recommendations about what action should be
taken. Likewise, any violation of the conditions of probation is a potential cause of revocation or
other sanctions by the court. For the fiscal year ending June 30, 2011, the total offender
population was 74,248, consisting of 12,429 parolees, 54,235 probationers, and 7,584 offenders
in the Community Corrections Program. During fiscal year 2011, 1,222 individuals had their
parole revoked and were reincarcerated. For the fiscal year ending June 30, 2012, the total
offender population was 77,432, consisting of 13,006 parolees, 56,833 probationers, and 7,593
offenders in the Community Corrections Program. During fiscal year 2012, 1,536 offenders had
their parole revoked and were reincarcerated.
In recent years, the Field Services Division has been working with the Department of
Correction (TDOC) on a Joint Offender Management Plan to cut expenses, increase offender
accountability, and effectively manage the offender population without forced early releases.
The plan provides the agencies with tools to reduce the risk of new offenses and improve
offender outcomes by using evidence-based practices shown to be effective in other jurisdictions,
and ensures offenders are evaluated by the same criteria.
As part of the Joint Offender Management Plan, in FY 2010, Field Services, Community
Corrections and TDOC began using the Level of Service Case Management Inventory
(LS/CMI), a nationally recognized and validated risk and needs assessment and case
management tool. Since all three programs are now using a common assessment instrument,
offenders should experience continuity of services as they transition through the Tennessee
criminal justice system.
Additionally, the Joint Offender Management Plan uses evidence-based behavior
modification tools such as motivational interaction and Thinking for a Change. Motivational
interaction is an interview style based on the principle that people have the capacity to change
when there is collaborative effort that respects their autonomy to make self-improving choices.
Thinking for a Change is a behavior change program for offenders, teaching offenders to
restructure their thinking patterns, reasoning, social skills, and problem-solving skills to lead to
positive changes in behavior.
New Offender Supervision Methods
Since our May 2006 performance audit, the board has implemented two new ways of
monitoring offenders: Interactive Offender Tracking and Programmed Supervision.

Interactive Offender Tracking allows low-risk offenders to phone in on a web-based
program each month and answer a series of questions programmed just for that offender. In the
event an offender does not call in, a call can be sent to the offender with modified questions
and/or instructing the offender to report to the probation and parole office.
After the board implemented Global Positioning System (GPS) Monitoring, they created
a Programmed Supervision Unit comprised of officers specifically trained in best practices for
supervising violent and sex offenders. Offenders convicted of rape of a child, other serious
violent felonies, and/or sex offenders at high risk of reoffending are monitored using GPS
technology. Programmed Supervision Unit offenders are closely supervised with targeted
treatment strategies monitored with frequent contact with offenders, their employers, families,
treatment providers, and law enforcement.
Additional Programs and Services Provided by the Board of Probation and Parole’s Division of
Field Services
Apprehension Unit – The board created an apprehension unit in the Memphis and
Jackson area to work with local law enforcement to locate and apprehend offenders under board
supervision who are absconders or are in warrant status. These officers often find themselves in
high-risk areas and situations so they are armed and receive the Peace Officers Standards and
Training (POST) like other certified law enforcement officers.
Forensic Social Workers – This program is budgeted to have 24 forensic social workers
located within the eight districts at assigned board offices statewide. Forensic social workers can
determine whether offenders’ needs can be met; they make community referrals or can provide
in-house services such as group or individual counseling.
Treatment Services Network – In fiscal year 2010, the board entered into an agreement
with the Department of Mental Health to create a Treatment Services Network to address
offenders’ alcohol and drug-related problems. The LS/CMI currently being used provides an
indication of any alcohol or drug-related concerns. Offenders who score in the medium to high
range on this part of the assessment are referred to the forensic social workers for further
screenings.
Employment – In November 2009, the board began an offender employment
development initiative by placing employment specialists in Memphis, Nashville, Chattanooga,
and Knoxville. Employment specialists provide job readiness classes as well as screening and
referrals for employment.
Gender Specific Programs – In April 2009, the board began a gender-specific project that
applies gender-responsive strategies to the supervision of women.
Work Project Program – Created by the General Assembly in 1984 as a special condition
added to probation certificates, the program requires probationers to complete a certain number
of community service work hours for nonprofit and governmental agencies. Parolees may also
be ordered to perform community service for technical violations in lieu of incarceration.

Institutional Probation and Parole Officers – Institutional probation and parole officers
(IPPOs) work with inmates and officers in all TDOC prisons and metropolitan jails to plan the
offender’s return to the community. IPPOs ensure board members and hearing officers have the
necessary information for parole hearings and provide information about board procedures and
policies to the inmates and to jail and prison staff.
Interstate Compact for Adult Offender Supervision – Tennessee participates in the
interstate compact with 49 other states, the District of Columbia, Puerto Rico, and the U.S.
Virgin Islands. The compact controls the movement of offenders between states and provides
tracking, supervision, and rehabilitation.
Administrative Case Review Committee (ACRC) – Section 41-1-113, Tennessee Code
Annotated, allows the board to impose sanctions for technical violations in order to promote
improved behavior and aid in the rehabilitation of the offender. Offenders on probation or parole
are expected to comply with set supervision standards and behaviors. Offenders face revocation
and re-incarceration when found to be out of compliance. Noncompliance may include
commission of minor criminal acts, or simply failure to meet minimum supervision
requirements. These are technical violations. A committee made up of several officers and/or
managers will meet with a technical violator to impose sanctions in an effort to bring the
offender back into compliance. Sanctions can include increased drug testing, mandatory
participation in a drug or alcohol treatment program, referral to other programs, curfews, etc.
Victim Services
The Office of Victim Services is responsible for responding to requests from victims of
offenders supervised by the Board of Probation and Parole. The office deals with victim
notifications and victim confidentiality issues, coordinates victim attendance at parole hearings,
and in some instances attends hearings with victims.
Internal Audit
The board receives routine internal audits and risk assessments from its internal auditor. The
internal auditor is responsible for the board’s compliance with the Financial Integrity Act and
sends annual reports and internal audits to the Comptroller’s Office and the Department of
Finance and Administration.

REVENUES AND EXPENDITURES
Statement of Revenues and Expenses*
Revenues by Source
For the Fiscal Year Ending June 30, 2011
Board of
Probation and
Community
Source
Parole
Field Services
Corrections
Total
State
$ 2,556,700 $ 69,591,000 $ 13,355,400 $ 85,503,100
Other
614,300
2,000
616,300
Total Revenue $ 2,556,700 $ 70,205,300 $ 13,357,400 $ 86,119,400
% of Total
3.0%
81.5%
15.5%

% of
Total
99.3%
0.7%

Statement of Revenues and Expenses*
Expenditures by Account
For the Fiscal Year Ending June 30, 2011
Board of
Probation and
Community
Source
Parole
Field Services Corrections
Total
Payroll
$ 2,310,500 $ 53,647,300 $
$ 55,957,800
Operational
246,200
16,558,000
13,357,400
30,161,600
Total Expenditures $ 2,556,700 $ 70,205,300 $ 13,357,400 $ 86,119,400
% of Total
3.0%
81.5%
15.5%

% of
Total
65.0%
35.0%

Budget and Anticipated Revenues*
For the Fiscal Year Ending June 30, 2012

Source
State

Board of
Probation and
Parole
$3,114,300

Other
Total Revenue

Field Services
$73,238,800

Community
Corrections
$13,810,500

837,200
$3,114,300

$74,076,000

Total
$90,163,600
837,200

$13,810,500

$91,000,800

*The source of the above data, the State of Tennessee’s The Budget Fiscal Year 2012-2013,
already shows Field Services and Community Corrections as part of the Department of
Correction. However, because Field Services and Community Corrections were part of the Board
of Probation and Parole during fiscal years 2011 and 2012, we have included Field Services and
Community Corrections revenues and expenditures as part of the board’s totals for these years.

FINDINGS AND RECOMMENDATIONS

1. Comparison of offender social security numbers to Department of Health death records
found that 82 offenders were still actively monitored after their death
Finding
During our audit, we compared the list of offenders provided by the Board of Probation
and Parole during January 2012 to the list of death records from the Tennessee Department of
Health through December 2011. When compared to social security number alone, we found 47
parole matches and 233 probation matches. With the knowledge that offenders are not always
honest about their names or social security numbers, we then reviewed the 280 records for
matches based on social security number, first name, last name, and date of birth. We found 107
cases (13 parole and 94 probation) actively monitored where all of these items matched. One
parole record indicated that the offender had faked his own death three times prior to 2008 so
this offender was not considered as part of our population. Simple Google searches and a review
of the social security death master file found additional evidence of death in 10 of the 12
remaining parole cases and 72 of 94 probation cases. These offenders had been deceased from
less than six months to over 19 years. See the table on page 11 for the 82 offenders broken down
by supervision level and type of supervision required.
In two probation files where the offender’s supervision is a residential treatment program,
we found that the offenders received contact codes in TOMIS indicating their probation and
parole officer had verified their placement after their death. In one file, the TOMIS entry was
made 19 days after the offender died and documents contact with the offender’s wife regarding
the offender still being sick and in a nursing home. In the second file, the offender died on
October 22, 2011; however, there are TOMIS entries on October 31, 2011; November 29, 2011;
December 20, 2011; January 15, 2012; and February 23, 2012, documenting the offender was
bedridden at home. In both of these instances, there is risk that the PPO was not actually
verifying the offenders’ placement and simply entering the same information month after month.

Recommendation
While the number of offenders (82) actively monitored after their death is small
compared to the over 60,000 offenders monitored each year, the Board of Probation and Parole
(and now the Department of Correction) should consider regularly comparing offender
information to either state or U.S. Social Security Administration death records.

Deceased Offenders Supervised

Supervision Level
Absconder
In Custody
Intake Parole
Interstate Custody
Agreement

Probation
Deceased Parole Deceased Auditors Found
Auditors Found
Additional
Additional
Evidence of
Evidence of
Supervision Required Offenders' Death Offenders' Death
Monthly Arrest Check
8
1
0
0
Monthly Monitoring
1
0

Annual Update
Quarterly Arrest
Judicial Suspension
Check, Monthly fee
of Supervision
monitoring
Medium Supervision Monthly Monitoring
Minimum Supervision Monthly Monitoring
Not in Arrest
Annual Arrest Check
Residential Treatment Monthly Placement
Placement
Verification
Warrant
Monthly Arrest Check
Total

5
1
3
50

0
0
0
7

2
1
72

0
2
10

Management’s Comment
Department of Correction Comment
We concur. A more thorough review of death records including state and national will be
added to the annual review of offender files. We are retraining staff on how to search for
deceased offenders and it will become part of the annual standards for Absconders and Not In
Arrest cases. All staff will be fully trained by December 21, 2012.

2. As noted in the May 2006 audit, the board’s probation and parole officers are still not
completing all supervision requirements, resulting in increased risk that the board will
not achieve its mission of minimizing public risk and maximizing lawful behavior
Finding
During the May 2006 audit we found probation and parole officers (PPOs) were not
completing all of the offender supervision requirements. We recommended the Board of
Probation and Parole work with the PPOs to develop corrective actions to ensure that officers
meet appropriate supervision standards. We also recommended that the board review and
approve the developed corrective actions and establish a timetable for completion, specify
11

responsibility for ensuring implementation, and monitor staff’s continuing compliance with the
supervision standards. The board concurred and provided detailed, step-by-step corrective action
plans for each supervision standard for which we found problems.
During our current audit, we found only 8 of 70 GPS-monitored offenders’ files and 69 of
120 regularly monitored offenders’ files that were in compliance with all board supervision
requirements. Failure to adequately supervise offenders results in increased risk that the board
will not achieve its mission of minimizing public risk and maximizing lawful behavior by the
prudent, orderly release and community supervision of adult offenders.
The Board of Probation and Parole’s Field Services Division establishes the standards for
offender supervision. The current Standards of Offender Supervision require PPOs to complete
the following activities at regular intervals:


face-to-face contacts (i.e., scheduled appointments where the offenders meet with
PPOs at board offices);



home visits;



drug tests;



arrest/continued incarceration/placements checks;



monitoring special conditions established by the board or courts;



employment verification;



monitoring of fee payments; and



risk assessments.

The frequency of these activities depends on an offender’s supervision level and is summarized
in the table on page 14.
In addition to the requirements shown in the table on page 14, risk assessments “must be
documented after the initial intake period and a minimum of every 2 years thereafter” for
offenders being supervised at the following supervision levels:


Enhanced;



Maximum;



Medium;



Minimum;



Judicial Suspension of Supervision; and



Sex Offenders, Violent Sex Offenders, and Other Violent Offenders Monitored with
Global Position System Technology

All sex offenders must receive a Vermont Assessment of Sex Offender Risk (VASOR) annually.
For the purposes of our review, we identified three types of supervision: Regular,
Interactive Offender Tracking (IOT), and Global Positioning System (GPS). All of the
supervision requirements of the regular offenders are listed in the table on page 14. For the sex
offenders, violent sex offenders, and other violent offenders monitored with GPS, PPOs must
also conduct monthly checks to verify that the offenders are attending sex offender treatment.
The IOT system is used to more efficiently monitor low-risk offenders who do not
require close supervision. The Field Services Division relies on a web-based phone-in program
that allows these offenders to call in each month and answer a series of pre-programmed
questions. PPOs are also required to conduct annual arrest checks for IOT offenders, and all IOT
calls, arrest checks, and any other supervision information must be recorded in the Tennessee
Offender Management Information System (TOMIS).
Sample Selection
During this audit, we reviewed supervision histories in TOMIS and paper files for 230
probationers and parolees (115 each) who were supervised during calendar year 2011. We
considered population size and risk in determining our sample size then selected a random
sample of each supervision type. Since offenders subject to regular supervision make up the
greatest proportion of the supervised population, we chose to review more of these files than the
other two groups. Since GPS-monitored offenders are considered to be at a higher risk of
reoffending than those supervised using IOT and regular supervision, we chose to review a larger
percentage of the total GPS population than the IOT files or regular supervision files.

Sample Size vs. Population Size

Supervision Type
IOT
Regular
GPS
Total

Sample
40
120
70
230

Population
2,821
66,690
662
70,173

% of Total
Population
4%
95%
1%

Note: T his is a judgemental sample, not a statistical sample and results
are not projected to the entire population.

Supervision Requirements

Supervision
Level/Description

Face-to-Face
Contact

Intake
Probation/Parole

2 per month

Enhanced
2 per month
2 per month
Maximum
Medium
1 per month
Minimum
1 per 3 months
Judicial Suspension
of Supervision
None
1 per 3 months
Misdemeanor
None
Absconder
Not in
Arrest/Suspension of
Direct Supervision
None
None
Warrant
None
Detainer
Residential Treatment
Placement
In Custody

None
None

Check of Arrest
Records (or
Special
Continued
Conditions
Incarceration or
Placement)
Monitoring
Home Visits
Drug Tests
Regular Offenders
1 per 3 months
1 per month
or as needed
1 per month
2 per month
1 per 3 months
2 per month
or as needed
1 per month
2 per month
1 per 2 months 1 per 6 months
1 per month
2 per month
1 per year
Random
1 per 2 months 1 per 2 months
1 per year
Random
1 per 3 months 1 per 3 months

Employment
Monitoring Fee Monitoring

1 per month

1 per month
1 per month
1 per month
1 per 3 months

None
None
None

1 per 3 months
1 per 6 months
1 per month

1 per 3 months
None
None

None
None
None

1 per month
1 per 3 months
None

None
None
None

1 per year
1 per month
1 per 3 months

None
None
None

None
None

1 per month
1 per month

None
None

Sex Offenders, Violent Sex Offenders, and Other Violent Offenders Monitored with Global Positioning System Technology
Maximum
Medium

2 per month
1 per month

1 per month 1 per 6 months
1 per 2 months 1 per 6 months

1 per month
1 per month

Methodology
According to board policy, TOMIS is considered to be the primary repository for
information about offenders and about interactions with them. If a supervision requirement
cannot be met because of noncompliance on the offender’s part, the PPO must document this in
TOMIS, explaining in the comments why the requirement was not met and what is being done to
enforce compliance.
For our purposes, we reviewed both the TOMIS record and the paper files, if available,
to determine if supervision requirements were met. We reviewed the offender’s information for
compliance over the 12-month period, January to December 2011. This means if the offender
was required to receive two face-to-face visits per month for the entire 12-month period, we
looked for 24 documented visits in TOMIS or 24 documented visits in the paper file. If the
offender had 24 visits in either TOMIS or the paper file, we considered this compliant. We did
not add the visits in TOMIS to the visits in the paper file because we knew that dates in TOMIS
and on the paper files may differ because of lag time in entering information into TOMIS.
For general risk assessments (Level of Service Case Management Inventory or LS/CMI),
we reviewed information back to calendar year 2010 to determine if the assessment was
completed within the initial 60-day intake period or at least every two years. For example, if an
offender did not have a risk assessment in 2011 but did in 2010, this was considered compliant
for our purposes. If an offender did not have an assessment in 2010 or 2011, this was considered
noncompliant for our purposes.
For sex offender risk assessments (Vermont Assessment of Sex Offender Risk, or
VASOR), we reviewed information back to calendar year 2010 to determine if there was an
annual review for 2010 and 2011. If the offender was supervised for one year or less, we could
not determine if the offender received an annual risk assessment.
Review Results
Our review found PPOs met all applicable supervision standards for only 8 of the 70 GPS
monitored offenders (11.4%) and 69 of the 120 regular supervision offenders (57.5%). The
average percentage of applicable supervision requirements met for each GPS offender was 72%
and for each regular supervision offender, 87%. Depending on when the offender began
supervision, and the requirements for the level of supervision, we tested seven to ten supervision
requirements for GPS offenders and one to eight supervision requirements for regular offenders.
The results are shown in the tables below.

