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Private Equity Firms Rebrand Prison Healthcare Companies, but Care Issue Continue, Nov. 2022

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PRIVATE
EQUITY FIRMS
REBRAND
PRISON
HEALTHCARE
COMPANIES,
BUT CARE
ISSUES
CONTINUE
November 2022 | Michael Fenne | michael.fenne@pestakeholder.org

2

KEY POINTS

2

■

W
 ellpath is owned by H.I.G. Capital, and is among the largest healthcare companies
serving U.S. prisons and jails.

■

W
 ellpath continues to be mired in regulatory and reputational risk related to conditions that
have endangered and harmed patients under its care.

■

R
 ecent investigations indicate that Wellpath facilities are characterized by poor intake and
screening; difficulty accessing care; and inconsistent medication management practices.

■

Inadequate

staffing at Wellpath facilities has contributed to concerns about access to care;
psychiatric staff are given caseloads in excess of what is reasonably manageable.

■

W
 ellpath has expanded beyond correctional healthcare, and recently began providing child
psychiatric services, mental health treatment, and substance use services to the general
population—including a psychiatric hospital providing care to children ages 5-13.

■

W
 ellpath’s political activities primarily involve contributions to local sheriff campaigns, and
relationship-building through existing clients and associates.

■

F
 ederal and state correctional authorities should not renew or seek new contracts with
Wellpath, and should ensure that existing contract terms are enforced in full. Where
options are more limited, authorities should place clear accountability measures into
contracts with private correctional healthcare providers.

Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

WELLPATH’S PRACTICES LEAVE INCARCERATED
PEOPLE UNWELL
I. Introduction
Days after taking office, President Joe Biden issued an executive order directing the
Department of Justice to not renew contracts with privately operated criminal detention
facilities, noting that privatwely operated facilities “consistently underperform Federal facilities
with respect to correctional services, programs, and resources.”1 A few years earlier, an
Obama-era Justice Department official noted that private prisons “simply do not provide the
same level of correctional services, programs, and resources; they do not save substantially
on costs; and as noted in a recent report by the Department’s Office of Inspector General,
they do not maintain the same level of safety and security.”2
However, privatization and its attendant harms continue in other forms and places, such
as within immigration facilities.3 Federal and state correctional authorities also continue
to privatize specific services within facilities,4 such as phone services,5 commissary,6 and
healthcare.7 In 2020, there were estimated to be over 4,100 corporations profiting from mass
incarceration in the U.S.8
In 2016, the Justice Department’s Office of Inspector General found that federal prison
spending on outsourced healthcare increased 24% to $327 million between 2010 and 2014,
while the overall prisons budget increased only 11%.9 In 2016 it was estimated that half of all
state and local prisons and jails had outsourced healthcare to an industry worth more than $3
billion annually.10 As of 2022, correctional healthcare is estimated to be worth $9.3 billion.11
In a 2020 report, Reuters estimated that over 60% of jails outsource their healthcare to
private companies. The report also reviewed deaths in more than 500 jails from 2016 to
2018, and found that “those relying on one of the five leading healthcare contractors had
higher death rates than facilities where medical services are run by government agencies.”12

In 2016 it was estimated that half of all state and local
prisons and jails had outsourced healthcare to an industry
worth more than $3 billion annually. As of 2022, correctional
healthcare is estimated to be worth $9.3 billion.

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

Prison healthcare contracting can be
incredibly lucrative. The Bureau of
Prisons negotiates federal medical
services contracts facility-by-facility
basis. According to an OIG report
in 2016, federal medical services
contracts had reimbursement rates
from 115 to 385 percent of the
Medicare rate.13 Contracting practices
vary between state departments of
corrections and costs can range from
$19,796 per patient on healthcare
in California to $2,173 per patient in
Louisiana.14
A handful of private equity firms have
invested heavily in private prison
services,15 including two of the biggest prison healthcare providers: Wellpath (H.I.G. Capital)
and YesCare (The Flacks Group, formerly BlueMountain Capital). In August 2022, the
American Correctional Association’s 152nd Congress of Correction—which counts among its
sponsors healthcare providers Wellpath and YesCare—included more than 120 exhibitors,
as well as four days of workshops including “Outsourcing Healthcare: Various Models
and Oversight.”16 Other private equity-backed healthcare exhibitors at the New Orleans
conference included SnapNurse (Pivotal Group17) and TridentCare (Silver Point Capital18).19
In 2019, the Private Equity Stakeholder Project, along with other organizations, sent letters
to firms invested in companies that profit from incarceration and detention, and asked the
firms to meet and to exit their investments in prison, jail, and detention service providers.
Letter recipients included, among others, BlueMountain Capital and H.I.G. Capital, respective
owners of correctional healthcare providers Corizon Health (now YesCare) and Wellpath.20
This report examines Wellpath, a company that claimed more than 15,000 healthcare
professionals serving over 300,000 adult and juvenile patients across the United States
and Australia in 2019.21 The report also looks at Wellpath’s private equity owner22 H.I.G.
Capital,23 and more generally examines private equity’s healthcare profiting from prisons,
jails, and mass incarceration. As discussed below, Wellpath has been found by regulators
and watchdogs to provide inadequate healthcare in some of its facilities and has continued to
staff some facilities to levels inadequate to provide adequate care.24
Despite ongoing concerns, the company has continued to make political contributions,
build local connections, and sign contracts to expand its services into new areas and
populations25—including an unprecedented contract to provide child psychiatric care in a
non-correctional hospital.26

