Dallas Police Department Academy Evaluation 2014

Contents Executive Summary....................................................................................................................................... 3 Evaluation Findings ....................................................................................................................................... 4 Area 1 - Requirements under 1701.255 - Enrollment Qualifications ....................................................... 4 Area 2 - Requirements under 1701.256 - Instruction in Weapons Proficiency ........................................ 4 Area 3 - Requirements under 215.2 (c) - Academy Staff and Facilities .................................................... 4 Area 4 - Requirements under 215.7 – Training Provider Advisory Board................................................. 5 4.1 Requirement for a Quorum ............................................................................................................ 5 4.2 Requirement for Public Members................................................................................................... 5 4.3 Requirement for appointment of Advisory Board Chair ................................................................. 6 4.4 Requirement to meet annually ....................................................................................................... 6 4.5 Advisory Board Duties ..................................................................................................................... 6 Area 5 - Requirements under 215.9 – Training Coordinator .................................................................... 7 5.1 Requirement to hold a valid instructors license ............................................................................. 7 5.2 Requirement to submit reports ...................................................................................................... 7 5.3 Requirement for Administration of training course ....................................................................... 8 5.4 Requirement related to learning objectives ................................................................................... 8 5.5 Requirement for examinations ....................................................................................................... 9 Evaluator’s Recommendation ....................................................................................................................... 9 R1 Academy Command Structure ............................................................................................................. 9 R2 Exam Retest and Class Average Procedures ...................................................................................... 10 R3 Remedial Training Times .................................................................................................................... 10 R4 Use of Adjunct Instructors for Basic Academy................................................................................... 10

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Executive Summary The Dallas Police Department (Department) operates a Law Enforcement Academy through a contract with the Texas Commission on Law Enforcement (Commission). Under provisions of the contract, Texas Occupations Code and the Texas Administrative Code, the commission may visit and inspect departments conducting law enforcement training and make necessary evaluations to determine if the school is in compliance with commission rules and state law. During the course of the evaluation the following areas were reviewed: 1.

Requirements under 1701.255 - Enrollment Qualifications

2.

Requirements under 1701.256 - Instruction in Weapons Proficiency

3.

Requirements under 215.2 (c) - Academy Staff and Facilities

4.

Requirements under 215.7 – Training Provider Advisory Board

5.

Requirements under 215.9 – Training Coordinator

Evaluators discovered issues in areas 4 and 5, while areas 1, 2, and 3 showed no deficiencies. Academy facilities are split between two buildings separating the law enforcement academy from the law enforcement in-service training. The 2010 partial evaluation showed an area of concern related to the late reporting (over 30 days) in violation with Rule 215.9. This evaluation showed that 16% of the rosters submitted by the academy inservice were in violation of the rule. A random sampling of the 87 courses reported by the in-service academy showed a lack of instructor biographies, course material, and exams for 3 of the 6 sampled courses. The basic police academy is coordinated by a departmental lieutenant who is assigned to the academy full-time as the training coordinator. By rule the training coordinator is responsible for all training conducted by the academy for commission credit, however; in this instance a second lieutenant is assigned who oversees the use of force unit within the academy. This creates a situation that limits the effectiveness of the training coordinator to carry out the responsibilities under Rule 215.9. The review of the advisory board minutes and composition is not consistent with requirements under Rule 215.7. Training materials reviewed showed that each lesson plan was up to date with current information and the instructors presenting at the academy appeared to be knowledgeable and interactive with the cadets. The evaluation focused on the methods and standards to which cadets were evaluated on skills based exercises. The Standardized Field Sobriety Training (SFST), Defensive Tactics (DT), and Police Vehicle Operators Course (PVOC) were reviewed and compared with existing policies and procedures. PVOC and SFSTs showed a lack of clear policies and procedures outlining the manner in which cadets are evaluated. Practical evaluations in the area of SFST seem to be consistent; however outdated review forms were used and there was no clear policy in place. In at least one instance, the Department did not follow its own policy in administering remedial training related to the PVOC. Dallas Police Department - Academy Evaluation 2014 Page | 3

The actual training provided by the academy appears to be solid in foundation and delivered in an effective manner. The administrative side of the training related to policies and procedures as well as the standard to which subjective skills are evaluated needs improvement to be consistent.

Evaluation Findings Area 1 - Requirements under 1701.255 - Enrollment Qualifications LAW: The commission by rule shall establish minimum qualifications for a person to enroll in a training program under Section 1701.251(a) that provides instruction in defensive tactics, arrest procedures, firearms, or use of a motor vehicle for law enforcement purposes. Finding: Evaluation showed compliance in this area. Required Action: None

Area 2 - Requirements under 1701.256 - Instruction in Weapons Proficiency LAW: A peace officer training program under Section 1701.251(a) must provide instruction in weapons proficiency. Finding: Evaluation showed compliance in this area. Firearms training had policies and procedures consistent with commission rules. Required Action: None