Results of Supervision Requirements Reviewed
GPS Monitored Offenders
Missing 4 Total by # of
# of
Requirements Missing 0 Missing 1 Missing 2 Missing 3 or more Requirements
7
0
2
1
0
0
3
8
6
4
3
3
5
21
9
2
11
3
4
5
25
10
0
1
7
5
8
21
8
18
14
12
18
70
Total
% of total
11.4%
25.7%
20.0%
17.1%
25.7%

Results of Supervision Requirements Reviewed
Regular Supervision Offenders
# of
Missing 4 Total by # of
Requirements Missing 0 Missing 1 Missing 2 Missing 3 or more Requirements
1-4
24
6
0
0
0
30
5
4
6
1
0
0
11
6
32
12
3
1
1
49
7
9
9
5
2
2
27
8
0
2
0
1
0
3
69
35
9
4
3
120
Total
% of total
57.5%
29.2%
7.5%
3.3%
2.5%

In our IOT testwork, we did not note any problems regarding the scheduled monthly calls
or PPOs’ follow-up actions in the event that an offender did not make the required call.
Appendix 3 details the results of our review by Grand Division. The information below
discusses the results of our review by supervision standard.
Address and Date of Birth
We found 15 instances each in the regular and GPS offender groups (30 total) and 7
instances in the IOT offender group where the address in TOMIS did not match the address
shown in the offender’s file. Without the correct address, the board cannot ensure that offenders
will receive necessary correspondence and that PPOs will be able to complete required home
visits. We also found one instance in each offender group (3 total) where the offender’s date of
birth in TOMIS did not match the date of birth recorded in the file.
Face-to-Face Contacts
For 9 regular offenders and 16 GPS offenders in our sample, PPOs failed to complete or
document their attempt to complete all of the required face-to-face contacts during 2011. Board

standards require that PPOs and offenders have up to two face-to-face contacts per month,
depending on the offenders’ level of supervision. Since TOMIS allows for contact codes to be
entered when a supervision requirement cannot be met, we considered these instances compliant;
however, in the cases noted above, there was no record in TOMIS or the offender’s file that faceto-face visits were attempted or the offender failed to arrive for a scheduled appointment.
Twenty-seven of the regular supervision files did not require face-to-face contacts because of the
offender’s supervision status.
Face-to-Face Contacts
Supervision
Regular Compliance
Requirements Met
Supervision
Rate
Yes
84
90.3%
No
9
9.7%
27
N/A
120
100.0%
Total Files Reviewed

GPS
Compliance
Supervision
Rate
54
77.1%
16
22.9%
0
70
100.0%

Based on our review of the Monthly Reporting Form in offenders’ case files, PPOs
typically use face-to-face appointments as an opportunity to conduct drug tests; perform arrest
record checks; and verify that offenders are employed, are current on their fees, and are
otherwise meeting their special conditions. Therefore, the failure to meet this supervision
requirement often resulted in one or more other requirements not being met.
Home Visits
PPOs did not perform all required home visits for 10 of the regular offenders and 27 of
the GPS offenders in our sample. Board standards require PPOs to conduct home visits up to
twice a month depending on the offenders’ level of supervision. While home visits are not
routinely documented in offenders’ case files (i.e., paper files), the PPOs have multiple ways of
documenting home visits or their inability to complete a home visit in TOMIS. For example, if
PPOs are unable to complete a home visit because no one is home, they should enter an
“XHOM” code in TOMIS and explain this. If the offender is not home but another member of
the household or a neighbor verifies the offender’s residence, a code of “HOMC” should be
used. In the 37 cases noted above, there were not enough of any of these codes entered in
TOMIS for us to conclude that the home visits were completed or even attempted. Thirty-three
regular supervision files did not require home visits because of the offender’s supervision status.

Home Visits
Supervision
Regular Compliance
Requirements Met
Supervision
Rate
Yes
77
88.5%
No
10
11.5%
33
N/A
120
100.0%
Total Files Reviewed

GPS
Compliance
Supervision
Rate
43
61.4%
27
38.6%
0
70
100.0%

We noted weaknesses in allowing multiple “XHOM” codes in a row. For one sex
offender under maximum (not GPS) supervision, handwritten notes in the case file state “no one
has seen offender at home.” Of the 8 required home visits, 6 were XHOM, 2 were HOMC “left
callback.” While the codes in TOMIS record that the PPO adequately supervised the offender by
making attempts at home visits, there may still be problems with the offender’s compliance and
meeting supervision requirements.
PPOs conduct home visits to verify the offenders’ address, determine if the offenders are
in compliance with special conditions such as curfews, and to determine/verify that GPS
equipment is working properly. Without these verifications, the board risks losing track of some
offenders, and for sex offenders, the verifications can serve to identify that there is a school or
other public place where children play close to the offender’s home.
Drug Tests
Board standards require PPOs to conduct drug testing at several different intervals
including once per six months, once per three months, once per three months as needed, or at
random, depending on the offender’s supervision level. PPOs failed to administer or did not
document administering drug tests for 19 regular offenders and 21 GPS offenders in our sample.
Twenty-four GPS offenders were not under supervision for enough time in calendar year 2011 to
require a drug test and therefore were considered not applicable. Seventy-nine regular offenders
were either not under supervision for enough time in calendar year 2011 or were only required to
have drug testing on an as-needed or random basis, and these were also counted as not
applicable.
Drug Tests
Regular Compliance
Requirements Met
Supervision
Rate
Yes
22
53.7%
No
19
46.3%
79
N/A
120
100.0%
Total Files Reviewed

GPS
Compliance
Supervision
Rate
25
54.3%
21
45.7%
24
70
100.0%

Based on our review of offenders’ files, as well as discussion with district managers,
there is no standard or requirement for documenting negative drug tests in case files but a code is
18

required to be entered in TOMIS. While some PPOs include all drug test forms in the case files,
most documented only positive drug screens. Based on our review of case files, however, we
found that the files for 9 regular offenders and 8 GPS offenders contained records of drug
screens that were not documented in TOMIS. This indicates that, contrary to board policy, the
computerized system is not consistently being used as the primary repository for offender
information.
Arrest/Incarceration/Placement Checks
PPOs or other board staff did not conduct required checks for arrests or continued
incarceration, or placement verifications for one IOT offender, 10 regular offenders, and 11 GPS
offenders in our sample.
Arrest/Incarceration/Placements Checks
Regular Compliance
Requirements Met
Supervision
Rate
Yes
110
91.7%
No
10
8.3%
0
N/A
120
100.0%
Total Files Reviewed

GPS
Compliance
Supervision
Rate
59
84.3%
11
15.7%
0
70
100.0%

Arrest record checks are conducted to determine whether the offenders have had an
incident that would be a violation of their probation or parole. An offender may not willingly
report incidents to the PPO, and if the offender is an absconder, this information can be helpful
in locating the offender. During our review, we also noted weaknesses in arrest checks in that it
cannot always be determined from TOMIS where the arrest check, etc. was completed. For
instance, in Davidson County, the PPO may fail to record whether they only checked with the
Metropolitan Police Department or if they also checked with the Davidson County Sheriff’s
Office.
Special Conditions and Employment
PPOs failed to complete or document their attempt to complete monitoring of special
conditions in 15 of the regular offender and 23 of the GPS files we reviewed. Further, PPOs
failed to complete or document employment verifications in 11 regular offender files and 15 GPS
offender files. The offender’s supervision status did not require monitoring of special conditions
or employment in 37 and 33 regular supervision files respectively.

Special Conditions Monitoring
Supervision
Regular Compliance
Rate
Requirements Met Supervision
Yes
68
81.9%
No
15
18.1%
N/A
37
Total Files Reviewed
120
100.0%

GPS
Compliance
Supervision
Rate
47
67.1%
23
32.9%
0
70
100.0%

Employment Monitoring
Supervision
Regular Compliance
Requirements Met Supervision
Rate
Yes
76
87.4%
No
11
12.6%
N/A
33
Total Files Reviewed
120
100.0%

GPS
Compliance
Supervision
Rate
55
78.6%
15
21.4%
0
70
100.0%

Board supervision standards require the PPOs to verify that special conditions (substance
abuse treatment, payment of court costs, etc.) are being followed and that the offender is
employed. For most supervision classifications, the special conditions monitoring frequency
ranges from two per month to one every three months. For employment verifications, the
frequency ranges from one per month to one every three months. Special conditions can be
monitored via contact with the treatment provider or court clerk (for payment of court costs) and
employment verifications can be completed by obtaining the offender’s pay stub.
Fee Payment
PPOs failed to adequately document offender fee payments for 7 regular offenders and 7
GPS offenders in our sample. Board supervision standards require the PPOs to monitor the
offender’s fee payments from once per month to once every 3 months depending on the
offender’s level of supervision. See page 61 for additional information regarding the fee system.
Twenty-six regular supervision files did not require monitoring of fee payments because of the
offender’s supervision status.

Fee Monitoring
Regular Compliance
Supervision
Rate
Requirements Met
Yes
87
92.6%
No
7
7.4%
N/A
26
120
100.0%
Total Files Reviewed

GPS
Compliance
Supervision
Rate
63
90.0%
7
10.0%
0
70
100.0%

Sex Offender Treatment Monitoring
The programmed supervision manual requires sex offender treatment monitoring to be
completed monthly for all sex offenders. Our sample of regular offenders included only 8 sex
offenders who required sex offender treatment monitoring. PPOs at least attempted to make all
of the required monthly checks to ensure that these offenders were receiving treatment; however,
one offender was monitored using GPS until February 2011 and was taken off based on a
psychological assessment. It was noted in the offender’s information that he “should be given
some careful supervision, especially while he is early in his sex offender supervision.” While the
case technically meets supervision requirements, the PPO was unable to successfully complete
home visits and sex offender treatment verifications for 3 of the 11 applicable months in 2011.
Based on a review of information in TOMIS, no action had been taken to revoke the offender’s
parole or change his supervision level as of May 31, 2012.
Our sample of offenders monitored by GPS equipment showed that 26 offenders had not
been properly monitored for sex offender treatment which is also a monthly requirement for all
of these offenders. One offender in our sample was being monitored using GPS due to the
violent nature of his crimes, not because of a sex-related crime.
Sex Offender Treatment Monitoring
Supervision
Regular Compliance
Requirements Met
Supervision
Rate
Yes
8
100.0%
No
0
0.0%
112
N/A
120
100.0%
Total Files Reviewed

GPS
Compliance
Supervision
Rate
43
62.3%
26
37.7%
1
70
100.0%

Risk Assessments
Section 41-1-412, Tennessee Code Annotated, requires the development (using a
validated instrument to evaluate risks and needs) of an individual treatment/supervision plan for
each offender. The board chose the Level of Service Case Management Inventory (LS/CMI) for
all offenders and the Vermont Assessment of Sex Offender Risk (VASOR) for sex offenders.

All offenders should receive a Level of Service Case Management Inventory (LS/CMI)
needs assessment to target supervision, services, and treatment to the offenders’ needs that have
a direct correlation with criminal behavior. This tool uses multiple levels of risk to identify
offenders at higher risk of recidivism and offers guidance on treatment and services to reduce
that risk. After the initial 60-day intake period, LS/CMI assessments must be completed at least
every two years.
We reviewed risk assessments dating back to calendar year 2010 to determine whether
the biannual requirement had been met. We found 5 offenders in our regular supervision sample
and 12 in the GPS sample who did not have the required biannual LS/CMI assessments. For an
additional 7 regular supervision offenders, there were risk assessments but they were not
completed within the initial 60-days, totaling 12 that were not in compliance. For 5 GPS
offenders, there were risk assessments, but they were not completed within the initial 60 days of
supervision, totaling 17 that were not in compliance. Twenty-eight regular supervision files did
not require LS/CMI risk assessments because of the offenders’ supervision status. Three GPS
supervision files did not require LS/CMI risk assessments because they were supervised for less
than 60 days.
LS/CMI Risk Assessments

Requirements Met
Yes
No
N/A
Total Files Reviewed

Regular Compliance
Supervision
Rate
80
87.0%
12
13.0%
28
120
100.0%

GPS
Compliance
Supervision
Rate
50
74.6%
17
25.4%
3
70
100.0%

With a few clearly defined exceptions, all sex offenders should receive the Vermont
Assessment of Sex Offender Risk (VASOR). VASOR is an actuarially based and validated risk
assessment scale for adult male sex offenders ages 18 and over. Because of the current lack of
an acceptable alternative, the creator of the assessment states that, although not validated on
females, the VASOR can be used with caution on female sex offenders. According to the
board’s Case Management Protocol Manual, these assessments must also be completed within
60 days of intake by the board and at least once a year thereafter.
We reviewed TOMIS records and case files back to calendar year 2010 to determine if
the assessments were being completed annually. We found 3 regular offender files and 19 GPS
offender files that did not have the VASOR completed annually. In 5 regular offender files and
10 GPS offender files, we were not able to determine whether the VASOR was completed
annually or not. In these files, there was not an annual VASOR in the offender’s hard copy file
and TOMIS codes did not have indications in its case notes of which risk assessment was
completed. For 112 regular supervision files, the offender was not a sex offender and therefore
was not required to have a VASOR. For 35 GPS supervision files, the offender had been
supervised for one year or less and therefore we could not determine if they received an annual
assessment.

Vermont Assessment of Sex Offender Risk

Requirements Met
Yes
No
Unable to Determine
N/A
Total Files Reviewed

Regular Compliance
Supervision
Rate
3
5
112
120

100.0%

GPS
Compliance
Supervision
Rate
6
24.0%
19
76.0%
10
35
70
100.0%

Deficiencies in offender supervision can be attributed to high caseloads, multiple
mandated activities a PPO must complete on each offender, lack of time management training,
and a lack of supervisory reviews to catch problems in a timely manner. For PPOs supervising
offenders on GPS, there is the additional task of reviewing and clearing alarms generated by the
GPS system when offenders enter prohibited areas (exclusion zones), when they tamper with
their GPS ankle bracelets, etc.
According to the Director of Field Services, on average, regular PPOs supervise 113
offenders and GPS officers have an average caseload of 40 offenders. The board’s goals for
regular and GPS officers are 70 and 25 offenders, respectively. In spite of their large caseloads,
officers rarely receive time management training to enhance their skills for managing a list of
over 50 tasks to be completed on each offender (see page 53 regarding training). We also noted
in this audit that supervisory reviews were conducted for less than half of the cases in our sample
during calendar year 2011. (See finding 7 regarding supervisory reviews.) We also observed
inefficiencies in the number of alarms the GPS system generates. (See observation and comment
on page 54.)
Failure to adequately supervise offenders results in increased risk that the board will not
achieve its mission of minimizing public risk and maximizing lawful behavior through the
prudent, orderly release and community supervision of adult offenders. Without correct
addresses and date of birth records in TOMIS, the board may not be adequately communicating
with and monitoring offenders. Also, PPOs’ failure to use TOMIS as the main repository of
information as required by the board creates the problem of the board lacking complete records
of offender supervision. Furthermore, the failure to adequately monitor sex offenders and other
violent offenders monitored via GPS and known to have a high risk of reoffending jeopardizes
public safety.

