CSC Audit and Evaluation of Structured Intervention Units, June 8, 2025

Official title: Correctional Service of Canada Joint Audit and Evaluation of Structured Intervention Units, June 8, 2025: Internal Audit and Evaluation Sector

Catalogue number: PS84-255/2025E-PDF
ISBN: 978-0-660-78252-2

Alternate format

On this page

• Acronyms and abbreviations
• List of figures
• List of tables
• Background
  • About the Joint Audit and Evaluation
  • About Structured Intervention Units
• Structured Intervention Unit model and framework
  • Examples of staff perceptions about Structured Intervention Unit
  • Examples of inmate perceptions about the Structured Intervention Unit
  • Structured Intervention Unit inmate profile
  • Structured Intervention Unit vision and objectives
  • Policy
  • Governance
  • Roles and responsibilities
• Operationalization
  • Multidisciplinary approach
  • Financial information
  • Human resources
  • Safety and security
  • Infrastructure and equipment
• Management of inmates
  • Overview of Structured Intervention Unit transfers
  • Transfer authorizations
  • Transfers out
  • Overview of procedural safeguards
  • Procedural safeguards
  • Overview of conditions of confinement
  • Conditions of confinement
  • Offers of time outside of cell
  • Overview of programming, interventions, services, and leisure
  • Effectiveness of programming, interventions, and leisure
  • Overview of health care
  • Effectiveness of Health Services
• Oversight and performance
  • Monitoring and reporting
  • Measuring performance
• Conclusions and recommendations
  • Overall conclusions
  • Recommendations
• Appendices
  • Appendix A: Glossary
  • Appendix B: Structured Intervention Units logic model
  • Appendix C: Audit objectives and criteria
  • Appendix D: Evaluation questions
  • Appendix E: Evaluation questions and audit criteria based on logic model components
  • Appendix F: Scope and approach
  • Appendix G: Legislation and policy framework
  • Appendix H: Statement of conformance
• Footnotes

List of acronyms and abbreviations

List of figures on this page

List of tables on this page

Background

About the Joint Audit and Evaluation

Objectives

The Joint Audit and Evaluation of Structured Intervention Units (SIUs) was conducted as part of Correctional Service of Canada’s (CSC) 2022 to 2027 Risk-based Audit and Evaluation Plan (RBAEP).

This engagement built upon CSC’s Internal Audit and Evaluation Sector (IAES) review of the SIU implementation (2019) as well as the SIU Audit Readiness Engagement (2022).

Key areas were selected for exploration.

• Compliance: provide assurance that CSC is complying with relevant legislation and policies related to SIUs
• Effectiveness/Performance: assess the achievement of expected outcomes and Gender-based Analysis Plus (GBA Plus) differences
• Efficiency: assess the efficiency of the SIU model
• Management Framework: provide assurance that a management framework is in place to support SIUs
• Relevance: assess the continued need for SIUs and alignment with departmental and federal government priorities and responsibilities

Scope and approach

Evidence was collected at 9 men’s institutions and 5 women’s institutions using a mixed-methods approach.

• Interviews were conducted with over 240 participants from May 2023 to November 2023, which included staff at the national, regional, and institutional levels, as well as inmates
• Observation of various SIU processes and procedures were conducted by the engagement team for over 70 hours throughout multiple points of the day and evening across the institutions visited between May 2023 and July 2023
• Document and literature review of scholarly articles, internal and external reports, and other documents
• Administrative data analysis covering the period from April 2016 to April 2024 from internal databases, including:
  • Electronic Medical Record System (EMRS)
  • Health Accreditation Reporting System (HARS)
  • Human Resource Management System (HRMS)
  • Offender Management System (OMS)
  • Performance Direct (PD)
  • Scheduling and Deployment System (SDS); and
  • Long-Term Evolution-Structured Intervention Unit (LTE-SIU)
• File review and testing of over 1,400 inmate-related files and data records covering the period from October 2021 to November 2023

It is acknowledged that the COVID-19 global pandemic had a significant impact on the operations of CSC. It is understood that certain aspects of the implementation and operation of the SIUs during the scope period of the joint audit and evaluation may have been affected.

Additional details about the Joint Audit and Evaluation can be found in Appendix B to F.

About Structured Intervention Units

The SIUs were introduced by Bill C-83 - An Act to amend the Corrections and Conditional Release Act (CCRA)^{Footnote 1} , that received Royal Assent on June 21, 2019. The purpose of the bill was to strengthen the federal correctional system. This included the elimination of administrative and disciplinary segregation and the establishment of the SIU correctional model.

There are 15 SIUs across all regions of the country. They are located within 10 men’s institutions and 5 women’s institutions.

Legislative and policy requirements guide the operationalization of SIUs and the management of inmates in SIUs. Key legislative requirements for the SIUs are included within sections of the CCRA and the Corrections and Conditional Release Regulations (CCRR).

CSC also developed SIU policy instruments, such as Commissioner’s Directive (CD) 711 and its associated guidelines.

Pursuant to CCRA section 34(1) and CD 711, a staff member may authorize the transfer of an inmate into an SIU if the staff member is satisfied that there is no reasonable alternative to the inmate’s confinement in an SIU and the staff member believes on reasonable grounds that the inmate has acted, has attempted to act or intends to act in a manner that jeopardizes the safety of any person or the security of a penitentiary and allowing the inmate to be in the mainstream inmate population would jeopardize the safety of any person or the security of the penitentiary, the inmate’s safety, or would interfere with an investigation.

The LTE-SIU application was developed to support the management of inmates in SIUs. The tool records the interventions and activities offered to inmates. It also records additional information regarding the interactions that are taking place.

In alignment with CCRA and CD 711 requirements, an infographic available on CSC’s intranet provides an overview, as outlined below, of how SIUs differ from segregation.

• structured interventions are tailored to address inmates’ specific needs
• inmates have the opportunity to spend a minimum of 4 hours a day outside of their cell, including 2 hours a day of meaningful human contact
• more rigorous and regular reviews, including by someone external to CSC (such as, Independent External Decision Makers [IEDM^{Footnote 2} ])
• inmates are to be seen daily by a healthcare professional
• individualized approach focused on skills-based interventions and activities
• the goal is to provide inmates with the tools they need to return to a mainstream inmate population as soon as possible, and to prevent a return to an SIU

A full list of institutions with an SIU can be found in Appendix F.

Additional details about the SIUs regulatory framework can be found in Appendix G.

Structured Intervention Unit model and framework

Examples of staff perceptions about Structured Intervention Unit

Vision and objectives

Policy

Multidisciplinary approach

Human resources

Transfer authorizations

Effectiveness of programming, interventions, and leisure

Measuring performance

Disclaimer: The staff quotes used above, as well as any other staff quotes used throughout the report, were based on interview notes that were taken by the audit and evaluation team during institutional visits. Quotes may have been adapted for clarity and readability.

Examples of inmate perceptions about the Structured Intervention Unit

Safety and security

Infrastructure

Conditions of confinement

Transfer out of the Structured Intervention Unit

Effectiveness of programming, interventions, and leisure

Disclaimer: The inmate quotes used above, as well as any other inmate quotes used throughout the report, were based on interview notes that were taken by the audit and evaluation team during institutional visits. Quotes may have been adapted for clarity and readability.

Structured Intervention Unit inmate profile

Length of stay

Administrative data from April 2020 to March 2023 revealed that:

• the median number of days spent was higher for Indigenous inmates (26 days) and lower for women (6 days); and
• inmates who had a previously identified mental health need spent slightly more time in the SIU than those who did not

Comparison with general population

Demographic characteristics

A year-end snapshot analysis comprising of multiple years (April 2020 to March 2023) revealed that 1% of all inmates were transferred at least once to an SIU. Of those:

• 98% were men (versus 95% in the general population)
• 95% were under 50 years old (versus 74% in the general population); and
• 22.5% were visible minorities (versus 17% in the general population)

Black and Indigenous inmates were overrepresented.

Indigenous women were overrepresented in the SIUs (86%, 6 out of 7) versus in the general population (47%, 861 out of 1,844).

Further definitions can be found in Appendix A.

Structured Intervention Unit vision and objectives

Identifying and communicating the vision and objectives

The general vision, objectives and expectations for SIUs are identified in:

• legislation, regulations, and various CSC policy instruments (CDs, guidelines, memos, interim policy bulletins); and
• monitoring mechanisms such as national dashboards and performance indicators

The vision and objectives for the SIUs were further communicated through staff training when SIUs were first established and top-down messaging.

• this has contributed to a common understanding of the vision, objectives, priorities, and envisioned outcomes for the SIU

SIU objectives are aligned with CSC’s mandate, policies, and corporate priorities, and lessons learned from the previous segregation model.

SIU objectives further complement broader federal priorities of public safety and humane treatment.

Implementing the vision and objectives

While institutional management generally perceived the vision and objectives for SIUs as clear, operational realities and experiences suggest that clarity diminishes in practice.

Challenges with operationalizing the SIU vision and objectives are due to the contradiction between providing programming, interventions, and services that respond to an inmate’s specific needs and risks and the expectation that inmates be transferred out of the SIU as soon as possible. Staff indicated that the focus is more on transferring inmates out of the SIU at the earliest opportunity instead of ensuring an effective correctional planning process that responds to an inmate’s specific needs.

As a result, inmates are not always getting the programming, interventions, and services they need before being transferred out of the SIU, which does not support CSC’s mandate, strategic priorities, and the intended vision and objectives for SIUs.

Structured Intervention Unit vision and objectives

As per CCRA section 32, “The SIUs were designed to provide an appropriate living environment for an inmate who cannot be maintained in the mainstream population for security or other reasons; and provide the inmate with opportunities for meaningful human contact and participation in programs, and to have access to services that respond to the inmate’s specific needs and risks.”

As per CCRA section 33, “An inmate’s confinement in a structured intervention unit is to end as soon as possible.”

CSC’s mandate

Contribute to public safety by actively encouraging and assisting offenders to become law-abiding citizens, while exercising reasonable, safe, secure, and humane control.

CSC’s corporate priorities

• Safe management and supervision of offenders during their transition from the institution to the community
• Safety and security of the public, victims, staff and offenders in institutions and the community
• Effective, culturally appropriate interventions and reintegration support for First Nations, Métis, and Inuit offenders
• Effective and timely interventions in addressing mental health needs of offenders
• Efficient and effective management practices that reflect values-based leadership in a changing environment
• Productive relationships with diverse partners, stakeholders, victims' groups, and others involved in support of public safety

Policy

Policy development

• when the SIU policy was first introduced it was based on a theoretical model which had not been operationally tested
• the current policy was promulgated in November 2019 and, apart from interim policy bulletins and memorandums, has not been updated since the inception of the SIU. The SIU policy suite is currently under review and is expected to be updated by Spring 2025
• additional guidance was created (memos, interim policy bulletins, email communications, etc.) to support the operations of the SIUs (for example, clarification of roles and responsibilities and specification of some operational requirements)
• however, not all SIU policy instruments were found in 1 easy to navigate repository. CSC’s intranet, “the Hub”, contained some of the revised guidance but not all information was on the same webpage
• staff expressed that this has created issues when applying policy and guidance. Some documentation superseded previous guidance but there was no indication in the previous documentation that new guidance had been issued. As a result, policy and associated guidance may not be applied as intended

Clarity of policy

• the role of health care and mental health within the SIU (for example, with respect to health care assessments, medication delivery, open door policy for daily health care visits)
• terminology used (for example, “authorized” versus “approved”, “working day” versus “calendar day”)
• addressing the needs of complex inmates (including those who refuse to transfer out of the SIU)
• SIU infrastructure requirements
• the scope of activities and interventions provided in the SIU
• what constitutes conditions of confinement
• what is considered a meaningful interaction

Gaps or lack of clarity in SIU policy instruments have resulted in lack of awareness and oversight, which have resulted in non-compliance with associated legal requirements, such as:

• meeting the requirements for time out of cell and interaction with others
• meeting health care requirements
• meeting institutional requirements
• ensuring an inmate’s transfer to an SIU is for the shortest time possible

SIU policy instruments have also been interpreted differently by staff in institutions or across institutions, which has resulted in inconsistent application and potential differences in the operation of the SIUs.

