S.H. v. Reed - Order Approving Seclusion Agreement - 5-21-14

) ) ) ) ) ) ) )

UNITED UNITED STATES STATES OF OF AMERICA, AMERICA,

Plaintiff, Plaintiff,

v. v.

THE THE STATE STATE OF OF OHIO, OHIO, etaL, et aL,

Defendants. Defendants.

) ) ) ) ) ) ) ) )

JUDGE JUDGE ALGENON ALGENON L. L. MARBLEY MARBLEY

AGREED AGREED ORDER ORDER

--- ---- ------

S.H., S.H., et et aI., al.,

Plaintiffs, Plaintiffs,

v. v.

HARVEY HARVEY J. J. REED, REED, Defendant. Defendant.

UNITED UNITED STATES STATES DISTRICT DISTRICT COURT COURT SOUTHERN SOUTHERN DISTRICT DISTRICT OF OF OHIO OHIO

EASTERN EASTERN DIVISION DIVISION

) ) ) ) ) ) ) )

CIVIL CIVIL ACTION ACTION NO. NO. 2:04-cv-1206 2:04-cv-1206

) ) ) ) ) ) ) ) ) )

CIVIL CIVIL ACTION ACTION NO. NO. 2:08-cv-475 2:08-cv-475

On On February February 18,2014, 18, 2014, Plaintiffs Plaintiffs in in S.H S.H v. v. Reed Reed filed filed a a motion motion for for specific specific performance performance

(Doc (Doc 389), 389), and and alleged alleged a a failure failure "to "to provide provide adequate adequate treatment treatment to to youth youth who who are are or or have have been been on on

the the mental mental health health caseload. caseload. As As a a result result many many of of these these youth youth are are experiencing experiencing excessive excessive periods periods

of of seclusion seclusion .... .... " " ld Id at at p. p. 1. L On On March March 12, 12, 2014, 2014, the the United United States States filed filed a a motion motion for for a a

temporary temporary restraining restraining order order in in United United States States v. v. Ohio Ohio raising raising concerns concerns about about Defendants' Defendants' use use of of

seclusion seclusion for for all all youth youth with with an an identified identified mental mental health health disorder. disorder. (Doc (Doc 131 131). ). The The United United States States

also also filed filed a a supplemental supplemental complaint. complaint. (Doc (Doc 140). 140).

Shortly Shortly thereafter, thereafter, the the parties parties engaged engaged in in settlement settlement negotiations negotiations aimed aimed at at addressing addressing the the

issues issues raised raised in in those those filings. filings. The The Court Court hereby hereby consolidates consolidates these these actions actions under under Fed Fed R. R. Civ. Civ.

Proc. Proc. 42. 42. They They shall shall retain retain their their separate separate status status but but be be consolidated consolidated for for the the purpose purpose of of case case

Case: 2:08-cv-00475-ALM-MRA Doc #: 148 Filed: 05/21/14 Page: 1 of 6 PAGEID #: 3130

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management and and monitoring. monitoring. The The terms terms of of this this Order Order are are intended intended to to be be implemented implemented consistent consistent

with with Docs Docs 108 108 and and 359 359 in in S.H S.H v. v. Reed Reed and and with with Doc Doc 85 85 in in United United States States v. v. Ohio. Ohio.

Attached Attached as as Exhibit Exhibit A A to to this this Order Order is is the the agreed agreed grid grid that that details details the the actions actions Defendants Defendants

will will undertake undertake to to improve improve mental mental health health services services and and reduce reduce seclusion seclusion of of youth youth who who are are on on the the

mental mental health health caseload. caseload. The The actions actions and and deadlines deadlines included included in in the the attached attached grid grid are are hereby hereby

incorporated incorporated into into this this Order. Order. Defendants' Defendants' compliance compliance with with those those terms terms will will be be co-monitored co-monitored by by

Mr. Mr. Will Will Harrell Harrell and and Dr. Dr. Kelly Kelly Dedel Dedel under under the the Court's Court's jurisdiction, jurisdiction, and and monitoring monitoring will will

continue continue until until Defendants Defendants have have maintained maintained substantial substantial compliance compliance with with all all provisions provisions and and

performance performance measures measures for for six six months. months.

Upon Upon entry entry of of this this Order, Order, Plaintiffs Plaintiffs in in S.H S.H v. v. Reed Reed agree agree to to withdraw withdraw their their pending pending

motions motions (Docs (Docs 389 389 and and 390) 390) without without prejudice. prejudice. The The United United States States agrees agrees to to withdraw withdraw without without

prejudice prejudice its its renewed renewed motion motion for for a a temporary temporary restraining restraining order. order. (Doc (Doc 145). 145). Because Because Defendants Defendants

have have committed committed to to the the eventual eventual elimination elimination of of disciplinary disciplinary seclusion seclusion for for all all youth youth housed housed in in a a

DYS DYS facility facility and and to to engage engage with with the the monitors monitors and and subject subject matter matter experts experts within within six six months months

hereof hereof to to formulate formulate steps steps to to reach reach that that goal, goal, the the United United States States also also agrees agrees to to withdraw withdraw without without

prejudice prejudice the the claims claims in in its its supplemental supplemental complaint complaint concerning concerning youth youth who who are are not not on on the the mental mental

health health caseload. caseload. (Doc (Doc 140). 140). The The United United States States agrees agrees that that it it may may not not renew renew those those claims claims until until

one one month month after after the the effective effective date date of of a a request request that that this this Court Court conduct conduct a a conference conference with with the the

United United States States and and the the Defendants Defendants regarding regarding a a resolution resolution ofthe of the United United States' States' claims claims and and that that the the

effective effective date date for for a a conference conference request request shall shall be be no no sooner sooner than than seven seven months months from from the the date date of of this this

Order. Order.

