30616 Federal Register / Vol. 65, No. 93 / Friday, May 12, 2000 / Notices

Control, Drug Enforcement

Administration, United States

Department of Justice, Washington, DC

20537, Attention: DEA Federal Register

Representative (CCR), and must be filed

no later than June 12, 2000.

This procedure is to be conducted

simultaneously with an independent of

the procedures described in 21 CFR

1301.34(b), (c), (d), (e), and (f). As noted

in a previous notice at 40 FR 43745–46

(September 23, 1975), all applicants for

registration to import the basic classes

of any controlled substances in

Schedule I or II are and will continue to

be required to demonstrate to the

Deputy Assistant Administrator, Office

of Diversion Control, Drug Enforcement

Administration that the requirements

for such registration pursuant to 21

U.S.C. 958(a), 21 U.S.C. 823(a), and 21

CFR 1301.34(a), (b), (c), (d), (e), and (f)

are satisfied.

Dated: April 25, 2000.

John H. King,

Deputy Assistant Administrator, Office of

Diversion Control, Drug Enforcement

Administration.

[FR Doc. 00–11885 Filed 5–11–00; 8:45 am]

BILLING CODE 4410–09–M

DEPARTMENT OF JUSTICE

Drug Enforcement Administration

Manufacturer of Controlled

Substances; Notice of Application

Pursuant to Section 1301.33(a) of Title

21 of the Code of Federal Regulations

(CFR), this is notice that on January 25,

2000, Mallinckrodt, Inc., Mallinckrodt &

Second Streets, St. Louis, Missouri

63147, made application by renewal to

the Drug Enforcement Administration

(DEA) for registration as a bulk

manufacturer of the basic classes of

controlled substances listed below:

Drug Schedule

Tetrahydrocannabinols (7370) ...... I

Dihydromorphine (9145) ............... I

Amphetamine (1100) .................... II

Methylphenidate (1724) ................ II

Cocaine (9041) ............................. II

Codeine (9050) ............................. II

Diprenorphine (9058) .................... II

Etorphine Hydrochloride (9059) .... II

Dihydrocodeine (9120) ................. II

Oxycodone (9143) ........................ II

Hydromorphone (9150) ................. II

Diphenoxylate (9170) .................... II

Hydrocodone (9193) ..................... II

Levorphanol (9220) ....................... II

Meperidine (9230) ......................... II

Methadone (9250) ........................ II

Methadone-intermediate (9254) ... II

Dextropropoxyphene, bulk (nondosage forms) (9273).II

Drug Schedule

Morphine (9300) ........................... II

Thebaine (9333) ........................... II

Opium extracts (9610) .................. II

Opium fluid extract (9620) ............ II

Opium tincture (9630) ................... II

Opium powdered (9639) ............... II

Opium granulated (9640) .............. II

Levo-alphacetylmethadol (9648) .. II

Oxymorphone (9652) .................... II

Noroxymorphone (9668) ............... II

Alfentanil (9737) ............................ II

Sufentanil (9740) .......................... II

Fentanyl (9801) ............................. II

The firm plans to manufacture the

controlled substances for distribution as

bulk products to its customers.

Any other such applicant and any

person who is presently registered with

DEA to manufacture such substances

may file comments or objections to the

issuance of the proposed registration.

Any such comments or objections

may be addressed, in quintuplicate, to

the Deputy Assistant Administrator,

Office of Diversion Control, Drug

Enforcement Administration, United

States Department of Justice,

Washington, D.C. 20537, Attention: DEA

Federal Register Representative (CCR),

and must be filed no later than July 11,

2000.

Dated: April 21, 2000.

John H. King,

Deputy Assistant Administrator, Office of

Diversion Control, Drug Enforcement

Administration.

[FR Doc. 00–11889 Filed 5–11–00; 8:45 am]

BILLING CODE 4410–09–M

DEPARTMENT OF JUSTICE

Drug Enforcement Administration

[Docket No. 98–34]

Edson W. Redard, M.D., Continuation

of Registration With Restrictions

On June 12, 1998, the Deputy

Assistant Administrator, Office of

Diversion Control, Drug Enforcement

Administration (DEA) issued an Order

to Show Cause to Edson W. Redard,

M.D. (Respondent) of Sacramento,

California, notifying him of an

opportunity to show cause as to why

DEA should not revoke his DEA

Certificate of Registration BR1670012

and deny any pending applications for

renewal of such registration as a

practitioner pursuant to 21 U.S.C.