Recommendation
The Board of Probation and Parole and the Department of Correction should work with
the Field Services Division and others within the agencies to develop a formal corrective action
plan which ensures the information in TOMIS is complete and accurate. Specifically, the plan
should focus on ensuring the following:
23



all drug screens and other offender interventions are properly documented in TOMIS;



required arrest checks or verifications of continued incarceration/placement are
completed for offenders, including those not actively supervised by Field Services
staff;



notes indicating that offenders’ special conditions have been terminated are entered
only once during a supervision period, include the necessary details, and are not
followed by other special conditions notes;



all X-type case notes specify the reason that the supervision requirement was not met
as well as the planned corrective action, and are carefully reviewed to determine the
effectiveness of the corrective action and whether further action is required;



risk assessments, including VASOR risk assessments for sex offenders, are completed
in a timely manner on all cases;



address and date of birth information is accurately maintained in TOMIS; and



all offender supervision requirements are otherwise being met.

The board and the Department of Correction should also ensure that TOMIS includes the
appropriate edit checks and data validation tools.

Management’s Comment
Department of Correction Comment
We concur and will ensure the following:








All drug screens and offender interventions will be documented in TOMIS.
Required arrest checks or verifications of incarceration/placement are completed
for offenders including inactive cases.
Notes indicating offender termination of special conditions are entered only once
and contain necessary details and are not followed by other special condition
notes.
All X-type case notes specify the reason the requirement was not met as well as
planned corrective action and are carefully reviewed to determine the
effectiveness of the corrective action and whether further action is needed.
Risk assessments, including VASOR risk assessments for sex offenders are
completed in a timely manner on all cases.
Address and Date of Birth information is accurately maintained in TOMIS and
All offender supervision requirements are met.

We make the following observations to clarify our current actions and future activities:
Address and Date of Birth
Some or all of the cases found to have a different date of birth in TOMIS and the file might
have the correct date of birth entered into the ALIAS conversation. Protocol for TOMIS
entries from its inception in 1992 has been to use the identifiers attached to the offender at
the time of sentencing and to record new identifiers as aliases. Because offenders often use
many deceptive practices to hide their identities all identifiers ever used by an offender must
be maintained. Should subsequent identifiers be revealed they will be recorded in TOMIS.
Checking the address in TOMIS with the case file was added to the manager’s annual file
review checklist and will be reiterated in training with managers and officers.
Face-to-Face Contacts
This standard is part of the annual case file review process and is used to assess the Probation
and Parole Officer’s job performance. One issue to consider is that once a standard is missed
it can never be met but it can be mitigated by officer action in the future. This will continue
to be a point of emphasis on case file reviews. It must also be pointed out that during the
year reviewed a significant number of officers had personnel action taken, including
termination, when they were found to have violated the standards in a significant manner.
Also, as noted in the audit, the workload on individual officers is enormous and continues to
grow. Our Top-to-Bottom review is intended to identify potential time savings and position
reallocation to address these caseloads. That process has begun and will be completed by
December 31, 2013.
Home Visits
Like Face-to face contacts, home visits are a significant part of the annual case file review
and will continue to be a point of emphasis. Managers have the responsibility to monitor
missed home visits and are being held accountable. Changes in management of PSU units
have been undertaken where these standards were not met. By December 31, 2012 there will
be a directive in place to re-emphasize that Home Visits are priority number one in routine
offender supervision.
Drug Tests
Drug testing is done according to the supervision level of the offender and by means of a
random drug testing list issued quarterly. Records of drug tests are recorded in TOMIS in
two ways. One is via a contact note and one is via a conversation that lists the drugs for
which the offender is tested and the results. That conversation is inelastic and must be
improved to identify all of the current drugs for which we test. This process will be initiated
immediately and will be completed by June 30, 2013 to accommodate ongoing technology
changes that are already in process.
Arrests/Incarceration/Placement Checks
Beginning in November 2011 we instituted a program in conjunction with the Administrative
Office of the Courts that automatically notifies the Officer, their Manager and a Director via
email any time an offender is arrested in Tennessee, if the arresting agency uses the proper

State Identification (SID) number that matches the number in TOMIS. It also will post a
contact note to TOMIS. In the sample reviewed the arrest checks would have been in the
county of residence only as that was the policy and restating that seems redundant, however,
the new system records the arresting authority as well as the charge in TOMIS. Incarceration
and other placements still must be addressed individually and is part of the case file
review. We will begin retraining managers on this immediately with a completion date of
June 30, 2013.
Fee Payments
BOPP and now TDOC use an accounting program called Great Plains to handle Fee
Transactions. Great Plains has been a difficult program to use and resulted in BOPP paying
for training for two staff members to learn to write the code necessary to make needed
charges. That is now in place. Great Plains is in need of replacing as it will not be supported
technology within 18 months. Meetings are already under way to find the proper
replacement. We expect this process to be completed and a changeover accomplished by
December 31, 2013. One significant issue with fees has been the waiver process which
depends on cooperation for offenders, officers, managers and central office staff. To
streamline and improve this process we undertook a LEAN Event beginning in August 2011.
It included staff from a probation parole office and made suggestions for improvement.
Those suggestions included establishing one fee specialist in the office at Blanton Avenue
and were piloted for four months beginning in April 2012. The results are promising and the
amount of waivers has fallen, the amount of money has increased and it has freed officers
and managers to do other supervision tasks. It will be continued in Blanton Avenue and we
will begin to roll out the process in other major offices by January 1, 2013. Another LEAN
Event to work on the process for smaller offices is in the planning stages and should take
place by December 31, 2012.
Sex Offender Treatment Monitoring
Managers have responsibility to ensure this standard is being met. There has been renewed
emphasis on training, as outlined later in this report, and treatment attendance will be
enforced without fail. As a follow-up to this report we will investigate the one case
mentioned in the audit report to see what the issue is and get it corrected. We will ensure
every sex offender ordered to attend treatment is in fact in treatment as required by October
31, 2012 or sooner. All those not in compliance will be reported to the releasing authority.
Risk Assessments
The VASOR is the assessment utilized for evaluating a sex offender’s risk to reoffend
sexually and is required to be performed within the first 60 days of opening a case, and
annually thereafter. There are categories of sex offenders who are not required to have a
VASOR completed, which are noted on the BP0239 PSU Override/VASOR Exemption
form. For example, the VASOR cannot be used if the offender’s sexual offense occurred
prior to the last ten years the offender has been in the community. It cannot be discerned
from the audit results if this was taken under consideration.
The VASOR form was designed with a “Submit” button which would email the assessment
to central office staff, where it was maintained in a spreadsheet. This spreadsheet could

periodically be sent out for managers’ review. The state’s transition from GROUPWISE to
OUTLOOK removed this capability. In order to forward the information, the officer has to
print and scan the assessment to email it. This may have impacted the number of
assessments submitted. The Administrative Services Assistant position which was tasked
with maintaining this data and had been reviewing the scanned assessments and entering the
information manually, was abolished due to budget cuts. In an effort to better monitor its
completion, the VASOR was added to the PSU Manager’s initial Case File Review Checklist
and annual Case File Review Checklist. Since sex offenders have two different assessment
tools, a separate contact note code and supervision standard requirement for the VASOR
completion will be established as an additional tool to monitor and improve compliance.
LS/CMI (assessments) not completed according to policy
There is a segment of our population for which an LS/CMI was never mandated and those
would be Cases in Custody, Absconders, Not In Arrest, and those already Minimum
Supervision. For the rest an LS/CMI is required and we will begin an LS/CMI audit
immediately and have it completed by October 31, 2012 to ensure that by December 31,
2012 all offenders required to have an LS/CMI have one completed. This is and will
continue to be part of the case file audits.
Supervision Standards for Sex Offenders
In the methodology utilized, the auditor’s determination of compliance used is absolute,
which is their mandate. The missing, through omission or being conducted outside a
specified time frame, of one single standard, over the course of a 12-month period, of
approximately 101+ standard total occurrences for an individual GPS case, has been
considered non-compliant, despite the possibility of a case being in substantial compliance.
The number of missed standards in comparison with the total number of standard
occurrences might be a more valuable tool, i.e., 8 cases were 100% compliant, 22 cases were
95-99% compliant, etc. Although the department continues to strive for 100%, individual
officers’ monthly compliance scores are considered acceptable if 95% or better.
Special Conditions
The definition of the contact code documenting special conditions are terminated (SPET) will
be expanded to include information on how the condition was satisfied and noting that
subsequent special condition notes are not needed by December 31, 2012.
Managing Xcodes
Xcode monitoring will be revised to ensure that managers, upon seeing an Xcode on a
standard review prior months to ensure they are not sequential and being used to avoid the
standard. This will be done as part of the training to be completed by June 30, 2013.
GPS Alerts
The department believes that some confusion remains on what an event is versus what an
alarm or/and an alert is. What is characterized in the report as alarms and alerts are actually
events, and as noted, 27,129 of the total 38,476 events were simply noting that the offender
had plugged in their unit to charge. The current vendor’s system has an additional step
beyond the original vendor’s system, which provides a place to check that the event is

confirmed or acknowledged, as well as the event’s start and stop times. If an event has a stop
time, it has been cleared. Open critical events reports can be requested by any GPS user to
determine if any alerts remain unresolved/in progress (not cleared yet) longer than a specified
period of time.
In training, the focus has been on clearing the alerts within the protocol. Confirming was not
stressed early in the transfer to the new vendor for the very reasons noted in the audit report.
Department procedures have not required confirmation of non-alert events. Managers were
trained in November 2011 on how to pull reports to review from VeriTracks. A follow-up
webinar was presented on 3-14-12 and is stored on the website where it can be reviewed at
any time. It has been stressed with managers, in training and manager conference calls, that
officers should be following through on the final step of confirming after clearing an event.
This will continue to be monitored more closely to assure that confirmations are entered.
The suggestion of programming to eliminate the need to confirm charging events or
otherwise streamline the process is duly noted and will be pursued with the vendor by
November 1, 2012.
GPS Protocol Manual
A temporary protocol manual was issued in June 2011, but was revised twice as we became
more familiar with the new vendor system. The current protocol manual was approved by
the Director of Field Services in August 2011, and disseminated to all PSU staff as a
directive and posted on the N drive, where it was available to all staff, pending formal
finalization by the legal division and official posting on the intranet page. Training has taken
place, including all sessions of in-service training at the academy.
Significant events that impacted Program Supervision Unit
1. The Programmed Supervision Unit target caseload size is 25 offenders to each officer.
This is based upon the American Probation Parole Association’s suggested caseload size for
a specialized supervision unit. Case sizes are averaging approximately 40. The merger of
the Enhanced Supervision Unit with the Programmed Supervision Unit was put into place
July 2011 in effort to bring more officers into the unit, equalize caseloads and mitigate the
impact of having an unmanageable number of GPS offenders on individual caseloads.
2. The department’s in house GPS Operation (GO) Center, which managed all initial alerts
and was manned 24 hours a day was closed due to budget cuts in the spring of 2011. The
department currently contracts for monitoring services through the vendor. This has resulted
in an increase of the number of alerts that are forwarded to the officer and more difficulty in
communications. The GO Center monitors knew the officers, were familiar with the
offenders and districts. This ensured the correct staff was contacted to address alarms. The
GO center staff provided a sense of security for officers when they had to go out on an alarm
and could provide remote assistance while they were in the field. Because it was comprised
of trained officers, the GO center was empowered to make informed decisions. Restoration
of the GO Center is a priority as part of our Top-to-Bottom Review process which is ongoing
at present.
3. The GPS alert response protocols were modified to escalate all alerts to the next level if
the officer does not answer the phone immediately. Since this means sometimes an officer
who couldn’t pick up the phone prior to it going to voicemail may be calling the center back

at the same time another officer has already been called, it frequently results in multiple
officers and monitors working the same incident.
4. The categories of offenders designated as mandatory for GPS monitoring has been
expanded from Rape of a Child and high/very high VASOR scoring offenders, resulting in
the number of offenders on active monitoring rising from approximately 350 in early 2011 to
over 800 at this time, at the same time the GO center was closed and the protocols increased.
5. Community Supervision for Life offenders continue to be released and added to
caseloads. These are cases that effectively never expire, require more court time for
prosecution of violations and are the highest risk offender we supervise.
Steps taken to Improve PSU
1. Merger of PSU and Enhanced Unit July 2011.
2. PSU-specialized 16-hour training session at the academy for managers November 2011.
3. 3 PSU-specialized 16-hour training sessions at the academy for officers were presented
on various dates in early 2012.
4. Technical assistance grant request were submitted to CASOM. In 2012, a grant was
received for technical assistance with a consultant, to review procedures, make
recommendations for adjustments to the program, and present two days of training. The
department has contracted to add an additional third day of training. The training will build
upon FY 12 in-service training, with an added training session on Compassion Fatigue.
Planned steps for further improvement
1. Field Services received a $113,000 Adam Walsh grant in August 2012 which will go
toward equipment upgrades and improvements, specialized training on development and
creation of web-based training modules. This will contribute to increased efficiency.
2. The TOP to BOTTOM review is taking place, and coupled with the recommendations
from the CASOM consultant, will be used to review the current procedures for potential
areas of improvement, focusing on evidence-based practices.
3. Time management training will be requested for both Pre-service and In-service.
4. In-service PSU specialized training will be continued.
5. Returning to in-house GPS monitoring will be evaluated.
6. Capability to electronically submit VASOR completion via OUTLOOK is requested,
however, it will have to be added to the technology list and may take until December 31,
2013 to accomplish.
7. Upgrading of Field Service Staff laptops.
8. Examine PSU officer turnover rates and pursue measures to improve officer retention is
on-going and targeted for the end of FY 2013 based on budget.
9. Review PSU offender population and explore potential options for reducing caseload
sizes is on-going with recommendations to be made by 11/30/12 with improvements by
January 1, 2013.

3. The board’s disaster recovery plan lacks the elements necessary to ensure resumption
of functioning and performing essential duties in the event of an emergency
Finding
Section 58-2-108, Tennessee Code Annotated, states that, at the direction of the
Governor, each agency should have an emergency services coordinator who is responsible for
preparing a disaster preparedness plan. This plan should be reviewed by the applicable local
emergency management agency and approved by the Tennessee Emergency Management
Agency (TEMA). Governor Bredesen’s Executive Order 23 established the National Incident
Management System (NIMS) as the state standard for incident management. NIMS is a
comprehensive, systematic approach to incident management which includes a core set of
concepts, principals, terminology, and organizational processes for all hazards. The first NIMS
concept is preparedness, which requires the validation and maintenance of plans, policies, and
procedures that define priorities and coordinate, manage, and support information and resources.
This can also be referred to as a Continuity of Operations Plan (COOP). The COOP serves as a
disaster recovery plan, ensuring that the agency can resume functioning and perform essential
duties in the event of a disruption of normal operations. The COOP template created by NIMS’
parent agency, the Federal Emergency Management Agency (FEMA), recommends that plans
should, at a minimum, include the following elements:


Readiness and Preparedness (how to identify and respond to a “continuity event”);



Activation and Relocation (how to establish basic operational capabilities at a new
location);



Continuity Operations (how personnel should operate at the new location); and



Reconstitution Operations (how to return to normal operations).

This document should also prioritize essential functions and define the personnel who are
responsible for implementing each part of the disaster recovery plan.
The wording of this finding does not identify specific vulnerabilities that could allow
someone to exploit certain weaknesses. Disclosing these vulnerabilities could present a potential
security risk by providing readers with information that might be confidential pursuant to Section
10-7-504(i), Tennessee Code Annotated. We provided the Board of Probation and Parole with
detailed information regarding specific vulnerabilities as well as our recommendations for
improvement.

Recommendation
The Board of Probation and Parole should thoroughly document specific disaster
recovery procedures and actions to be taken, from the declaration of a disaster until the time that
normal business operations are resumed. The plan should contain adequate detailed information
to permit staff to use it as a stand-alone field manual. The plan should be reviewed, updated,

tested, and reapproved as processes change and, at a minimum, on an annual basis. The plan
should be submitted to TEMA and made readily available to board employees.

