ICE Assistant Director for Field Operations, Jon Gurule, dedicated over one full page of his sworn declaration from June 3, 2016 to a company he referred to as Danya International.
“In May 2015, ICE contracted with Danya International to provide compliance monitoring and oversight at all FRC. Pursuant to the contract with JFRMU’s Compliance Inspection Program, a team of dedicated inspectors conduct unannounced, monthly inspections of each FRC. The inspections include a detailed review of areas of compliance and noncompliance with ICE’s Family Residential Standards (FRS)…, general observations, and recommendations to achieve compliance. ICE contracted with Danya International because it has extensive experience in family/child-centered programming, educational services, Head Start Compliance, at-risk populations, and conditions of confinement in detention and residential settings.
In addition to its compliance work, Danya International also provides staff with ongoing technical assistance and training in areas intended to improve center conditions and programming. From August 2015, when it conducted its first monthly inspection, to present, Danya has generally found the FRCs to be compliant with the majority of physical plant, procedures/processes and quality control standards at FRCs. Where Danya observed individual issues of non-compliance, the facilities took corrective action as appropriate and achieved compliance although this is a continuos process. These inspections are ongoing, and Danya continually provides feedback on how to improve and resolve noncompliance issue at the facilities as they arise.
Danya has also noted the dedication and professionalism of FRC staff and at Dilley, a positive environment. For example, on November 10, 2015, Danya reported that staff at Berks ‘was welcoming and professional and committed to the facility’s mission’ On September 10, 2015, a report on Karnes noted that ‘the staff was welcoming and professional and committed to the facility’s mission of protecting women and their children.’ On January 27, 2016, Danya’s report on Dilley stated that ‘residents appeared to be in good spirits.’ In addition to assessing FRC compliance with the FRS, beginning in the spring of 2016, Danya also began interviewing a small sample of residents to obtain resident feedback to ensure that staff and management are aware of resident concerns. (Attached hereto as Exhibits (‘Exhs’) 1, 2, & 3 are true and correct copies of Danya International Reports of Compliance Inspections of BFRC, dates Nov. 10, 2015, KCRC, dated Sept. 10, 2015 and STFRC, dated Jan. 27, 2016).”
Before I eviscerate the substance (or lack thereof) of Danya International’s inspection reports, I feel obliged to clear up one factual error in Mr. Gurule’s declaration:
On May 3, 2016, DLH Holdings Corp, an Atlanta-based provider of healthcare services to the federal government focused on health and medical logistics, paid $38.75 million to acquire Danya International.
In a press release, DLH Holdings said, “Danya will operate as a unit of DLH, with founder Jeff Hoffman serving as a strategic market advisor for up to two years…”
Zachary Parker, DLH’s President and CEO, exuberantly proclaimed that with the acquisition of Danya, “the two companies are…able to leverage the combined capabilities of the ‘new’ DLH to target larger opportunities that would have previously been unavailable to either company standalone. Danya’s federal IT management services experience will accelerate our health IT initiatives.”
Would a larger opportunity be a contract with Immigration and Customs Enforcement (“ICE”)worth at least $250 million dollars to provide healthcare services to 22 of its detention centers, including the South Texas Family Residential Center and the Berks County Family Residential Center?
Yes. You guessed it.
ICE is currently soliciting bids for a new contract to provide healthcare services at the following ICE detention centers:
In response to questions from companies interested in the contract, ICE disclosed the value of the current contract, as shown below:
Ingenesis still has at least one year on its contract with ICE to provide healthcare services, but apparently ICE is not thrilled with the current providers’ services, stating that there have been challenges with “staffing and retention of staff for the remote locations, and the difficulty finding staff willing to work in a correctional/detention environment.”
DLH Holdings is actively bidding to be awarded the 5 year contract worth at least $250 million to provide healthcare services at the locations as described above, as can be seen from a job posting on its website:
$250 million is at best a conflict of interest with respect to DLH’s inspection and compliance monitoring contract and potential evidence of a quid quo pro of “Sign off on Compliance Reports for Family Detention Centers and you will nearly double your annual revenue.”
DLH Holdings Corp’s annual revenue for Fiscal Year 2015 and 2014 was approximately $65 million and $60 million, respectively. If DLH was awarded the $250 million ICE contract, it would nearly double its annual revenue with $50 million in additional revenue per year, to $115+ million per year.