823(f), 824(a)(2) and (a)(4).

By letter dated June 26, 1998,

Respondent, through counsel, filed a

request for a hearing, and following

prehearing procedures, a hearing was

held in Sacramento, California on April

27 and 28, 1999, before Administrative

Law Judge Mary Ellen Bittner. At the

hearing both parties called witnesses to

testify and introduced documentary

evidence. After the hearing both parties

submitted proposed findings of fact,

conclusions of law and argument. On

December 20, 1999, Judge Bittner issued

her Opinion and Recommended Ruling,

Findings of Fact, Conclusions of Law

and Decision, recommending that

Respondent’s registration not be

revoked subject to two restrictions.

Neither party filed exceptions to Judge

Bittner’s Opinion and Recommended

Ruling, Findings of Fact, Conclusions of

Law and Decision, and on January 24,

2000, the record was transmitted to the

Deputy Administrator.

The Deputy Administrator has

considered the record in its entirety,

and pursuant to 21 CFR 1316.67, hereby

issues his final order based upon

findings of fact and conclusions of law

as hereinafter set forth. The Deputy

Administrator adopts the Opinion and

Recommended Ruling, Findings of Fact,

Conclusions of Law and Decision of the

Administrative Law Judge, but includes

additional restrictions on Respondent’s

continued registration. His adoption is

in no manner diminished by any

recitation of facts, issues and

conclusions herein, or of any failure to

mention a matter of fact or law.

The Deputy Administrator finds that

Respondent graduated from medical

school in 1987, and in 1991 he began

working as a family practitioner at a

large multi-specialty clinic in

Sacramento, California.

On August 27, 1997, a pharmacist

called the California Department of

Justice, Bureau of Narcotic Enforcement

(BNE) and told an investigator that on

May 20, 1997, Respondent had

presented a prescription in the name of

Donald Gram, for Vicodin ES, a

Schedule III controlled substance. At

that time, Respondent filled out a

patient information form using the name

Donald Gram. The pharmacist had

previously met Respondent when she

worked at another pharmacy, so she

knew that this was not Respondent’s

name. Further investigation revealed

that the address given to the pharmacist

on the patient information form was

Respondent’s address.

The pharmacist told the investigator

that Respondent had presented another

prescription for Vicodin on July 25,

1997, which another pharmacist filled.

The pharmacist further told the

investigator that a pharmacy technician

advised her that Respondent had

presented controlled substance

prescriptions in the name Carol Jordan.

Federal Register / Vol. 65, No. 93 / Friday, May 12, 2000 / Notices 30617

Subsequently, the investigator

obtained prescriptions issued to Carol

Jordan on Respondent’s prescription

forms from three different pharmacies.

These prescriptions accounted for 1,510

dosage units of Vicodin ES for the

period February 27, 1995 to August 26,

1997.

Thereafter on October 20, 1997, the

pharmacist again contacted the

investigator and advised him that

Respondent had just presented two

prescriptions, one for 80 dosage units of

Vicodin ES and the other for a noncontrolled substance, in the name of

Donald Gram. The investigator also

learned that on October 17, 1997, one of

the other pharmacies had filled a

prescription issued to Carol Jordan on

Respondent’s prescription form for 80

dosage units of Vicodin ES. A check of

Department of Motor Vehicle records

revealed no matches for the purported

names and dates of birth of Donald

Gram or Carol Jordan.

On November 24, 1997, a search

warrant for Respondent’s office,

residence and car was executed. In

Respondent’s car, the investigators

found prescription receipts and

numerous empty prescription bottles in

the names of Donald Gram and Carol

Jordan. In the master bedroom of

Respondent’s residence, the

investigators found empty prescription

bottles and physician samples.

During the search an investigator with

the Medical Board of California

(Medical Board) interviewed a

physician assistant whom Respondent

supervised. The physician assistant

admitted to calling in about four

prescriptions for Vicodin for

Respondent during the previous year

using another physician’s name.

Respondent cooperated with the

investigators during the search, and

admitted that he was addicted to

Vicodin. Respondent told the Medical

Board investigator that he was originally

prescribed Vicodin for two or three

months for a back problem. At some

point he stopped taking the drug for

approximately six months but resumed

taking it sometime in 1995. Respondent

told the Medical Board investigator that

initially he took two or three tablets per

day, but that as of the date of the search

he was taking eight to twelve tablets per

day. Respondent also admitted to taking

Ionamin, Ambien, Doral, Brontex, and

Xanax, all controlled substances.

