Dear Commissioner Kelly,
We have had the opportunity to review the updates to the Commissioner’s Memo in regards to the implementation of some of the BOI recommendations.
Unfortunately, we do not believe that the revisions to your most recent Memo dated March 5, 2021 properly address some of the significant issues USJE has repeatedly flagged when it comes to the viability of the administrative reviews that CSC is requesting for Schedule 1 offenders.
These issues include the practicality of Parole Officers further requesting/obtaining what is often hundreds of pages of court documentation (containing often competing testimony and analyses of what led the person to offend) – much of which will not be able to be procured in the timelines stated for reasons entirely outside of the Parole Officer’s control.
As USJE and many Parole Officers have highlighted, police agencies and courts often take several months, sometimes years, to provide this documentation and render it accessible to CSC employees.
Further, once the documentation is obtained, USJE is most concerned about the distinct lack of capacity and time for Parole Officers to carefully review and incorporate any new information into relevant risk assessment tools, particularly for offenders who are often mid-stream in their sentence.
Given these concerns, instead of notable improvements to risk assessment, the tasks being outlined in the recent Commissioner’s Memo largely reduce this effort to a paper collection exercise.
To this end, we are requesting an immediate suspension of the direction provided in your Memo until such time as CSC fully consults USJE on a tenable way forward that can be agreed to by both parties, and reflects a more realistic understanding of the challenges of obtaining and incorporating this information in the first place.
As we have stated to you and your officials on a number of occasions, if CSC insists on going down this road, it must invest in and deploy its regionally-led information retrieval teams to take on the administrative challenges of requesting, following up, cataloging and sharing this information with Parole Officers.
Additionally, CSC must anticipate that overtime will be required, and deadlines extended, so that already oversubscribed Parole Officers are compensated for the significant effort and time of revisiting offender risk given the introduction of new and often very lengthy written materials from courts.
USJE understands how much the Correctional Service of Canada relies on (and rightly so) its Intervention (rehabilitative) staff to provide crucial correctional programming and supervision to offenders residing in federal penitentiaries – and those who are in the process of reintegrating back to communities across the country.
These Interventions staff include Canada’s approximately 1400 federal Parole Officers, as well as hundreds of Program Officers, Indigenous Liaison Officers, Teachers, Administrative and Food Services staff, among others.
As we have stated both publicly and privately, over several years, USJE has observed a distinct erosion of resources when it comes to the general management of offendersby Parole Officers.
At the same time, there has been an intensification of responsibilities placed upon Parole Officers who oversee an increasingly high-needs federal offender population.
Since 2014, numerous reports and court cases have highlighted the need to approach the rehabilitation of offenders with more nuance and care given the relevance of offenders’ societal histories and personal identities, triggering many new protocols and efforts.
This has occurred at the same time as CSC absorbed significant cuts under the Deficit Reduction Action Plan in 2014 – 2015 that increased Parole Officer caseloads, reduced administrative supports, and allowed for little to NO backfilling of Parole Officers on sick leave/secondments/extended absences.
Five years later, this has produced a very difficult situation where Parole Officers can no longer shoulder the burden of good public safety outcomes, without considerably more staff, and more administrative supports, to do this incredibly high stakes work.
Parole Officers have legislated duties to uphold public safety and manage risk appropriately in order to avoid recidivism and minimize danger to the public by federally sentenced individuals.
These duties are integral to the confidence that Canadians have in the federal Correctional system, confidence that is sometimes wavering in light of some persistent and chronic problems CSC continues to face.
It is fundamental that there are the proper supports in place for the Correctional system, including the role Parole Officers play in it, to function as intended, and as Canadians expect.
To this end, death by a thousand cuts is no longer an option. The most recent Commissioner’s Memo is not in line with the stark realities most Parole Officers face each and every day. Thoughtful and productive consultation with USJE must be immediately launched in order to resolve the current impasse.
Therefore, as stated above, we are requesting an immediate suspension of the direction provided in your recent Commissioner’s Memo.
USJE is urging you to quickly commence real dialogue with our leadership so that we can acknowledge and confront the challenges we have outlined in all of their complexity, and find viable solutions which will ultimately enable the BOI recommendations to be implemented.
Sincerely,
Stan Stapleton
USJE President