Management’s Comments
Board of Parole Comment
We concur. The Board currently has a limited plan which includes a staff notification list
for communication and IS allocation of resources. The Board, prior to July 1, 2012, also had
access to operational space at the closest BOPP office. In May 2012, with this limited plan and
the assistance of TDOC, the Board was able to reestablish operations of all critical functions
within the first 24 hours of Parkway Towers being uninhabitable.
Board of Parole Corrective Action Plan
The Board will build on the limited disaster recovery plan currently in place to
thoroughly document specific disaster recovery procedures and actions to ensure continuity of
operations. The plan will include at a minimum the key elements as outlined by FEMA:
readiness and preparedness, activation and relocation, continuity operations, and reconstitution
operations. All staff will be trained on the plan once it is completed. The plan will be submitted
to TEMA and posted on the Board’s intranet. On an annual basis the plan will be reviewed and
updated as needed.

Department of Correction Comment
We concur. The Department will develop disaster recovery plans that ensure continuance
of services in an emergency.
Department of Correction Corrective Action Plan (Field Services/Community Supervision)
Within days of the merger of Field Services into TDOC the Director of TDOC’s
Emergency Operations Unit contacted the Assistant Commissioner and the planning process for
developing an enhanced disaster recovery project has begun. Each office will have its own plan
on which all staff will be trained. Secondary work sites, all necessary telephone numbers and
other contact information will be established.


There will be a Team Leader for each location who will be trained in the duties
required.



Personnel Notification Levels will be established



General and specific task lists will be developed



Vital Supplies and location of such will be identified



Computer needs and their location will be established



External Contacts will be developed



A Continuation Strategy that ensures a quick and effective return to business will be
implemented



A manual of all items will be published and trained on

This process will be completed by March 31, 2013.

4. The board should reevaluate current procedures for posting meeting notices, to better
ensure compliance with public meetings law
Finding
Currently, the Board of Probation and Parole posts meeting notices in the elevator lobby
at the central office on the 13th floor of the Parkway Towers Building in downtown Nashville.
Notices are not posted in field offices or on the board’s website. The board did post the January
and April 2012 administrative meetings to the Public Meetings area of the state website, but
these notices were posted less than 48 hours prior to the meetings.
Section 8-44-101, Tennessee Code Annotated, declares it to be “the policy of this state
that the formation of public policy and decisions is public business and shall not be conducted in
secret.” Section 8-44-102 stipulates that all meetings of any governing body are declared to be
public meetings open to the public at all times. Further, Section 8-44-103 requires adequate
public notice of both regularly scheduled and special meetings.
In the decision on Englewood Citizens for Alternate B v. Town of Englewood, No.
03A01-9803-CH-0098, slip op. (E.S. Tenn. Ct. App. June 24, 1999), the Tennessee Court of
Appeals for the Eastern Section outlined the following three-prong test for “adequate public
notice.”


notice must be posted in a location where a member of the community could become
aware of such notice;



contents of the notice must reasonably describe the purpose of the meeting or the
action proposed to be taken; and



notice must be posted at a time sufficiently in advance of the actual meeting in order
to give citizens both an opportunity to become aware of and to attend the meeting.

The board’s current procedure communicates to an audience including central office board staff,
field services leadership staff, district field staff who attend the meetings via teleconference on a
rotating basis, and other state and legislative officials involved in the corrections process. Notice
would only reach the general public if they visited the 13th floor of the Parkway Towers Building
in Nashville or visited the Public Meetings area of the state website less than 48 hours before the
32

meeting. Additionally, the posting of meeting notices to the state’s website less than 48 hours
prior to the meeting may not fulfill the requirements of “adequate public notice” as defined by
the Tennessee Court of Appeals.

Recommendation
The Board of Probation and Parole should strengthen formal, written policies and
procedures for complying with the requirements for public meeting notices by mandating the
posting of meeting dates on its website, in field offices, and/or advertising meeting dates in local
newspapers. Implementing these procedures would better ensure that board personnel and the
general public are aware of the meetings of the board. Further, the board should ensure its
notices are posted at a time sufficiently in advance of the actual meeting in order to give citizens
both an opportunity to become aware of and to attend the meeting.

Management’s Comment
Board of Parole Comment
We concur. The Board notes that in addition to the physical posting of the notice on the
13 floor of our central office building and on the State Calendar website that the Notice was
forwarded electronically to various State departments as well as to the Associated Press. While
notices are not posted in field offices, it is to be noted that District Directors received electronic
notice of the meetings and in turn informed their senior staff.
th

Board of Parole Corrective Action Plan
The Agency will strengthen procedures for complying with the requirements of the Act.
The Board will post meeting Notices at least five days in advance of meetings. The Notices will
be physically posted in the lobby of the central office building as well as on the 13th floor. In
addition to electronically posting the Notice on the State Calendar, the Board will electronically
post the Notice on the BOP website, BOP intranet and Facebook. The Board will also continue
to forward notice to key State and legislative contacts and the Associated Press.
Target date of implementation is September 19, 2012.

5. In some instances, the board still fails to comply with state law regarding hearing
decisions; further, decision letters denying parole omit appeal rights
Finding
The two previous performance audits of the Board of Probation and Parole (May 2006
and June 2001) found problems in the parole hearing and final decision notification procedures.
The June 2001 audit found the board failed to notify public officials of hearing results in the
statutory time frame of 30 days. The board concurred with the finding and stated it would begin
sending monthly reports regarding decisions and continue with plans to post final decisions on
the agency website. The May 2006 audit found the procedures regarding hearings still needed
improvements. The board concurred with the finding and provided a corrective action plan
regarding policy changes, monthly audits, training, and reviews before accepting completed
notices.
During the current audit, we found that notifications of parole hearings and notifications
of final decisions were still not sent to offenders and interested parties as required by board
policy and state statutes.
Board of Probation and Parole policy requires written advisement of a parole or grant
hearing for a given offender, including time and place. The board requires that offenders eligible
for parole be given due consideration in a timely manner. Section 40-28-505(b) and (c),
Tennessee Code Annotated, requires notification at least 30 days prior to a scheduled parole
hearing and 3 days prior to a parole revocation hearing conducted pursuant to Section 40-28-122.
The board is to send a notice of the date and place of the hearing to the following individuals:


The trial judge for the county in which the conviction occurred, or the trial
judge’s successor;



The district attorney general in the county in which the crime was prosecuted;



The sheriff of the county in which the crime was committed; and



The victim or the victim’s representative who has requested notification of the
date and place of the scheduled hearing or notice of the board’s final decision.

The board must send notice of its decision to those required to receive notice (see above) no later
than 30 days after a parole or parole revocation decision has been finalized.
The Board Operations Division’s Docket Unit is responsible for preparing dockets for
parole hearings held throughout the state at Department of Correction institutions and county
jails. Preparing a parole hearing docket includes, but is not limited to, sending hearing notices
and final hearing dispositions to the parties listed above in accordance with state law and board
policy.
Prior to the 2006 audit, the board developed an in-house process to automatically
generate all hearing notification letters. Currently, the Board Operations Application Suite
interfaces with TOMIS to generate the notices for parole hearings and the hearing decision letters
34

to offenders and interested parties. The docket technician has a checklist by which to confirm
that the notice has been sent and received.
Notice to Offenders
We reviewed a random sample of 48 offender files from dockets in fiscal years 2009,
2010, and 2011.1 In reviewing files for this audit, we found that there were no problems with
timeliness of sending out the notifications for the scheduled hearings to offenders but that
problems still exist for sending out notifications of hearing decisions. Of the 48 files reviewed,
all of the offenders had at least a 30-day notice of the scheduled hearing date based on the
information in the offender’s paper file. The average number of days from the offender’s notice
of a hearing to the actual hearing was 44 days. For notification of hearing decisions, the average
number of days from the date of the finalized decision to the date the offender was notified was
30 days. However, we found 15 instances where the time from the final vote to offender
notification exceeded 30 days (ranging from 32 to 86 days). Additionally, our review revealed
that “Offender Hearing Decision Notices” were not on file for two offender files and one
“Offender Hearing Decision Notice” was not dated by the offender or the institutional probation
and parole officer (IPPO), which would have shown when the offender received the notice.
We also determined that information related to appeal rights was not included in the
letters to offenders whose parole was denied or revoked.
Notice to Interested Parties
We discovered that problems also exist with sending notifications to interested parties for
hearings and hearing decisions. We determined that interested parties were listed in TOMIS for
each offender in our sample but that documentation of notification to those parties was only
included in 4% of the offender files reviewed. According to the Director of Board Operations,
the division changed notification procedures for interested parties from written letter to e-mail
communication during fiscal year 2006-2007 or fiscal year 2007-2008; however, this change
only applied to officials, not victims.
Review of Hearing Notices
Hearing Notices
Average Days

Offender

Interested
Parties

44
Undetermined
because of lack of
support in offender
file

Hearing Notices Not in
Compliance
No issues of noncompliance based on
requirement for at least 30day notification
Undetermined because of
lack of support in offender
file

Hearing Decisions
Average Days

30
13 (This average was
based on support
obtained from only 7
of 48 files tested.)

Hearing Decisions
Not in Compliance
18 of 48 or 38%
tested (ranging from
32 to 86 days)
46 of 48, or 96%
tested, due to lack
of support

The sample size reflects a non-statistical sample, and results are not projected to the entire population of 49,378
hearing dockets in fiscal years 2009, 2010, and 2011.

The Director of Board Operations acknowledged problems existed because IPPOs do not
always return the Offender Hearing Decision notifications to the central office/file room in a
timely manner. The issue was addressed with Field Services during April 2012. The director
also stated that hearing officials and IPPOs discuss appeal rights with offenders during the
hearing process.
Lack of compliance with state law could call into question the decisions made by the
board and put the board in a position of having to reconsider multiple cases because of its lack of
timely notifications.

Recommendation
The Director of Board Operations should collaborate with other divisions of the Board of
Probation and Parole such as Information Systems and Field Services (now at the Department of
Correction), to implement manual and automated controls to strengthen existing parole hearing
notification procedures in order to ensure compliance with the statutes. Any revisions/updates
should be made to the operating procedures/manuals of the board and posted to the intranet. The
board should also revise the notification of hearing decision letters to include appeal rights for
the offender to ensure that the board’s communication of appeal rights to the offender is
documented.

Management’s Comment
Board of Parole Comment
We concur. BOP complies with statutory requirements for parole hearing notifications,
however, in some instances parole hearing decision notifications were not completed within 30
days from the final vote. Decision letters denying parole omit appeal rights.
Board of Parole Corrective Action Plan
The Director of Board Operations and the automation Project Lead are currently
collaborating with BOP Information Systems and DOC Field Services to strengthen existing
parole hearing notification controls. This will include establishing formal timelines for
dissemination, delivery and return of signed parole hearing decision notification letters to Board
Operations.
The procedure of sending parole hearing notifications and parole hearing decision
notifications to officials and other interest parties is different. Officials are notified by email and
other interested parties are notified by letter. Operating procedures are maintained in the Unit
Manual of Operations. During the course of this audit, the Board Operations unit manual of
operations was updated to comport with the procedures currently in place. The Board
Operations unit manual of operations will continue to be posted on the intranet and updated
promptly to comport with changes in operating procedures.

The appeal process is only applicable to those offenders whose parole has been denied,
revoked, or rescinded. Advising offenders of their appeal rights has been the responsibility of
the Hearing Official and Institutional Probation/Parole Officers and there is no formal
requirement to include appeal rights on parole hearing decision letters. To ensure conspicuous
and undisputed conveyance of offender appeal rights, all parole hearing decision notification
letters will be modified to include offender appeal rights.
Target date of implementation is November 1, 2012.

6. Weaknesses in the Tennessee Offender Management Information System (TOMIS)
could result in inaccurate analysis of some programs
Finding
During our review, we found instances in two separate programs where offenders were
allowed to participate in programs without first being referred to the program as required by
board policy. This means the Tennessee Offender Management Information System (TOMIS)
lacks appropriate edit checks to help probation and parole officers (PPOs) ensure they are
completing all required steps for getting offenders into programs. The lack of edit checks also
negatively affects the ability to analyze and rely on the information in TOMIS.
Victim Impact and Courage to Change
According to the Victim Liaison Services Director, all Victim Impact and Courage to
Change class participants should be referred to these classes by their PPO, and the PPO should
document the referral in TOMIS. The district facilitator should enter a code into TOMIS upon
the participant’s successful completion of the class. (Also see the observation and comment on
page 58 for additional information regarding this program.) Based on information documented
in TOMIS, the board provided us with four lists from calendar year 2011:


Referrals to Courage to Change;



Completed Courage to Change;



Referrals to Victim Impact; and



Completed Victim Impact.

Our intent was to compare the referrals listing to the completed listing for each class in an effort
to get a completion rate and then to determine how many individuals who had completed the
programs had been rearrested; however, we found multiple issues with the data provided. First
we found that some offenders were on the referral list multiple times. Next, we found
individuals on the completed lists who did not always have a referral. With this knowledge, we
reviewed TOMIS to determine if some of these individuals had a referral date or completion date
outside of our original data request. Thus, we reviewed TOMIS for any referral date prior to
37

calendar year 2011 (classes began in January 2011) and for completion dates through May 2012.
The following tables show what we found.
Victim Impact

# of items on list reviewed for calendar year 2011
# of individuals on list reviewed for calendar year 2011

Referral Completion
List
List
234
161
218
161

Referred Completed
# of Individuals
Referral Code in TOMIS, No Completion Code
140
Referral Codes and Completion Code in TOMIS
72
72
Completion Code in TOMIS, No Referral Code
101
Referred and completed but no completion code in TOMIS
8
Total
220
173
Completion Rate = # Completed with a referral divided by total referrals
36.4%
2 referrals obtained from December 2010 by review of TOMIS data
12 offenders on the referral list completed Victim Impact between January and May 2012

Courage to Change

# of items on list reviewed for calendar year 2011
# of individuals on list reviewed for calendar year 2011

Referral Completion
List
List
224
87
191
87

Referred Completed
# of Individuals
Referral Code in TOMIS, No Completion Code
132
Referral Codes and Completion Code in TOMIS
53
53
Completion Code in TOMIS, No Referral Code
63
Referred and completed but no completion code in TOMIS
8
Total
193
116
Completion Rate = # Completed with a referral divided by total referrals
31.6%
2 Referrals obtained from December 2010 by review of TOMIS data
29 offenders on the referral list completed Courage to Change between January and May 2012

The lack of an edit check in TOMIS that would require a person to be referred to a
program before attending or completing the program provides multiple opportunities for
problems with the reliability of the data in TOMIS’ and with statistics the board provides to the
citizens of Tennessee resulting in erroneous conclusions.

Interactive Offender Tracking
We found a similar issue regarding TOMIS’ lack of edit checks during our review of 40
offender files. According to the Interactive Offender Tracking (IOT) manual, PPOs are to record
in TOMIS when an individual is referred to and approved for IOT monitoring. We found six
instances where an offender was not referred to IOT but was accepted into the IOT program. We
also found six instances where an offender was not accepted into the IOT program but did have a
referral code in TOMIS.
The lack of appropriate edit checks to keep offenders from being accepted into a program
before they are referred to it can cause problems with the analysis of successful completion rates
for the IOT program, resulting in erroneous conclusions.

Recommendation
The Board of Probation and Parole and the Department of Correction should work
together to ensure that appropriate edit checks and data validation tools are developed and
implemented for TOMIS.

Management’s Comment
Department of Correction Comment
We concur. The Department will work to see that the proper edit checks and data
validation tools are developed and implemented for TOMIS.
Victim Impact and Courage to Change
We will increase checks and balances in the TOMIS entry system through additional training
of officers and facilitators relative to all appropriate TOMIS codes. In addition, we will add
checking TOMIS for a referral code for all participants in a program prior to entry of
attendance or other program TOMIS codes by December 31, 2012.
It is possible an offender might be on a referral list more than once if the offender dropped
the class or was terminated from the class at one point, but was again referred to the class at a
later time. Additionally, the additional training previously mentioned will address the need
to ensure there is no duplication of referral code entry for a single referral.
Interactive Offender Tracking
Additional training will be added for managers and officers. A system will be put in place
for managers to review the TOMIS entries when an offender is referred to IOT. We will be

using the BI01MJQ report for checks and balances when reviewing files. This will be in
place by June 30, 2013.
We are currently in the process of working with Fieldware to develop a report that will edit
entries to prevent offenders from being accepted into a program before they are referred.
Completion date is not known at this time as it may require contract modification or added
funding.