Further, Respondent admitted that he

had issued prescriptions in the fictitious

names Donald Gram and Carol Jordan;

that he asked the physician assistant to

call in prescriptions for him; and that he

know that when the physician assistant

called in those prescriptions the

physician assistant indicated that they

were authorized by another physician.

Following the execution of the search

warrant, Respondent was arrested and

charged with obtaining a controlled

substance by fraud, prescribing for a

non-patient, and possession of a

controlled substance.

After Respondent’s arrest, the Medical

Board investigator continued her

investigation of Respondent and

discovered several additional

prescriptions written prior to

Respondent’s arrest in the name of

Donald Gram or Carol Jordan for a total

of 720 dosage units of Vicodin or its

generic equivalent. In addition the

investigator found four prescriptions,

each for 50 dosage units of Vicodin ES,

that were called into a local pharmacy

between July 23, 1996 and October 30,

1997. Three of these prescriptions were

called in by the physician assistant and

one was called in by a nurse practitioner

at the clinic where Respondent was

employed. All of these prescriptions

indicated that they were authorized by

a physician other than Respondent. The

Medical Board investigator interviewed

the physicians who allegedly authorized

these prescriptions and they indicated

that they had not authorized the

prescriptions and were unaware that

their names had been used.

On December 1, 1997, Respondent

was arraigned in the Sacramento

Superior/Municipal Court on three

felony counts of obtaining and

attempting to obtain hydrocodone by

fraud. On March 9, 1998, Respondent

pled nolo contendere to one count and

the court ordered that he be diverted

from further proceedings for an 18-

month period. On March 18, 1998, the

Sacramento County Probation

Department ordered Respondent to

obtain counseling from the MexicanAmerican Alcohol Program. Respondent

testified that he successfully completed

this program. On April 12, 1999, the

court entered an order terminating

Respondent’s diversion, and ultimately

dismissed the criminal proceedings.

On December 23, 1997, an interim

suspension of Respondent’s license to

practice medicine was issued.

Thereafter, on January 9, 1998, the

Medical Board filed an Accusation

against Respondent alleging that

Respondent had written prescriptions

for Vicodin for fictitious persons, asked

a physician assistant to call in

prescriptions for Vicodin purportedly

on the authorization of another

physician, admitted abusing Vicodin

and other controlled substances, and

tested positive for hydrocodone on

November 24, 1997.

Effective March 19, 1998, Respondent

and the Medical Board entered into an

Agreement in Lieu of Discipline

wherein Respondent agreed to enter and

complete the Medical Board’s Diversion

Program and the Medical Board agreed

to withdraw the Accusation upon

Respondent’s successful completion of

that program. Respondent’s authority to

handle controlled substances was not

limited.

On April 9, 1998, the Medical Board

issued a Modification of Interim

Suspension Order, permitting

Respondent to return to the practice of

medicine on condition that he be

monitored by the Diversion Program,

meet with the Diversion Evaluation

Committee, and sign a Diversion

Agreement after that meeting. In May

1998, Respondent formally entered the

Medical Board’s Diversion Program and

on June 24, 1998, the Medical Board

terminated the interim suspension of

Respondent’s medical license.

At the hearing in this matter,

Respondent testified that he injured his

back in 1991, and that after his

physician stopped issuing him

prescriptions for Vicodin, he took

samples of the drug from his office. He

also admitted that although Vicodin was

his drug of choice, he also took samples

of other drugs to avoid the symptoms of

withdrawal. According to Respondent,

his drug abuse intensified in 1995

during the breakup of his marriage. He

became concerned that he was taking

too many samples from his office, so he

began issuing prescriptions using the

fictitious names of Donald Gram and

Carol Jordan. Respondent testified that

he was relieved when he was arrested.

According to Respondent, upon his

arrest he contacted that Medical Board’s

Diversion Program and began attending

diversion group meetings. However,

Respondent was concerned that it could

take several months to be formally

admitted to the Diversion Program, so

on December 4, 1997, he voluntarily

entered a hospital in Oregon that offered

a treatment program for addicted

physicians. Respondent was an

inpatient at the hospital until March 13,

1998.