DLH Holdings has a $250 million incentive to refrain from meaningfully critical inspection reports of ICE’s family residential facilities, especially as it seeks to provide the very services that it is currently responsible for inspecting and monitoring.
The rosy yet wholly conclusory and unsubstantiated inspection reports submitted in the Flores litigation by ICE may have been pre-determined.
Also, one perplexing question remains:
Why did Danya International attend a March, 2016 conference for vendors interested in the contract for healthcare services when it had no capability or experience in providing healthcare staffing or direct services and when less than a year prior, it had signed contract with ICE for $1.6 million to inspect and monitor conditions at Family Detention Centers? Before answering, first look at the sign in sheet for the healthcare contract:
As one can see, several executives from both Danya International, Inc. and DLH Holdings attended the conference, including DLH’s President and CEO, Zachary Parker, who can be reached at Zach.Parker@DLHCORP.com or 678-325-10723, if anyone is interested.
It appears that DLH’s reference of the larger opportunities that would have not been possible but for the acquisition of Danya International, Inc. includes the $250+ million contract award to provide medical services to 22 of ICE’s detention facilities.
A quick note on the actual inspection reports:
They are rubbish. And a red flag immediately jumps out: The individual who inspected Berks and Karnes is listed as “Elfreida Curtis-Crawley.” Danya first gives her the title of “Compliance Inspector” but calls her a “Compliance Reviewer” in a subsequent report.
Elfreida Curtis-Crawley’s past experience solely in inspecting Adult Correctional Facilities. In other words, individuals detained because they have either been charged with a crime and are awaiting trial or have been convicted and sentenced as a crime.
The State of Georgia’s open records website contains the following information regarding Curtis-Crawley:
Here, we can see that Curtis-Crawley’s specific past job title was “Senior Inspector” with the Georgia State Department of Corrections:
So much for the “family/child centered programming” that ICE purportedly contracted Danya for…
Some final observations:
Observation: The facility is using paper files to document resident’s medical information. Recommendation: IHSC COR and Field Office COR explore the implementation of an electronic health record system that will track resident medical information, calendar medical appointments, and track upcoming needs.
Dr. Diaz noticed the way I worked and demanded that I stop leaving a paper trail of the women’s concerns. In an evaluation of my performance dated December 26, 2014, Dr. Diaz wrote: “Also discussed again with Dr. Lopez that on the Weekly Checks the only written comments acceptable would be that the Resident asked and was informed about how to access needed medical or mental health services through our Referral form process. Any other type of problem was to be redirected to the other Case Management/Social Work staff for their follow up.” For women who were illiterate in Spanish or had low levels of education, he directed me and the employees I supervised to suggest to residents that they find other residents who were literate in Spanish and ask that they complete all requests on their behalf. This held for medical, mental health, concerns about their children, status of immigration and all other requests. Dr. Diaz was clear about his belief that residents and their attorneys “try and use medical records to positively impact their asylum”.
Use of isolation rooms: The Facility Administrator, Rose Thompson, said the facility does not use isolation rooms. They have rooms where residents who were exposed to TB or any other possible contagious medical issue are kept separate, but the doors are never locked and the residents are allowed to go in and out of the dayroom at any time. Residents with possible TB exposure are asked to notify the medical staff before they enter the dayroom with their children so that the rooms can be sanitized once the resident vacates. The rooms are immediately sanitized after use by a resident with possible TB exposure or other contagious medical issue.
There were no posters in the area stating that residents are free to go to the dayroom, but Ms. Thompson said that the residents are fully aware of this.
Recommendation: Hang posters in medical rooms used for those residents exposed to TB or with other possible contagious medical issues informing residents that they are able to visit the dayroom.
Residents are required to return to housing unit at 7:00 pm: The resident cohort that was exposed to Varicella was provided recreation at 7:00pm for one hour. Other residents are asked to return to their housing units to avoid contact. The cohort was separated from the general population and was required to remain in their housing for the entire day, limiting freedom of movement to one hour per day (7pm-8pm). The general population returned to their housing units when the cohort was using the recreation area/yard.
Recommendation: Develop a plan for approval to provide the cohort freedom of movement from 8am to 8pm while maintaining the health of the rest of the residents.