Additional details about the SIUs policy framework can be found in Appendix G.

Governance

Governance structure

Various institutional management are involved with the SIU while also having responsibilities in other areas of the institution. These positions include:

• Institutional Head (IH)
• Deputy Warden (DW)
• Assistant Warden, Interventions (AWI); and
• Assistant Warden, Operations (AWO)

The implementation of SIUs has resulted in increased workload for these positions given the differences in managing inmates in the SIU when compared to the former segregation model.

The SIU governance model establishes different roles and accountabilities for institutional management depending on circumstances or based on a decision that must be taken. There is no one position working directly within the SIU on a full-time basis that has overarching responsibility for the day-to-day operations of the SIU.

Indirect reporting relationships exist which can result in inconsistent or conflicting direction being provided. For instance, health care staff and some interventions staff (for example, teachers, Elders, Indigenous Liaison Officers [ILOs]) directly report to individuals outside the SIU but have informal relationships with SIU-specific managers.

Unclear and inconsistent reporting structures exist. For example, it is not consistent from region to region who certain positions report to, and for certain positions it is not clear if they report to individuals at the institutional level or the regional level.

Some management and staff at all levels of the organization feel it is not always clear who to contact at National Headquarters (NHQ) when they have SIU-related questions, as some issues are both operational and “corporate“ in nature.

There is usually an attempt to resolve matters at the working level first, prior to escalating to management/senior management. However, with the current structure, security often takes priority despite the various groups’ different objectives. This has resulted in friction amongst staff at times.

Institutional management has suggested that the identification or addition of a specific position in charge of the SIU at the AWI or DW level would be beneficial for decision-making and due to the workload associated with SIU operations.

Information sharing

At the institutional and regional levels:

• institutional level staff involved with the SIU typically have discussions with each other on a bi-weekly basis
• many institutional management are in regular contact with the Regional Senior Project Officer(s) (RSPO)^{Footnote 3} ; and
• institutional staff communicate with staff at other institutions to share information and best practices and discuss reintegration options for inmates

At the national level:

• NHQ has established meetings with various SIU-related stakeholders at all levels of the organization; and
• expectations are reviewed, continually revisited, and clarified during these meetings for the institutions and regions

Some institutional management feel that support at the national level could be improved. It was mentioned that the focus at the national level tends to be more on compliance and oversight (for example, reviewing data quality, overseeing the number of inmates who have been authorized to the SIU, verifying whether inmates were offered 4 hours of time out of cell and 2 hours of interaction with others each day) instead of providing support directly to the institutions.

Formal information sharing mechanisms (for example, updates to SIU-related policy and guidance documentation such as interim policy bulletins, memos, and other electronic communications) support a common understanding of expectations and contribute to ensuring that key decisions and relevant information are effectively communicated.

Informal mechanisms (for example, SIU-related meetings, discussions, and other correspondence) contribute to providing management and staff at various levels with a support system to regularly obtain information on topics such as:

• SIU case information (including complex cases)
• SIU policy and process-related requirements, concerns, and updates
• SIU human resources updates
• LTE-SIU application updates
• good practices
• monthly reporting; and
• infrastructure

Some staff occupying newly introduced positions such as Behavioural Skills Coaches (BSCs) and SIU Data and Activity Coordinators, or positions that differ in terms of their context in the SIU such as social programs officers (SPOs), have supported their peers at other institutions by sharing ideas and practices to better understand their role in the SIU.

Roles and responsibilities

Understanding of roles and responsibilities

It is not always clear how SIU positions and associated roles should work within the context of the SIU versus how they work in the mainstream population (for example, teacher, SPOs, mental and physical health).

• a document review confirmed that standardized job descriptions were often being used and did not always include SIU-specific roles and responsibilities

CD 711 and its associated guidelines outline additional SIU-related roles and responsibilities of some staff working in and supporting SIUs. However, not all staff with SIU-related roles and responsibilities are referenced within the CD and guidelines (for example, BSCs and SIU Data and Activity Coordinators), and some expectations are not clearly identified (for example, expectations of the SIU parole officer (PO) versus the inmate’s PO from general population versus the PO at the institution where the inmate is being transferred to).

Some staff in newly created positions (for example, BSCs and SIU Data and Activity Coordinators) felt their role was not fully defined, which was further confirmed through a document review of their job descriptions.

CD 711 indicates that the approving authority for an inmate’s authorization to transfer to an SIU is the AWI. Most of the time, regions are requiring ADCCO consultation and/or agreement before an inmate SIU transfer. This direction was not found within CSC’s policy instruments and some AWIs expressed concerns with this process, as it risks impacting the impartiality of the AWI in the authorization process.

Structured Interventions Unit-related training

Staff expressed a desire for further training on mental health, crisis intervention, the LTE-SIU application, and the vision and objectives for the SIU.

While training provided to staff was most often on the LTE-SIU application, some staff who did not receive this training expressed a desire to receive it.

Some staff expressed a lack of understanding of the roles and responsibilities of other positions that work in the SIU, as well as a lack of understanding of how their position differed from other positions that work in the SIU.

Inadequate training may increase the risk to staff and inmate safety. Not fully understanding others’ roles and responsibilities within the SIU causes frustration for staff because they do not know why certain positions are working in a certain manner.

It was mentioned that informal training or information sessions would be beneficial to understand the role of each position working in the SIU.

Operationalization

Multidisciplinary approach

Coordination of work among Structured Interventions Unit staff

Examples of positions added to the SIUs include:

• SPOs
• POs
• Correctional Program Officers (CPOs)
• COs
• Elders

78% of the staff interviewed felt that the SIU team was taking a multidisciplinary approach to working with inmates.

72% of the staff interviewed felt that they were part of the multidisciplinary team.

At the institutions, the staff were discussing specific inmate’s cases and their planned approach.

• Document review and interviews also indicated that most institutions are having SIU Correctional Intervention Board or Interdisciplinary Team (SIU-CIB/IDT) meetings on a regular basis to discuss SIU inmates, as outlined in CD 711.
• The meetings include representatives from operations, interventions, and health care

Having staff assigned specifically to work in the SIU contributes to ensuring a consistent approach and better coordination of activities through the rapport built between staff.

Challenges with multidisciplinary approach

Certain positions amongst the intervention staff reported that they did not feel like they were part of the multidisciplinary team.

Some issues were identified during observations and interviews.

• for example, in the SIU some COs were observed not communicating with intervention and case management staff about the timing of inmates’ movement or why movement was not taking place. Staff appeared to become frustrated during these interactions
• some correctional staff still holding what was expressed as the “segregation” mentality
• at times, Elders were not respected when requesting assistance

Some institutional management and staff identified concerns regarding staff not taking a multidisciplinary approach. For example, correctional staff did not always respect interventions or health care staff (for example, not supporting proposed plans for inmate interactions, ignoring or not making them feel welcomed when entering the range, etc.) and a culture change was still required to move away from what was expressed as the “segregation” mindset.

Based on file reviews and interviews, although each discipline (interventions, operations, health care) is consulted as part of the decision-making process, some positions within those disciplines are not always consulted. For example, some COs and Elders indicated that they were not consulted. Although policy indicates that all staff must actively explore and consider all reasonable alternatives to confinement in an SIU, the COs explained that it was often left to the managers.

A definition for SIU-CIB/IDT can be found in Appendix A.

Financial information

Structured Interventions Unit funding

Over the 4 years analyzed, SIU expenditures^{Footnote 5}  have consistently exceeded the forecasted spending for SIU activities. Expenditure in excess of forecasts fluctuated between approximately $1.0 million and $9.5 million over the 4 years^{Footnote 6} . However, as CSC had authority to redistribute funds as appropriate, CSC has managed the creation of SIUs without exceeding the total funding received for the Transforming Federal Corrections initiative (Bill C-83).

There was no planned operations and maintenance (O&M)^{Footnote 7}  budget for infrastructure. However, significant expenditures were incurred for this purpose.

Construction projects were undertaken at some institutions prior to the SIUs becoming operational, and there are still changes being made. This has included adding:

• common rooms
• program rooms
• Indigenous specific rooms
• barrier rooms
• interview rooms
• yards

Note about years identified in graphs:

• 2019 to 2020 is April 2019 to March 2020
• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

Human resources

Funding additional resources

As a result of a CSC needs analysis, additional human resources costing over $16 million have been added to the SIU beyond the initial funding.

Positions added include:  

• BSCs
• CPO
• POs
• SIU managers
• SIU Data and Activity Coordinators^{Footnote 8}

Administrative positions were also added at the regional and national levels.

There have been additional management, correctional and interventions staff added at some institutions which are funded internally to help relieve SIU-related workload pressures and are not covered by funding allocated for SIUs.

• based on interviews and requests made to institutions to identify positions which are funded internally, many institutions will add additional staff to the SIU when the number of inmates approaches maximum SIU capacity. This results in less resources being available for non-SIU inmates
• for interventions positions such as POs, SPOs, and CPOs, some are added on a temporary basis, while others are added on a permanent basis
• for COs, this additional coverage in the SIU is provided through extra duty posts or operational enhanced security. At times, due to the fluid nature of the SIU population, these additional CO positions working in the SIU are not captured as SIU-specific positions in the SDS; therefore, it is difficult for CSC to determine the full number of CO positions required to operate the SIU on a daily basis

An SIU environmental scan completed in June 2023 identified that SIU positions are not currently coded to differentiate them from the overall positions within the institution where they are located, which restricts the availability of data specific to SIU positions.

• not having all SIU positions identified and differentiated from the overall positions within the institution also limits the ability to properly assess workloads of SIU staff and allocate additional funding for these positions
• some institutions become dependent on these additional positions, which cannot be guaranteed without permanent funding. This leaves CSC vulnerable to not meeting its legislative obligations and fulfilling its mission and objectives should challenges continue due to various factors (for example, fiscal climate or increased number of SIU transfers)

As well, operationally, institutions are adjusting staffing levels within other areas of the institution and reassigning those staff to the SIU. This reduces the ability for other areas of the institution to function as intended or increases the risk of security-related incidents occurring.

Staff vacancies and turnover

Although additional CO coverage has been provided in SIUs at some institutions, correctional staff in the SIU had higher turnover^{Footnote 9}  and vacancy rates, compared to non-correctional staff in the SIU.

Correctional Manager (CM) positions had the highest turnover rate for correctional staff in the SIUs (43%).

ILOs experienced the highest turnover rate for interventions positions in the SIUs (40%). Both Indigenous Correctional Program Officers and ILOs have the highest vacancy rate amongst the intervention staff in the SIUs (16%).

Interviewees noted repeated turnover for intervention positions such as SIU managers, SPOs, CPOs, and POs.

Over a quarter (28%) of institutional staff interviewed reported wanting to leave the SIU in the next 2 years, as the SIU is considered to be a more demanding posting than others in the institution.

Staff vacancies and turnover results in instability within the SIU team, which can also increase the risk of errors or negatively affect the ability to build a consistent rapport between inmates and staff.

Interviewees noted frustration among inmates in the mainstream population related to the perception that resources are being taken away from them to support the SIUs in meeting legislative requirements.

Staff interviewed also expressed feelings of frustration, discouragement, stress, and lack of motivation to fulfill their roles and responsibilities because of a heavy workload, busy schedule, and inmates being disengaged or refusing to avail themselves of the opportunity to spend time out of cell.