While Respondent was in treatment,

the medical director of the clinic where

he was employed sent Respondent a

letter advising him that the clinic

intended to terminate his employment,

but because he was participating in a

professional assistance program, the

clinic would indefinitely suspend his

termination if he entered into a Last

Chance Agreement with the clinic.

Respondent agreed to the terms of this

Last Chance Agreement which requires

Respondent, among other things, to (1)

30618 Federal Register / Vol. 65, No. 93 / Friday, May 12, 2000 / Notices

Submit to a minimum of two random

urine tests each month; (2) notify the

medical director in writing of any

prescriptions he has filled at any

pharmacy; (3) abstain from consuming

any controlled or mood-altering

substances; (4) provide a certificate from

both the court-ordered and Medical

Board diversion programs stating that he

has begun and, when applicable,

completed a treatment program; and (5)

participate in the diversion programs’

recommended aftercare program.

Respondent also agreed that he would

not order or accept any controlled

substance samples and that the

agreement would be in effect for four

years from February 26, 1998. There was

testimony at the hearing that

Respondent has complied with this Last

Chance Agreement.

The Associate Medical Director for

Quality Management at the clinic where

Respondent is employed testified that

the Credentialing Committee reviewed

approximately 50 randomly selected

records of patients that Respondent

treated in the three months prior to his

arrest, between 50 and 100 controlled

substance prescriptions issued by

Respondent between 1996 and 1999,

and 50 patient records for the three

months after Respondent returned to

work following his suspension. This

review did not disclose any problems

with Respondent’s practice of medicine.

Further, none of the staff who worked

with Respondent perceived that he

engaged in any impaired behavior or

inappropriate prescribing of

medications.

As of the date of the hearing,

Respondent was still participating in the

Medical Board’s Diversion Program. He

regularly attends diversion meetings

and undergoes random urine tests three

to four times a month, which have all

been negative. The staff of the Diversion

Program believes that Respondent can

safely practice medicine.

The Administrator of the Medical

Board’s Diversion Program testified that

in order to successfully complete the

program a physician must have a

minimum of three years of continuous

sobriety or abstinence, and must have

implemented lifestyle changes that are

sufficient to maintain the physician’s

abstinence and recovery. The

Administrator testified that because

Respondent has not been abstinent for

three years he cannot be considered to

have successfully completed the

Diversion Program, but if he maintains

the lifestyle changes he has made and

continues to be abstinent, he will

complete the program.

Respondent is also monitored by the

Wellness Committee of the hospital

where he sees patients. In addition,

Respondent’s physician manager and

workplace monitor testified that he

randomly reviews patient records after

Respondent sees a patient and he has

found no problem with the quality of

care provided by Respondent. Several

supervisors and/or colleagues testified

that Respondent practices competently,

he has never appeared to be under the

influence of any substance, and his

rehabilitation is progressing well.

Respondent testified that he has not

abused drugs since November 24, 1997.

Respondent further testified that

although he is not proud of his

addiction, he is proud that he was

honest with investigators, he sought

help, he admitted his shortcomings, and

he has a support group that monitors his

recovery and ability to practice on a

daily basis.

According to Respondent, he needs a

DEA registration in order to effectively

treat his patients and in order to

maintain his employment since the Last

Chance Agreement with his current

employer requires him to have an

unrestricted ability to practice

medicine.

Pursuant to 21 U.S.C. 824(a)(2), the

Deputy Administrator may revoke a

DEA Certificate of Registration upon a

finding that the registrant has been

convicted of a felony relating to

controlled substances under state or

Federal law. It is undisputed that on

March 9, 1998, Respondent pled nolo

contender in state court to one felony

count of obtaining hydrocodone by

fraud. The court granted a deferred

entry of judgment and the criminal

proceedings were dismissed after

Respondent completed criminal

diversion program.

Respondent contends that he was not

convicted of a felony offense since no

judgment was entered against him and

the criminal proceedings were

dismissed. The Deputy Administrator

agrees with Judge Bittner that

Respondent has been convicted of a

controlled substance related felony

offense for purposes of these

proceedings.

DEA has consistently held that a plea

of nolo contendere constitutes a

‘‘conviction’’ within the meaning of 21

U.S.C. 824(a)(2). See Clinton D. Nutt,

D.O., 55 FR 30,992 (1990); Eric A.

Baum, M.D., 53 FR 47,272 (1988).