On On a a quarterly quarterly basis basis starting starting July July 31, 31, 2014, 2014, DYS DYS will will provide provide AMS AMS reports reports for for youth youth not not

on on the the MHCL, MHCL, but but who who were were held held in in seclusion seclusion for for an an act act of of violence, violence, that that will will contain contain a a narrative narrative

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of the the incident incident resulting resulting in in seclusion, seclusion, the the AMS AMS number, number, the the date date and and time time the the youth youth went went into into

seclusion seclusion and and the the date date and and time time the the youth youth was was released released from from seclusion, seclusion, the the date date the the youth youth entered entered

DYS, DYS, the the date date the the youth youth was was released released from from DYS DYS (if (if youth youth has has been been released) released) and and the the type type of of

seclusion. seclusion. On On July July 31, 31, 2014, 2014, DYS DYS shall shall send send the the monitors monitors such such documents documents from from May May 1, 1, 2014 2014 to to

July July 30, 30, 2014. 2014. These These documents documents will will be be provided provided quarterly quarterly until until DYS DYS reaches reaches substantial substantial

compliance compliance with with regard regard to to seclusion, seclusion, or or the the lawsuit lawsuit terminates, terminates, whichever whichever occurs occurs first. first. The The

monitors monitors may may share share this this information information with with counsel counsel for for the the United United States States and and SH. S.H Plaintiffs. Plaintiffs.

The The following following areas areas are are hereby hereby removed removed from from monitoring: monitoring: psychotropic psychotropic medication, medication,

sufficiency sufficiency of of psychiatric psychiatric resources, resources, and and equitable equitable treatment. treatment. The The remaining remaining areas areas of of monitoring monitoring

(QAlQI (QA/QI and and peer peer review review for for mental mental health health and and psychiatry, psychiatry, case case formulation, formulation, fidelity fidelity of of treatment treatment

provided provided to to treatment treatment model, model, treatment treatment planning planning and and treatment treatment teams, teams, behavior behavior contracts, contracts, suicide suicide

prevention, prevention, and and discipline discipline for for youth youth on on the the mental mental health health case caseload load through through the the intervention intervention

hearing hearing process) process) are are addressed addressed by by the the grid grid and and will will be be monitored monitored in in accordance accordance therewith. therewith.

This This Order Order is is necessary necessary to to address address and and redress redress ongoing ongoing constitutional constitutional violations violations already already

found, found, and and the the relief relief set set forth forth herein herein is is narrowly narrowly drawn, drawn, extends extends no no further further than than necessary, necessary, and and is is

the the least least intrusive intrusive means means to to do do so. so. Defendants Defendants may may seek seek to to terminate terminate this this Order Order no no earlier earlier than than

July July 15,2015 15, 2015 at at which which time time the the SH. S.H Plaintiffs Plaintiffs and and United United States States shall shall bear bear the the burden burden of of proof proof to to

demonstrate demonstrate the the existence existence of of an an ongoing ongoing violation violation of of federal federal law law and and that that the the current current order order

reflects reflects narrowly narrowly drawn drawn relief relief which which extends extends no no further further than than necessary necessary and and is is the the least least intrusive intrusive

means means to to remedy remedy that that violation. violation.

IT IT IS IS SO SO STIPULATED STIPULATED AND AND AGREED AGREED FOR FOR S.H. S.H. PLAINTIFFS: PLAINTIFFS:

DATE: DATE: May May 20,2014 20,2014

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sf Alphonse Alphonse A. A. Gerhardstein Gerhardstein sf s/Kim Kim Brooks Brooks Tandy Tandy ALPHONSE ALPHONSE A. A. KIM KIM BROOKS BROOKS TANDY TANDY GERHARDSTEIN GERHARD STEIN (Ohio (Ohio Bar Bar No. No. 0076173) 0076173) (Ohio (Ohio Bar Bar No. No. 0032053) 0032053) Attorney Attorney for for Plaintiffs Plaintiffs Trial Trial Attorney Attorney for for Plaintiffs Plaintiffs Children's Children's Law Law Center, Center, Inc. Inc. Gerhardstein Gerhardstein & & Branch Branch Co. Co. LP LP A A 104 1 04 East East 7th 7th Street Street 432 432 Walnut Walnut Street, Street, Suite Suite 400 400 Covington, Covington, Kentucky Kentucky 41011 41 011 Cincinnati, Cincinnati, Ohio Ohio 45202 45202 (859) (859) 431-3313 431-3313 (513) (513) 621-9100 621-9100 [email protected] [email protected] (513) (513) 345-5543 345-5543 fax fax [email protected] [email protected]

Attorneys Attorneys for for Plaintiffs Plaintiffs

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IT IS IS SO SO STIPULATED STIPULATED AND AND AGREED AGREED FOR FOR THE THE UNITED UNITED STATES: STATES:

DATE: DATE: May May 20, 20,2014 2014

CARTER CARTER STEWART STEW ART JOCELYN JOCELYN SAMUELS SAMUELS United United States States Attorney Attorney Acting Acting Assistant Assistant Attorney Attorney General General Southern Southern District District of of Ohio Ohio Civil Civil Rights Rights Division Division

United United States States Department Department of of Justice Justice

lsi Is/ Deborah Deborah F. F. Sanders Sanders DEBORAH DEBORAH F. F. SANDERS SANDERS (0043575) (0043575) EVE EVE HILL HILL Assistant Assistant United United States States Attorney Attorney Deputy Deputy Assistant Assistant Attorney Attorney General General Southern Southern District District of of Ohio Ohio Civil Civil Rights Rights Division Division 303 303 Marconi Marconi Boulevard, Boulevard, Suite Suite 200 200 Columbus, Columbus, Ohio Ohio 43215 43215 JONATHANM. JONATHAN M. SMITH SMITH (614) (614) 469-5715 469-5715 {T) (T) Chief Chief (614) (614) 469-5653 469-5653 (F) (F) Special Special Litigation Litigation Section Section Deborah. Deborah. [email protected] Sanders@usdoj. gov

lsi Is/ Benjamin Benjamin 0. O. Tayloe. Tayloe, Jr. Jr. BENJAMIN BENJAMIN 0. O. TAYLOE, TAYLOE, JR. JR. Deputy Deputy Chief Chief Special Special Litigation Litigation Section Section 950 950 Pennsylvania Pennsylvania Avenue, Avenue, N.W. N.W. Washington, Washington, D.C. D.C. 20530 20530 (202) (202) 514-8103 514-8103 (T) (T) (202) (202) 514-4883 514-4883 (F) (F) [email protected] [email protected] SILVIA SILVIA J. J. DOMINGUEZ-REESE DOMINGUEZ-REESE CYNTHIACOE CYNTHIACOE ALEXANDRA ALEXANDRA L. L. SHANDELL SHANDELL Trial Trial Attorneys Attorneys Special Special Litigation Litigation Section Section

Attorneys Attorneys for for Plaintiff Plaintiff

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WHEREFORE, WHEREFORE, for for good good cause cause shown, shown, this this ORDER ORDER shall shall be be entered entered this this :bL ~ day day of of