Most commonly, it was mentioned by staff interviewed that more interventions staff are needed, which included CPOs, POs, Indigenous Interventions staff, and SPOs. For example, there is a need for more Elders and staff supporting Indigenous inmates as these staff carry high caseloads.

Additionally, some staff would like to see scheduling changes for some interventions staff to allow for additional support and coverage during evenings and weekends.

The following reasons were cited:

• challenging work environment
• valuable learning experience
• great staff to work with
• feeling of being a role model; and
• meaningful work

Safety and security

Prevalence of assaults and incidents among populations

Prior to the implementation of SIUs a risk was identified that CSC will not be able to maintain required levels of operational safety and security in institutions with the elimination of segregation.

The rates of assault on staff by inmates, and on inmates by inmates (with the exception of 2022 to 2023), were higher for inmates who had been authorized to transfer to an SIU compared to the general population and the previous segregation model. The surge in assaults against staff was mainly driven by assaults involving fluids or waste.

The rate of use of force incidents was also higher for inmates who had been authorized to transfer to an SIU. Most use of force incidents are related to incident types “Behaviour Related” (for example, disruptive behaviours) or “Assault Related” (for example, inmate fight). Rates were higher at women’s institutions than at men’s institutions.

This increase in rates of assaults and incidents is further substantiated by interview responses referencing a changing inmate profile (such as, younger, more violent or having more complex needs), particularly at women’s institutions.

Note about incident data: An incident occurred if 1 of the participants in the incident (no limitations on role and/or involvement) had an active SIU authorization for transfer on the incident date. Therefore, the data includes inmates who met any of the 3 SIU authorization criteria.

Note about years identified in graphs:

• 2016 to 2017 is April 2016 to March 2017
• 2017 to 2018 is April 2017 to March 2018
• 2018 to 2019 is April 2018 to March 2019
• 2019 to 2020 is April 2019 to March 2020
• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

Safety and security concerns

Some staff that experienced threats or assaults from inmates, expressed concerns with unpredictable behaviour and the volatility of some inmates.

Interventions staff shared concerns with not being properly escorted or monitored. Some recalled incidents of being alone or locked in program rooms with inmates for an extended time.

Some staff also expressed their concern for themselves or for others, particularly women working in men’s institutions. A review of Threat Risk Assessments (TRAs) as well as on-site observations confirmed that some inmates have male-only protocols in place due to the nature of their behaviours towards women.

45% of inmates interviewed reported not feeling safe in the SIU as they feel other inmates can be hostile and violent.

Both inmates and staff expressed that incidents have occurred where incompatibles crossed paths, resulting in physical altercations.

Addressing concerns

Management reported addressing staff safety concerns by adapting operations and procedures as needed; for instance, requiring the use of barriers during inmate interactions when it is supported by a TRA.

Some staff expressed concerns regarding insufficient communication of TRAs and the need to use barriers, as well as the pressure to remove barrier restrictions early or feeling a reluctance to use them.

Staff interviewed explained that inmates’ safety and security concerns are reported to correctional staff and appropriate measures are taken; for instance, by strategically changing how an inmate is grouped with others.

Infrastructure

Observations and staff interviews identified many infrastructure issues that led to safety and security concerns. They include:

• lack of cuff slots to facilitate handcuffing an inmate
• insufficient number of cameras
• program areas out of sight
• availability and use of Personal Portable Alarms (PPA) and portable radios
• furniture or equipment not bolted down

Infrastructure and equipment

Inconsistent infrastructure

SIUs were placed into pre-existing locations within the institutions; thus, there were limitations to the design of the units. For instance, non-SIU inmates reside on ranges within the same buildings as the SIU, and the location of many of the spaces such as rooms and yards were already established. This means that at some institutions, non-SIU inmates are within visual and/or physical proximity of the SIU and in some cases, time spent in rooms and yards is split between SIU and non-SIU inmates.

A review of the number of spaces available for inmates to spend time out of cell revealed significant variances across institutions. When comparing the institutions visited, it was found that some SIU inmates are not able to be out of cell with other inmates or can only do so in small groups (2 to 3 inmates); therefore, if all inmates wanted access to a yard or room, or the SIU was at full capacity, it would not be possible for all inmates to be out of their cell.

Impacts of infrastructure

In addition to the safety and security concerns previously identified (refer to "Safety and Security" section for additional information), 90% of institutional staff and management have concerns with the existing infrastructure at their SIU location they most frequently cited the need for more inmate spaces.

Through interviews and observations, it was noted that at some institutions, there were not enough areas (for example, yards and rooms) available for inmates, or it took a significant length of time to move an inmate from their cell to the designated area. For example:

• due to the layout of the SIU, inmates could often not be moved out of their cell while other inmates were moving, which often delayed the start of an inmate’s time out of cell; and
• at times, inmates would be willing to accept an offer to come out of their cell, but there were no rooms available

As noted through interviews and observations, due to the unavailability of barrier-free spaces, some interactions took place through barriers when there was no need to have them in place.

Equipment for inmates

National minimum standards have not been established for the equipment available for inmate use in the SIUs, such as workout equipment, phones, kitchen appliances (for example, fridge, microwave), washers and dryers. This has resulted in significant variances in the amenities available for inmates to utilize while out of their cells.

It was noted during interviews and observations that equipment availability for inmate use is important to encourage inmates to come out of their cells. For example, having an insufficient number of phones available impacts an inmate’s ability to remain in contact with those outside the institution, including family and community ties.

There are a number of additional items that inmates and staff would like to see added to SIUs, including:

• basketball nets and yard benches
• better or more gym equipment
• microwaves
• computers
• additional phones
• televisions

Staff expressed concerns that inmates are often breaking the available equipment and that they are not able to protect it. Having to constantly replace the equipment that inmates are breaking results in additional costs to CSC.

Some additional equipment and infrastructure changes have taken place or are planned (for example, adding gym equipment into the outdoor yards). These changes will address some of the need for additional items.

Management of inmates

Overview of Structured Interventions Unit transfers

An overview of the procedures related to transfers is presented below.

1. pursuant to CCRA section 34(1), an inmate may be authorized to transfer into an SIU based on 1 or more of the following criteria: the inmate jeopardizes the safety and security of the institution, the inmate’s safety would be jeopardized if they were to remain in the mainstream population, or the inmate remaining in the mainstream population would interfere with an ongoing investigation
2. pursuant to CD 711, the AWI, during regular business hours, or the CM in charge of the institution outside of regular business hours, is responsible for authorizing an inmate’s transfer to the SIU. This authorization will be cancelled within 5 working days if a reasonable alternative is identified
3. pursuant to CD 711, inmates are transferred to an SIU once all reasonable alternatives have been explored and if the SIU is determined to be the least restrictive measure available
4. pursuant to CSC Guidelines 081-1, an inmate can file a grievance when they believe that a decision for or against a transfer to an SIU was unfair or improperly made, or when they want to get into or out of an SIU. This includes grievances on the procedures pertaining to a transfer to an SIU; right of recourse to the services of legal counsel at the time of transfer; any subsequent reviews and recommendations; and the rationale for remaining in an SIU. Decisions made by IEDMs cannot be grieved

Transfer authorizations

Rate of transfer authorization

National transfer authorization rates significantly decreased from 2020 to 2021, to 2021 to 2022 but increased in 2022 to 2023.

Men consistently had higher transfer authorization rates than women.

Indigenous inmates had higher transfer authorization rates than non-Indigenous inmates.

Note about years identified in graph:

• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

Reasons for transfer authorization

Initially, most inmates were transferred to the SIU for jeopardizing the safety and security of the institution (58.3% in 2020 to 2021). However, over time, the most common reason for transfer was for the inmate’s own safety (49.8% in 2021 to 2022 and 50.4% in 2022 to 2023).

Interviewees explained that some institutions have felt pressured to accept inmates with more challenging profiles. When these inmates impose their influence on the population, this results in an increased risk for victimization.

Documentation for transfer authorization

100% (75/75) of SIU authorization forms analyzed included the incident description or circumstances for transfer.

71% (53/75) of SIU authorization forms analyzed included evidence of consultation with the Case Management Team. The 29% (22/75) of SIU authorization forms analyzed that were missing this evidence took place after hours (such as, evenings and weekends). Documenting evidence of consultation with the inmate’s Case Management Team supports CSC’s ability to demonstrate that all reasonable and viable alternatives to a transfer to an SIU have been explored, as required by CD 711.

For instance, some inmates may satisfy multiple authorization criteria (which cannot be entered into the LTE-SIU), and there can be uncertainty around the appropriate recording of authorizations for inmates who resist to integrate into a non-SIU population (as this is a scenario not covered in legislation and policy).

Regional staff review SIU authorization forms to confirm whether the legislative criteria was met to authorize an inmate transfer to the SIU. However, the risk remains that staff authorized a transfer when it should not have been authorized, thus resulting in non-compliance with legislation.

Factors influencing transfer authorizations

The main contextual factors identified by interviewees included:

• reluctance or hesitancy to use the SIU (for example, pressure to keep the number of transfer authorizations low)
• insufficient time to investigate the incident or the inmate prior to authorizing a transfer to the SIU; and
• availability of alternatives, particularly when they are all perceived to have been exhausted

As referenced by some staff and observed during institutional visits, in response to pressure to keep SIU numbers low, inmates who otherwise would have been authorized for a transfer to the SIU based on meeting the legal criteria are sometimes housed in other ranges in the institution.

Interviews and file review of SIU authorization forms confirmed that institutions are working to ensure that various factors and alternatives are considered prior to a transfer to the SIU. Examples include:

• institutional or inmate safety
• inmate comments/statements
• informal conflict resolution
• needs or risks of inmate
• cultural interventions
• suitability of another institution; and
• security reclassification

Indigenous Social History considerations on transfer authorizations

Some institutional management feel that it was not clear how ISH factors apply to the transfer authorization and that ISH does not impact the decision to authorize the inmate into the SIU if the inmate’s risk in the institution supersedes the factors.

Interviewees also noted challenges in finding culturally appropriate alternatives for Indigenous inmates when a transfer to the SIU is being considered.

Alternatives to Structured Interventions Unit at women’s institutions

Staff at women’s institutions credited their low number of SIU transfers to:

• availability of options specific to women’s institutions (for example, Structured Living Environment Units and Enhanced Support Houses)
• effective programming, activities, or interventions
• lower number of inmates overall
• characteristics of women (for example, women are generally less violent, prefer building relationships, and less likely to misdirect anger towards others when compared with men); and 
• effective interdisciplinary approach

However, infrequent use of the SIU presented challenges for staff, who often needed to refamiliarize themselves with SIU policy each time a woman was authorized to the SIU.

At some women’s institutions, unused SIU cells were repurposed for other uses (for example, medical isolation or observation). At times, this impacted opportunities for time out of cell or interaction time for SIU inmates (for example, due to disruptions on the SIU range or not being able to use the range to facilitate activities).

Transfers out

Rates of transfers out

The goal of SIUs is to return the inmate to mainstream population as soon as safely possible. National transfer out rates significantly decreased between 2020 to 2021 and 2021 to 2022 but increased in 2022 to 2023.

Of the fiscal years (FYs) analyzed, 2020 to 2021 was the only FY where the transfer out rate was lower compared to those that were transferred in (refer to “Transfer Authorizations” section for trend data).

Men had consistently higher transfer out rates than women.

Indigenous inmates had higher transfer out rates than non-Indigenous inmates.

Note about years identified in graph:

• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

Transferring to a new institution

File review data noted that institutions are being consulted prior to transfer and that receiving institutions are typically supportive; however, some interviewees noted that at times the receiving institutions are not in agreement with the transfer that is being proposed making it more of a challenge to find a suitable population to transfer the inmate to.

Gaps were noted with regards to information that was included within Assessments for Decisions (A4Ds), as a review of A4Ds found that 38% (8/21) did not reference any previous SIU transfers and 29% (6/21) did not provide a summary and analysis for previous SIU transfers.