Further, DEA has held that there is still

a ‘‘conviction’’ within the meaning of

the Controlled Substances Act even if

the proceedings are later dismissed. The

Deputy Administrator agrees with Judge

Bittner that any other interpretation

would mean that ‘‘the conviction could

only be considered between its date and

the date of its subsequent dismissal

* * * [which would be] inconsistent

with holdings in other show cause cases

that the passage of time since

misconduct affects only the weight to be

given the evidence’’ citing Mark Binette,

M.D., 64 FR 42,977, 42,980 (1999);

Thomas H. McCarthy, D.O., 54 FR

20,938 (1989), aff’d No. 89–3496 (6th

Cir. Apr. 5, 1990).

Therefore, since Respondent has been

convicted of a felony relating to

controlled substances, the Deputy

Administrator finds that grounds exist

to revoke Respondent’s DEA Certificate

of Registration pursuant to 21 U.S.C.

824(a)(2).

Also, pursuant to 21 U.S.C. 823(f) and

824(a)(4), the Deputy Administrator may

revoke a DEA Certificate of Registration

and deny any pending applications, if

he determines that the continued

registration would be inconsistent with

the public interest. Section 823(f)

requires that the following factors be

considered in determining the public

interest:

(1) The recommendation of the

appropriate State licensing board or

professional disciplinary authority.

(2) The applicant’s experience in

dispensing, or conducting research with

respect to controlled substances.

(3) The applicant’s conviction record

under Federal or State laws relating to

the manufacture, distribution, or

dispensing of controlled substances.

(4) Compliance with applicable State,

Federal, or local laws relating to

controlled substances.

(5) Such other conduct which may

threaten the public health and safety.

These factors are to be considered in

the disjunctive; the Deputy

Administrator may rely on any one or a

combination of factors may give each

factor the weight he deems appropriate

in determining whether a registration

should be revoked or an application for

registration be denied. See Henry J.

Schwarz, Jr., M.D., 54 FR 16,422 (1989).

Regarding factor one, it is undisputed

that Respondent’s license to practice

medicine was suspended in December

1997. Subsequently the Medical Board

filed an Accusation against Respondent

and in March 1998, Respondent and the

Medical Board entered into an

Agreement in Lieu of Discipline

wherein Respondent agreed to complete

the Medical Board’s Diversion Program.

On April 9, 1998, the suspension order

was modified to allow Respondent to

return to the practice of medicine, but

he was required to remain in the

Diversion Program. No restrictions have

been placed on Respondent’s ability to

handle controlled substances by the

Medical Board. Therefore, Respondent

Federal Register / Vol. 65, No. 93 / Friday, May 12, 2000 / Notices 30619

is authorized to practice medicine and

handle controlled substances in

California subject to his continued

participation in the Medical Board’s

Diversion Program. But, as Judge Bittner

stated, ‘‘inasmuch as State licensure is

a necessary but not sufficient condition

for a DEA registration, * * * this factor

is not determinative.’’

As to factors two and four,

Respondent’s experience in handling

controlled substances and his

compliance with applicable laws,

Respondent has admitted that he issued

controlled substance prescriptions in

fictitious names, took office samples of

controlled substances, and used his

authority over subordinates to obtain

controlled substances. Clearly these

actions violated 21 U.S.C. 843(a)(3) as

well as California law. However, the

Deputy Administrator finds that

Respondents’s behavior was motivated

by his addiction to controlled

substances for which he has since

received extensive rehabilitative

treatment.

As previously discussed, factor three

is relevant since the Deputy

Administrator finds that Respondent

was convicted of a felony offense

relating to controlled substances.

Regarding factor five, there is no

question that Respondent abused

controlled substances for several years

prior to November 1997 when he was

arrested. Particularly troubling to the

Deputy Administrator is that

Respondent abused these substances

while performing his duties as a

physician.

In light of Respondent’s abuse of

controlled substances, the methods he

employed to obtain the drugs, and his

felony conviction, the Deputy

Administrator agrees with Judge Bittner

that the Government has mad a prima

facie case that Respondent’s continued

registration would be inconsistent with

the public interest. Judge Bittner

concluded however that while

‘‘Respondent’s misconduct was

obliviously egregious[,]’’ his testimony

and that of his witnesses was credible

‘‘that Respondent now understands the

gravity of his actions and is remorseful,

that he had been conscientious in

pursuing his recovery, and that he has

a support network, including

appropriate monitoring at his

workplace, to assist him in those

efforts.’’