~2014 ~2014

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IT IT IS IS SO SO STIPULATED STIPULATED AND AND AGREED AGREED FOR FOR DEFENDANTS DEFENDANTS REED REED AND AND THE THE STATE STATE OF OF OHIO, OHIO, ET ET AL.: AL.:

DATE: DATE: May May 20,2014 20,2014

/s/ Is/ Judith Judith Goldstein Goldstein /sl Is/ Thomas Thomas Anger Anger JUDITH JUDITH GOLDSTEIN GOLDSTEIN THOMAS THOMAS ANGER ANGER (Ohio (Ohio Bar Bar No. No. 0069655) 0069655) (Ohio (Ohio Bar Bar No. No. 0088577) 0088577) Assistant Assistant Attorney Attorney General General Assistant Assistant Attorney Attorney General General Criminal Criminal Justice Justice Section Section Criminal Criminal Justice Justice Section Section 150 150 East East Gay Gay Street, Street, 16th 16th Floor Floor 150 150 East East Gay Gay Street, Street, 16th 16th Floor Floor Columbus, Columbus, Ohio Ohio 43215 43215 Columbus, Columbus, Ohio Ohio 43215 43215 (614) (614) 644-7233 644-7233 (614) (614) 644-8742 644-8742 Fax: Fax: (614) (614) 728-9327 728-9327 (877) (877) 584-2041 584-2041 Judith. Judith. [email protected] goldstein@ohioattorneygeneral. gov [email protected] Thomas.anger@ohioattorneygeneral. gov

Attorneys Attorneys for for Defendants Defendants

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A.11 A.ll A.ll Vrrlfy Vrrlfy Vcrlfy Trcqtmcot Trcqtmcot Trcqtmcot lnfmfty 'nfmfty 'nfmfty CLJJ eLlI eLlI Reduce Reduce Reduce RcIIqnq RcIIqnq Rcllqnq po po po SulI11ipo SulI11ipo Sullllipo C11 '11 '11 TmzJmmt TmzJmmt TmzJmmt Plgn Plgn Plqn Bmcw RmCW RmCW • • • Quality Quality Quality Assurance Assurance Assurance (OA) (OA) (QA) will will will be be be put put put in in in place place place to to to • • • No No No intervention intervention intervention seclusion seclusion seclusion (IS) (IS) {IS) for for for High High High Severity Severity Severity (e.g., (e.g., (e.g., fight, fight, fight, • • • Within Within Within 2 2 2 days days days of of of every every every AOV, AOV, AOV, the the the treating treating treating

ensure ensure ensure that that that individual individual individual treatment treatment treatment is is is aligned aligned aligned with with with consensual consensual consensual sexual sexual sexual activity), activity), activity), unless unless unless the the the victim victim victim requires requires requires offoffoff clinician/lOT clinician/lOT clinician/lOT will will will review review review the the the treatment treatment treatment plan plan plan to to to treatment treatment treatment goals. goals. goals. Each Each Each month, month, month, the the the PsycholoBY PsycholoBY Psychology grounds grounds grounds emergency emergency emergency medical medical medical treatment treatment treatment (and (and (and then then then up up up to to to 24 24 24 identify identify identify antecedents antecedents antecedents and and and function function function of of of the the the Supervisor Supervisor Supervisor will will will sample sample sample 2 2 2 files files files per per per clinician. clinician. clinician. hours hours hours can can can be be be imposed). imposed). imposed). behavior; behavior; behavior; review review review treatment treatment treatment goals goals goals and and and Monitors Monitors Monitors will will will review review review the the the cases cases cases sampled sampled sampled and and and the the the • • • Interdisciplinary Interdisciplinary Interdisciplinary Team Team Team (lOT) (lOT) {IDT) determines determines determines sanction. sanction. sanction. interventions. interventions. interventions. If If If implementation implementation implementation of of of existing existing existing completed completed completed OA OA QA audit audit audit tools. tools. tools. • • • Timelines: Timelines: Timelines: plan plan plan has has has not not not been been been sufficient, sufficient, sufficient, it it it will will will be be be fortified. fortified. fortified.

• • • Timel;ne: Timel;ne: Timeljne: o o o Policy Policy Policy changes changes changes to to to be be be completed completed completed by by by June June June 30, 30, 30, 2014. 2014. 2014. If If If existing existing existing plan plan plan was was was property property properly implemented implemented implemented yet yet yet o o o Tools Tools Tools are are are developed; developed; developed; o o o OA OA QA for for for Performance Performance Performance Measure Measure Measure by by by July July July 15, 15, 15, 2014. 2014. 2014. ineffective, ineffective, ineffective, it it it will will will be be be revised revised revised to to to include include include o o o Will Will Will be be be implemented implemented implemented by by by May May May 1, 1, 1, 2014. 2014. 2014. o o o Training Training Training Completed Completed Completed by by by August August August 31, 31, 31, 2014. 2014. 2014. additional additional additional skill-development skill-development skill-development or or or environmental environmental environmental

o o o Implementation Implementation Implementation by by by September September September 1, 1, 1, 2014. 2014. 2014. changes. changes. changes. May May May use use use Behavior Behavior Behavior Contract Contract Contract if if if • • • OA OA QA will will will be be be put put put in in in place place place to to to verify verify verify that that that group group group appropriate. appropriate. appropriate.

treatment treatment treatment displays displays displays fidelity fidelity fidelity to to to design. design. design. Each Each Each month, month, month, • • • Intensity Intensity Intensity of of of treatment treatment treatment will will will be be be increased increased increased to to to a a a sample sample sample of of of groups groups groups (Managing (Managing {Managing Anger Anger Anger and and and 3x/week 3x/week 3x/week individual individual individual sessions sessions sessions for for for two two two weeks; weeks; weeks; Violence, Violence, Violence, Cognitive Cognitive Cognitive Behavioral Behavioral Behavioral Therapies Therapies Therapies overlays, overlays, overlays, daily daily daily homework homework homework will will will be be be assigned. assigned. assigned. etc.) etc.) etc.) will will will be be be audited audited audited using using using a a a OA OA QA tool tool tool that that that has has has been been been • • • Timeline: Timeline: Timeline: Implemented Implemented Implemented by by by July July July 1, 1, 1, 2014. 2014. 2014. drafted. drafted. drafted. Monitors Monitors Monitors will will will review review review the the the completed completed completed OA OA QA tools. tools. tools.