Area 3 - Requirements under 215.2 (c) - Academy Staff and Facilities RULE: A training provider applicant must have and maintain; (1) qualified instructors and staff to conduct successful training; (2) instructional resources to conduct successful training, to include, but not limited to, convenient access to a law enforcement reference library or sufficient number of computers for student and staff use; (3) access to current and appropriate teaching tools and electronic equipment, including video players, projection equipment, computer hardware, software, and the Internet;

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(4) a proprietary interest in or a written contract providing for a firing range suitable for the course of fire required in the current basic peace officer course, with safety rules clearly posted, secure storage and first aid equipment while on the premises; and (5) a proprietary interest in or a written contract providing for at least one facility to conduct police driving training, to include at least one law enforcement automobile for training. Finding: Evaluation showed compliance in this area. Required Action: None

Area 4 - Requirements under 215.7 – Training Provider Advisory Board 4.1 Requirement for a Quorum RULE: All training providers approved by the commission must establish and maintain an advisory board, as required by §1701.252 of the Texas Occupations Code. The board must have at least three members who are appointed by the sponsoring organization. Board membership must not fall below a quorum for more than 30 days. A quorum of the advisory board is defined as a minimum of 51% of the voting membership. Finding: Advisory Board minutes were provided for meetings in 2010, 2011, 2012 and 2013. A review of the minutes could not determine compliance with the 51% requirement for a quorum. Written documentation showing current members of the advisory board was not produced to show who was actually a voting board member. Members shown to be present also included the training coordinator who is ex-officio. Required Action: A document should be signed by the Chief of Police officially appointing or removing a person to or from the Advisory Board. This document should be maintained in an advisory board file with the training coordinator. 4.2 Requirement for Public Members RULE: The board may have members who are law enforcement personnel; however, one-third of the members must be public members, as defined in §1701.052 of the Texas Occupations Code, having the same qualification as any commissioner who is required by law to be a member of the general public. The chief administrator, or head of the sponsoring organization, and the designated training coordinator may only serve as ex-officio, non-voting members. Board members are required to successfully

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complete the commission developed advisory board training course within one year of appointment to an advisory board. Finding: Biographies or resumes were not on file to show compliance with this requirement. After interviews with academy staff it does not appear that the current board meets the requirement of one-third public members. Training records did not reflect completion of the required Advisory Board Training within 1 year of appointment. Required Action: Obtain biographies or resumes of each board member to show compliance and place in a file with the training coordinator. Conduct the Advisory Board training for all members of the Advisory Board. 4.3 Requirement for appointment of Advisory Board Chair RULE: The chief administrator, or head of the sponsoring organization, may appoint a board chair, or the board may elect a board member to serve as the board chair. The board may elect other officers and set its own rules of procedure. A quorum must be present in order to conduct business. Finding: Documents provided did not show an appointment of a Chairperson. Required Action: Document the appointment or election of a Chairperson. 4.4 Requirement to meet annually RULE: A board must meet at least once each calendar year. More frequent meetings may be called by the board chair, the training coordinator, or the person who appoints the board. A board will keep written minutes of all meetings. These minutes must be retained for at least five years and a copy forwarded to the commission upon request. Finding: Documents provided did show that the Board did meet at least annually. Required Action: None 4.5 Advisory Board Duties RULE: A board is generally responsible for advising on the development of curricula and any other related duty that may be required by the commission. The board must, as specific duties: (1) discharge its responsibilities and otherwise comply with commission rules; (2) advise on the need to study, evaluate, and identify specific training needs; (3) advise on the determination of the types, frequency, and location of courses to be offered; (4) advise on the establishment of the standards for admission, prerequisites, minimum and maximum class size, attendance, and Dallas Police Department - Academy Evaluation 2014 Page | 6

retention; and (5) advise on the order of preference among employees or prospective appointees of the sponsoring organization and other persons, if any. No person may be admitted to a training course without meeting the admission standards. The admission standards for licensing courses must be available for review by the commission upon request. A board may, when discharging its responsibilities, request that a report be made or some other information be provided to them by a training or course coordinator. Finding: The Advisory Board is not involved in the areas listed by rule. After review of the minutes it appears that most meetings consisted of receiving updates on activities of the academy. Required Action: Involve the advisory board in all aspects of the academy training as outlined in the rule. Include the advisory board on all new policies and procedures developed related to the academy.

Area 5 - Requirements under 215.9 – Training Coordinator 5.1 Requirement to hold a valid instructors license RULE: A training coordinator must hold a valid instructor license or certificate and must be a full-time paid employee. Finding: The appointed Training Coordinator does meet this requirement. Required Action: None. 5.2 Requirement to submit reports RULE: prepare, maintain, and submit the following reports within the time frame specified: Reports of training: basic licensing course shall be submitted prior to students attempting a licensing exam; and within 30 days of completion of continuing education course Finding: Training Conducted under the In-service training unit was reported in violation of the 30 day rule. 576 rosters were submitted in FY14 with 97 of those exceeding the 30 day requirement with the worst being 107 days late. It was discovered during the evaluations the areas such as telecommunications has reporting capabilities which are not currently under the academy’s purview.