Therefore, Judge Bittner

recommended that Respondent be

permitted to retain his DEA registration

subject to the following restrictions:

1. For three years after issuance of a

final order in this proceeding,

Respondent shall not be employed as a

physician with any entity that does not

impose the same conditions on him that

MedClinic imposed in the February 26,

1998, Last Chance Agreement.

2. Each calendar quarter, Respondent

shall provide the Special Agent in

Charge of the local DEA office (or that

agent’s designee) a list of all controlled

substance prescriptions he has issued,

including the patient’s name and

contact information, the name of the

substance, the dosage form, strength,

and quantity prescribed of the

substance, and the number of refills

authorized, if any.

The Deputy Administrator agrees with

Judge Bittner that revocation of

Respondent’s DEA registration is not

warranted. Respondent has accepted

responsibility for his actions. He

underwent extended inpatient treatment

for his addiction, completed the courtordered treatment program, and is still

participating in the Medical Board’s

Diversion Program. His practice of

medicine, as well as his continued

recovery, is monitored by the Medical

Board’s Diversion Program, his

employer through the Last Chance

Agreement, and the hospital’s Wellness

Committee. However, the Deputy

Administrator is troubled by the

relatively short period of time that

Respondent has been drug-free.

Therefore, the Deputy Administrator

concludes that additional restrictions

should be imposed on Respondent’s

DEA Certificate of Registration in order

to protect the public health and safety.

The Deputy Administrator concludes

that Respondent’s DEA Certificate of

Registration should be continued

subject to the following restrictions for

three years from the effective date of

this final order:

1. Respondent shall continue to

participate in the Medical Board of

California’s Diversion Program

regardless of whether the Medical Board

authorizes the termination of his

participation at an earlier date.

2. Respondent shall not practice

medicine as a solo practitioner and he

shall not be employed as a physician

with any entity that does not impose the

same conditions on him that MedClinic

imposed in the February 26, 1998 Last

Chance Agreement.

3. Upon request, Respondent shall

submit copies of the results of his

random urine screens to DEA.

4. Respondent shall not prescribe any

controlled substances for himself or any

immediate family member.

5. Each calendar quarter, Respondent

shall provide to the Special Agent in

Charge of the local DEA office, or his

designee, a log of all controlled

substances that he prescribes, dispenses

or administers, including the patient’s

name and contact information, the name

of the substance, the dosage form,

strength and quantity prescribed,

administered or dispensed, and the

number of refills authorized on

prescriptions, if any.

Accordingly, the Deputy

Administrator of the Drug Enforcement

Administration, pursuant to the

authority vested in him by 21 U.S.C. 823

and 824 and 28 CFR 0.100(b) and 0.104,

hereby orders that DEA Certificate of

Registration BR1670012, previously

issued to Edson W. Redard, M.D., be

and it hereby is continued, subject to

the above described restrictions. This

order is effective June 12, 2000.

Dated: May 4, 2000.

Donnie R. Marshall,

Deputy Administrator.

[FR Doc. 00–11890 Filed 5–11–00; 8:45 am]

BILLING CODE 4410–09–M

DEPARTMENT OF JUSTICE

National Institute of Corrections

Solicitation for a Cooperative

Agreement—Assessment of

Institutional Culture

AGENCY: National Institute of

Corrections, Department of Justice.

ACTION: Solicitation for a cooperative

agreement.

SUMMARY: The Department of Justice

(DOJ), National Institute of Corrections

(NIC) announces the availability of

funds in FY–2000 for a cooperative

agreement to develop and document a

methodology and process to assess

institutional culture within prison

settings.

Background

Beginning in 1996 the Prisons

Division initiated a special emphasis on

addressing staff sexual misconduct.

NIC’s approach to assisting agencies has

included on-site technical assistance,

training programs and dissemination of

information. Throughout the extensive

work with institutions in addressing

staff sexual misconduct, consistent

themes from correctional staff and the

offender population underscore the

importance of the institutional

environment. Additional work at NIC in

the area of mission change of

institutions and the identification of the

challenges of keeping an effective

workforce also provide background for

NIC’s interest in institutional culture.

Staff and inmate relations, consistent

and fair supervisors, well trained staff,

and strong institutional and agency