Transfer times

An analysis of transfer time subsequent to an IH decision to transfer an inmate out of the SIU suggested that the actual amount of time to arrange a complete transfer was not being captured.

• the median transfer times were less than a day
• the average varied from 8 to 17 days

Longer wait times for transfers within the same institution may have occurred when a decision had been rendered to transfer the inmate out of the SIU but after this decision was made, the inmate’s behaviour suggested that they may still pose a risk to their own safety, to others or to the security of the institution. As a result, the inmate was not immediately transferred out.

Inmates are prioritized for flights depending on their specific circumstances, but due to the infrequency of intra-regional ground transportation and inter-regional flights, inmates have at times been required to remain in the SIU at their current institution for longer than necessary. This issue is compounded at women’s institutions as inter-regional transfers are often the only choice.

Other challenges with transfers out included inmates needing to remain in the SIU while awaiting court, the transfer of inmate property, and limited population options to transfer inmates due to incompatibles. These challenges complicated the ability to facilitate the transfer of some inmates following an approved transfer decision and placed additional strains on resources.

Readiness for transfer out

Staff mentioned that in some cases they did not think an inmate was ready to be transferred out, mainly due to the inmates’ needs or risks not having been addressed, or continued safety and security concerns.

In these circumstances, staff reported that they would try to minimize the risks posed by these transfers by developing a risk management plan.

For example, taking preventative measures or finding a suitable alternative for the inmate.

Inmates’ refusal to transfer out

A major factor impacting the amount of time between the decision to transfer out and the actual transfer was an inmate’s resistance to leave the SIU.

Based on the administrative data analyzed, close to 1 in 5 (18%) inmates refused to transfer out after an IH decision. In addition, refusals were more commonly cited by staff working at men’s institutions.

Average wait times substantially decreased when refusals were factored out of the calculation.

Reasons for refusals

Staff interviewees identified several reasons for an inmate’s refusal to transfer out of the SIU.

Many inmates interviewed noted that while they wanted to transfer out of the SIU, they were waiting on a preferred option. For example, they wanted:

• security reclassification
• transfer to a specific population or institution; and
• transfer somewhere they would feel safe

Staff shared strategies used to get inmates to transfer out of the SIU. They include:

• encouraging and negotiating with inmates or addressing their concerns
• collaborating with other staff
• waiting until the inmate accepts a voluntary transfer; and
• involuntarily transferring the inmate (for example, using negotiators or the Emergency Response Team)

Staff also used creative strategies to ease inmates’ reintegration to a mainstream population, such as range visits or doing a gradual return to the range.

Overview of procedural safeguards

An overview of procedural safeguards is presented below.

1. as outlined in CD 711, inmates are subject to various internal reviews and decisions throughout their time in the SIU. Internal reviewers and decision-makers include the SIU Review Committee (SIURC), the Institutional Head, the ADCCO, and the Senior Deputy Commissioner (SDC)
2. pursuant to CD 711, after an inmate is approved for transfer to an SIU, the SIURC (normally chaired by the Deputy Warden and includes members of the inmate’s Case Management Team as applicable) will review each case pursuant to the required timeframes and provide recommendations to designated decision-makers. Following a review of the inmate’s case, the SIURC chairperson will meet with the inmate to advise them of the SIURC’s recommendation
3. pursuant to CD 711, the Institutional Head is required to meet with the inmate prior to the Institutional Head reviews, which take place within 5 working days of the SIU authorization and within 30 calendar days from the date of the SIU authorization to transfer
4. as outlined in CD 711, after a review or decision is rendered by a decision-maker, inmates are to be verbally advised within 1 working day and/or provided a written copy within 2 working days from the date of the review or decision
5. pursuant to CD 711 and CSC Guideline 711-1, once a designated decision-maker has determined that an inmate no longer meets the legislative criteria to remain in the SIU, a decision is rendered to transfer the inmate out of the SIU and into the mainstream population as soon as possible

Further information regarding CSC SIU review timeframes can be found in CD 711.

Procedural safeguards

Comprehensiveness of Structured Intervention Unit Review Committee recommendations and Institutional Head reviews

29% (499/1,724) of SIURC recommendations examined between April 2021 and March 2023 that were made prior to the IH 30-day SIU transfer decision recommended that the inmate be transferred out of the SIU.

78% (1,686/2,163) of inmates transferred out of the SIU after an SIURC recommendation to transfer out were successful^{Footnote 10}  in not returning to the SIU, a much higher percentage than that for SIU inmates overall. This suggests that their approach to considering alternatives and assessing risks when making recommendations is effective.

Most interviewees spoke to an efficient SIURC process with minimal delays, as decision-makers receive timely recommendations within the 20-day review deadline and generally regard this timeframe as appropriate. File review confirmed that SIURCs took place within the required timeframes for the sample selected.

79% (53/67) of the IH 5-working day SIU transfer decisions analyzed did not have all required sections completed. Sections most commonly missing information included inmate representations including legal counsel/assistant, inmate engagement in opportunities for interaction with others, and inmate personal representation.

62.5% (30/48) of the IH 30-day SIU transfer decisions analyzed did not have all required sections completed. Sections most commonly missing information included inmate representations including legal counsel/assistant and gender identity/expression factors.    

Outcome of Institutional Head reviews

The decision-maker believed that the legislative criteria was no longer met for the inmate to remain in the SIU:

• 27% (18/67) of the time for the IH 5-working day SIU transfer decisions reviewed
• 52% (25/48) of the time for the IH 30-day transfer decisions reviewed
• 40% (20/50) for the regional reviews reviewed
• 10% (3/31) of the time for the SDC decisions reviewed
• 31% (13/42) of the time for the non-ad-hoc SIURC recommendations reviewed

Most often, it was determined that the inmate had a viable option for transfer to another unit, range, or other institution, or the behaviours that resulted in their initial transfer to the SIU were no longer present.

When the decision-maker determined that an inmate no longer met the legislative criteria to remain in the SIU, they rendered a decision to transfer the inmate out of the SIU. However, at times, it can be challenging to remove the inmate from the SIU after this decision has taken place (refer to “Transfers Out” section for additional information). This impacts CSC’s ability to fulfill CCRA section 34 “an inmate’s confinement in an SIU is to end as soon as possible”.

Transfer-related grievances

Between April 2021 and March 2023, a total of 121 grievances regarding an inmate’s SIU transfer were filed. Of those, 21.5% (26/121) were upheld or upheld in part^{Footnote 11} .

Meeting with inmates and quality of information sharing discussions

CD 711 requires the IH to meet with the inmate prior to making their 5-working day and 30-day SIU transfer decisions.

• a meeting occurred between the inmate and IH 46% (31/67) of the time prior to the 5-working day IH decision 
• a meeting occurred between the inmate and IH 31% (15/48) of the time prior to the 30-day IH decision

Without sufficient discussions between the inmate and the decision-maker prior to decisions taking place, all pertinent information may not be shared.

CD 711 requires the SIURC chairperson to meet with the inmate to advise them of the SIURC recommendation. The Chairperson of the SIURC met with the inmate 14% (6/42) of the time to advise them of the recommendation that was being proposed to the decision-maker regarding whether they should remain in the SIU.

Although 89% (17/19) of the inmates who were asked indicated that they received information in writing regarding their time in the SIU, about 33% (8/24) of institutional management interviewed indicated that they have challenges sharing information verbally or in writing with inmates.

1 challenge mentioned was sharing information in the inmate’s official language of choice.

It was observed that the quality of discussions taking place when decisions were being shared varied from institution to institution and depended on the individual who was sharing the information. At some institutions there was an engaged discussion, while at others, the inmate was provided with the paperwork without a discussion taking place.

Without sufficient discussions following a recommendation or decision, the inmate may not be aware of, or understand, the recommendations and decisions being made.

Sharing information with inmates: Verbal and written notification of reviews and decisions

CD 711 requires the inmate to be verbally notified within 1 working day, and provided the written decision within 2 working days, upon completion of the IH 5-working day SIU transfer decisions and IH 30-day SIU transfer decisions.

• in 42% (48/115) of the files reviewed, evidence was missing of verbal notification taking place within 1 working day
• in 49% (56/115) of the files reviewed, evidence was missing of written notification taking place within 2 working days

CD 711 requires the inmate to be provided the written decision within 2 working days upon completion of a regional review.

• in 66% (33/50) of the files reviewed, evidence was missing of written notification taking place within 2 working days

CCRR section 23.01(2) requires the inmate to be verbally notified within 1 working day, and provided the written decision within 2 working days, upon completion of the Commissioner’s decision (which has been delegated to the SDC as per CD 711).

• in 25% (8/32) of the files reviewed, evidence was missing of verbal notification taking place within 1 working day
• in 19% (6/32) of the files reviewed, evidence was missing of written notification taking place within 2 working days

Only 42% (11/26) of information or decision sharing interactions observed across all institutions were documented in the LTE-SIU.

Reviews of inmates’ paper files were completed while visiting the institutions to see if a handwritten signature could be located on the documentation shared with the inmate. A handwritten signature by the inmate and/or 2 staff witnesses is required on review and decision documentation to acknowledge that the document was shared.

• in 17% (22/129) of the files reviewed, the information sharing documents could not be located
• 94% (101/107) of the information sharing documents that could be located had a handwritten signature to acknowledge that the document was shared

Overview of conditions of confinement

An overview of the procedures related to the conditions of confinement is presented below.

1. pursuant to CCRA sections 36(1), once transferred to the SIU, CSC is required to offer inmates a minimum of 4 hours of time out of the cell and a minimum of 2 hours of meaningful interaction
2. pursuant to CD 711, while an inmate is in the SIU, every effort will be made to provide them time out of cell and interactions with others without the use of barriers. Any imposition of barriers for inmates transferred to an SIU must be supported by the completion of an SIU Threat Risk Assessment (SIU-TRA) that identifies the specific risk(s) the inmate presents as well as the barriers required to mitigate the risk(s). Where barriers are used on an inmate, a daily SIU-TRA must be completed to confirm the need for continued use, to amend the use or type of barrier, or to discontinue the use
3. pursuant to CCRA section 37.83(1) and CCRR sections 23.06(1) and 23.07(1), an IEDM review can be triggered when:
   • an inmate is not out of cell for a minimum of 4 hours/day OR an inmate is not engaging in meaningful human contact for a minimum of 2 hours/day for 5 consecutive calendar days, for 15 out of 30 calendar days, or for 10 consecutive calendar days; and
   • an inmate who was authorized to be transferred to an SIU at least 4 times within a period of 180 consecutive days and the case was not, during that period, referred to the IEDM
4. pursuant to CCRA section 37.83, when an IEDM review is triggered, the IEDM determines whether CSC has taken all reasonable steps to provide the inmate with opportunities for time outside of their cell and encourage the inmate to avail themselves of those opportunities. If the IEDM determines that CSC has not done this, they may make any recommendation to CSC that they consider appropriate to remedy the situation. CSC must then satisfy the IEDM that they have taken all reasonable steps; if not, the IEDM shall direct CSC to remove the inmate from the SIU
5. pursuant to CSC Guidelines 081-1, an inmate is also entitled to grieve their conditions of confinement while in the SIU

Further information regarding IEDM reviews and decision timeframes can be found in CD 711.

Conditions of confinement

Offers of time outside of cell

Staff and inmates reported that inmates were offered time out of cell more often compared to when inmates were in segregation.

According to the LTE-SIU data from April 2020 to March 2023, time out of cell was offered to SIU inmates 92% of the time when such an offer was required by CCRA section 36(1)(a).

• women were offered less frequently (87%) than men (92%)
• Indigenous inmates were offered more frequently (93%) than non-Indigenous inmates (92%)

However, inmates accepted the offer 32% of the time.