7. Approximately half of the cases in our sample were not reviewed by probation and
parole officer supervisors during calendar year 2011
Finding
The May 2006 performance audit of the Board of Probation and Parole reported problems
with contradictory policies for supervisory reviews, making it difficult for the board (and
auditors or others reviewing case files) to determine with any accuracy the extent to which
supervisors reviewed case files as required. We recommended board management review and
revise the policies as needed to ensure clarity and consistency in how supervisors’ reviews are to
be documented. The current audit found that policies have been clarified in an effort to ensure
all files receive at least one supervisory review per year; however, only about 50% of the cases
we reviewed had documentation of any type of supervisory review during calendar year 2011.
We reviewed 230 offender files for documentation of supervisory review, and requested
documentation of reviews from supervisors during field visits. We found instances where


no supervisory review codes were in the Tennessee Offender Management
Information System (TOMIS) and no documentation of a review was provided;



supervisory review codes were present in TOMIS but no documentation of a review
was provided;



documentation of a review was provided but there were no supervisory review codes
in TOMIS;



multiple supervisory review codes were present in TOMIS but only one supervisory
review document was provided;



supervisory review codes were present in TOMIS and documentation of a review was
provided, but the review was not dated; and



supervisory review codes were present in TOMIS and documentation was provided,
but the reviews were dated in different months.

Supervisory Reviews
Calendar Year 2011
No supervisory reviews
documented in TOMIS or files ‐
50.4%
2.2% 1.8%

At least 1 review in TOMIS, no
supporting documentation
provided ‐ 19.2%

3.6%
4.0%

Month of supervision in TOMIS
matches month of supervision
on documentation provided ‐
18.8%

18.8%

Review in TOMIS, supporting
documentation has no date ‐
4.0%
50.4%
Documentation provided, no
review documented in TOMIS ‐
3.6%
At least 1 review but the month
of supervision in TOMIS does not
match the month of supervision
on supporting documentation ‐
2.2%
Up to 3 reviews in TOMIS, only
one supporting document
provided ‐ 1.8%

19.2%

A March 2010 Directive classified supervisory reviews into 3 types: initial, annual, and
closing. For each type of review, the directive defines what is to be reviewed. Initial and closing
reviews have timelines for when the review should be conducted. By providing guidelines for
each review type and establishing timeliness standards for initial and closing reviews, the board
intended to ensure that 100% of cases were reviewed each year. Additionally, the directive
states that managers are to maintain spreadsheets of the reviews and refer to them during
41

performance evaluations and other personnel actions. An August 2011 Directive clarified the
differences in supervisory reviews in TOMIS by changing the contact codes entered for each
review type but leaving all other requirements the same. Pursuant to a December 2011
Directive, the board developed a monitoring process using TOMIS information to determine if
supervisors complete their reviews.
Each type of review includes a list of items or activities that require the supervisor to
review from multiple sources including TOMIS, the case file, the offender’s Transitional
Assessment Plan-Behavioral Intervention Goals, and others to get a complete picture of the
PPO’s supervision of the offender. As with the PPO’s list of over 50 items to complete for each
offender, the supervisor is then required to review these items to ensure the PPOs are completing
their requirements. With multiple items to look for and multiple places to look for information,
this becomes cumbersome and time-consuming in an environment that also requires the
supervisor to be reactive to issuing violations and warrants for rearrests, and responding to court
summons, etc.
Even though these reviews may be cumbersome, a lack of supervisory reviews can lead
to lack of appropriate monitoring by PPOs, which can then lead to offenders not being rearrested
for violations of probation and parole. This in turn interferes with the board’s goals regarding
public safety.

Recommendation
The Board of Probation and Parole and Department of Correction should use all available
tools for monitoring to determine if supervisory reviews are being completed. The board and
Department of Correction should also ensure that the supervisory reviews are discussed with
PPOs as required by board directive.

Management’s Comment
Department of Correction Comment
We concur. The Department will use all tools available for monitoring to determine if
supervisory reviews are completed and discussed with PPOs as required by directive.
This issue became apparent in early 2011 and we began a process of improvement that
included adding new contact codes that identified each type of supervisory review followed by a
report called the ZZZ report that tracks when supervisors are doing the reviews. This has greatly
expanded our ability to track who has had the review and who has not, however, the old
computers that many of our managers have cannot use the best and most productive version of
this report so another version has been devised but is not nearly as useful. Currently we are
reviewing as part of our Top-to-Bottom Review whether 100% case file reviews is reasonable or
if it can be managed better with technology. We are reviewing whether an old report under case
management assistance can be expanded to do some of the most detailed work for us and reduce

the amount of time each review takes. Results of the case file reviews will be part of the Job
Performance Planning process and will be monitored by Director level staff. This should be
completed by June 30, 2013.

8. The board’s Field Services Division does not adequately document and monitor
Administrative Case Review Committee actions for offenders who commit technical
violations and, in some instances, fails to administer proper sanctions
Finding
Section 41-1-413, Tennessee Code Annotated, grants the Board of Probation and Parole
the authority to use intermediate administrative sanctions when appropriate to manage offenders.
Board policy establishes the Administrative Case Review Committee (ACRC) as a means of
dealing with “technical violations,” failures to comply with supervision conditions which do not
amount to criminal offenses. The board’s ACRC manual provides guidance to the probation and
parole officers (PPOs) and Field Services Division management who serve on ACRC panels.
The manual sets forth a system of progressive intervention whereby violations are labeled as
low, moderate, and high severity (i.e., Level 1, 2, and 3). The manual also lists the sanctions that
would be appropriate at each level (e.g., one failed drug test would be a Level 1 violation and
might result in another drug or alcohol test being conducted). See the following table for a list of
the sanctions for each level of violation.
ACRC Sanctions by Violation Level
Level 1 - Low Severity
Deliver oral reprimand

Level 2 - Moderate Severity
Sanctions
Review condition/reinstruct

Mandatory transitional housing

Deliver written reprimand

Staffing with supervisor

Electronic monitoring or GPS

Set limits

Letter of warning, written
reprimand

Establish deadlines

Increase drug testing

Request parole or probation
violation warrant except where
special circumstances warrant a
less serious response
Arrest with revocation

Assign minor restrictions

Curfew (with or without
electronic monitoring)
Home detention

Recommend for Technical
Violation Program
Inpatient treatment

Placement in halfway house
for monitoring

Recommend special treatment
program while incarcerated,
followed by supervised release
as approved by the supervisor

Establish behavior
expectations
Increase reporting

Level 3 - High Severity

Level 1 - Low Severity
Increase supervision level
Conduct drug/alcohol test
Review conditions
Counsel
Provide job assistance
Refer for services
Refer to self-help group
Provide budget/financial
help
Enlist collateral support

Level 2 - Moderate Severity
Sanctions
Community service hours

Level 3 - High Severity

Request revocation optional
Counsel
Refer for counseling services
Refer for psychiatric
evaluation
Refer for budget/financial
services
Refer to self-help group
Refer to job/training
placement
Refer to anger management
group

Refer to marriage counseling
Refer to a parenting shelter
The board’s Contact Notes Manual states that ACRC hearings should be documented in
the Tennessee Offender Management Information System (TOMIS) using a contact note with the
OPHC contact note type and with comments that list the violation and the “decision of the
ACRC determining what sanctions shall be used/given to [the] offender.” Board policy states
that “statistics will be kept, by the ACRC Chairperson on all ACRC meetings held and on the
offender’s level of compliance for one year.” Based on discussion with a Probation/Parole
Program Specialist in the board’s Research, Policy, and Planning Division, the ACRC
chairpersons in each district office are required to submit reports each month listing the offenders
who have had some type of ACRC activity in their cases. These monthly summary reports,
along with the TOMIS case notes, are the only two methods that board management has of
monitoring ACRC activity.
As a part of our audit, we reviewed the ACRC activity from January 2009 to December
2011 for the offenders in our regular, Global Positioning System (GPS), and Interactive Offender
Tracking (IOT) testwork samples discussed in Finding 2 on page 11. As noted in Finding 2, the
results of this review are not projected to the entire offender population.
Regular Supervision Sample
For the offenders in our regular testwork sample, 13 had ACRC action. For 2 of these 13
offenders (15%), we found that TOMIS notes and the case files did not document that
appropriate sanctions had been imposed for drug violations. One of these two offenders (a
parolee) had failed a drug screen and, as a result, was scheduled for an ACRC intervention.
Later TOMIS case notes state that the offender received a substance abuse screening and a
referral for clinical services; however, there was nothing entered under an OPHC case note or in
the case file to indicate whether this was done as a result of the ACRC hearing. The other
44

offender where we noted a problem with sanctions was a probationer who, at the time of his
hearing, had three positive drug screens within the preceding three months. At the time of the
September 22, 2009, drug screen that prompted the ACRC referral, the PPO noted that the
offender would be retested in 30 days. However, according to the board’s ACRC manual,
increased drug testing is only identified as an appropriate sanction for one or two positive drug
screens, which are Level 1 and 2 violations. Three positive drug tests should have been
considered a Level 3 violation, which requires court intervention or mandatory inpatient
treatment. Moreover, neither the OPHC case note in TOMIS nor the case file documented that
the ACRC addressed the failed drug tests. (The only sanctions listed as having been imposed
were for the failure to pay fees and complete community service work.) The retest, which should
have been administered within 30 days of the September 22, 2009, drug screen, was not
administered until November 18, 2009, almost a month late.
GPS Supervision Sample
Our testwork on offenders who were subject to GPS monitoring included one parolee and
two probationers with ACRC activity. Out of these three cases, we found that adequate
sanctions were not noted as having been imposed for the parolee (33%). The parolee was
referred to the ACRC for the following Level 1 violations: travel out of county without
permission, failure to seek employment, and failure to pay fees/financial obligations. Based on
our review of TOMIS and the case file, the field supervisor who conducted the Level 1 ACRC
hearing restricted the offender’s travel privileges but did not impose any sanctions addressing the
offender’s failure to pay fees or seek employment. Based on the available information, we could
not find any indication that the travel restrictions were also intended as a penalty for the other
two violations. No issues were noted regarding the two probationers with ACRC activity.
IOT Supervision Sample
For one of the four offenders with ACRC action in our IOT sample, we found that
sanctions were not noted as having been imposed for all of the offender’s violations. This
offender, a probationer, was referred to the ACRC for failure to provide proof of employment,
failure to meet financial obligations, and a positive drug screen. The ACRC issued the offender
a written reprimand to provide proof of employment monthly and make regular restitution
payments, but did not address the failed drug test. According to the board’s ACRC manual, the
field staff should have issued a verbal or written reprimand, conducted an additional drug/alcohol
test, or referred the offender for some type of services as a result of a positive drug screen.
TOMIS Codes
For the offenders in our testwork, we examined whether Field Services personnel entered
OPHC case notes in TOMIS and found that these notes were missing for 7 of 13 offenders
(53.8%) in our regular supervision sample. The committee members did enter case notes for all
of the GPS and IOT offenders in our testwork. (As noted above, however, we could not
determine whether all of the necessary content was included in these case notes.)

Monthly Summary Reports
During our audit, we also reviewed the monthly summary reports for calendar year 2011
and found that they also lacked complete information on ACRC hearings. The template for the
district’s monthly reports follows the system of dividing violations and sanctions into three
different levels and, in a final set of columns, reports successful/unsuccessful completions of
ACRC-imposed sanctions, continuances, revocations, and hearing non-appearances. Although
the ACRC reports should include data for more offenders than just the ones who had hearings,
the ACRC chairpersons in the districts and the program specialist in the Research, Policy, and
Planning Division did not begin using a reporting template that included all three ACRC levels
until mid-year. (Level 1 violations are not required to be formally heard by an Administrative
Case Review Committee made up of three PPOs; they can be handled by the offender’s
“PPO/Supervisor and do not require ACRC.”) As a result, not all ACRC hearings would have
been reported at the start of 2011. For this reason and because of the inconsistent use of OPHC
case notes, we were unable to fully reconcile the reports and TOMIS. In spite of this limitation,
we checked months where no ACRC activity was reported against a report of all OPHC case
notes for 2011. Based on our comparison, we found that ACRC chairpersons in several districts
did not submit any ACRC reports for the following months, despite the fact that OPHC case
notes in TOMIS documented that there were hearings.

Missing ACRC Summary Reports for Districts and Months With OPHC Case Notes
District

Month

1
3
3
3
3
3
3
3
5
5
5
5
6
6
7
7
7
7
7
7
7
7
7

October 2011
January 2011
June 2011
August 2011
September 2011
October 2011
November 2011
December 2011
June 2011
September 2011
October 2011
December 2011
March 2011
September 2011
March 2011
April 2011
May 2011
June 2011
July 2011
August 2011
September 2011
October 2011
November 2011

Number of Hearings Per OPHC Case Notes
No Reported ACRC Activity Per Monthly
Report
2 hearings
4 hearings*
5 hearings*
25 hearings
8 hearings
7 hearings
4 hearings
9 hearings
85 hearings
2 hearings
9 hearings
4 hearings
8 hearings*
7 hearings
64 hearings*
63 hearings*
48 hearings*
75 hearings*
50 hearings*
60 hearings*
53 hearings*
13 hearings*
21 hearings*

*The number of hearings reported here is based on OPHC case notes in TOMIS, some or all of which
may have been Level 1 hearings. Based on our review of other ACRC Summary Reports, the ACRC
chairperson for this district may not have been reporting Level 1 hearings on the monthly reports at
this time since, as noted in the discussion above, these cases were not heard by a formal committee.

PPOs may be unable to adequately review ACRC cases, document the sanctions imposed
during hearings, or perform the necessary follow-up on these sanctions because of their large
caseloads. PPOs might also be assisted in following up on ACRC recommendations for
offenders if they could rely on accurate records from their districts’ ACRC chairpersons.
However, neither the board’s ACRC manual nor its policy include any formal, documented
instructions regarding the monthly summary reports or the other summary information that
should be maintained. Without imposing sanctions for all violations and documenting these
sanctions properly in TOMIS, PPOs may not be able to ensure that offenders receive the
intervention necessary to address their failures to comply with supervision provisions. At an
organizational level, the board cannot effectively manage the ACRC program if adequate records
are not being maintained in TOMIS and if the monthly summary reports provided by the districts

are inaccurate or incomplete. Further, without adequate, accurate, and complete records, the
success or failure of the program cannot be determined.

Recommendation
The Board of Probation and Parole’s (now the Department of Correction’s) Field
Services Division management should ensure that PPOs and supervisors who are reviewing
ACRC cases impose sanctions for all violations. The Field Services Division should also ensure
that PPOs and supervisors enter OPHC case notes and thoroughly document the sanctions that
have been imposed. The Field Services Division should consider incorporating a review of
OPHC case notes and the sanctions imposed into the supervisory reviews of case files. The Field
Services Division should also take the necessary steps to ensure that the ACRC chairpersons in
each district are maintaining adequate records of ACRC activities. The management of the Field
Services and the Research, Policy, and Planning Divisions should document the requirements for
the monthly ACRC reports and take whatever other steps are necessary to ensure that these
reports are properly submitted.
Management’s Comment
Department of Correction Comment
We concur. The Department will ensure that PPOs and supervisors who are reviewing
ACRC cases impose sanctions for all violations as per policy and directive. The correct contact
codes will be entered and sanctions will be documented upon imposition. A review of the OPHC
case notes and sanctions will become part of the case file review. We will ensure accurate and
up to date records on all ACRCs are kept. The agency will develop the standards for
documentation and ensure these reports are properly submitted.
We are currently in the process of developing an automated system for referrals to ACRC
to reflect violations with appropriate sanction options, review and completion information, as
well as an offender’s ACRC history. The automated system envisions a direct referral from the
PPO to the ACRC chairperson to be used throughout the ACRC process through offender
completion/termination/warrant request.
The review and development of this process
encompasses revision of the ACRC manual and policy, as well as development of the
technological process. Training on the updated system will be provided to PPOs, managers,
deputy district directors, and district directors. Scheduling this process will be driven by the
workload of the research division and will be completed no later than December 31, 2013.
In the interim, as part of the policy review related to the transfer of Field Services to the
Department of Correction, all Field Services policies are currently under review for revision.
Pending completion of the automated process, the current ACRC policy revision will incorporate
instructions regarding submission of monthly summary reports. As noted in this Finding, Level
1 violations are not required to be formally heard through ACRC. This will continue to be true
under the revised policy so monthly reports will continue to reflect only Level 2 or 3 violation
activity. Distribution of the revised policies will include direction regarding appropriate OPHC

contact notes. In addition, ACRC training will be developed and provided to field staff, focusing
on the responsibilities of the PPO, the ACRC chairperson and the other members of the
committee to ensure each participant fully understands the responsibilities of each role in the
ACRC process.
GPS Supervision Sample
Due to the seriousness of the offender type, there is more of a “Zero Tolerance” approach to
their violations and very few are referred for ACRC.
IOT- Supervision Sample
IOT cases are transferred from the IOT officer back to the original officer when a violation
occurs. However, in light of the fact all technical violations are to be addressed during an
ACRC referral, reinforcement of this policy will take place for all staff by October 31, 2013.
TOMIS Codes
Missing Contact Codes can occur from time to time in PPO efforts to meet the number of
tasks on one case with a focus on speed and accuracy. We will continue to train, reinforce,
and check for accuracy.