• • • Timeline: Timeline: Timeline: o o o Tools Tools Tools are are are under under under development, development, development, will will will be be be sent sent sent to to to

Monitors Monitors Monitors immediately immediately immediately for for for input; input; input; o o o Will Will Will be be be implemented implemented implemented by by by May May May 1, 1, 1, 2014. 2014. 2014. I Peiformonce Peiformonce Pedormance Measure Measure Measure 8.1 B.l B.l

• • • Proportion Proportion Proportion of of of youth youth youth who who who commit commit commit High High High Severity Severity Severity infractions infractions infractions Performqnce Performqnce Perfocmqnce Measure Measure Measure C.l (,1 (,1 Performance Performance Pedormance Measure Measure Measure A.l A.l A.l who who who were were were given given given intervention intervention intervention seclusion seclusion seclusion (should (should (should be be be 0%, 0%, 0%, • • • 90% 90% 90% of of of youth youth youth involved involved involved in in in AOV AOV AOV have have have Treatment Treatment Treatment • • • 90% 90% 90% of of of all all all cases cases cases reviewed reviewed reviewed showed showed showed unless unless unless victim victim victim required required required off-grounds off-grounds off-grounds emergency emergency emergency medical medical medical Plan Plan Plan Review Review Review within within within 2 2 2 days days days of of of the the the incident. incident. incident.

correspondence correspondence correspondence between between between content content content of of of individual individual individual treatment). treatment). treatment). o o o % % % of of of cases cases cases in in in which which which implementation implementation implementation was was was sessions sessions sessions and and and treatment treatment treatment goals. goals. goals. fortified. fortified. fortified.

• • • 90% 90% 90% of of of all all all groups groups groups included included included in in in the the the sample sample sample score score score o o o % % of of %of cases cases cases in in in which which which interventions interventions interventions were were were 80% 80% 80% or or or better better better on on on a a a measure measure measure of of of treatment treatment treatment fidelity. fidelity. fidelity. revised. revised. revised.

o o o These These These should should should total total total 100%, 100%, 100%, not not not an an an option option option to to to do do do nothing. nothing. nothing.

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EXIDBIT EXIDBIT EXIDBIT A A A

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YOUTH YOUTH YOUTH ON ON ON THE THE THE MENTAL MENTAL MENTAL HEALTH HEALTH HEALTH CASE CASE CASE LOAD: LOAD: LOAD: PROPOSAL PROPOSAL PROPOSAL TO TO TO REDUCE REDUCE REDUCE VIOLENCE VIOLENCE VIOLENCE AND AND AND IMPROVE IMPROVE IMPROVE THE THE THE RESPONSE RESPONSE RESPONSE TO TO TO VIOLENCE VIOLENCE VIOLENCE IN IN IN DYS DYS DYS FACILITIES FACILITIES FACILITIES

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Case: 2:08-cv-00475-ALM-MRA Doc #: 148-1 Filed: 05/21/14 Page: 1 of 9 PAGEID #: 3136

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A. A. A. Prevention Prevention Prevention 5tt:at 5tt:at .... .... Sttat.ates s s 8:tmmediate lnterverati~·strateates A.ll A.lI A.lI OmlOR OmlOR Qmlqp SloPsycbpSqclql 810PmbpSqdql 810PmbpSqdql Asmvncnt Asmvncnt Assmmcnt that that that 8.21 S.ll S.ll fkduq Redu" Redu" DyrptIon DyrptIon Dyrptlon qfS,duslqo pfS,duslqo pfS,duslqo C.ll C.ll C.ll SRCdgl SRCdql8cy1cw SRCdql8cy1cw Rcyfcw Tcqm Tcqm Tcqm CSRD (SSD (SSD lnduda lnduda lnduda Qfnfcal alalm' alalm' gad gad qnd Qlqqnostk Qlqqnostk Qlqqn9Sfk Eqanulqrlon Eqanulqrlon fqanulqrloa • • • Interim Interim Interim Measure: Measure: Measure: Effective Effective Effective no no no later later later than than than July July July 15, 15, 15, 2014, 2014, 2014, and and and • • • Within Within Within 2 2 2 days days days of of of a a a youth's youth's youth's 2rwJ 2nd 2nd Severe Severe Severe or or or 33n1 n1 3rd • • • Initial Initial Initial BioPsychoSocial BioPsychoSocial BioPsychoSocial Assessment Assessment Assessment includes includes includes a a a ending ending ending on on on September September September 1, 1, 1, 2014, 2014, 2014, any any any youth youth youth on on on seclusion seclusion seclusion High High High Severity Severity Severity AOV, AOV, AOV, he he he will will will be be be referred referred referred to to to the the the

broad broad broad range range range of of of informational informational informational sources sources sources and and and (intervention (intervention (intervention or or or pre-hearing) pre-hearing) pre-hearing) for for for over over over 72 72 72 hours hours hours in in in a a a rolling rolling rolling SRT SRT SRT for for for a a a clinical clinical clinical staffing, staffing, staffing, led led led by by by the the the culminates culminates culminates in in in a a a clinical clinical clinical formulation formulation formulation and and and diagnostic diagnostic diagnostic 30-day 30-day 30-day period period period must must must be be be reviewed reviewed reviewed by by by the the the Treatment Treatment Treatment T Team Team earn psychologist psychologist psychologist and and and specifically specifically specifically focused focused focused on on on formulation, formulation, formulation, which which which is is is reflected reflected reflected in in in the the the youth's youth's youth's and and and any any any continued continued continued seclusion seclusion seclusion must must must first first first receive receive receive approval approval approval understanding understanding understanding and and and addressing addressing addressing the the the AOV AOV AOV treatment treatment treatment plan. plan. plan. from from from the the the Bureau Bureau Bureau Chief Chief Chief for for for Facilities Facilities Facilities or or or the the the Deputy Deputy Deputy Director Director Director behavior. behavior. behavior.

• • • Tjmeljoe: Tjmeljoe: Tjmeljne: before before before the the the seclusion seclusion seclusion continues continues continues past past past 72 72 72 hours hours hours in in in a a a rolling rolling rolling • • • The The The SRT SRT SRT will will will function function function as as as the the the lOT lOT IDT until until until the the the o o o Guidance Guidance Guidance on on on the the the formulation formulation formulation concept concept concept for for for 3O-day 3O-day 30-day period. period. period. youth's youth's youth's behavior behavior behavior improves. improves. improves.

