Thank you, Committee Chairs and members, for the opportunity to speak to you this morning on the Office of Inspector General’s (OIG) audit of the Juvenile Intervention and Support Center (JISC). The JISC operates as a partnership between the Chicago Police Department (CPD) and Department of Family and Support Services (DFSS), implemented to divert youth arrested for low-level offenses away from the juvenile justice system and into social service case management. The objectives of the audit were to determine if JISC is designed according to best practices for law enforcement-based youth diversion and if JISC’s administration of diversion programming is consistent with its goals, including reducing youth recidivism.
A. OVERVIEW
OIG concluded that although JISC has been in operation since 2006, the City still does not know whether the program is meeting its stated goal of reducing recidivism. This uncertainty is due to poor record-keeping and a lack of collaboration among the JISC program partners. Additionally, components of JISC’s design do not align with best practices for youth diversion programs, and because of it, law enforcement informed and oriented staffing and protocols may actually retraumatize youth or increase their likelihood of reoffending.
B. FINDINGS
Among other things, our audit found that the JISC program partners cannot reliably assess the case management program’s effect on youth recidivism due to poor record-keeping and communication among program partners. The contracted case management agency overseen by DFSS—SGA Youth & Family Services (SGA)—did not keep complete and consistent records of its cases, and CPD destroyed youth screening records in violation of the Local Records Act. In addition to poor records management, performance measures of the program’s impact are exacerbated by the fact that DFSS and CPD have resisted sharing program data with each other and with the public. As a result, the two agencies have operated JISC for almost fourteen years without demonstrating evidence of its effectiveness. Moreover, CPD and DFSS have had different visions for JISC and have found it difficult to come to a shared understanding of the program’s purpose and goals. That disconnect is abetted by the fact that the JISC has operated with no charter, memorandum of understanding, or governing board to establish goals and accountability measures. JISC cannot function effectively without collaboration between the partner agencies and other relevant stakeholders.
OIG also found that because JISC is not designed according to best practices for youth diversion programs, it subjects youth to a negative experience that does not encourage their success. The JISC facility does not present a trauma-informed setting; it operates much like a traditional police station. CPD staff bid for positions at JISC based on seniority rather than experience or aptitude for working with youth, and they receive no specialized training. CPD does not use an empirically validated screening tool to determine which youth to offer diversion through JISC. Further, less than half of referrals to SGA for case management are made in person; the resulting cold handoffs undermine a crucial feature of the program.
Lastly, OIG found that the existence of JISC is probably not leading officers to arrest more juveniles than they otherwise would, and that the vast majority (89.9%) of eligible arrestees were brought to JISC for processing. However, while we found that JISC is diverting many youth from court, we also found inequities in the process for determining which JISC arrestees were diverted from further involvement in the justice system, and that, in 34.7% of cases, SGA recommended social services to youth that did not need it. SGA acknowledged that sending low-needs youth to unnecessary services may do more harm than good and could ultimately increase the risk of recidivism.
C. RECOMMENDATIONS
OIG recommended that CPD and DFSS improve their record-keeping procedures and collaboration. This should include creating accountability mechanisms for JISC’s case management contractor and the establishment of partnerships with external agencies. OIG also urged CPD and DFSS to engage with community organizations, subject-matter experts, and criminal justice system stakeholders to bring JISC’s design into accordance with best practices for diversion programs and to provide a more trauma-informed experience for youth. Additionally, OIG recommended that CPD also select and train its JISC staff in accordance with best practices, use a validated risk screen to determine diversion eligibility, and ensure that disposition overrides are justified and equitable.
D. CPD AND DFSS’ RESPONSE
CPD and DFSS mostly agreed with OIG’s recommendations. However, CPD did not confirm whether it intended to notify the Local Records Commission of its failure to retain JISC risk screening forms per the Local Records Act. Both departments report that they have begun corrective actions, noting that the Mayor’s Office has convened an advisory council to oversee JISC reform efforts. In taking that important step, the City should assure participation of and input from experientially informed critical perspectives from relevant legal and policy advocate organizations.
Additionally, CPD and DFSS represent having engaged the University of Chicago Crime Lab to assist with ongoing data tracking and evaluation, and having begun to improve their case management and risk screening records and tools. The involvement of such analytical and policy expertise is critical, but we would be remiss in failing to highlight, as noted in the audit report, that prior engagements of the Crime Lab in connection with this program have faltered due to inadequate data quality and access.
Finally, the departments also stated their intention to redesign the JISC facility to create a more welcoming and less detention-focused environment, to select and train officers with the skills and aptitudes suited for working with youth, and to engage with other stakeholder agencies in the juvenile justice field and the broader community.
In sum, we find those responses and commitments to be a meaningful acknowledgement of past program shortcomings and an embrace of the opportunity to reform alternative diversion options for low-risk youth better served through social and community support and guidance. However, hearings such as this, are a critically important means of assuring that all options are explored and all voices and perspectives heard and factored into the creation of a program that best serves the needs of the eligible juvenile population.