• women accepted offers more frequently (42%) than men (32%)
• Indigenous inmates accepted offers more frequently (40%) than non-Indigenous inmates (25%)

Note about years identified in graphs:

• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

Offers of interaction with others

According to the LTE-SIU data from April 2020 to March 2023, interaction time was offered to SIU inmates 94% of the time when such an offer was required by CCRA section 36(1)(b).

• women were offered less frequently (91%) than men (94%)
• Indigenous inmates were offered the same (94%) as non-Indigenous inmates (94%)

However, inmates accepted the offer 53% of the time.

• women accepted offers less frequently (43%) than men (53%)
• Indigenous inmates accepted offers more frequently (58%) than non-Indigenous inmates (48%)

Note about years identified in graphs:

• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

Structured Interventions Unit grievances

Between April 2021 and March 2023, a total of 101 grievances were filed related to conditions of confinement in the SIU. Of those, 9% (9/101) were upheld or upheld in part.

Meeting requirements

Some SIUs are in former segregation ranges which in some cases impacted how staff and inmates viewed the SIU. Some staff noted that the environment is not conducive to rehabilitation, nor does it support wellness.

Staff indicated in interviews that they were not always able to adequately provide the required time out of cell and interaction with others for various reasons such as inadequate infrastructure, staff shortages or vacancies, institutional routines, and challenges managing incompatible inmates.

Some institutions have undertaken efforts to make rooms used for outside of cell time more inviting, such as painting the walls and adding items such as televisions and workout equipment.

Interviews and observations revealed that in some instances, inmates are not accepting offers due to the condition of the rooms being used. For example, some rooms had benches and chairs that are hard and made of metal, which are uncomfortable to sit on for long periods of time. Also, mesh screens used for inmates on barriers, as well as poor ventilation in some rooms makes communication difficult.

Observations identified that a wide variety of approaches were used by staff to offer time out of cell and interaction time to inmates. There were differences in the tone of the staff members that offered the activities to the inmates, the number of activities that were offered by staff to the inmates, and the time taken by staff to discuss the activities offered to the inmates.

For some offers, limited information was provided to the inmate about the activity being offered. For example, staff asked the inmate if they wanted “programs” without explaining what that entailed. In some cases, when more information was provided, the inmate changed their mind about not participating or was willing to participate in the initial offer.

Threat Risk Assessment documentation

When a barrier was identified as being used, the required TRA as per CD 711 was in place 62% (28/45) of the time for the sample reviewed.

• 44% (20/45) included sufficient information to justify the use of barriers and identified the risk the inmate presented
• 18% (8/45) did not contain enough information to justify the use of barriers

For inmates who remained on barrier restrictions, a daily TRA was completed 60% (26/43) of the time. However, only 35% (15/43) of the files identified whether the risk the inmate presented still existed.

The information on whether barriers were used or not was accurately recorded in the LTE-SIU application for 94% (233/248) of the interactions observed during institutional visits. However, for 44% (7/16) of the interactions observed where barriers were used, the inmate did not have a current TRA on file.

Without a TRA on file, CSC is unable to demonstrate compliance with CCRA section 32(2) that requires that every reasonable effort be made to ensure opportunities for interaction are not mediated or interposed by a physical barrier.

File review, observations and interviews identified instances where an inmate refused to come out of their cell because they were on barrier restrictions.

Responding to Independent External Decision Maker reviews

An analysis of a sample of 119 IEDM reviews that took place between December 2019 and November 2023, due to the inmate not receiving their daily entitlements for a consecutive 5-day period, or 15 cumulative days over a 30-day period, showed that:

• in 14% (17/119) of the cases, the IEDM, pursuant to their authority outlined in CCRA section 37.83(1), determined that CSC had not taken all reasonable steps for the inmate to receive at least 4 hours per day outside of cell and 2 hours of interaction with others
• it took a median of 7 days for CSC to respond to the IEDM decision
• of the cases where the IEDM, pursuant to their authority outlined in CCRA section 37.83(3), determined that CSC had not taken all reasonable steps, the IEDM directed CSC to transfer the inmate out of the SIU 18% (3/17) of the time; and
• it took a median of 17 days for the inmate to be transferred out of the SIU after the IEDM’s decision date

An analysis of a sample of 53 IEDM reviews that took place between December 2019 and November 2023, due to the inmate not receiving their daily entitlements for a consecutive 10-day period, showed that:

• in 15% (8/53) of the cases, the IEDM, pursuant to their authorities outlined in CCRR section 23.06(1) and CCRA section 37.83(3), directed CSC to remove the inmate from the SIU; and
• it took a median of 39 days for the inmate to be transferred out of the SIU after the IEDM’s decision date

Delays in the transfer out process impact CSC’s ability to fulfill CCRA section 34 “an inmate’s confinement in an SIU is to end as soon as possible.”

Overview of programming, interventions, services, and leisure

An overview of the procedures related to programming, interventions, services and leisure is presented below.

1. pursuant to CCRA section 36(1)(b)(i), CSC is required to provide inmates with programming, interventions, services, and leisure time that encourage progress towards the objectives of their correctional plan or that support the inmate’s reintegration into the mainstream population
2. pursuant to CD 711, all inmates in a men’s institution who are transferred to an SIU are to be considered for a referral to the Motivational Module - Structured Intervention Unit (MM-SIU) or the Motivational Module - Structured Intervention Unit - Indigenous (MM-SIU-I), regardless of whether they have an identified correctional program need. The continuation of a program, intervention or services that commenced prior to an inmate’s transfer to an SIU is to be prioritized, pending approval
3. as outlined in CD 711 and CSC Guidelines 711-1, there are various key SIU case management documentation that are to be completed during the inmate’s time in the SIU which include or assess several types of factors (example: Structured Intervention Unit - Correctional Plan Updates (SIU-CPUs), Correctional Plan Updates (CPUs), Assessments for Decision (A4Ds), and Program Performance Reports for the Motivational Module). An A4D is only required to be completed when an inmate in the SIU is being transferred out to a different institution.

Effectiveness of programming, interventions, and leisure^{Footnote 12}

Outcomes of programming, interventions, and services

Approximately 50% of CPOs interviewed perceived the MM-SIU/MM-SIU-I programs (only available at men’s institutions) as relatively ineffective. The most cited reasons by CPOs and inmates for their ineffectiveness include:

• program not tailored to the inmate’s needs (such as, if the inmate is the victim or if the inmate is the subject of an investigation)
• program not addressing the transfer reason (such as, issues that led to the transfer to the SIU still need to be addressed such as incompatibles or debts); and
• programs were repetitive or not effective even if taken multiple times

An analysis of administrative data found that 50% (10/20) of inmates who participated in the MM-SIU/MM-SIU-I programs returned to an SIU. These results suggest that the MM-SIU/MM-SIU-I programs are not entirely effective in reducing the likelihood of returning to an SIU.

A file review of 20 inmate cases that had a program report for MM-SIU/MM-SIU-I found that:

• 45% (9/20) of program reports documented that the inmate had a better understanding of what led to their SIU placement as a result of participating in the MM-SIU/MM-SIU-I; and
• 55% (11/20) reported that the inmate transferred out of the SIU prior to completing the modules assigned to them, although there is no requirement in policy that all modules assigned need to be completed

A file review of 50 SIU-CPUs found that:

• 96% (48/50) had an Intervention Plan, but 78% (39/50) did not reference consulting with the inmate on the Intervention Plan; and
• 74% (37/50) had progress documented, but only 50% (24/48) of SIU-CPUs that had an Intervention Plan documented progress made against the objectives identified in this plan

In addition, of the 30 CPUs reviewed:

• few documented progress against accountability (3%), engagement (7%), and motivation (17%)
• no progress was documented against reintegration potential; and
• less than 10% documented a rating change for dynamic factors while in the SIU and in most CPUs, progress made on dynamic factors was not linked to the provision of programming, interventions, and services in the SIU
  • most inmates in general have limited change in their risk or need levels from the beginning of their sentence to their release into the community

70% (14/20) of SIU-CPUs for Indigenous inmates with an Intervention Plan had ISH incorporated into them and 71% (10/14) of these Intervention Plans included assignments to cultural interventions to address the inmate’s ISH factors and Indigenous-specific needs.

Further definitions can be found in Appendix A.

Documentation issues

A review of 50 SIU-CPUs found that:

• 100% (50/50) of the SIU-CPUs were completed; and
• some required considerations were not included within the documentation

A review of 36 files for inmates who were assigned to the MM-SIU or MM-SIU-I found that:

• 56% (20/36) of program reports did exist; and
• of the 20 files where a program report existed, some information was not included within the documentation

A review of assessments for decision (A4Ds) found that:

• 69% (22/32) did not document the inmate’s participation in programs and interventions since their SIU transfer, as required by CSC Guidelines 711-1; and
• 50% (16/32) of A4Ds had a plan to manage the inmate in the mainstream population, and 46% (13/28) of the A4Ds for an involuntary transfer out of the SIU had a plan to manage the inmate in the mainstream population

Access to programming, interventions, services, and leisure

Most inmates interviewed at men’s institutions stated that they received immediate access to programming, interventions, services, and leisure in the SIU.

A review of SIU-CPUs found that inmates were mostly assigned to the MM-SIU/MM-SIU-I, social programs, and educational programs.

According to CCRA section 4(g), CSC is guided by the principle that correctional policies, programs and practices respect:

• gender
• ethnic
• cultural
• religious and linguistic differences
• sexual orientation 
• gender identity and expression

However, staff and inmate interview responses noted a lack of access to programming, interventions, services, and leisure specific to Black and gender diverse inmates while in the SIU. Some inmates also noted challenges accessing programming, interventions, services, and leisure in their official language of choice while in the SIU.

Access to mainstream correctional programming

Only 12% (6/50) of SIU-CPUs reviewed had documented assignments to mainstream correctional programming.

Interviewees noted that mainstream correctional programming is often suspended until the inmate is reintegrated into the mainstream population. This delays an inmate’s progression against their correctional plan.

Although it can be a challenge, interviewees noted that some institutions still try to deliver some of the modules from mainstream correctional programs. At some institutions (mainly women’s institutions), staff from the mainstream population will continue to work with the inmate during their time in the SIU, or some inmates will attend programming in the mainstream population if it is safe to do so.

Challenges accessing activities

Interviewees noted that the shortage of Elders and Indigenous staff has impacted access to Indigenous activities, including MM-SIU-I, and that having many incompatible inmates in the SIU can impact the facilitation of Indigenous cultural interventions, which are typically intended to take place in a group setting.

Challenges with inmate movement may also impact the ability to offer some activities (for example, at some institutions, inmate movement does not occur during medication distribution or deployments of the Emergency Response Team, which can range from minutes to hours; therefore, inmates are not able to be out of their cells during this time).

Inmates’ willingness to participate in programming, interventions, services, and leisure

Only 48% of inmates interviewed said that they typically accept offers of programming, interventions, services, and leisure.

Social, educational, and correctional programs were the types of activity most frequently accepted by inmates.

Inmates accepted offers for MM-SIU-I (71%) more often than the MM-SIU (65%), as well as other types of programs (63%).

Staff and inmates noted common reasons why inmates refused to avail themselves of opportunities, including:

• fear for safety and/or concerns about incompatible inmates
• preferring to be alone
• not wanting to participate in an activity with a group
• weather was too cold or too hot
• offer was made too early in the day
• mental or physical health concerns
• disliking or not believing the activity would be helpful; and
• dislike or distrust towards the staff member who made the offer

Inmates felt that yards are too small, there was a lack of equipment, or were uncomfortable sharing a space with another inmate.

Aa review of 20 files found that some modules within the MM-SIU and MM-SIU-I programs were more popular.

Staff interviewees also shared strategies used to encourage inmates to accept offers.