Department Department Department of of of Youth Youth Youth Services Services Services (DYS) (DYS) (DYS) staff staff staff will will will • • • TImeljne TImeljne Dmeline for for for interim interim jnterjm measure: measure: measure: Effective Effective Effective July July July 15, 15, 15, 2014. 2014. 2014. • • • The The The SRT SRT SRT will will will explore explore explore the the the causes causes causes and and and functions functions functions be be be fully fully fully developed developed developed ASAP, ASAP, ASAP, with with with input input input from from from DYS DYS DYS of of of the the the behavior behavior behavior and and and will will will prescribe prescribe prescribe clinicians clinicians clinicians and and and Monitors; Monitors; Monitors; • • • DYS DYS DYS will will will decrease decrease decrease the the the minimum minimum minimum length length length of of of stay stay stay (LOS) (LOS) (LOS) for for for interventions interventions interventions designed designed designed to to to address address address those those those

o o o TraininB TraininB TraininB for for for all all all clinicians clinicians clinicians will will will occur occur occur within within within 60 60 60 youth youth youth engaged engaged engaged in in in AOVs AOVs AOVs to to to two two two to to to four four four hours, hours, hours, not not not to to to exceed exceed exceed causes causes causes and and and functions functions functions (e.g., (e.g., (e.g., Intensive Intensive Intensive Behavior Behavior Behavior days days days of of of entry entry entry of of of this this this Order; Order; Order; 24 24 24 hours. hours. hours. Contract; Contract; Contract; staff staff staff mentor; mentor; mentor; change change change unit; unit; unit; skill skill skill

o o o QA QA QA tools tools tools will will will be be be developed developed developed and and and implemented implemented implemented • • • The The The Safe Safe Safe to to to Release Release Release (STR) (STR) (STR) process process process will will will be be be initiated initiated initiated between between between building building building work; work; work; referral referral referral to to to Mental Mental Mental Health Health Health by by by May May May 1, 1, 1, 2014. 2014. 2014. two two two and and and four four four hours hours hours and and and if if if the the the youth youth youth refuses refuses refuses to to to engage engage engage or or or faciljty). faciljty). facility).

the the the suitability suitability suitability of of of the the the climate climate climate indicates indicates indicates safety safety safety concerns, concerns, concerns, • • • Tjmeline: Timeljne: Timeljne: Implemented Implemented Implemented by by by July July July 1, 1, 1, 2014. 2014. 2014. staff staff staff will will will attempt attempt attempt to to to engage engage engage the the the youth youth youth every every every two two two to to to three three three hours hours hours thereafter, thereafter, thereafter, up up up to to to the the the 24 24 24 hour hour hour period. period. period.

• • • If If If the the the 24 24 24 hour hour hour period period period is is is reached reached reached and and and the the the youth youth youth continues continues continues to to to refuse refuse refuse or or or the the the suitability suitability suitability of of of the the the climate climate climate indicates indicates indicates safety safety safety concerns, concerns, concerns, the the the Superintendent Superintendent Superintendent must must must approve approve approve any any any further further further seclusion. seclusion. seclusion.

• • • TImelines: TImelines: Dmelines: o o o Poljcy Poljcy Policy changes changes changes to to to be be be completed completed completed by by by June June June 30, 30, 30, 2014. 2014. 2014. o o o QA QA QA for for for Performance Performance Performance Measure Measure Measure by by by July July July 15, 15, 15, 2014. 2014. 2014. o o o Training Training Training Completed Completed Completed by by by August August August 31, 31, 31, 2014. 2014. 2014. o o o Implementation Implementation Implementation by by by September September September 1, 1, 1, 2014. 2014. 2014.

• • • Decrease Decrease Decrease intervention intervention intervention seclusion seclusion seclusion time time time imposed imposed imposed for for for Severe Severe Severe AOVs AOVs AOVs (e.g., (e.g., (e.g., assault, assault, assault, sexual sexual sexual exposure/assault; exposure/assault; exposure/assault; imposed imposed imposed by by by Hearing Hearing Hearing Officer, Officer, Officer, not not not consecutive consecutive consecutive to to to pre-hearing pre-hearing pre-hearing seclusion seclusion seclusion (PHS)). (PHS)). (PHS)). o o o 111st st st gets gets gets Credit Credit Credit for for for TIme TIme Time Served. Served. Served. o o o tt wJ wJ 2rwJ gets gets gets up up up to to to 4 4 4 hours. hours. hours. o o o 33n1 n1 3nl gets gets gets up up up to to to 8 8 8 hours. hours. hours. o o o 4th 4th 4th gets gets gets up up up to to to 12 12 12 hours. hours. hours. o o o Sth+ Sth+ 5th+ gets gets gets up up up to to to 24 24 24 hours. hours. hours. o o o Unless Unless Unless victim victim victim requires requires requires off-grounds off-grounds off-grounds emergency emergency emergency medical medical medical

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treatment, treatment, treatment, then then then up up up to to to 24 24 24 hours. hours. hours. o o o For For For the the the purposes purposes purposes of of of calculating calculating calculating how how how many many many previous previous previous

"Severe" "Severe" "Severe" rule rule rule violations violations violations youth youth youth have have have committed, committed, committed, the the the number number number of of of "Severe" "Severe" "Severe" rule rule rule violations violations violations is is is considered considered considered zero zero zero if if if a a a youth youth youth goes goes goes 30 30 30 days days days without without without a a a "Severe" "Severe" •Severe" rule rule rule violation violation violation unless unless unless the the the superintendent superintendent superintendent decides decides decides otherwise; otherwise; otherwise; and, and, and, if if if so, so, so, the the the youth youth youth will will will be be be reviewed reviewed reviewed again again again in in in 30 30 days. days. 30days.

o o o Served Served Served on on on Saturday Saturday Saturday and and and Sunday. Sunday. Sunday. o o o The The The State State State shall shall shall not not not substitute substitute substitute physical physical physical restraints restraints restraints for for for

seclusion. seclusion. seclusion. • • • Dmeljnes: Iimelines: Iimelines:

