GEO GROUP RESPONSE TO HOUSE COMMITTEE ON OVERSIGHT AND REFORM STAFF REPORT REGARDING IMMIGRANT DETAINEE HEALTHCARE

Last month, the House Committee on Oversight and Reform released a staff report addressing medical care at ICE-contracted facilities. While we welcome the staff’s efforts in performing their proper oversight function and reviewing the healthcare services provided at ICE-contracted facilities, including several of GEO Group’s facilities, we believe that this report fails to present necessary information and context related to the services we provide and the standards mandated by our contracts.

GEO’s Health Services Division

GEO Health Services’ mission is to manage the health care of patient populations in our ICE processing centers with compassion and competence. We strictly follow the requirements of our contracts, the federal government’s Performance-Based National Detention Standards (PBNDS), internal and government agency policies. We adhere to the standards established by national accreditation agencies, such as the American Correctional Association and the National Commission on Correctional Health Care at our ICE processing centers.

We think it is important to point out the difference in contractual staffing requirements at GEO’s ICE processing centers compared to state correctional facilities that GEO operates on behalf of state criminal justice agencies throughout the country. The additional staffing at GEO’s ICE processing centers meets the PBNDS that were heavily revised under President Obama’s administration and that remain in effect today.

Overall facility staffing at GEO’s ICE processing centers is approximately 30 percent more than at GEO operated state correctional facilities. This difference is the direct result of the enhanced requirements set by ICE versus the requirements set by our state  government partners. ICE requires the additional staffing to provide more services and transportation support for ICE detainees. Further, healthcare staffing at GEO’s ICE processing centers is approximately 117 percent more than what is contractually required at GEO’s state-level correctional facilities. The additional healthcare staffing is required by ICE to provide a high-level of treatment for detainees who often have numerous health and mental health needs due to arriving from countries with limited healthcare services. GEO has initiated the implementation of an electronic health records system and virtual visits with medical and mental health providers to support its healthcare services to detainees at four of our ICE facilities.

The healthcare needs of the individuals placed into our care are often significant. Those needs can include acute or chronic healthcare conditions and mental health issues. However, according to statistics from the U.S. Department of Justice, the mortality rate in state correctional facilities averages 256 per 100,000 inmates. In the federal prison system, the average mortality rate is 225 per 100,000 inmates. By comparison, the mortality rate at ICE processing centers is significantly lower at less than three per 100,000 detainees.

Since 2014, GEO has provided 2,677,170 medical screenings to those who have been admitted into our facilities across the country; beginning upon intake and continuing throughout until release from the facility. These screenings include medical, mental health and dental evaluations. The screenings and evaluations include regular physical, immunizations, lab tests, and patient education.

Importantly, GEO’s healthcare program has materially improved detainee health. The following are just a few examples of cases where our health services’ intervention prevented an adverse outcome:

  • A twenty-five year old patient from the Adelanto ICE Processing Center arrived feeling poorly. After his medical examination, the healthcare team determined that he had a high white blood cell count. Soon afterwards, he was diagnosed with acute leukemia. He received quick treatment from outside oncologists and was admitted to an outside hospital for three months during his first round of chemotherapy. ICE released him from custody to continue his treatments in the community.
  • A detainee is his forties was scheduled to spend one night at the Adelanto ICE Processing Center; that night, he suddenly developed episodes of vomiting. He was immediately sent to an outside hospital, where a scan unfortunately revealed brain cancer. He was immediately sent for surgery. He was subsequently released from the hospital and cared for in our infirmary. ICE later released him in stable condition to continue his treatments.
  • A detainee at the Aurora ICE Processing Center arrived with a history of acute heart failure and severe cardiomyopathy. He was initially scheduled by ICE to attend a court appearance after completing the intake process, and, three days later, for a visit to the hospital for a cardiac evaluation and procedure to implant a cardioverter­ defibrillator (ICD). However, during his intake evaluation he complained of chest pain. Because of his cardiac history, the physician and nurse practitioner immediately sent him, via ambulance, to the hospital. The quick action to have this procedure done may have reduced his risk of a heart attack.