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

II. H.I.G.’s Dubious Track Record in Prisons and Healthcare
Wellpath was formed in 2018 from the consolidation of H.I.G. Capital-owned companies
Correct Care Solutions (CCS), which H.I.G. acquired in 2018, and Correctional Medical
Group Companies (CMGC), acquired by H.I.G. in 2013.27
CCS was no stranger to private equity; before H.I.G. acquired it, the company was owned
by private equity firms Audax Group, Frazier Healthcare Partners and GTCR. The firms had
created CCS out of their own flurry of consolidations beginning in 2012.28
California Forensic Medical Group, a CMGC company now part of Wellpath, paid out millions
in settlements to families of incarcerated people who alleged negligence by the company
after it was acquired by H.I.G.29 In 2018 the Project on Government Oversight reported that
CCS had been sued nearly 1,400 times in federal courts over course of the decade before
H.I.G. acquired the company, largely during Audax Group’s, Frazier Healthcare Partners’ and
GTCR’s tenure.30
In the year before H.I.G. acquired Correct Care Solutions, the company also came under
scrutiny from the U.S. Department of Homeland Security Office of Inspector General and
members of Congress for poor conditions at an immigration facility where it provided
healthcare in Adelanto, California. The inspector general’s report raised concerns about
“untimely and inadequate medical care” and 80 detainee medical care grievances filed
between November 2017 to April 2018. At another facility in Texas, the U.S. Justice
Department found CCS failed to meet federal staffing standards more than 90 percent of the
time.31
In addition to the healthcare provider, H.I.G. Capital also owns TKC Holdings, which provides
food, commissary, and telecom services to jails, prisons, and immigrant detention centers.32
The company was formed by combining Trinity Services Group, which H.I.G. acquired in
2012, and the Keefe Group, acquired in 2016. Before that, H.I.G. helped make Securus
Technologies one of the largest correctional telecommunications companies in the U.S.,
before selling the company in 2011.33
H.I.G. Capital has itself been named as a defendant in lawsuits related to its portfolio
companies. For example, the Massachusetts Attorney General sued H.I.G. Capital alleging
the firm knew about fraudulent Medicaid claims submitted to the state by a company that
H.I.G. owned and controlled. The company, a subsidiary of H.I.G.’s behavioral health
provider Community Intervention Services (CIS), paid $4 million to settle the False Claims
Act violations in 2018.34 CIS declared bankruptcy in January 2021.35 In October 2021, H.I.G.
Capital paid a $19.95 million settlement but admitted no wrongdoing.36
H.I.G. was also named a defendant for its alleged role in the fraudulent activity of its portfolio
Surgery Partners Inc., which paid $41 million in 2020 to settle U.S. Justice Department
allegations that the company defrauded federal health programs through claims for medically