Pedocmqnce Pedormgnce Pedormgnce Meqsure Meqsure Meqsure A A A 2 2 2 o o o Policy Policy Policy changes changes changes to to to be be be completed completed completed by by by June June June 30, 30, 30, 2014. 2014. 2014. • • • 90% 90% 90% of of of initial initial initial assessments assessments assessments include include include a a a solid solid solid o o o QA QA QA for for for Performance Performance Performance Measure Measure Measure by by by July July July 15, 15, 15, 2014. 2014. 2014. Performance Performance Performance Measure Measure Measure C.2 C.2 C.2

clinical/diagnostic clinical/diagnostic clinical/diagnostic formulation. formulation. formulation. Every Every Every month, month, month, a a a o o o Training Training Training Completed Completed Completed by by by August August August 31, 31, 31, 2014. 2014. 2014. • • • Number Number Number of of of youth youth youth involved involved involved in in in 2 2 2 Severe Severe Severe or or or 3 3 3 High High High sample sample sample of of of cases cases cases will will will be be be reviewed reviewed reviewed by by by the the the Monitor Monitor Monitor o o o Implementation Implementation Implementation by by by September September September 1, 1, 1, 2014. 2014. 2014. AOVs AOVs AOVs (descriptive). (descriptive). (descriptive). and and QA. QA. andQA. o o o SRT SRT SRT was was was convened convened convened within within within 2 2 2 days days days for for for 100%. 100%. 100%.

• • • 90% 90% 90% of of of treatment treatment treatment plans plans plans reflect reflect reflect information information information from from from Pedormance Pedormance Pedormonce Measure Measure Measure B.2 B.2 8.2 o o o 90% 90% 90% of of of the the the SRTs SRTs SRTs explored explored explored the the the causes causes causes and and and the the the formulation. formulation. formulation. Every Every Every month, month, month, a a a sample sample sample of of of cases cases cases • • • Proportion Proportion Proportion of of of youth youth youth released released released at at at 4 4 4 hours hours hours or or or less. less. less. functions functions functions of of of the the the behavior. behavior. behavior.

will will will be be be reviewed reviewed reviewed by by by the the the Monitor Monitor Monitor and and and QA. QA. QA. • • • 100% 100% 100% of of of youth youth youth were were were sanctioned sanctioned sanctioned according according according to to to the the the IS IS IS o o o 90% 90% 90% of of of the the the SRT SRTs SRTs s prescribed prescribed prescribed interventions interventions interventions

graduated graduated graduated scheme. scheme. scheme. that that that addressed addressed addressed those those those causes causes causes and and and functions. functions. functions.

• • • 0% 0% 0% of of of youth youth youth spent spent spent more more more than than than 72 72 72 hours hours hours in in in seclusion seclusion seclusion in in in a a a rolling rolling rolling 30-day 3£ktay 3£ktay period period period (except (except (except in in in rare rare rare circumstances circumstances circumstances with with with approval approval approval from from from the the the Bureau Bureau Bureau Chief Chief Chief for for for Facilities Facilities Facilities or or or the the the Deputy Deputy Deputy Director). Director). Director).

3 3 3


8.31 8.3' 8.3' Rnlusc Rnlusc Rnlusc Hqcm Hpan Hpan Apqclqtcd Apqclqtcd Apqclqtcd with with with Seduslqo Seduslqo Sufustqo • • • Intervention Intervention Intervention seclusion seclusion seclusion is is is imposed imposed imposed only only only on on on Saturday Saturday Saturday & & &

Sunday, Sunday, Sunday, to to to reduce reduce reduce interference interference interference with with with core core core programming. programming. programming. • • • For For For IS, IS, IS, provide provide provide 1 1 1 hour hour hour out out out for for for every every every 4 4 4 hours hours hours in in in seclusion, seclusion, seclusion,

during during during waking waking waking hours. hours. hours. • • • Youth Youth Youth in in in IS IS IS participate participate participate in in in treatment treatment treatment activities, activities, activities, school school school and and and

recreation recreation recreation out out out of of of their their their room room room and and and time time time counts counts counts toward toward toward seclusion seclusion seclusion hours hours hours if if if behavior behavior behavior is is is appropriate. appropriate. appropriate.

• • • Timelines: Timelines: Timelines: o o o Policy Policy Policy changes changes changes to to to be be be completed completed completed by by by June June June 30, 30, 30, 2014. 2014. 2014. o o o OA OA OA for for for Performance Performance Performance Measure Measure Measure by by by July July July 15, 15, 15, 2014. 2014. 2014. o o o Training Training Training Completed Completed Completed by by by August August August 31, 2014. 31,2014. 31,2014. o o o Implementation Implementation Implementation by by by September September September 1, 1, 1, 2014. 2014. 2014.

Performance Performance Performance Measure Measure Measure 8.3 8.3 8.3

• • • 90% 90% 90% of of of youth youth youth in in in intervention intervention intervention seclusion seclusion seclusion spent spent spent 4 4 4 in/1 out in/lout in/lout during during during waking waking waking hours. hours. hours.

• • • 90% 90% 90% of of of youth youth youth in in in intervention intervention intervention seclusion seclusion seclusion participated participated participated in in in all all all programming programming programming (e.g., (e.g., (e.g., recreation, recreation, recreation, treatment) treatment) treatment) that that that was was was scheduled scheduled scheduled during during during seclusion seclusion seclusion time. time. time.

8.41 8.4. 8.4. Rnlusc Rnlusc Rnlusc Amunulgtiqo Amunulgtiqo Amlmulqtiqo qfSedUllqo qfSedUllqo qfSufwlqo • • • To To To apply apply apply more more more than than than 72 72 72 hours hours hours of of of seclusion seclusion seclusion in in in a a a 30-day 30-day 30-day

period: period: period: o o o Conduct Conduct Conduct Treatment Treatment Treatment Plan Plan Plan Review Review Review (see (see (see Strategy Strategy Strategy C.1). Cl). Cl). o o o Obtain Obtain Obtain approval approval approval from from from Bureau Bureau Bureau Chief Chief Chief for for for Facilities Facilities Facilities or or or the the the

Deputy Deputy Deputy Director. Director. Director. o o o Monitors/Plaintiffs Monitors/Plaintiffs Monitors/Plaintiffs will will will be be be provided provided provided with with with information information information

on on on youth youth youth reviewed reviewed reviewed on on on a a a monthly monthly monthly basis. basis. basis.