Programming, interventions, and services

Examples included:

• social programming
• cultural interventions from Elders
• substance abuse programming (for example, Wellbriety)
• Dialectical Behaviour Therapy (DBT)
• Fit for Life
• educational programming and partnerships with post-secondary institutions
• skills coaching, vocational training and self-study programs (for example, Workplace Hazardous Materials Information System (WHMIS), the National Employability Social Program, CORCAN); and
• programs with a connection to the community (for example, Dad Hero Program, therapy dogs, John Howard Society)

Additional programming, interventions, and services

Examples included:

• hobby training
• physical education
• culturally relevant support programming
• a program or module to introduce the SIU
• additional substance abuse programming (for example, Alcoholics Anonymous, SMART recovery)
• community integration programming and life skills training
• additional vocational and skills training and certification programs
• mental health or behavioural programming (for example, anger management); and
• spiritual and religious programming

Overview of health care

An overview of the procedures related to health care is presented below.

1. pursuant to CCRA section 37.1(1), CSC must ensure that measures are taken to provide for the ongoing monitoring of the health of inmates in an SIU. This is done through daily visits and health assessments
2. pursuant to CCRA section 37.1(2)(b), CSC is to ensure a visit to the inmate at least once every day by a registered health care professional. As per CD 711, the visit must include a visual observation, without physical barriers, of the inmate, unless due to exceptional circumstances, such observation would jeopardize the security of the institution or the safety of any person
3. pursuant to CD 711, inmates are to be provided with an assessment of their health, including mental health, by a registered health care professional within 24 hours of the inmate’s authorized transfer to an SIU and every 14 days from transfer to an SIU. A mental health assessment will also be completed no later than the 28th day from the authorization to transfer to the SIU. As referenced in CCRA section 2(1), the mental health assessment must be conducted by a medical professional with recognized specialty training in mental health diagnosis and treatment, such as a psychiatrist, psychologist or psychiatric nurse or a primary care physician who has had psychiatric training

Effectiveness of Health Services

Structured Interventions Unit population mental health overview

Women were more likely to have a mental health need identified prior to transfer compared with men (67% vs 29%).

Hispanic (36%), Indigenous (35%), and Caucasian (31%) inmates had higher proportions of identified mental health needs than Asian (20%), Black (17%), Multiracial (16%), and other racial groups (14%).

Amongst inmates with an identified mental health need:

• inmates with a rating of considerable or higher needs on the Mental Health Needs Scale (MHNS^{Footnote 13} ), on average, spent around 4 days less than those with a rating of some need (23 days vs 27 days)
• Indigenous inmates, on average, spent slightly more time in the SIU in comparison to other racial groups (Indigenous: 29 days, Black: 25 days, White: 22 days); and
• women, on average, spent fewer days in an SIU than men (5.5 days vs 27 days)

Practices include:

• review of reports and case documentation
• daily interactions and IH visits
• consultation with other staff
• observation of inmates’ behaviour, appearance, and environment
• tracking inmates refusing to avail themselves for time out of cell and meaningful interaction
• mental health assessments and daily health care visits

Although the proportion varied over the years, according to April 2022 to March 2023 HARS data, 9% (147/1,645) of inmates had a negative change in their mental health need during their time in the SIU.

The majority of those with increasing needs in the SIU did not require care beyond the services that were already provided within the SIU and therefore did not require more intensive services (either intermediate or inpatient).

Some interviewees explained that the experience of the SIU can worsen the mental health of inmates with previously identified mental health needs.

Some inmates reported a deterioration in their mental health and experiencing feelings of isolation, depression, anxiety, anger, or frustration following their transfer. This deterioration can manifest as extreme weight loss, self-harm, or violent behaviour.

Despite the mental health challenges of the SIU population, interviewees noted some positive impacts on the inmate’s well-being. For some inmates, the SIU can be a constructive environment and positively impact their mental health.

Health intervention and reintegration support

Some staff and inmates interviewed did not perceive the health services received in the SIU as being a contributor to an inmate’s reintegration, but rather as a service to be provided if needed.

The perceived effectiveness of health interventions in supporting inmates in the SIU with their reintegration to the mainstream population increases when:

• inmates participate in their assessments
• the health care team is well integrated and coordinated in the SIU with the rest of the case management team
• there is the provision of ongoing support and care to inmates, particularly mental health care
• effective treatment plans are developed that tailor to the inmates’ needs and risks; and
• inmate needs are not as complex

The quality of care^{Footnote 14}  review conducted by Health Services at NHQ identified that the quality of care for inmates in an SIU was mostly rated as appropriate, despite these perceptions of the effectiveness of health interventions in the SIU. As well, with increased oversight by Health Services at NHQ, the overall appropriateness of care and documentation has improved over the years.

• a minority of inmate cases were considered as having major or minor quality of care or documentation issues^{Footnote 15}
  • issues were mostly related to assessment, documentation, and response to referral
  • for example, due to the mental health or health assessments not being completed, providing insufficient details, or being repetitive

Provision of health services

68% (1,107/1,619) of inmates with an identified mental health need received treatment, regardless of level of need.

The proportion of inmates receiving treatment increased slightly over the years.

Some groups received treatment at higher rates such as:

• inmates with considerable or higher needs rating on the MHNS scale compared to inmates with some needs
• women compared to men; and
• Indigenous inmates (with high/considerable need) and Black inmates (with some need) compared to white inmates

• most of the inmates interviewed reported having more (42%) or equal (26%) access to health care services in the SIU compared to the mainstream population. Many attributed the increased access to the daily health care visits, which are required as per CCRA section 37.1(2)(b)
• through a review of LTE-SIU data, evidence could be located 91% of the time (858/940 days) to demonstrate that the daily health care visit took place
  • as daily health care visits generally only take place once per day, there is a risk that inmates may not have an opportunity to meet with them if they are transferred in or out of the SIU before or after the daily visit
  • If first day and last day of SIU placement are removed from the results, evidence could be located 95% of the time (892/940 days) to demonstrate that the daily health care visit took place

A detailed review of a sample of inmate files found:

• 98% (49/50) of the 1-day assessments on file for the sample, of which 96% (47/49) took place at the correct interval
• 100% (186/186) of the 14-day assessments on file for the sample of inmates, of which 86% (160/186) took place at the correct interval; and
• 96% (48/50) of the 28-day assessments on file for the sample of inmates, of which 87.5% (42/48) took place at the correct interval

Further, the 28-day mental health assessments must be completed by an individual with the appropriate qualifications as defined within the CCRA. This requirement was fulfilled for 90% (43/48) of the 28-day mental health assessments reviewed.

Critital challenges

Inmates refused to participate in health assessments 63% (10,356/16,384) of the time.

• fewer women refused to participate (22%, 43/195) than men (64%, 10,313/16,189)
• a higher proportion of Black inmates refused to participate

Interviewees noted the following reasons:

• inadequate infrastructure (for example, lack of rooms to conduct assessments, distance from SIU to health care unit)
• lack of coordination of health care visits
• privacy concerns (for example, lack of a private setting); and
• time of day

Most interviewees deemed that health assessments were somewhat to rarely effective, and the effectiveness was dependent on factors such as:

• willingness of inmates to participate
• ability to tailor treatment plans to needs and risks
• if information from the assessment is communicated to other staff (when relevant); and
• completeness and timeliness of treatment plans

Because of the complex profile of the SIU population, some institutions have taken specific approaches to the daily visits; for instance, open door, closed door, or behind barrier. However, not all of these approaches are in alignment with policy which states that visits are to take place without physical barriers unless under exceptional circumstances.

The quality of the daily health care visits varied due to factors such as the length of the visit, staff’s level of engagement with the inmates, and the physical proximity between the staff and the inmate.

There is some guidance on the expectations regarding daily visits within the CSC Mental Health Guidelines. However, it is not referenced directly within CD 711, increasing the risk that not all staff are aware of the existence of this guidance.

As well, there are no health care resources exclusively assigned to the SIU and the number and type of health care staff providing services to SIU inmates was inconsistent across institutions. This affects familiarity with expectations regarding the approach to the daily visits.

If visits are taking place with physical barriers or if health care is not having a discussion with the inmate, health care may not be able to properly assess the inmate’s current state and identify day-to-day changes in their overall health.

In addition, inmates may also be less willing to communicate with health care staff when it is through a barrier as it removes the personal element of the interaction.

Oversight and performance

Monitoring and reporting

Accuracy of Long-Term Evolution-Structured Intervention Unit information

CD 711 outlines that the time an inmate spends out of their cell and the time they engage in meaningful human contact must be documented in the LTE-SIU application. However, 23% (76/331) of interactions observed while visiting the institutions were not recorded in the LTE-SIU. Of those that were recorded in the LTE-SIU, the information aligned with the interaction observed only 62% (159/255) of the time.

There is inconsistency in how staff determine which interactions are recorded, what should be recorded, what is meant by meaningful interaction, and who is inputting entries into the LTE-SIU.

• at the same institution, a staff member said they would record all interactions in the LTE-SIU because even a -minute conversation might make a difference, while another staff member believed that if a conversation was less than 5 minutes there was no point in entering that interaction into the LTE-SIU
• some institutional staff indicated that the responsibilities for entering information into the LTE-SIU were not clearly documented, nor did they understand the extent or level of detail they had to document

The SIU can get very busy due to multiple inmates participating in activities at the same time. At times, staff were delayed in inputting their entries into the LTE-SIU. Other times, staff were having to enter information about interactions on behalf of their colleagues based on what they were observing from a distance or based on the information they were provided. These types of situations impact the ability to accurately record the exact start and end times, duration, and details of the interaction and lead to a misrepresentation of time out of cell and meaningful interaction for inmates.

There are also restrictions within the LTE-SIU application. For example:

• the LTE-SIU application does not allow for multiple entries to take place at the same time, such as a health care visit taking place during an inmate’s yard time. If there is an entry already inputted incorrectly, staff need to move their activity time around which leads to overall inaccuracy within the system as it causes a ripple effect onto other entries
• the activity type drop-down options for categorizing an interaction with an inmate are restricted based on the staff member’s position. Staff must pick the most fitting choice from the drop down, which may not fully reflect the activity that took place with the inmate

Long-Term Evolution-Structured Intervention Unit interaction information

There are multiple systems where staff can record information for inmates (for example, OMS, LTE-SIU), but these systems are not integrated.

Some staff felt this was a duplication of effort and redundant. When staff put detailed information in an OMS casework record and do not put in the same effort when documenting in the LTE-SIU, this results in poor quality of information within the LTE-SIU interaction details.

Long-Term Evolution-Structured Intervention Unit reason for refusal

Per CCRA section 37(2), “CSC should maintain a record of every instance the inmate refused, indicating the specific opportunity and any reason given for the refusal.” A review of LTE-SIU data found that the pre-populated generic options were almost always completed but did not provide additional information on the specific reason the inmate was refusing and, in some cases, did not align with the reason written in the notes.

Additionally, some descriptions in the notes were unclear, making it challenging to determine if it was the staff member’s assessment of the situation or the inmate’s response.

As a good practice, some institutions within the Quebec Region used a specific structure to write their notes in the LTE-SIU application when an inmate refused to participate in an activity. They identified the staff member who made the offer, the length of time of the proposed activity, the inmate’s reason for refusal, the methods used to encourage the inmate to participate, and the alternative activities that were offered to the inmate.

There is recognition that improvements are required related to the quality of the LTE-SIU information.

Measures have been put in place since the initial implementation of the SIUs, such as data review by Correctional Managers and SIU Data and Activity Coordinators.

Additionally, when interactions need to be adjusted, follow-ups with staff are done to make the required changes.

Monitoring Structured Interventions Unit information

IHs, AWIs, SIU managers, CMs, SIU Data and Activity Coordinators, and COs are responsible for collecting, analyzing, and monitoring SIU-related information.

Through monitoring the information available, CSC compares current trends and results with prior periods to assess performance.

