Chicago Police Department and Department of Family and Support Services’ Administration of the Juvenile Intervention and Support Center Audit Follow-Up

The City of Chicago Office of Inspector General (OIG) has completed a follow-up to its February 2020 audit of the Chicago Police Department (CPD) and Department of Family and Support Services’ (DFSS) administration of the Juvenile Intervention and Support Center (JISC). Based on the Departments’ responses, OIG concludes that CPD and DFSS have fully implemented 12 of the 24 corrective actions related to the audit findings, substantially implemented 3, partially implemented 6, and not implemented 3.

The purpose of the 2020 audit was to determine whether JISC was designed according to best practices for law enforcement-based youth diversion and whether its administration of diversion programming was consistent with its goals, such as reducing youth recidivism. The audit concluded that although JISC had been in operation since 2006, the City still did not know whether the program met its goal of reducing recidivism. This uncertainty was due to poor recordkeeping and a lack of collaboration among the JISC program partners. Additionally, components of JISC’s design did not align with best practices for youth diversion programs and ran the risk of retraumatizing youth or increasing their likelihood of reoffending.

Based on the results of the audit, OIG recommended that CPD and DFSS improve their record-keeping procedures and collaboration efforts. We stated that the departments should create accountability mechanisms for JISC’s case management contractor and establish partnerships with external agencies. We also recommended that CPD and DFSS engage with community organizations, subject-matter experts, and criminal justice system stakeholders to align JISC’s design with best practices for diversion programs and to provide a more trauma-informed experience for youth. Finally, we recommended that CPD 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. In their responses to the audit, CPD and DFSS described corrective actions they would take. The departments stated, however, that they would not enact some of the recommended corrective actions because the City planned to replace JISC with a new diversion model in 2022.

In April 2021, OIG inquired about corrective actions taken by CPD and DFSS in response to the audit. Based on the departments’ follow-up responses, OIG concludes that CPD, DFSS, and the Office of the Mayor have implemented corrective actions related to program goals and responsibilities, performance review procedures, training, and adjustments to the diversion process. Specifically, the City has,

  • defined on-site protocols with other JISC stakeholders, outlining shared goals, individual roles and responsibilities, and procedures for reporting and monitoring;
  • contracted with a new case management service provider which uses a system with data accuracy controls and outcome tracking and reporting mechanisms;
  • included a youth case management referral range based on historical referral rates in the contract;
  • contracted with the University of Chicago Crime Lab to conduct recidivism and outcome analyses;
  • updated a directive and related instructions to ensure that JISC risk screens are sent to CPD’s Youth Investigations Division;
  • provided written guidance regarding record retention requirements to all JISC personnel;
  • provided training for JISC staff on topics related to youth diversion;
  • adjusted the case management agency’s on-site hours based on youth arrest data;
  • implemented procedures for transferring cases between CPD and the case management agency, including a reconciliation process to ensure referrals are not lost;
  • formed a Youth Diversion Advisory Council to monitor the JISC program and reforms;
  • engaged with community stakeholders via interviews and workshops conducted by third parties;
  • implemented a process for offering youth services without the threat of prosecution;
  • informed field officers in JISC districts that they must bring eligible arrestees to JISC;
  • developed informational materials about diversion opportunities and posted them at the JISC facility and JISC district stations; and
  • contractually revised needs assessment procedures to avoid the risk of net widening.

Once fully implemented, OIG believes the corrective actions may reasonably be expected to resolve the core findings noted in the audit. We urge the City to fully implement corrective actions related to our recommendations, to include,

  • notifying the Local Records Commission of CPD’s failure to retain JISC risk screens;
  • adding input controls to its system to ensure that detectives complete all youth screening fields;
  • avoiding handcuffing youth to stationary objects unless necessary;
  • recording and tracking the practice of handcuffing youth in CPD’s database;
  • working with the relevant unions to revise its selection process, allowing officers skilled at working with youth to be selected for JISC positions;
  • utilizing an empirically validated risk screening tool;
  • periodically reviewing processed JISC arrests and dispositions by associated personnel to identify patterns in diversion and override decisions;
  • ensuring that supervisors review and approve diversion decisions in real time; and
  • offering youth processed at district stations the same diversion opportunities as JISC-processed youth.