GEO’s Team of Healthcare Professionals

GEO healthcare services are performed under the oversight of the GEO Healthcare Division located in our corporate headquarters in Boca Raton, Florida. The division is robustly staffed by healthcare professionals and performs numerous functions, including, but not limited to: monitoring staff vacancies, clinical outcomes, special incidents, clinical encounters, outside patient care, medication management, and implementing updates to clinical guidelines.

GEO’s Chief Medical Officer is a licensed physician with forty years of clinical experience in primary care, who leads a team of twenty-one corporate health services professionals and over 400 facility health care professionals nationwide. In our corporate office, the vice president of Health Services Operations is a physician with nearly thirty years of experience with the Federal Bureau of Prisons. GEO’s Chief of Nursing has approximately twenty-five years of experience in correctional medicine. Our senior director of Health Service Operations and director of Health Services have a combined sixty-five years of correctional healthcare experience.

Under the supervision of our vice president of Health Services Operations, three regional healthcare directors oversee a team of regional healthcare managers who regularly visit our facilities’ health services units throughout the year to support each facility’s medical staff. To further enhance and complement our corporate team, we have added an infectious disease nurse and an Electronic Healthcare Records (“EHR”) nursing specialist, who is an expert in electronic medical records, as our company has embarked on placing EHR systems in all our GEO facilities. Additionally, GEO’s corporate mental health team is led by a senior director of Behavioral Health and three PhD psychologists.

Delivering High Quality Healthcare Services in Our Facilities

Our skilled, licensed physicians and mid-level providers in each of our facilities are assisted by a staff consisting of registered nurses, licensed practical nurses, mental health care providers, and dentists who address the health care needs of our patients. Many of ICE’s detainees arrive at our facilities without years of basic healthcare screenings and treatments. As required by ICE, GEO’s healthcare team performs initial health screenings within twelve hours of a detainee’s admission to a facility. Next, within fourteen days of admission a comprehensive health assessment is completed. If a facility’s healthcare team determines that an individual’s medical needs require further or specialized evaluation or treatment, he or she is quickly scheduled to be seen by an outside medical provider or specialist.

At every ICE processing center, all individuals have 24/7 access to healthcare services. They are given the opportunity to submit oral or written healthcare requests at any time. These requests are triaged each day by healthcare staff to ensure ill individuals are treated appropriately.

All individuals in our care also have the right to refuse or question the healthcare they are receiving through an established grievance process. This process is an important component of our quality control program. The grievance process is carefully explained to all individuals in our care during the admission process and is detailed in the facility’s detainee handbook.

Suicide risk assessment and prevention is also a very important objective of ICE’s PENDS and our mental health program. Accordingly, our suicide prevention program is clearly defined in policies and procedures, and serves to minimize the occurrence of a suicide by reducing risk of self-harm or self-destructive individual behaviors.

GEO’s Efforts to Combat COVID-19

Informed by ICE’s Guidance on COVID-19, at the outset of the unprecedented coronavirus pandemic we rapidly implemented mitigation initiatives to prevent, detect, and mitigate the spread of COVID-19 among both our employees and the individuals in our ICE processing centers.[1] We have further detailed our comprehensive efforts to combat COVID-19 at https://www.geogroup.com/covid19.

By using an aggressive COVID-19 testing policy, we are able to identify infected detainees and follow their clinical status daily as they are placed in isolation. Those with a history of exposure to COVID are properly quarantined and monitored as recommended by Centers for Disease Control and Prevention (CDC) guidelines.

To date, our results have been successful. Throughout the pandemic, only one ICE detainee in our care has regrettably succumbed to COVID-19. Others who have contracted the virus have been treated, and the overwhelming majority have fully recovered.

GEO’s Contract Compliance Department

To provide a consistent industry-leading level of quality and safety, GEO requires its facilities to operate in compliance with strict governmental detention standards, national accreditation and certification standards, medical accreditation agencies, educational agencies, and the contractual requirements of our government customers. We take our responsibility to meet these goals very seriously. To ensure that we meet these requirements, GEO implemented a comprehensive quality control plan. This plan is coupled with our commitment to respect the human rights of all persons in our care.