• • • TImeljnes: TImeljnes: Umeljnes: o o o Policy Policy Policy changes changes changes to to to be be be completed completed completed by by by June June June 30, 30, 30, 2014. 2014. 2014. o o o OA OA OA for for for Performance Performance Performance Measure Measure Measure by by by July July July 15, 15, 15, 2014. 2014. 2014. o o o Training Training Training Completed Completed Completed by by by August August August 31, 31, 31, 2014. 2014. 2014. o o o Implementation Implementation Implementation by by by September September September 1, 1, 1, 2014. 2014. 2014.

Performance Performance Performance Measure Measure Measure 8.4 8.4 8.4

• Number of youth secluded each month and number of

4


4


4


5 5

A. A. A. Prevention Prevention Strlift!l~.· Strlift!l~.· PreventionS~

hours hours hours in in in seclusion seclusion seclusion (Monthly-for (Monthly-for (Monthly-for all all all youth youth youth on on on MHCL, MHCL, MHCL, provide provide provide date, date, date, type type type of of of AOV, AOV, AOV, PHS PHS PHS and and and IS). IS). IS).

• • • Number Number Number of of of youth youth youth who who who spent spent spent more more more than than than 72 72 72 hours hours hours in in in 30-30-30-day day day period period period (descriptive). (descriptive). (descriptive).

o o o 90% 90% 90% received received received Treatment Treatment Treatment Plan Plan Plan Review. Review. Review. o o o 90% 90% 90% receive receive receive approval approval approval for for for exception exception exception to to to the the the 72 72 72 hour hour hour

rule. rule. rule.

• • • TImelipe: TImelipe: Dmelipe: o o o To To To be be be implemented implemented implemented by by by July July July 15, 15, 2014. 2014. 15,2014.

8.51 8.5' 8.5' Pcpyfdc Pcpyfd, Pcpyfd, Cd", Cd", CdR lntf!Ycotfqo lntf!Ycotfqo lntf!Ycotfqo Whlle Whlle While In In In PHS PHS PHS

• • • STR STR STR process process process will will will be be be initiated initiated initiated with with with every every every youth youth youth engaged engaged engaged in in in an an an AOV AOV AOV between between between two two two and and and four four four hours. hours. hours.

• • • STR STR STR process process process will will will include include include a a a structured structured structured interview interview interview by by by Social Social Social Worker/Unit Worker/Unit Worker/Unit Manager/Operations Manager/Operations Manager/Operations Manager Manager Manager that that that discusses discusses discusses triggers, triggers, triggers, decision-making, decision-making, decision-making, external external external influences influences influences on on on behavior. behavior. behavior.

• • • Timeline: Timeline: Timeline: o o o Obtain Obtain Obtain input input input from from from Monitor Monitor Monitor on on on STR STR STR interview interview interview guide guide guide by by by

April April 1, 1, April1, 2014. 2014. 2014. Completed. Completed. Completed.

• • • Timelines: Timelines: Timelines: o o o STR STR STR Interview Interview Interview Form Form Form developed developed developed and and and

Policy Policy Policy changes changes changes to to to be be be completed completed completed by by by June June June 30, 30, 30, 2014. 2014. 2014. o o o QA QA QA for for for Performance Performance Performance Measure Measure Measure by by by July July July 15, 15, 15, 2014. 2014. 2014. o o o Training Training Training Completed Completed Completed by by by August August August 31, 2014. 31,2014. 31,2014. o o o Implementation Implementation Implementation by by by September September September 1, 1, 1, 2014. 2014. 2014.

Pedormance Pedormance Pedormance Measure Measure Measure 8.5 8.5 8.5

• • • STR STR STR process process process was was was initiated initiated initiated with with with 90% 90% 90% of of of youth youth youth within within within 4 4 4 hours. hours. hours.

• • • 90% 90% 90% of of of STR STR STR checks checks checks examine examine examine the the the underlying underlying underlying causes causes causes of of of the the the youth's youth's youth's behavior, behavior, behavior, both both both internal internal internal and and and external. external. external.

8.61 8.61 8.6J EYCatuqltv ERn_tv ERn_tv Eliminate Eliminate Ellmfaqtc Usc Usc Usc ofSulusion ofSulusion ofSu/uslon • • • DYS DYS DYS is is is committed committed committed to to to the the the eventual eventual eventual elimination elimination elimination of of of

disciplinary disciplinary disciplinary seclusion seclusion seclusion for for for all all all youth youth youth housed housed housed in in in a a a DYS DYS OYS facility. facility. facility. Thus, Thus, Thus, six six six months months months from from from the the the acceptance acceptance acceptance of of of this this this proposed proposed proposed settlement, settlement, settlement, DYS DYS DYS will will will engage engage engage the the the monitors monitors monitors and and and subject subject subject matter matter matter experts experts experts in in in formulating formulating formulating steps steps steps to to to take, take, take, and and and the the the timeline timeline timeline for for for completing completing completing those those those steps, steps, steps, to to to eliminate eliminate eliminate disciplinary disciplinary disciplinary seclusion. seclusion. seclusion.

5


Stnlteltft"''

• • • Timeline: Timeline: Timeline: o o o Six Six Six (6) (6) (6) months months months from from from the the the entry entry entry of of of this this this Order. Order. Order.

Omqll Omqll Omqll Pcdpcmqnq Pcdpcmqnw Pcdpcmqnw MAsuCCi MAsuCCi Mgsvrc; Vlolcnq Vlolcnq Vlolcnq R"'uct1qp R"'uct1qp Rducflqp 0mqI1 0mqI1 Ovmfl Pcdpnnq"" Pcdpnnq"" Pcdpnnqm Maw,,; Maw,,; Muwt!i BcrJuq WuW WuW fqtqf T*# T*# Su/uslop Su/uslop Suluslop Hours Hours Hours • • • Increase Increase Increase proportion proportion proportion of of of youth youth youth who who who do do do not not not engage engage engage • • • Reduce Reduce Reduce the the the number number number of of of youth youth youth who who who serve serve serve 72+ 72+ 72+ seclusion seclusion seclusion

in in in Acts Acts Acts of of of Violence Violence Violence (AOV) (AOV) (AOV) (baseline: (baseline: (baseline: February February February 14, 14, 14, hours hours hours per per per month month month by by by 10% 10% 10% each each each month, month, month, compared compared compared to to to 2014, 2014, 2014, 83% 83% 83% system-wide). system-wide). system-wide). previous previous previous month. month. month.