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Required Action: Review the procedures relating to reporting to bring this number into compliance. Review the different areas that have reporting capabilities and make those areas accountable to the academy coordinator.

5.3 Requirement for Administration of training course RULE: be responsible for the administration and conduct of each course, including those conducted at ancillary sites, and specifically: Appointing and supervising qualified instructors; Maintaining course schedules and course files, including lesson plans; Enforcing all admission, attendance, retention, and other standards set by the commission and the training provider; Securing and maintaining all facilities necessary to meet the inspection standards of this section; Controlling the discipline and demeanor of each student and instructor during class; Distributing a current version of the Texas Occupations Code, Chapter 1701 and commission rules to all students at the time of admission to any course that may result in the issuance of a license; Distributing learning objectives to all students at the beginning of each course; Finding: In-Service files lacked documentation on updated lesson plans. Training conducted by the Caruth Police Institute and reported by the academy did not have any course material on file for the New Supervisors Course. Instructors did not have updated and detailed resumes on file. Required Action: Create a process for ensuring compliance with this rule prior to conducting the course. Ensure that each instructor the academy or in-service training program uses has an updated resume on file. Ensure that learning objectives and lesson plans are detailed and instructors follow the lesson plan. Develop a review of instructors to determine if the instructor is effective and ensure a process is in place to capture the student’s critiques of the instructor. 5.4 Requirement related to learning objectives RULE: Ensure that all learning objectives are taught and evaluated Finding: When reviewing PVOC, SFST, and DT it was discovered that PVOC evaluations were not conducted consistently between adjunct instructors. The academy reported a cadre of approximately 120 evaluators for PVOC skills evaluations. The PVOC evaluators interviewed during the evaluation were not consistent in explaining how each evaluator graded a specific series of skills. PVOC policy on remedial training and dismissal procedures were not followed in at least one case. SFST evaluation sheets used to evaluate cadets were outdated and lacking Dallas Police Department - Academy Evaluation 2014 Page | 8

policies and procedures for evaluations, remedial training, and documenting failures. DT was reviewed and found to be in compliance with departmental policy and evaluations were consistent and grading criteria is briefed to each evaluator and cadet before each test. SFST training is conducted by staff not assigned to the academy and not under the academy’s command structure.

Required Action: Conduct a complete review of department policy for SFST and PVOC with the advice and consent of the Advisory Board. If policy doesn’t exist or the department has operated on a practice developed over time, review the practice and develop a policy. Ensure that each evaluator used for SFST and PVOC is instructed on and can explain each of the dimensions of the evaluation sheet. Move the SFST training under the academy’s command structure either on a permanent or temporary basis while conducting SFST training. SFST instructors should be accountable to the Training Coordinator. Ensure that the SFST instructors are current and have attended the SFST update course as required. 5.5 Requirement for examinations RULE: Proctor or supervise all examinations to ensure fair, honest results and maintaining records of tests and other evaluation instruments for a period of five years. Finding: In-Service student exam answers for the Mental Health Peace Officer Course did not match the master exam on file. The Instructor modified the exam and failed to file that change to the master course file. Required Action: Ensure that all exam answers and/or exam matrix are consistent with the master exam and course file.

Evaluator’s Recommendation R1 Academy Command Structure The academy operates with two lieutenants serving two different areas of responsibilities within the academy. Under rule and contract the Commission holds the Training Coordinator responsible for all aspects of the training including the training conducted by the reality based training unit.

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Recommendation: Make the training coordinator’s lieutenant position senior to the reality based training lieutenant to reinforce the training coordinators ability to carry out the responsibilities identified under rule 215.7.

R2 Exam Retest and Class Average Procedures The academy counts the first score received on an exam as the only recorded score even if a retest is administered. For example, if a cadet takes a penal code exam and scores a 40 they are allowed to take a retest. If at the retest they score a 90 they are allowed to continue in the academy with the 40 being the official score averaged against future grades despite the retake. Staff explained that this is to prevent a student who constantly fails the first attempt and passes the retake with a higher score from being rewarded with higher grades than those who pass on first attempt. Recommendation: Review this policy with the advisory board and compare it to the academic standard of recording the retest score as a maximum of 70. This would give the cadet credit for passing and allow a 70 to be averaged in lieu of the failing score being calculated each time throughout the academy.

R3 Remedial Training Times Remedial training in the area of PVOC is often delayed for an extended amount of time due to conflicting availabilities of the training facilities. A delay of 5 weeks was reported on at least one occasion. Recommendation: Review the policy for use of training facilities and prioritize resources to decrease the time between a failure and remedial training and testing. Explore the feasibility to contract with another entity for intermittent use of an offsite driving track.

R4 Use of Adjunct Instructors for Basic Academy The department utilizes adjunct instructors from various divisions outside of the academy to evaluate PVOC and SFST. Utilizing a large number of outside instructors to evaluate practical skills causes a difficulty maintaining consistency across all instructors. Recommendation: Decrease the number of instructors used as adjunct evaluators and designate the minimum number of evaluators necessary to maintain constancy.

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