GEO has an independent Corporate Contract Compliance Department that provides the overall direction and oversight of operational compliance for the company’s domestic operations. The Contract Compliance Department reports directly to the Chairman and Chief Executive Officer. Based out of GEO’s Corporate Headquarters, the Contract Compliance Division is led by an Executive Vice President and Vice President each with over twenty years of legal, compliance, and law enforcement experience. They are supported by forty-two subject matter experts in security, medical, American Correctional Association (ACA) accreditation, the Prison Rape Elimination Act (PREA), The Joint Commission, National Commission on Correctional Health Care (NCCHC), ICE’s PBNDS, DOJ’s Federal Performance-Based Detention Standards (FPBDS), and multiple other agency standards.

The Contract Compliance Department provides ongoing compliance oversight with in-depth reviews and audits conducted monthly, quarterly, and annually as well as on an ad hoc basis. GEO’s Contract Compliance and Quality Control Program is embedded throughout the company’s operations with corporate, regional, and facility support staff having distinct roles in the oversight and review process. In broad terms, the process consists of rigorous audits, collaborative post-audit workshops that develop meaningful corrective action plans, and continuous follow-up on all non-compliant findings regardless of whether the finding stems from a GEO, ICE, or a third-party audit.

To produce precise reviews of a facility’s performance, GEO’s Contract Compliance Department develops thorough audit tools that systematically review all of a facility’s operational areas based on GEO policies, ICE policies, and ICE detention standards. This monitoring program is referred to as GEO’s Quality Control Program (QCP).

We acknowledge, as is noted in the staff report, that our audits do find our facilities non­compliant on occasion. What the report does not describe are the steps GEO takes to correct those findings and to reach ongoing compliance moving forward. GEO takes its performance seriously, and when we find an area in need of improvement, we work hard to fix problems quickly and transparently.

GEO’s Quality Control Framework

  1. The first phase of GEO’s quality control framework is our audits. GEO’s auditing is led by Contract Compliance Department staff working alongside field-based subject matter experts. Contract Compliance-led audit teams travel to facilities across the country, conducting annual reviews and engaging with staff to study each specific operation. Each facility also employs compliance personnel responsible for auditing daily internal operations according to the QCP, forwarding findings and proposing corrective action plans to be approved by the Contract Compliance Department. Following this audit, the Contract Compliance Department ensures that stakeholders at all levels remain invested in positive developments at our facilities between annual audits.
  2. At the close of the audit, the second phase begins through the Post-Audit Workshop. The workshops assist in identifying root causes, implementing appropriate corrective measures, and detailing effective follow-up activities to be conducted by facility staff. This approach empowers facility staff to promptly initiate plans to resolve the deficiencies. The post-audit workshop also serves as a training opportunity for regional and facility staff.
  3. The third phase of GEO’s QCP begins with the follow-up reviews that are conducted at designated intervals following an annual audit. The Contract Compliance Department tracks the follow-up and reviews new samples to determine if a finding can be closed. Each facility is responsible for implementing the QCP and for ongoing monitoring and evaluating the agreed upon corrective action plans while Operations work towards the remediation or closure of those findings. To assist in remediation, the Client Concerns Log (CCL) is regularly provided to the operational team. Every other month, the facilities report on the progress of their remedies. The Contract Compliance team reviews the facilities’ reports and open items. The facility staff provide evidence or proof of the remedial activities that Contract Compliance will review and close findings as they become compliant. All remaining non-compliant items will be subject to continued review and oversight. Additionally, Contract Compliance may review any previously identified non­compliant items during follow-up or annual activities.

We appreciate the opportunity to share this information with the Committee in order to provide additional perspective as to the role we play as a services provider to ICE, as well as to the professional commitment our healthcare staff have toward our mission of providing high quality healthcare to those entrusted to our care at these facilities.

[1] See generally https://www.ice.gov/coronavirus

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