OBSERVATIONS AND COMMENTS

The topics discussed below did not warrant a finding but are included in this report
because of their effect on the operations of the Board of Probation and Parole and on the citizens
of Tennessee.

The Board’s Information Systems Division Does Not Maintain an Adequate Record
of Source Code Changes, Increasing the Risk of Unauthorized Changes and
Interruptions of Service
Best practices dictate that agencies should keep a record of changes to source code (a text
listing of commands to be complied into an executable computer program) with source control
software and that there should be documented approval of all program changes. Regarding
control over program changes, the U.S. Government Accountability Office’s Federal
Information System Controls Audit Manual (FISCAM) states the following:
Library management software provides an automated means of inventorying
software (ensuring that differing versions are not accidentally misidentified) and
maintaining a record of software changes. Specifically, such software can be used
to


produce audit trails of program changes and maintain version number control,
49



record and report program changes made,



automatically number program versions,



identify creation date information,



maintain copies of previous versions, and



control concurrent updates so that multiple programmers are prevented from
making changes to the same program in an uncontrolled manner.

The Board of Probation and Parole’s Information Systems (IS) Division does not use a
library system to keep a record of changes to source code and does not maintain documented
approval of program changes. The IS director stated that there are relatively few applications
that are developed and maintained in-house by the board. For example, the Tennessee Offender
Management Information System (TOMIS) is administered by the Department of Correction,
and the call-in Interactive Offender Tracking (IOT) system and the VeriTracks system for
monitoring offenders with global positioning system (GPS) devices are maintained by vendors.
However, portions of the Offender Fee System and the Board Operations Application Suite rely
on code that is updated by the board’s IS staff. According to the IS Director, instead of using
source control software, a record of old code is kept in the current code. The old code is
“commented out” by adding syntax around it that makes it a comment that will not be executed
when running the program. The IS Director stated that, while changed programs are reviewed by
IS management, this review is not documented.
According to the IS Director, the Offender Fee System and the Board Operations
Application Suite primarily display information from TOMIS and, in the case of the fee system,
from INovah, the State of Tennessee’s cashiering system. The risk of any unauthorized changes
being made to these read-only systems is, therefore, reduced.
While the risk of source code changes being made for fraudulent purposes may be
mitigated due to the nature of these systems, the risk of unauthorized changes for malicious
purposes still exists. In addition, storing old source code within current code could make it
difficult to rely on previous versions if needed, resulting in interruptions of service and monetary
losses.
The board’s IS Division should begin using source control software to keep a record of
changes to the source code for the Offender Fee System, the Board Operations Application Suite,
and any other in-house applications that it currently maintains. IS management should use
source control software to ensure that source code is labeled, dated, inventoried, and organized in
a way that diminishes the risk that programs will be misidentified or lost. IS management should
also maintain documented approval of all program changes.

Conflict of Interest Disclosures Do Not Adequately Document Compliance with
Policy
Board of Probation and Parole policy requires board members and staff to annually sign a
form acknowledging receipt of the Conflict of Interest Policy; however, this form does not
document an individual’s compliance with the policy or provide space for disclosures of
potential conflicts.
Section 12-4-101, Tennessee Code Annotated, prohibits officers and board members from
any involvement in the letting or administration of any contract in which they have a direct
interest. Governor Haslam issued Executive Order 1 concerning Ethics Policy and Disclosures
by the Executive Branch; however, this order did not supersede Executive Order 3 concerning
Ethics and Conflicts of Interest issued by former Governor Bredesen.
Additionally, Board of Probation and Parole Administrative Policy 202.01 prohibits
employees from engaging in any activity that directly or indirectly constitutes a conflict of
interest.
We determined that the board’s mechanism for compliance with the Conflict of Interest
Policy is documented by having the employee sign a form to acknowledge receipt of the policy.
Conflict of Interest acknowledgement forms are maintained in the personnel files of the Human
Resources Division. The forms do not include space for disclosure of potential conflicts. As a
result, the board is only allowing board members and employees to acknowledge receipt of the
policy, not actual compliance with it.
In reviewing personnel files for this audit, we discovered that annual declarations were
not always on file for members of the board and staff. We reviewed all seven board members
and a sample of 50 staff composed of new and existing employees for the period 2009, 2010, and
2011 to determine whether policies were being followed and statements were updated regularly.2

Since we reviewed the entire population of the board members’ annual declarations, no projection is required. The
sample size of 50 employees reviewed reflects a nonstatistical sample and results are not projected to the entire
population of 1,104 board employees at the time of the sample.

Based on our review, we determined the following:
Area Reviewed

File Review Results

Problem

New Hires 2011

3 of 25 files 12%
tested

No form on file for retirees
on 120 day contracts.

New Hires 2011
Board Members
2011
Board Members
2010
Board Members
2009
Existing Employees
2011
Existing Employees
2010
Existing Employees
2009

16 of 25 files 64%
tested
3 of 7 members 43%
tested
1 of 7 members 15%
tested
3 of 7 members 43%
tested
12 of 25 files 48%
tested
2 of 25 files 8% tested
6 of 25 files 24%
tested

Range

Acknowledgement form
1-129 days after
was not signed on or before the date of hire
the date of hire or rehire.
or rehire.
No acknowledgement form
on file.
No acknowledgement form
on file.
No acknowledgement form
on file.
No acknowledgement form
on file.
No acknowledgement form
on file.
No acknowledgement form
on file.

Although no issues with the appearance of a conflict of interest were identified from a review of
the actual employee disclosure forms on file, the risk for potential conflicts to go unidentified is
high because the current mechanism used by the board does not allow for adequate disclosure.
We also determined that the Employee Handbook does not state that annual declarations
for conflict of interest are required and there is no link to the disclosure form on the board’s
intranet. Additionally, we observed that the acknowledgement form is not available on the
Authorized Forms page of the board’s intranet, but a link to the ethics policy is there.
The Board of Probation and Parole should create a new form that includes an
acknowledgement that board members and staff have received and understand the Conflict of
Interest Policy, as well as space for board members and staff to disclose any potential conflicts of
interest. The form should be completed and signed by all board members and employees on a
regular basis and in a timely manner to readily identify and address potential problems or issues
of appearance. The form and policy should require the individual to promptly update the form
anytime a conflict arises. Disclosure forms should also be accessible to all employees to ensure
that changes are swiftly reported to the board.
We also recommend that the board update the Employee Handbook to include
information on the annual disclosure for conflicts of interest.

While Board Policy Regarding Pre-service Orientation Is Not Consistent With
Practice, Most Employees Received Training Required by Board Practice;
However, There Is Room for Improvement in the Training Offered to New and
Rehired Employees
We reviewed a random sample of 49 Board of Probation and Parole employees who were
newly hired or rehired in calendar year 2011 to determine if these probation and parole officers,
graduate associates, and other employees received the training required by the board and to
determine whether any time management or case management training was provided.3 We found
84% of new/rehired employees received the 83.5 pre-service orientation training hours required
by board practice. Of the 49 employee training histories we reviewed, only 2 (4%) had received
time management or case management training and these were rehires who had received the
training during their previous employment with the board.
Board Administrative Policy 210.05 requires full-time employees and specialized staff to
participate in 40 hours of pre-service orientation training; however, board practice requires 83.5
hours. When new probation and parole officers (PPOs) are hired, they are scheduled to attend
pre-service training at the Tennessee Correction Academy in Tullahoma as soon as possible. This
training takes two full weeks and two days. One week is devoted to the LS/CMI (Level of
Service/Case Management Inventory) risk assessment tool used to evaluate new
parolees/probationers. Two days are scheduled for motivational interaction training. The other
week is spent on various other topics including but not limited to computer systems, supervision
standards, self-defense, and investigative report writing.
Since more than half of the board’s employees and two-thirds of our sample are probation
and parole officers, we focused our comments and conclusions below on training for the
probation and parole officers.
In addition to pre-service training, each new officer must complete a New Employee
Orientation Program within the first four to six weeks of orientation. This program has a
mentoring component, where new hires “shadow” an established officer in the same district to
learn various techniques and styles for handling cases and an overview of the day-to-day
activities of the position. The new officers may also perform some of the job duties under the
supervision of their mentors.
Often, when new officers complete their initial training, they have an established
caseload waiting for them. This puts the new officers in the position of learning the process of
managing a caseload and actually supervising those cases before they complete the New
Employee Orientation Program.
A study by the American PPO Society shows that the issue of proper case management
relates more to the number of services provided to the offender than the number of offenders
3

The sample size reflects a nonstatistical sample and results are not projected to the entire population of 97 new
employees. All new employees are required to receive 83.5 pre-service orientation training hours. Graduate
Associates were included in our sample because they are considered new employees of the board.

supervised. The Board of Probation and Parole provided documentation that for each case that
an officer supervises, there are 22 mandated actions that must be completed daily.
In reviewing files for this audit, we found files of a few officers who had been terminated
at the end of their probationary period. The terminations were a result of the officers being
unable to properly manage all the requirements for case and client supervision. Without proper
training in time management or caseload management, new probation and parole officers are left
in a position of being given an active caseload that they are not prepared to manage. Further,
without properly prepared and trained staff, the board is left in a precarious position where
turnover rates for probation and parole officers can be high and public safety is put at risk
because offenders may not be properly supervised.
The Board of Probation and Parole and the Department of Correction should implement
policy that reflects current practices regarding training and should consider including time
management and case management training as part of pre-service orientation for new employees.
In addition, the board and department management should consider implementing a suggestion
shared with the auditor by board training coordinators that new officers be able to observe
established officers for at least a week or two before being assigned a caseload. The suggestion
included having weekly panel meetings consisting of new hires, trainers, and managers in order
to address any concerns/problems so a plan of action can be established before an officer
becomes overwhelmed.

Over 80% of GPS-Monitored Offenders’ Alarms Reviewed Appear Unmonitored
Eighty-two percent of alarms we reviewed from the GPS monitoring system, VeriTracks,
were not cleared or confirmed by probation and parole officers (PPOs). When GPS-monitored
offenders enter a prohibited area, leave an area they are required to be in, remove their
monitoring equipment, allow their battery charge to drop too low, or charge their battery, the
computer system issues an alarm. From March to December 2011, 68 GPS-monitored offenders
in our sample generated 38,476 alarms. The types of alarms and their definitions are shown in
the table on page 55.
From March to August 2011, there was no clear protocol for how alarms in VeriTracks
should be handled; however, there were protocols issued in May 2010 for the previous GPS
system which was similar to VeriTracks. We compared the definitions of alarms and activities in
the two protocol manuals and found several similarities. For instance, the August 2011 protocol
for VeriTracks requires PPOs to confirm certain alarms while the previous system required PPOs
to record actions in violation notes. Board personnel stated that confirming an event in
VeriTracks would be the equivalent of recording actions in violation notes in the previous
system. However, our review found the following alarms in both protocol manuals required the
PPOs to either confirm an alarm or enter information into the computer system:




911 Exclusion Zone Alarm
Exclusion Zone Alarm
Global Exclusion Zone Alarm





Inclusion Zone Alarm
Master Tamper Alarm
Message Gap Alarm

With this information, we refined our review to focus on these types of alarms and still found
that over 80% of the alarms were not cleared or confirmed by a PPO. The table on page 56
shows the types of alarms and whether they were cleared or confirmed by a PPO.

Alarm Name
911 Exclusion Zone
Alarm
Exclusion Alarm
Global Exclusion
Alarm
Inclusion Alarm

All VeriTracks Alarms
March 2011 - December 2011
Alarm Definition
Received Cleared % Cleared
Offender entered a prohibited area, may be
victim's residence
1
1
100.0%
Offender entered a prohibited area
221
14
6.3%
Offender entered a prohibited area
preloaded in system: schools, parks,
daycares, etc.
5,232
980
18.7%
Offender exited an area in which they are
required to stay
830
135
16.3%

Low Battery Alarm

Battery needs recharging

Master Tamper

Bracelet's strap may have been tampered
with, except the tamper event does not close
until the agent rectifies the strap connection
issue and personally acknowledges the
action in VeriTracks

Message Gap
Jamming Possible

No GPS
On Charger
Press Button
Shielding Possible
Zone Start Location
Unknown

Unit failed to call in a specified time period
Illegal equipment is being used to disrupt
GPS signal
Unit has not called in its GPS location usually caused by line-of-site issues such as
tall buildings, being inside a building, etc.
Unit is plugged in to charge the battery
Enrollee presses button for unit to call- in
data immediately instead of waiting for the
10-minute call in time
Metallic substance is wrapped around the
device and blocks history
The offender does not have a GPS point at a
specified scheduled time
Total alerts

886

128

14.4%

83.9%

635

172

27.1%

0.0%

1,879
27,129

693
4,414

36.9%
16.3%

228

25.9%

318

0.3%

1,085
38,476

350
6,973

32.3%
18.1%

VeriTracks Alarms
March 2011 - December 2011

911 Exclusion Alarm
Exclusion Alarm
Global Exclusion Alarm
Inclusion Alarm
Master Tamper
Message Gap

Cleared
1
14
980
135
26
172
1,328

%
Cleared
100.0%
6.3%
18.7%
16.3%
83.9%
27.1%
19.1%

Not
Cleared
207
4,252
695
5
463
5,622

% Not
Cleared
0.0%
93.7%
81.3%
83.7%
16.1%
72.9%
80.9%

Total
1
221
5,232
830
31
635
6,950

Several of the May 2010 protocols allow at least 5 minutes for an alarm to self-clear
before a PPO would be contacted. We reviewed the above data further to determine if maybe the
PPOs were only confirming alarms if they were over 5 minutes. Our review found 78% of the
alerts over 5 minutes were not cleared or confirmed either.
VeriTracks Alarms Over 5 Minutes
March 2011 - December 2011

911 Exclusion Alarm
Exclusion Alarm
Global Exclusion Alarm
Inclusion Alarm
Master Tamper
Message Gap
Total

Cleared
304
71
24
171
570

%
Cleared
0.0%
23.6%
12.2%
92.3%
27.0%
21.8%

Not
Cleared
85
982
511
2
462
2,042

% Not
Cleared
100.0%
76.4%
87.8%
7.7%
73.0%
78.2%

Total
85
1,286
582
26
633
2,612

As of July 26, 2012, the August 2011 protocol manual has not been finalized with the
board’s or now the Department of Correction’s Legal Division. Without official or finalized
protocols, it is difficult to determine exactly what the board expects the PPOs to do with the data
in VeriTracks.
Not all of the offenders in our sample were monitored using VeriTracks for the entire
period we reviewed so the number of alarms has the potential to be even larger and the number
of alarms that each PPO has the potential to receive in a given day adds up. When added to all of
the PPOs’ other tasks, it seems that including trying to work their way through multiple alarms in
VeriTracks would be difficult and some important alarms could be overlooked.
Board staff stated that the PPOs requested a “Confirm All” button, but the board said no
on the advice of the vendor. According to the board, a “Confirm All” button would invite PPOs

to quickly skim case alarms which would increase their chance of missing an important alarm.
In addition to notification in VeriTracks, the PPOs receive e-mail reports for each alarm that
required action by the Solution Center. This is a lot of information that could be narrowed down
using data mining tools and summary reports. Specifically, the “On Charger” alarm generated
27,129 of the 38,476 alarms in our review and programming or summary reporting could allow
the PPOs to only be notified if someone is not charging as required by board rules.
Requiring the PPOs to at least see all of the alarms increases the risk of missing important
alarms; however, without requiring PPOs to confirm alarms in VeriTracks, the board has no way
of knowing if the alarms are being reviewed by the PPOs. It seems the PPOs have too many
items to review and the task of reviewing or confirming alarms in VeriTracks is not completed
regularly. Not reviewing the alarms in VeriTracks could lead to some of the most violent
offenders and sex offenders not being monitored properly, which increases the risks to public
safety.
The Board of Probation and Parole and Department of Correction should finalize
protocols for offenders monitored using GPS that allow PPOs to focus on alarms that pose the
greatest risk to communities. Also, the board and the Department of Correction should work
with the Field Services Division and the vendor to determine how the information gathered by
the system can be more efficiently used by the PPOs. They may want to consider reporting
functions for offenders who do not meet charging requirements, summary reports of alarms that
clear themselves within 5 minutes, etc. They may also want to consider programming the system
to allow the PPOs to confirm alarms that meet charging requirements at one time and to confirm
alarms that clear themselves within a certain time frame.