Institutions use real-time data to target certain inmates for program offers and identify best practices with the goal of increasing the overall inmate’s acceptance of offers.

Institutions also use what they learn through monitoring processes to focus on the areas where a need for improvement has been identified. Information and training is also provided to staff on how to make improvements to areas such as:

• data collection
• completeness and accuracy of LTE-SIU and OMS information
• timeliness of certain reviews and associated documentation

Measuring performance

Performance indicators

CSC currently reports on 2 SIU-related performance indicators in the Departmental Results Framework.

Percentage of successful transfers out of SIUs

• CSC only met its current target range in 2021 to 2022

Median number of days spent in SIUs

• CSC met its target range in 2020 to 2021 and 2022 to 2023

Note about years identified in graphs:

• 2020 to 2021 is April 2020 to March 2021
• 2021 to 2022 is April 2021 to March 2022
• 2022 to 2023 is April 2022 to March 2023

A large number of inmates experience multiple transfers to the SIU.

• 47% of inmates in the sample experienced 2 or more SIU transfers
• 2.1 was the average number of transfers per inmate
• 33% of inmates with subsequent transfers returned after 120 days

Interviewees identified challenges with reintegration, such as:

• inmate issues with behaviour in the mainstream population
• inmate escalating or continual violence or threats
• inmate fear or concern for their safety and security
• unavailability of a reasonable alternative placement; and
• SIU’s perceived attractiveness

Interviewees noted concerns with the effectiveness of the SIU model, such as:

• some inmates could benefit from staying longer in the SIU to receive interventions that will address their needs and risks, conflicting with the expectation that an inmate’s confinement in an SIU is to end as soon as possible; and
• performance is highly dependent on the inmate’s willingness to engage and take accountability for their behaviour

There is a perception that the SIU model may be ineffective for some sub-populations of inmates. For example, inmates who have very high mental health needs, are extremely violent, do not want to integrate, or prefer isolation. It was referenced that some of these inmates are transferred from institution to institution to try and reintegrate them into a mainstream population, but their behaviours have not changed.

Measuring outcome-based performance

In addition to the SIU-related performance indicators in the Departmental Results Framework, CSC monitors:

• percentage of days inmates housed in SIUs were offered time out of their cell
• percentage of days inmates housed in SIUs were out of their cell
• percentage of days with interaction time offered to inmates housed in SIUs
• percentage of days where interaction time was availed by inmates housed in SIUs
• percentage of accepted offers of interventions in SIU; and
• median number of days from decision to transfer an inmate out of the SIU to the actual transfer

Interviewees emphasized that there is a heavy focus on showing compliance with legislative requirements and using quantitative data. It was believed that this does not reflect other relevant aspects of performance that take into consideration an inmate’s progress and/or “small wins” in the SIU and that recognize the efforts of the staff working with the inmates in the SIU.

Examples of small wins and success stories shared by interviewees were related to:

• a staff member building a rapport with an inmate
• an inmate who previously refused to engage deciding to converse with a staff member
• an inmate being able to remain in the mainstream population for longer after each SIU transfer out
• an inmate developing the tools and skills required to change behaviours
• introducing new types of staff and volunteer programs within the SIU

When there are differing views of what a success would be in the SIU and when these other relevant aspects of performance are not taken into consideration as part of performance measures, staff motivation is impacted, as some inmates are not able to meet the identified expectations.

Conclusions and recommendations

Overall conclusions

Compliance

Concerns were noted regarding the existence, accuracy, and level of detail of information in the LTE-SIU application and SIU-associated documentation, and evidence was not always available to support that CSC complied with relevant legislation and policies related to SIUs.

Effectiveness/Performance

The effectiveness of the SIU in meeting inmate-specific needs is varied, largely dependent on the inmate’s level of accountability and willingness to engage in the programming, interventions, and services offered to them.

While the SIU model provides an increased level of timely access to programming, interventions, and services, challenges remain, such as:

• access to mainstream correctional programming
• the applicability of the MM-SIU/MM-SIU-I for some inmates; and
• consultation with Elders, ILOs, and spiritual advisors

There are also challenges maintaining institutional safety and security in the SIU.

Efficiency

Despite the significant amount of financial and human resources that have been allocated to SIUs, CSC is falling short of achieving its objectives in responding to inmate risks and needs and contributing to the successful reintegration of inmates into the mainstream population.

CSC faces challenges in operationalizing the SIU model due to:

• the contradiction between the SIU objectives of providing programming, interventions, and services aimed at changing behaviours and the expectation that inmates be transferred out of the SIU as soon as possible
• staff vacancies and turnover; and
• insufficient and improper infrastructure and equipment

Management framework

CSC has implemented a management framework for SIUs; however, areas for improvement have been identified. These include:

• clarifying and developing key elements of the policy framework, governance structure, and roles and responsibilities
• establishing rigorous processes for tracking and monitoring resource allocation; and
• reviewing CSC’s SIU performance measurement framework to ensure it is comprehensive and that metrics are sound, accurate, consider the complexities of SIU inmates, and support CSC in reflecting the efforts made by staff with SIU inmates

Relevance

SIU objectives are aligned with CSC’s mandate, policies, corporate priorities, and lessons learned from the previous segregation model.

SIU objectives further complement broader federal priorities of public safety and humane treatment.

There are notable differences between men and women’s institutions in the operationalization of the SIU model. Inmates at women’s institutions:

• experience fewer transfers to the SIU
• spend less time in the SIU
• have a higher prevalence of mental health needs
• have access to alternative options not available at men’s institutions; and
• benefit from the work of the interdisciplinary team within the Intensive Intervention Strategy Framework

Recommendations

Recommendation 1

The Assistant Commissioner, Correctional Operations and Programs, in collaboration with the Senior Deputy Commissioner, should ensure that the CSC SIU objectives within a multidisciplinary context are clearly articulated; and that the performance measurement framework in place for the purposes of monitoring compliance and results is reviewed to include key performance indicators that are outcome-based and capture the complexity of inmates in the SIU environment. SIU human and financial resource allocations should also be accurately captured and documented to support decision making and reporting.

Management response/Position: Accepted

Management response to recommendation 1

CSC acknowledges that clear objectives for Structured Interventions Units (SIUs) aligned with the policy framework support in achieving the objectives of SIUs. It is also acknowledged that CSC faces the challenge of balancing the need to provide inmates with programs and interventions that support behavior change and safer institutions, while doing so under the dichotomous legislative requirement to also return SIU inmates to a mainstream population as soon as possible. Defining objectives and approaches in responding to varied offender profiles will facilitate aligning organizational multidisciplinary efforts.

To address this challenge, several actions are identified in this MAP that address all 5 recommendations, including identifying clear SIU objectives, a renewed SIU policy suite, a review and addition to Key Performance Indicators (KPIs), and an analysis allocation of human and financial resources to inform decision making. More specifically, the revised draft SIU policy suite includes added accountabilities for the Assistant Commissioner, Correctional Operations and Programs (ACCOP) to ensure processes are in place related to data collection, quality assurance and reporting, as well as human and financial resource allocations. This will ensure oversight and ongoing improvement of the SIU performance. Additionally, CSC continues to update the SIU-LTE application to ensure improved user functionality and data entry, leading to more accurate performance data and compliance measurement. 

Finally, CSC has commenced the development of a SIU Strategic Plan that will focus on strengthening the foundation of SIUs, while laying the groundwork for the future. The SIU Strategic Plan is informed by an evidence-based approach, synthesizing findings from the current Joint Audit and Evaluation, with other external and internal reports on SIUs, such as the research report, A Multi-Site Field Study of CSC’s Structured Intervention Units (SIUs): Challenges and Opportunities.

Please see recommendation number 5 for actions specific to performance indicators.

Recommendation 2

The Assistant Commissioner, Correctional Operations and Programs, as part of its ongoing policy framework review exercise, should ensure that all SIU-related policy instruments and guidance documents are aligned with the CSC SIU objectives; and that employee roles, responsibilities, and expectations are clearly articulated and understood.

Management response/Position: Accepted

Management response to recommendation 2

CSC acknowledges that effective SIU management requires SIU policy instruments that are clear. Consistent policy allows for staff to understand their roles and responsibilities and support efficient service delivery within SIUs. In support of this, CSC will promulgate a renewed SIU policy suite and SIU procedures manuals that clarifies staff roles and responsibilities. We will also establish communication and information-sharing channels to socialize SIU policy with staff to support congruence between SIU policy and its application at the regional and site levels.

To ensure the renewed SIU policy suite meets the intended objectives of clearer staff roles and responsibilities, Compliance and Operational Risk Report (CORR) tools will continue to be utilized.

In addition, in conjunction with Learning and Development (L&D), formal SIU training is currently in development. It will support staff in understanding their and their colleagues, roles and responsibilities in SIUs.

Recommendation 3

The Assistant Commissioner, Correctional Operations and Programs, while considering safety, security, and cost, should review the infrastructure and equipment in place within SIUs to determine whether enhancements or improvements should be made to support the achievement of SIU objectives.

Management response/Position: Accepted

Management response to recommendation 3

CSC acknowledges that the infrastructure of each SIU varies in the number of yards, internal leisure or recreation areas, program rooms, interview rooms, common rooms, staff offices, etc. Although several SIU sites have purchased various equipment for SIUs, it has so far been left to each site to determine their own needs, allowing for inconsistencies in the availability of equipment in SIUs. These differences are managed operationally by each site, including having practices in place to maximize opportunities for inmate engagement via daily routines and efficient time/space management and movement strategies. CSC will focus on leveraging existing space and short-term enhancements.

CSC is developing national standards for secure interview and meeting spaces. Once approved, a review of existing SIU facilities will be completed against the established standards and any deficiencies will be submitted as part of the National Call Letter process for inclusion in the regional and/or national Program of Work. In addition, the SIU Strategic Plan will include a focus on infrastructure and SIU environments.

Recommendation 4

The Assistant Commissioner, Correctional Operations and Programs should re-examine the access to, and delivery of correctional interventions for inmates in the SIU to ensure that interventions are meeting SIU objectives.

Management response/Position: Accepted

Management response to recommendation 4

The joint audit report showed that offenders have more access to programming, interventions, services, and leisure in the SIU compared to the mainstream population. Additionally, the report demonstrated that offenders are typically referred to programming, interventions, services, and leisure right away after their transfer. As per Interim Policy Bulletin 690 for Commissioner’s Directive: 711 Structured Intervention Units, all inmates transferred to an SIU are assessed to determine the most appropriate correctional intervention required to address their specific needs while in SIU. The Motivational Module Structured Intervention Unit (MM-SIU) is usually the most suitable intervention provided to offenders in SIUs given that it provides offenders with the tools that they require to address the behaviours that led them to their transfer and successfully return and remain in mainstream population. While the report highlighted that MM-SIU does not address the need for offenders transferred to SIU for their own protection, the intervention is in fact designed to address the needs of those offenders. Therefore, we draw the conclusion that intervention staff require additional support and coaching opportunities to better understand the objectives of MM-SIU and improve access to interventions for all offenders, including those transferred for their own safety.

The report also showed that approximately 12% of cases reviewed had participated in their main correctional program while in the SIU. The short stays in SIU combined with the need to address the factors that led to the offender’s transfer to the SIU seem to be reflected in that percentage. However, there are opportunities to improve the consistency and effectiveness of Correctional Intervention Boards in SIUs, to enhance cohesion and ensure that interventions are tailored to the offender’s needs, such as, access to main correctional programs for offenders with extended SIU stays. Additionally, in order to further enhance access to interventions, CSC created the Behavioural Skills Coach (BSC) positions in men SIUs in 2022. Since then, a new intervention entitled Behavioural Skills Coaching Intervention (BSCI) was developed and implemented in July 2024. The BSCI is a structured behavioural intervention that will further assist certain inmates on working on maladaptive behaviours that impede their ability to successfully reintegrate and remain in mainstream inmate population. While BSCs were provided with an initial training in 2024 to 2025, CSC will also develop a continuous training and support mechanism to ensure the effectiveness of the BSCIs by end of March 2025. Given the above, CSC agrees that improvements can be made to enhance access to correctional interventions in SIUs to ensure that they meet SIU objectives.