• • • Decrease Decrease Decrease number number number and and and proportion proportion proportion of of of Mental Mental Mental o o o DYS DYS DYS to to to calculate calculate calculate pre-policy pre-policy pre-policy change change change total. total. total. Health Health Health Case Case Case load load load (MHCl) (MHCl) (MHCl) youth youth youth who who who engage engage engage in in in 3 3 3 or or or more more more AOVs AOVs AOVs each each each month month month (any (any (any severity). severity). severity).

• • • A A A 10% 10% 10% reduction reduction reduction goal goal goal each each each month month month based based based upon upon upon the the the previous previous previous month's month's month's total. total. total.

6 6 6


means act of violence.

"BioPsychoSocial Assessment" means an assessment of all biological, psychological, and social factors present for an individual in order to inform that individual's treatment.

"Disciplinary Seclusion," also known as "Intervention Seclusion," means a period of confinement in a locked room that is used as a disciplinary sanction following a Severe Rule Violation.

"DOJ" means the United States Department of Justice, which represents the United States in this matter.

"DYS" means the Ohio Department of Youth Services.

"Effective Date" means the date by which this Agreed Order has been signed by representatives for each of the parties to this Agreed Order and issued as this Court's Order.

"Facilities" or "Facility" means Scioto Juvenile Correctional Facility, Circleville Juvenile Correctional Facility, Cuyahoga Hills Juvenile Correctional Facility and Indian River Juvenile Correctional Facility, including any DYS facility that replaces or supplements any of those named facilities.

"High Rule Violation" means actions that create immediate and direct threats to the security, safe and order of the facility, its staff, visitors or youth.

"IDT" means Interdisciplinary Team.

"Implement" means to give practical effect and ensure actual fulfillment by concrete measures, including appropriate training of relevant staff.

"Intervention Grid" means a DYS.grid of sanctions for rule violations ranging in severity from Low, to Moderate, High and Severe.

"Intervention Hearing" means a disciplinary hearing that is conducted, consistent with due process, to determine by a preponderance of the evidence whether a Severe Rule Violation has been proven or not proven.

"Intervention Seclusion," also known as "Disciplinary Seclusion," means a period of confinement in a locked room that is used as a disciplinary sanction following a Severe Rule Violation.

"LOS" means Length of Stay.

7

DEFINITIONS

"AOV" means act of violence.








"lOT" means Interdisciplinary Team.






7

DEFINITIONS

"AOV" means act of violence.








"lOT" means Interdisciplinary Team.






7


Caseload" or "MHCL" means all youth with an identified mental health disorder, including those youth who have a psychiatric disorder, including but not limited to psychoses, schizophrenia, bipolar with psychotic features, depression with psychotic features, severe post-traumatic stress disorder, or schizoaffective disorders and who, consistent with reasonable professional judgment, DYS believes require psychiatric or psychological care.

"Monitor" means Will Harrell and Dr. Kelly Dedel, including anyone else the court or parties by agreement may designate as their replacements.

"Monitoring" at facilities other than Indian River, Circleville, Cuyahoga Hills, and Scioto means a review of youth files or other materials requested by the monitor or subject-matter experts. The parties agree to meet and confer should additional access be requested and a good faith effort will be made to resolve any such requests. Monitoring at Indian River, Circleville, Cuyahoga Hills, and Scioto shall otherwise be conducted in accordance with Doc 359 in SH v. Taft 04 cv 1206 and with Doc 85 in United States v. Ohio ..

"Order" means this agreed order.

"Pre-hearing Seclusion" means placement of an out-of-control youth or a youth whose behavior poses an immediate threat to himself or others, in a locked room for a period of time until he or she regains control of his or her behavior and can be safely returned to the general population

"Quality Assurance/Improvement Program" or "QA" means a system of self-auditing and improvement to assess the implementation and effectiveness of all remedies instituted pursuant to this Order, to identify deficits that may exist, and to effectuate new measures to cure deficits identified.

"Restraints" means any chemical or mechanical device used to control the behavior of a youth.

"Safe to Release" means a determination pursuant to DYS guidelines that a youth should be released from Pre-hearing Seclusion.

"Seclusion," "seclude," and "secluding" mean isolating a youth in a room from which the youth's ability to egress is blocked. The term seclusion does not apply to locking a youth in a room during normal hours of sleep.

"Severe Rule Violation" means actions that have potential to create immediate and direct harm to the security, safety and order of the Facility, its Staff, visitors or youth, including assault, escape, sexual assault or riot/disturbance.

"Staff' means employees who work at any of the Facilities.

"Subject Matter Experts" means Dr. Daphne Glindmeyer, Dr. Andi Weisman, and anyone else the court or parties by agreement may designate as their replacements.

8

"Mental Health Caseload" or "MHCL" means all youth with an identified mental health disorder, including those youth who have a psychiatric disorder, including but not limited to psychoses, schizophrenia, bipolar with psychotic features, depression with psychotic features, severe post-traumatic stress disorder, or schizoaffective disorders and who, consistent with reasonable professional judgment, DYS believes require psychiatric or psychological care.












8

"Mental Health Caseload" or "MHCL" means all youth with an identified mental health disorder, including those youth who have a psychiatric disorder, including but not limited to psychoses, schizophrenia, bipolar with psychotic features, depression with psychotic features, severe post-traumatic stress disorder, or schizoaffective disorders and who, consistent with reasonable professional judgment, DYS believes require psychiatric or psychological care.












8


the State of Ohio, Harvey Reed, Director of the Ohio Department of Youth Services, the Ohio Department of Youth Services, and their successors, contractors and agents.

"Treatment Fidelity" means strategies that monitor the implementation of a behavioral health intervention (e.g., group treatment) to ensure it is delivered according to design/curriculum/theory and that it is delivered in a comparable manner across all youth.

"Youth" means any juvenile or juveniles committed by a court to, and residing at, the Facilities during the pendency of this Agreed Order. The specific terms set out in the grid only apply to youth at facilities directly managed by DYS. Youth at other facilities shall receive mental health services consistent with those described herein but appropriately tailored for the such non-DYS managed facilities.

9

"State" means the State of Ohio, Harvey Reed, Director of the Ohio Department of Youth Services, the Ohio Department of Youth Services, and their successors, contractors and agents.



9

"State" means the State of Ohio, Harvey Reed, Director of the Ohio Department of Youth Services, the Ohio Department of Youth Services, and their successors, contractors and agents.



9


Documents

S.H. v. Reed - Order Approving Seclusion Agreement - 5-21-14