The Division of Internal Audit and the Division of Research, Policy, and Planning
Duplicate Efforts in Completing Reviews of All Board Activity
The Division of Internal Audit and the Division of Research, Policy, and Planning in the
Board of Probation and Parole conduct compliance reviews and audits of board activity. A
review of the divisions’ methodologies and reports issued revealed some duplication of effort
and similarities in purpose and function.
During a review of a sample of reports from the Division of Internal Audit and the
Division of Research, Policy, and Planning, we found that some audit periods overlapped and
similar procedures were often performed in the areas of training and field services. We also
identified similarities in scope and overall purpose of the reviews and audits, which was to
determine compliance with applicable state laws and rules, regulations, and policies of the board.
We did note that the annual reviews were typically not as detailed as the internal audit reports.
Board policy requires the Division of Research, Policy, and Planning to perform annual
compliance reviews of all central office divisions or units and all field services, districts, and
areas or programs during each fiscal year. These reviews focus on compliance with current
office procedures and administrative policies of the board. State law authorizes the board to

formulate, develop, and implement policies and procedures; however, we determined the board
has not developed any policies for the Division of Internal Audit.
Based on interviews with management, an underlying cause for the duplication of efforts
among the divisions could be the absence of board policy for the Internal Audit function and a
lack of communication between the two divisions. The overlapping reviews by two different
divisions could result in inefficient use of state resources.
Our review occurred prior to the move of Field Services to the Department of Correction.
This transition may eliminate some instances of duplication of efforts; however, moving forward,
the board should determine the most efficient use of resources regarding internal reviews and
develop policies regarding the Division of Internal Audit.
At a minimum, the Board of Probation and Parole should consider posting internal audits
and compliance reviews on its intranet site so the results are readily accessible for board staff.
The board may also want to consider posting internal audits and compliance reviews on its
website.
We also noted that none of the fieldwork performed for the internal audits we reviewed
related to follow-up on prior audit findings from external audits. Per the narrative in the Audit
Schedules, the internal audit function is often used to correct issues as they occur and ensure that
issues are resolved prior to external audits to potentially avoid external findings. We recommend
that the internal audit function implement procedures to focus on activities in the area of
monitoring and correcting/resolving findings from external audits to prevent repeat findings.
The Research, Policy, and Planning audits cite board policy in their annual reviews, but
the internal audits do not cite statute or a governing board policy. We recommend that
applicable statute or board-approved policy be cited as the authority for all internal audits.

The Board’s Office of Victim Liaison Services Does Not Have an Effective System
for Evaluating or Even Measuring Completion or Success Rates for the Offenders
Referred to the Victim Impact and Courage to Change Classes
In addition to its primary role of working with victims, the Board of Probation and
Parole’s Office of Victim Liaison Services also administers the Victim Impact and Courage to
Change courses for offenders. Victim Impact is a 12-week evidence-based program that teaches
offenders about the human consequences of crime. The intent of this class is to discourage
offenders from committing new crimes by demonstrating how these actions affect them, their
families and friends, and their communities. Courage to Change is a 24-week batterers’
intervention program that is aimed at exploring and ending male violence against women. These
classes are administered by trained facilitators in the board’s district offices across the state.
As a best practice, the Office of Victim Liaison Services should measure the completion
rates for these programs and whether the classes are successful in deterring offenders from
committing new crimes.

According to the Director for the Office of Victim Liaison Services, the board does not
monitor the completion or success rates for program participants. Offenders in the Victim
Impact classes are required to complete surveys before and after attending the program. These
surveys can be scored to measure the changes in offenders’ understanding and attitudes toward
crime. However, based on discussion with the director, the Office of Victim Liaison Services
receives copies of these tests but does not perform any review of the results for the offenders in
the Victim Impact classes. For the Courage to Change program, the director stated that the office
only receives from the district offices rosters of offenders who have completed the program.
Based on case notes entered in the Tennessee Offender Management Information System
(TOMIS), we performed limited testwork on the offenders referred to these programs during
calendar year 2011 and the offenders who completed the program during calendar year 2011, as
summarized in the tables below. For those referred during calendar year 2011, we reviewed
TOMIS to determine if they had completed the program by May 31, 2012.
Program Referrals During Calendar Year 2011, Completed by May 31, 2012
Program

Completed

Victim Impact

Total Referrals During Calendar Year
2011 (Less Offenders Still Enrolled on
May 31, 2012)
223

Courage to Change

179

Percent
Completed
37%
33%

Of the 223 offenders who were referred to the Victim Impact program during 2011 (and
who were not still enrolled), 83 (37%) had TOMIS case notes that they had completed the
program as of May 31, 2012. For the Courage to Change program, 59 of 179 offenders (33%)
referred to the program in 2011 had TOMIS case notes showing they had completed the class by
May 31, 2012. However, in our review of separate listings of offenders noted as having
completed these programs during 2011, we found that, based on a review of TOMIS, many of
them lacked a program referral date. As noted in the table below, 102 of the 161 offenders
(63%) who completed Victim Impact and 63 of the 87 offenders (72%) who completed Courage
to Change did not have case notes that they had been referred to the programs. We discussed
this discrepancy with the Victim Liaison Services Director, who confirmed that all program
participants should have a referral date. (See additional information in Finding 6.)

Program Completions During Calendar Year 2011

Victim Impact

161

102

63%

Number
Arrested
Since
Completing
Program (as
of 5/31/12)
40

Courage to Change

72%

Program

Number
with No
Total
Program
Completed
Referral
Date

Percentage
with No
Program
Referral
Date

Percentage
Arrested
Since
Completing
Program (as
of 5/31/12)
25%
33%

In our review of TOMIS case notes for the offenders who completed the classes in 2011,
we found that 40 of the 161 who completed Victim Impact (25%) and that 29 of the 87 who
completed Courage to Change (33%) were, as of May 31, 2012, known to have been rearrested
after finishing the programs. While these statistics indicate that the programs have some
potential to reduce crime, we did not conduct a more detailed review of the offenders’ arrests
(e.g., verifying which arrests were for violence against women or other criminal violations) since
the board lacks any statistics that could be used for direct comparison.
The Office of Victim Liaison Services has not yet been able to measure the overall
success of the Victim Impact and Courage to Change programs (how much less likely those who
have completed the programs are to commit crimes) because of the problems with the TOMIS
data. Given the number of offenders who were labeled as having completed the program but
who did not have a program referral date, it appears that either facilitators are not entering all of
the required case notes in TOMIS or offenders are getting into the programs without first being
referred. Without accurate and complete data in TOMIS, the Office of Victim Liaison Services
cannot compile accurate statistics on the Victim Impact and Courage to Change programs. It
should also be noted that the Courage to Change classes began in January 2011. The recidivism
rate, which is considered to be the benchmark measurement of success in rehabilitating
offenders, is calculated as the percentage of offenders who are reincarcerated within three years
of having been released. While offenders are not necessarily referred to these programs
immediately upon their release, the board does not yet have a three-year time period to determine
if offenders have been rehabilitated since they have only recently completed the classes.
Without complete and accurate information in TOMIS, the Board of Probation and Parole
cannot effectively monitor individual offenders or large-scale programs such as Victim Impact
and Courage to Change. Unless the Office of Victim Liaison Services performs some type of
monitoring for the programs, it cannot determine the extent to which these programs are
successful in reducing crime and/or the changes that could be made to improve the efficacy and
the completion rates for these programs.
As a part of offering the Victim Impact and Courage to Change classes to offenders, the
Office of Victim Liaison Services should consider reviewing data including, but not limited to,
the following:



the number of offenders attending and completing these programs out of the total
number referred;



the reason that offenders who were referred to the programs were unable to attend or
complete them;



any available pre-/post-class surveys completed by the offenders; and



the post-class arrest histories for the offenders who have been referred to and who
have completed either of these classes.

Additionally, the facilitators in the board’s field offices should ensure that all of the
required case note entries are made in TOMIS regarding offenders’ referral, attendance, and
completion of these programs. If necessary, the board should work with the Department of
Correction, which maintains TOMIS, to ensure that edit checks and data validation tools are
developed for the system and that all of the logical, required case note entries are made.

Weaknesses in the Fee Collection Process Previously Noted in the June 2001 and
May 2006 Performance Audits and the 2007 Financial and Compliance Audit Still
Need to Be Rectified
The June 2001 and May 2006 performance audits and the June 2007 financial and
compliance audit found problems with the Board of Probation and Parole’s fee collection
process. The board concurred with our findings and responded with plans to correct weaknesses
in the process. In calendar year 2010, four internal audits of board districts found problems with
fee collections. There were also two internal audits of board districts in 2009 that found
problems with fee collections. These reports cover six of the eight board districts, suggesting a
continuing systemic problem.
When fieldwork on this audit began, the Director of Field Services stated that the fee
collection process had not changed since the May 2006 audit and the board was in process of
issuing a request for proposal (RFP) for a collection agency to take care of offender fee
collections. In 2012, legislation passed transferring offender supervision responsibilities to the
Department of Correction (TDOC). According to the Director of Field Services (previously at
the board, now at TDOC), the RFP and the building of an application regarding offender fees
were last discussed in January, when it was noted that policies and manuals would have to be
revised under TDOC before a new fee application could be built or an RFP issued.
Given that these same issues regarding fee collections have been raised in at least 3
different audits over the last 11 years, the board and Department of Correction should pursue a
solution to their fee collection and assessment problems as soon as possible.

RESULTS OF OTHER AUDIT WORK

JAG/ARRA Grant Agreement Implementation Status
In 2009, the Board of Probation and Parole received a Justice Assistance Grant through
the American Recovery and Reinvestment Act (JAG/ARRA) to procure, install, and implement
program evaluation software to enable the board and the Department of Correction to retrieve
data, monitor performance, evaluate programs, conduct predictive modeling, and analyze
statistical data. The grant also covered procurement and implementation of job readiness and
training software, KeyTrain, for assisting ex-offenders in obtaining employment.
The grant for $207,950 began on July 1, 2009, and ran until June 30, 2011, with
implementation of both software programs to be completed by May 2010. An amendment to the
grant was signed in March 2011, which changed the implementation date of the program
evaluation software to June 30, 2011, and reallocated funds to purchase hardware and upgrade
software.
Program Evaluation Software
As of July 2012, the program evaluation software is live, but only 50 users at the board
and TDOC can access the data in the software. The parts that are accessible include data on
population served, revocations, successful discharges of sentences, and community corrections.
Each section includes key performance indicators with bar charts and line graphs. The data can
also be reviewed by district, program, or probation and parole officer.
KeyTrain Software
The board had a one-year license to use the KeyTrain software from July 1, 2009,
through June 30, 2010, and did not renew the license because there were logistical issues with
the board’s staff being able to monitor offenders while they were using a computer and having
computer work space available. The software was designed to improve ex-offender’s skills in
the following areas:


reading for information;



applied mathematics;



locating information;



applied technology;



writing;



listening;



observation;



teamwork; and



business writing.

Upon successful completion of training and testing, the ex-offender would receive a career
readiness certificate. The grant agreement included two performance measures with one
specifically relating to the KeyTrain software regarding the percentage of those under Board of
Probation and Parole supervision who completed the software training, received the career
readiness certificate, and were employed either full-time or part-time. According to the Assistant
Director of Field Services, this program was one part of the board’s workforce development
effort and not a “stand-alone program” so statistical information regarding this program on its
own is not available.

RECOMMENDATIONS

ADMINISTRATIVE
The Board of Probation and Parole and the Department of Correction should address the
following areas to improve the efficiency and effectiveness of the operations of the board and the
Field Services Division (now part of the Department of Correction) .
1. While the number of offenders (82) actively monitored after their death is small
compared to the over 60,000 offenders monitored each year, the Board of Probation
and Parole (and now the Department of Correction) should consider regularly
comparing offender information to either state or U.S. Social Security Administration
death records.
2. The Board of Probation and Parole and the Department of Correction should work
with the Field Services Division and others within the agencies to develop a formal
corrective action plan which ensures the information in TOMIS is complete and
accurate. Specifically, the plan should focus on ensuring the following:


all drug screens and other offender interventions are properly documented in
TOMIS;



required arrest checks or verifications of continued incarceration/placement are
completed for offenders, including those not actively supervised by Field Services
staff;



notes indicating that offenders’ special conditions have been terminated are
entered only once during a supervision period, include the necessary details, and
are not followed by other special conditions notes;



all X-type case notes specify the reason that the supervision requirement was not
met as well as the planned corrective action, and are carefully reviewed to
determine the effectiveness of the corrective action and whether further action is
required;



risk assessments, including VASOR risk assessments for sex offenders, are
completed in a timely manner on all cases;



address and date of birth information is accurately maintained in TOMIS; and



all offender supervision requirements are otherwise being met.

3. The Board of Probation and Parole should thoroughly document specific disaster
recovery procedures and actions to be taken, from the declaration of a disaster until
the time that normal business operations are resumed. The plan should contain
adequate detailed information to permit staff to use it as a stand-alone field manual.
The plan should be reviewed, updated, tested, and reapproved as processes change
64

and, at a minimum, on an annual basis. The plan should be submitted to TEMA and
made readily available to board employees.
4. The Board of Probation and Parole should strengthen formal, written policies and
procedures for complying with the requirements for public meeting notices by
mandating the posting of meeting dates on its website, in field offices, and/or
advertising meeting dates in local newspapers. Implementing these procedures would
better ensure that board personnel and the general public are aware of the meetings of
the board. Further, the board should ensure its notices are posted at a time
sufficiently in advance of the actual meeting in order to give citizens both an
opportunity to become aware of and to attend the meeting.
5. The Director of Board Operations should collaborate with other divisions of the
Board of Probation and Parole such as Information Systems and Field Services (now
at the Department of Correction), to implement manual and automated controls to
strengthen existing parole hearing notification procedures in order to ensure
compliance with the statutes. Any revisions/updates should be made to the operating
procedures/manuals of the board and posted to the intranet. The board should also
revise the notification of hearing decision letters to include appeal rights for the
offender to ensure that the board’s communication of appeal rights to the offender is
documented.
6. The Board of Probation and Parole and the Department of Correction should work
together to ensure that appropriate edit checks and data validation tools are developed
and implemented for TOMIS.
7. The Board of Probation and Parole and Department of Correction should use all
available tools for monitoring to determine if supervisory reviews are being
completed. The board and Department of Correction should also ensure that the
supervisory reviews are discussed with PPOs as required by board directive.
8. The Board of Probation and Parole’s (now the Department of Correction’s) Field
Services Division management should ensure that PPOs and supervisors who are
reviewing ACRC cases impose sanctions for all violations. The Field Services
Division should also ensure that PPOs and supervisors enter OPHC case notes and
thoroughly document the sanctions that have been imposed. The Field Services
Division should consider incorporating a review of OPHC case notes and the
sanctions imposed into the supervisory reviews of case files. The Field Services
Division should also take the necessary steps to ensure that the ACRC chairpersons in
each district are maintaining adequate records of ACRC activities. The management
of the Field Services and the Research, Policy, and Planning Divisions should
document the requirements for the monthly ACRC reports and take whatever other
steps are necessary to ensure that these reports are properly submitted.