In addition, the SIU Strategic Plan will include a focus on interventions, including areas that impact access to interventions, such as scheduling, routines, and offender groupings.

Recommendation 5

The Assistant Commissioner, Correctional Operations and Programs, in collaboration with the Senior Deputy Commissioner, should develop a data strategy to improve data quality, accuracy, and completeness; and to reduce duplication of data entry.

Management response/Position: Accepted

Management response to recommendation 5

This response and associated action items also respond to the performance measurement framework component of recommendation 1.

It is acknowledged that meaningful performance analyses requires accurate and sound data structures and recording practices and that this is an area that the joint audit evaluation identifies as a concern. Through Bill C-83, CSC funded positions within the Performance Measurement and Management Results Division and within the Research Branch to focus on SIU results, performance measurement, etc. Further, CSC funded a dedicated team within Information Management Services to develop and maintain an enhanced offender management module (SIU-LTE) specific for recording and reporting on SIU activities.  

Since the inception of SIUs, there has been a multi-pronged, evolving scheme of internal and external reporting strategies to shed light on trends and performance related to SIUs. Current reporting strategies include:

• quarterly public-facing reports on key SIU indicators (PMMR) and basic analysis of trends (Research)
• internal Power BI reports that provide a visualization of SIU data, updated on a monthly basis (PMMR)
• quarterly internal analytical reports prepared by Research using datasets produced by PMMR
• monthly performance-based/trend reports prepared by Research using IT Power BI reports
• ad hoc research and analytics as requested

To date, there have been ongoing efforts to enhance the quality of SIU data and establish reporting measures and approaches that are responsive to organizational information need areas so as to promote evidenced-based decision-making. Ongoing enhancements to the LTE have and will continue to occur (action items under recommendation 1). These enhancements are unpinned by the aim of promoting accurate, consistent, and sound recording practices, which allow for meaningful analyses of SIU performance and results.

Since the inception of SIUs, data integrity issues have been identified and solutions implemented. Concern has been raised regarding the lack of outcome-based measures to examine SIU performance. In 2024, CSC established an SIU performance indicator working group (SIU-WG), with members from SIU NHQ, the Policy Sector (Research and PMMR), and other key OPIs to explore the development of outcome-based performance measures using the current data structures. The SIU strategic plan will address longer term outcome-based enhancements which will require changes in data structures. 

Further, in 2023, as part of the review of the SIU model, CSC established Data Quality and Activity Coordinator positions to support the effective operation of SIUs, activity coordination and data entry. In consultation with the sites and regions, CSC is committed to developing national standards for these positions to ensure consistency, clarity, and accountability in roles, skills, and practices across the country, which will lead to improved data collection.

Appendices

Appendix A: Glossary

Appendix B: Structured Intervention Units logic model

Appendix C: Audit objectives and criteria

Objective 1

To provide assurance that a management framework is in place to support Structured Intervention Units.

Criteria for objective 1

1.1 Policy Framework: Commissioner’s Directives, guidelines and other guidance documents are clear, support Structured Intervention Units, and comply with applicable legislation.

1.2 Governance: A defined governance structure is in place to effectively support the Structured Intervention Units.

1.3 Roles and Responsibilities: Roles and responsibilities are clearly defined, documented, communicated and understood.

1.4 Monitoring and Reporting: A systematic, disciplined approach is in place to monitor Structured Intervention Units performance and commitments, and relevant information is being used to inform decision-making at all levels.

1.5 Resources: Infrastructure, equipment and human resources are in place to assist in the effective operation of the Structured Intervention Units.

Objective 2

To provide assurance that CSC is complying with relevant legislation and policies related to Structured Intervention Units.

Criteria for objective 2

2.1 Transfer Criteria: Documentation exists to demonstrate that the inmate meets the legislative and Commissioner’s Directive criteria to be authorized, to transfer, and to remain in the Structured Intervention Unit.

2.2 Reviews: Structured Intervention Unit reviews are completed within the required timeframes by the appropriate level of authority, and are documented.

2.3 Daily Interactions

2.3.1 The daily inmate interaction requirements have been met and are documented.

2.3.2 The recording of daily inmate interactions is accurate and contains sufficient information to understand the interactions that are taking place.

2.4 Barriers: The required threat-risk assessment documentation has been completed and consistently updated as per the CD 711 when a Structured Intervention Unit inmate is subject to barriers.

2.5 Decision and Information Sharing: Decision sharing and information sharing with inmates is taking place, is documented, and includes all required information.

2.6 Implementation of Recommendations: Reviews recommending a change to an inmate’s conditions of confinement are implemented and/or responded to.

Appendix D: Evaluation questions

Relevance

Continued need: Is there a demonstrable need for SIUs within federal corrections?

Alignment with departmental and government priorities: How do SIU objectives align with departmental priorities and federal government priorities?

Alignment with federal government roles and responsibilities: Do SIUs align with the roles and responsibilities of CSC and the federal government?

Efficiency

Demonstration of efficiency: How efficient is the SIU model in providing access to programming in the least restrictive and secure environment possible?

Effectiveness/Performance

Achievement of expected outcomes

Are transfers to and out of SIUs completed in an effective and efficient manner?

Are SIURCs recommendations effective in ensuring that an inmate’s stay in an SIU is as short as necessary?

Are inmates’ health care needs met, including mental health needs as documented by CSC?

Are inmate-specific needs met through the provision of programs, interventions, and services?

Are SIUs staffed in a manner that enables CSC to provide the necessary programs, interventions, and services while maintaining institutional safety?

Are SIUs effective at maintaining institutional safety?

GBA plus: Are there notable differences in the delivery of programs, interventions, services, and outcomes depending on offender’s characteristics?

Comparison of performance indicators based on characteristics of offenders such as:

• sex or gender expression
• Indigenous Offenders
• Black offenders
• persons with disabilities
• persons with mental health issues
• persons with substance use issues

Appendix E: Evaluation questions and audit criteria based on logic model components

Appendix F: Scope and approach

Observation of 10 institutions to examine SIUs processes and procedures.

Institutional visits were conducted from May to July 2023.

Considerations for selection included whether an institution had an SIU, the number of SIU inmates, staffing levels, and results from the previous SIU Audit readiness engagement.

Interviews with more than 240 participants were conducted from May to November 2023.

During institutional visits, 28 interviews were conducted with current SIU inmates and Chairs of Inmate Welfare Committees.

Over 200 interviews were conducted with management and staff who are involved with the SIUs at the Institutional levels. Staff positions that were interviewed included:

• Wardens
• Deputy Wardens
• Assistant Warden Interventions
• Assistant Warden Operations
• Correctional Managers
• SIU Managers/Managers Assessment and Interventions
• Correctional Officers/Primary Workers
• Parole Officers
• Social Program Officers
• Security and Intelligence Officers
• Elders
• Correctional Program Officers
• Behavioural Counsellors/Behavioural Skills Coaches
• Teachers
• Maximum Unit Nurses
• Mental Health Nurses
• Chiefs of Mental Health
• SIU Data and Activity Coordinators

Institutions were provided a list of positions the joint audit and evaluation team wished to interview, and participants were selected by institutional management.

Interviews were also conducted with staff at the national and regional levels.

Informal, ad-hoc conversions also took place.

Document and literature review of internal and external reports and documents, and scholarly articles, including:

• legislation and policy instruments
• corporate documents, job descriptions, locally produced documents and email communications
• procedural documents such as process maps; and
• monitoring and reporting information

The reviews covered the period between November 2019 to January 2024.

Administrative data analysis of internal databases, extracted by Performance Measurement and Management Reports (PMMR) and Health Service.

The data sets covered the period between April 1, 2016 to April 29, 2024. Each data set contains year end snapshot data. They include:

• Electronic Medical Record System (EMRS)
• Health Accreditation Reporting System (HARS)
• Human Resource Management System (HRMS)
• Offender Management System (OMS)
• Performance Direct (PD)
• Scheduling and Deployment System (SDS); and
• Long-Term Evolution-Structured Intervention Unit (LTE-SIU)

Given the source of data differs, analysis was carried out in isolation of each other and not linked by individual inmates.

File review and testing of over 1,400 inmate-related files and data records was performed.

Files covered the period between October 2021 and November 2023.

The key SIU case management documents examined included:

• Structured Intervention Unit Correctional Plan Update (SIU-CPU)
• Correctional Plan Update (CPU)
• Assessment for Decision (A4D); and
• Program Performance Report for the Motivational Module

The decision and review documents examined included:

• SIU authorizations
• Institutional Head 5-working day SIU transfer decision
• SIU Review Committee recommendation
• Institutional Head 30-day SIU transfer decision
• regional review
• Senior Deputy Commissioner review and decision; and
• information and decision sharing documentation

Data records were examined through the LTE-SIU application and tracking sheets.

Many different factors were considered when selecting samples to review, including but not limited to:

• gender
• race
• institution
• health needs
• number of SIU placements
• length of SIU placement; and
• timing and length of SIU placement

Appendix G: Legislation and policy framework

Legislation

There are specific legislative requirements that guide the operationalization of SIUs and the management of its inmates. The following sections are specific to, or relate to, SIUs:

Corrections and Conditional Release Act (CCRA)

The act governs the detention and conditional release of inmates, and the following sections apply to SIUs: 15.1, 29, 31 to 37.91, 78, 80. 86, 87, 96. Additionally, section 79 (1) of the CCRA states that CSC must take Indigenous Social History into consideration when making any decisions affecting an Indigenous inmate.

Corrections and Conditional Release Regulations (CCRR)

The regulations provide details guiding the interpretation or application of the CCRA and the following sections apply to SIUs: 5(1), 6(c), 16(b), 19 to 23.07, 97.

Criminal Code of Canada (CCC)

Although there are no sections specific to SIUs, section 718.2(e) of the Criminal Code, as well as the Supreme Court of Canada in R. v. Gladue (1999) 1 S.C.R states that the unique circumstances of an Aboriginal inmate, as described in the definition of the Aboriginal Social History, as well as culturally appropriate/restorative options must be taken into consideration in decisions regarding Indigenous inmates. The Ontario Court of Appeal clarified that Aboriginal Social History should be considered not only during sentencing but throughout the entire justice process (for example, R v. Sim, 2005).  

Correctional Service of Canada Policy Instruments

CSC’s policy devoted to SIUs is Commissioner’s Directive (CD) 711.

The purpose of CD 711 is to ensure an inmate’s transfer to an SIU is used as the least restrictive measure necessary and for the shortest time possible, consistent with the protection of society, staff and inmates, when there are no reasonable alternatives that could address the inmate’s risk and to ensure an effective correctional planning process that responds to the inmate’s specific need and risk.

In addition, requirements applicable to SIUs are included in the following policy instruments:

• Commissioner’s Directive 702 Indigenous Offenders
• Guidelines 711-1 Structured Intervention Unit (SIU) Transfer Procedures - SIU Sites
• Guidelines 711-2 Structured Intervention Unit (SIU) Transfer Procedures - Non-SIU Sites; and
• Interim Policy Bulletins 646, 649, 660, 679, 690, and 698

This policy suite is currently under review.

Appendix H: Statement of conformance

This internal audit engagement was conducted in conformance with the International Standards for the Professional Practice of Internal Auditing, the Treasury Board of Canada Policy on Internal Audit, and the Treasury Board of Canada Directive on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program of Correctional Service of Canada.

Daniel Giroux, CIA 
Chief Audit and Evaluation Executive

Footnotes