Appendix 1
Title VI and Other Information
In response to a request from members of the Government Operations Committee, we
compiled information concerning federal financial assistance received by the Board of Probation
and Parole, results of the Tennessee Human Rights Commission’s most recent review of the
board’s Title VI Implementation Plan, and demographic information on board members and
staff.
According to the state’s Budget documents, the Board of Probation and Parole did not
receive any federal funding for fiscal years 2010 and 2011, and no federal funding was estimated
to be received for fiscal year 2012.
According to the Tennessee Title VI Compliance Program Report to the Governor and
General Assembly for Fiscal Years 2009 to 2011, completed by the Tennessee Human Rights
Commission, a Title VI implementation plan must consist of the following sections:















an overview;
a description of the federal programs or activities;
the organization of the Civil Rights Office and duties of the Civil Rights
Coordinator;
data collection and analysis, including total number of complaints received;
definitions;
discriminatory practices;
Limited English Proficiency (LEP);
complaint procedures;
a compliance review of subrecipients;
compliance/noncompliance reporting;
a Title VI training plan;
public notice and outreach;
evaluation procedures of Title VI implementation; and
responsible officials.

The report lists the Board of Probation and Parole among 20 entities whose plans were in
compliance with the guidelines and requirements but notes that two of the plans were submitted
untimely. According to Human Rights Commission records, the board’s 2011 Title VI plan was
received on October 10, 2011, instead of the October 1 due date. Further, the Human Rights
Commission’s report does not show any Title VI complaints about the Board of Probation and
Parole received directly by the commission or reported by the board in its Title VI
Implementation Plan.
Detailed below is the breakdown of board members and staff by title, gender, and
ethnicity.

Board of Probation and Parole
Staff Ethnicity and Gender by Position
January 31, 2012
Title

Gender
Male Female
2
12
1
0
1
0
0
1
1
1
0
1
0
7
0
1
0
21
0
1
0
4
1
1
0
2
0
2
0
2
1
0
1
1
1
1
0
4
0
1
1
1
0
2
1
1
0
1
5
14
1
0
0
1
0
1
1
0
0
2
1
0
1
0
4
1
2
1
1
0
0
1
1
0
0
1
1
0

Account Clerk
Accountant 3
Accounting Manager
Accounting Technician 1
Accounting Technician 2
Administrative Assistant 1
Administrative Assistant 2
Administrative Assistant 3
Administrative Secretary
Administrative Services Assistant 2
Administrative Services Assistant 3
Administrative Services Assistant 4
Administrative Services Assistant 5
Administrative Services Manager
Attorney 3
Auditor 3
Clerk 2
Clerk 3
Correctional Program Director 1
Correctional Program Director 2
Correctional Program Manager 1
Executive Secretary 2
Fiscal Director 1
General Counsel 1
Graduate Associate
Grants Program Manager
Human Resources Analyst 1
Human Resources Analyst 2
Human Resources Director 2
Human Resources Manager 1
Human Resources Technician 2
Human Resources Technician 3
Information Resource Support Specialist 3
Information Resource Support Specialist 4
Information Resource Support Specialist 5
Information Officer
Information Systems Director 2
Legal Assistant
Parole Board Chairman

Ethnicity
Black White
3
10
0
1
0
0
0
1
0
1
0
1
2
4
0
0
10
11
1
0
3
1
1
1
1
1
1
1
1
1
0
1
2
0
1
1
1
3
1
0
1
1
1
1
0
2
0
1
10
9
0
1
1
0
0
1
0
1
2
0
0
1
0
1
1
4
1
2
0
1
0
1
0
1
0
1
1
0

Other
1
0
1
0
1
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

Title

Gender
Male Female
4
2
0
1
1
0
4
10
3
1
1
1
0
3
1
0
3
4
4
3
1
0
0
1
40
42
10
23
216
355
78
68
2
3
1
0
0
1
0
1
2
0
2
0
1
0
1
0
1
19
0
1
0
62
0
1
0
4
1
5
0
1
1
0
1
0
0
1
408
703

Parole Board Member
Parole Hearings Assistant Director
Parole Hearings Director
Parole Hearings Officer
Parole Hearings Regional Supervisor
Probation/Parole Administrator
Probation/Parole Assistant Field Director
Probation/Parole Board Executive Director
Probation/Parole Deputy District Director
Probation/Parole District Director
Probation/Parole Field Director
Probation/Parole Field Services Administrator
Probation/Parole Manager
Probation/Parole Officer 1
Probation/Parole Officer 2
Probation/Parole Officer 3
Probation/Parole Program Specialist
Probation/Parole Technical Services Director
Probation/Parole Training Director
Procurement Officer 2
Programmer/Analyst 3
Programmer/Analyst 4
Programmer/Analyst Supervisor
Property Officer 2
Psychiatric Social Worker 1
Psychiatric Social Worker 2
Secretary
Sentence/Docketing Technician 1
Sentence/Docketing Technician 2
Sentence/Docketing Technician 3
Statistical Analyst 3
Statistical Programmer Specialist 1
Statistical Programmer Specialist 2
Training Specialist 2

Black
2
0
0
4
1
1
1
0
2
0
0
1
31
16
162
50
3
1
1
0
0
0
0
0
9
0
20
0
3
4
1
1
0
1
361

Ethnicity
White
Other
4
0
1
0
1
0
10
0
3
0
1
0
2
0
1
0
5
0
7
0
1
0
0
0
51
0
17
0
403
6
94
2
1
1
0
0
0
0
1
0
2
0
2
0
1
0
1
0
10
1
1
0
42
0
1
0
1
0
1
1
0
0
0
0
1
0
0
0
734
16

Appendix 2
Performance Measures Information
As stated in the Tennessee Governmental Accountability Act of 2002, “accountability in
program performance is vital to effective and efficient delivery of governmental services, and to
maintain public confidence and trust in government.” In accordance with this act, all executive
branch agencies are required to submit annually to the Department of Finance and
Administration a strategic plan and program performance measures. The department publishes
the resulting information in two volumes of Agency Strategic Plans: Volume 1 - Five-Year
Strategic Plans and Volume 2 - Program Performance Measures. Agencies were required to
begin submitting performance-based budget requests according to a schedule developed by the
department, beginning with three agencies in fiscal year 2005, with all executive-branch agencies
included no later than fiscal year 2012. The Board of Probation and Parole began submitting
performance-based budget requests effective for fiscal year 2010.
Detailed below are the Board of Probation and Parole’s performance standards and
performance measures, as reported in the September 2011 Volume 2 - Program Performance
Measures.
Also reported below is a description of the agency’s processes for (1)
identifying/developing the standards and measures; (2) collecting the data used in the measures;
and (3) ensuring that the standards and measures reported are appropriate and that the data are
accurate.
Performance Standards and Measures
324.02 – Probation and Parole Services
Performance Standard 1
Improve the offender success rate by decreasing the percentage of probation offenders who are
revoked to 5.2%.
Performance Measure 1
Percent of total probation population served during the year whose community supervision status
is revoked during the fiscal year.
Actual (FY 2010-2011)
5.9%

Estimate (FY 2011-2012)
5.2%

Target (FY 2012-2013)
5.2%

Performance Standard 2
Improve the offender success rate by decreasing the percentage of parolees who are revoked to
6.8%.
Performance Measure 2
Percent of total parole population served during the year whose community supervision status is
revoked during the fiscal year.

Actual (FY 2010-2011)
8.3%

Estimate (FY 2011-2012)
6.8%

Target (FY 2012-2013)
6.8%

The Field Services Division is responsible for the direct supervision of felons granted parole, as
well as offenders sentenced to probation by the courts. Probation and parole officers supervise
the conduct and progress of probationers and parolees and report to the board and the courts on
the progress of those under their supervision.
According to the board, one of the best measures of community safety is how many offenders on
probation or parole are returned to prison as a result of revocation. A lower revocation
percentage rate should demonstrate a decrease in crimes committed along with fewer victims.
This measure should also reflect the quality of the supervision and the programming associated
with it.
Research, Policy, and Planning Division staff calculate the revocation rate using data entered
into TOMIS by probation and parole officers. The formula takes the number of revocations for a
period of time and divides it by the total population served during this same time period to arrive
at the revocation rate. The measures are reviewed at multiple levels at the Board of Probation
and Parole from the district directors to the board chairman. This information is also reviewed
by the Department of Correction. The board shares the calculation with the General Assembly
and the Governor and publishes it in its annual report.
The board does not have formal written procedures used to collect the data. Research, Policy,
and Planning staff discuss methodology in detail before any data is assembled and disseminated.
The staff place emphasis on consistency in methodology from year to year.
According to the board, TOMIS is very old technology that limits and makes statistical analysis
difficult. Analyzing data from TOMIS requires relying on one metric of whether an offender
was revoked or not. According to staff, it would be better if there were additional metrics for
cross-referencing offenders by offense, risk at the time of supervision, program referral, and
program completion, etc. Although there are plans to use a new program, staff stated it is “years
and a lot of money away from completion.” (See finding 6 on page 37 for further discussion of
issues noted with TOMIS during our review.)
324.04 – Community Corrections
Performance Standard 1
Improve offender success by decreasing the percentage of the total program population who are
revoked from the program prior to successful discharge to 8.9%.
Performance Measure 1
Percentage of total offender population who are revoked from the program prior to successful
discharge.
Actual (FY 2010-2011)
10.6%

Estimate (FY 2011-2012)
8.9%

Target (FY 2012-2013)
8.9%

The Community Corrections Program is a cost-lowering alternative to incarceration. The
program is intended to provide services and programs in local jurisdictions for eligible felony
offenders in lieu of incarceration in state penal institutions or local jails. State grant dollars fund
19 local agencies responsible for the programming for probationers sentenced by the courts.
Community Corrections personnel collect data from TOMIS entries monthly. The Research,
Policy, and Planning Division then assembles the data and calculations are made using the
following programs: Excel, Access, Statistical Analysis Software (SAS), and Statistical Package
for Social Sciences (SPSS), and eventually, Micro-Strategy.
The measure is calculated by dividing the number of revocations by the number of clients served
during the fiscal year.
There are three stages of review to ensure and verify the measures and calculations are
appropriate and accurate. In the first stage, the data are analyzed, compared, and researched for
accuracy by board staff. The second stage of review is done by middle management including
the Community Corrections Division directors and others. In the second stage of review, board
staff review the data collection, compare past calculations, and analyze the data to expose any
inaccuracies or inconsistencies. In the final review stage, the results are presented to
administrative level staff for review.

Appendix 3
Finding 2 Testwork Results by Grand Division
Eastern
Supervision
Requirements Met
Yes
No
N/A
Files Reviewed

Regular
35
4
5
44

%
90%
10%
100%

GPS
17
4
0
21

Face to Face Contacts by Tennessee Grand Division
Middle
West
%
81%
19%
100%

Requirements Met
Yes
No
N/A
Files Reviewed

%
89%
11%

GPS
11
10
0
21

%
97%
3%

GPS
27
9
0
36

100%

%
75%
25%
100%

Regular
18
4
11
33

Home Visits by Tennessee Grand Division
Middle

Eastern
Supervision
Requirements Met
Yes
No
N/A
Files Reviewed

Regular
31
1
11
43

%
52%
48%

Regular
12
8
24
44

Regular
41
3
0
44

Arrest/Incarceration/Placements Checks by Tennessee Grand Division
Eastern
Middle
West
%
GPS
%
Regular
%
GPS
%
Regular
%
GPS
93%
19
90%
40
93%
31
86%
29
88%
9
7%
2
10%
3
7%
5
14%
4
12%
4
0
0
0
0
0
100%
21 100%
43 100%
36 100%
33 100%
13

100%

%
64%
36%
100%

Regular
19
2
12
33

Drug Test by Tennessee Grand Division
Middle
Regular
%
GPS
%
Regular
5
42%
12
50%
5
7
58%
12
50%
4
31
12
24
43 100%
36 100%
33

100%

Regular
84
9
27
120

%
90%
10%
100%

GPS
54
16
0
70

%
77%
23%
100%

Total

Eastern
%
GPS
60%
10
40%
4
7
100%
21

100%

GPS
23
13
0
36

%
77%
23%

West

100%

%
71%
29%

%
86%
14%

100%

GPS
10
3
0
13

Regular
33
4
7
44

100%

Regular
25
4
14
43

%
82%
18%

Total

GPS
9
4
0
13

West
%
GPS
56%
3
44%
5
5
100%
13

%
69%
31%
100%

%
37%
63%
100%

%
69%
31%
100%

Regular
77
10
33
120

%
89%
11%

GPS
43
27
0
70

100%

Regular
22
19
79
120

Total
%
GPS
54%
25
46%
21
24
100%
70

Regular
110
10
0
120

Total
%
GPS
92%
59
8%
11
0
100%
70

%
61%
39%
100%

%
54%
46%
100%

%
84%
16%
100%

Supervision
Requirements Met
Yes
No
N/A
Files Reviewed

Regular
29
7
8
44

Eastern
%
GPS
81%
19%

14
7
0
21

100%

Requirements Met
Yes
No
N/A
Files Reviewed

Regular
31
6
7
44

Regular
36
3
5
44

%
84%
16%
100%

GPS
17
4
0
21

Eastern
%
GPS
92%
18
8%
3
0
100%
21

Eastern
Supervision
Requirements Met
Yes
No
N/A
Files Reviewed

Regular
2
0
42
44

67%
33%
100%

20
4
19
43

83%
17%
100%

22
14
0
36

61%
39%
100%

19
4
10
33

83%
17%

11
2
0
13

100%

%
85%
15%
100%

Regular
68
15
37
120

Employment Monitoring by Tennessee Grand Division
Middle
West

Eastern
Supervision
Requirements Met
Yes
No
N/A
Files Reviewed

Special Conditions Monitoring by Tennessee Grand Division
Middle
West
%
Regular
%
GPS
%
Regular
%
GPS

%
81%
19%
100%

Regular
25
3
15
43

%
89%
11%
100%

GPS
29
7
0
36

%
81%
19%
100%

Regular
20
2
11
33

%
91%
9%
100%

GPS
9
4
0
13

%
69%
31%

%
81%
19%

100%

Regular
4
0
39
43

%
100%
0%
100%

GPS
23
13
0
36

%
64%
36%
100%

Regular
2
0
31
33

%
100%
0%
100%

82%
18%

67%
33%

100%

47
23
0
70

100%

%
77%
23%
100%

Regular
76
11
33
120

100%

Regular
87
7
26
120

Total
%
GPS
93%
63
7%
7
0
100%
70

Sex Offender Treatment Monitoring by Tennessee Grand Division
Middle
West

GPS
17
4

100%

Total

Fee Monitoring by Tennessee Grand Division
Middle
West
%
Regular
%
GPS
%
Regular
%
GPS
86%
30
94%
35
97%
21
91%
10
14%
2
6%
1
3%
2
9%
3
11
0
10
0
100%
43 100%
36 100%
33 100%
13

%
100%
0%

Total
%
GPS

GPS
3
9
1
13

%
87%
13%

GPS
55
15
0
70

%
79%
21%
100%

%
90%
10%
100%

Total
%
25%
75%
100%

Regular
8
0
112
120

%
100%
0%
100%

GPS
43
26
1
70

%
62%
38%
100%

Requirements Met
Yes
No
N/A
Files Reviewed

Requirements Met
Yes
No
N/A
Unable to Determine
Files Reviewed

Regular
35
4
5
44

Regular
0
1
42
1
44

Eastern
%
GPS
90%
14
10%
5
2
100%
21

LS/CMI Risk Assessments by Tennessee Grand Division
Middle
West
%
Regular
%
GPS
%
Regular
%
GPS
74%
29
97%
30
86%
23 100%
6
26%
1
3%
5
14%
0
0%
7
13
1
10
0
100%
43 100%
36 100%
33 100%
13

Eastern
%
GPS
0%
2
100%
1
14
4
100%
21

VASOR Assessments by Tennessee Grand Division
Middle
West
%
Regular
%
GPS
%
Regular
%
GPS
67%
0
0%
3
19%
0
0%
1
33%
2 100%
13
81%
0
0%
5
39
15
31
6
2
5
2
1
100%
43 100%
36 100%
33
0%
13

%
46%
54%
100%

%
17%
83%

100%

Regular
80
12
28
120

Total
%
GPS
87%
50
13%
17
3
100%
70

Regular
0
3
112
5
120

Total
%
GPS
0%
6
100%
19
35
10
100%
70

%
75%
25%
100%

%
24%
76%

100%