5

Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

unnecessary urine drug testing services.37 After the settlement, the case against H.I.G.
continued before an appellate court affirmed its dismissal on procedural grounds in 2022.
Until recently, private equity owners of healthcare companies were rarely implicated in False
Claims Act actions.38
Despite fraud allegations, CIS’s bankruptcy, and thousands of lawsuits involving its portfolio
companies, H.I.G. Capital remains active in acquiring healthcare providers. In late 2020,
the firm acquired a leading provider of hospice services,39 and partnered to create a new
digestive health investment platform.40
Private Equity Stakeholder Project has continued to track H.I.G. Capital’s repeated problems
with regulatory and reputational risk across multiple portfolio companies,41 including
Wellpath.42 In 2020, PESP reached out to H.I.G. to ask the firm to take steps to mitigate the
harmful impacts of its prison and detention businesses in light of the COVID-19 pandemic;43
and later that year examined
data on outbreaks and resident
deaths at ten Wellpathmanaged facilities across the
country.44
Recently, Wellpath came
under scrutiny from the
U.S. Department of Justice,
which in 2021 published an
investigation of California’s
San Luis Obispo County Jail
and found reasonable cause
to believe that the jail failed
to provide constitutionally
adequate medical and mental
health care, and denies
prisoners with mental health disabilities access to services, programs, and activities.45 Justice
Department investigators were accompanied by medical and mental healthcare consultants
for visits to the jail in January 2019 and August 2019. The county health agency provided
and mental health services to the jail until Wellpath began providing services in February
2019. The report includes comparisons of before and after Wellpath began providing the jail’s
healthcare services.46
In early 2022, the Disability Law Center in Massachusetts investigated a Wellpath-serviced
state hospital, and published a report identifying concerns including illegal chemical and
physical restraint practices, limitations on medical care, and a lack of programming for people
who have intellectual and/or developmental disabilities.47 In July 2022, Moody’s downgraded
Wellpath’s corporate family rating to B3 from B2 because of persistent labor issues as well as
an increase in pharmacy supply costs.48

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

III. YesCare/Corizon Health – BlueMountain Capital Management, Flacks Group
One of Wellpath’s largest competitors is YesCare, which was known as Corizon Health until
the company rebranded in May 2022.49 YesCare/Corizon was previously owned by private
equity firm BlueMountain Capital Management until its 2020 acquisition by the Flacks
Group.50 According to a press release at the time of its acquisition, YesCare/Corizon provided
primary medical services, behavioral health, dental care, and pharmacy services to 149
facilities in 16 states, employing more than 5,000 people and generating approximately $800
million in annual revenue.51 Gerard Boyle, the Wellpath founder who pleaded guilty of bribery
in 2021,52 started his correctional healthcare career at a company that would eventually
rebrand as Corizon Health.53
Flacks Group, which owns YesCare, is an investment firm with more than 20 real estate
investments in the U.S. and Europe. The firm also makes corporate investments including
pharmacy services, beauty products, and fossil fuel pump manufacturers.54
In the five years leading up to April 2020, YesCare/Corizon paid at least $16 million in fines,
penalties, or lost revenue due to inadequate staffing levels and failures to improve patient
healthcare around the country.55 At one facility in Arizona, a judge-appointed expert observed
that “recruitment and retention are an ongoing issue, resulting in staff being stretched too
thin to provide coverage.”56 At the same facility, staff described the situation in an email to
management with the subject line, “IN NEED OF HELP!!”57
By late 2021, YesCare/Corizon had faced more than 1,000 lawsuits across the country
alleging substandard care in jails and prisons and paid out millions of dollars to settle
wrongful death lawsuits.58 Together with the Wellpath examples described above, YesCare/
Corizon’s performances demonstrate the risks to life and health in correctional healthcare,
particularly where it is contracted out to private-equity-backed providers.59

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

IV. Wellpath’s inadequate screening practices during patient intake
Concerns at Wellpath facilities have arisen as early as intake into a facility when patient
screening occurs. At one Wellpath facility in California, the U.S. Justice Department
observed that incarcerated persons were “routinely” examined beyond 14 days of
admission—”or not at all”—in violation of facility policy.60 Additionally, the report stated that
“[p]ost-intake mental health assessments are also inadequate, and sometimes occur after
significant delay.”61
The findings were part of an investigation announced
in November 2018, which San Luis Obispo County
officials said was not focused “on any single event,
but rather on the delivery of medical and mental
health services.”62 The report contained findings on
healthcare, use of force, and other topics at San
Luis Obispo Jail, where Wellpath started providing
services in February 2019.63
Patients who are screened may still not receive
appropriate follow-up for medical conditions.
The Justice Department report observed that
“[w]hen nursing staff learn through initial
screenings that prisoners have chronic
diseases or are actively withdrawing from
drugs, the Jail does not provide prompt
evaluation and diagnosis by a medical
provider.”64

INVES
TIGAT
ION OF
SAN LU
THE
IS OBI
SPO CO
(SAN L
UNTY
UIS OB
JAIL
ISPO, C
ALIFO
RNIA)

United S

tates De
Civil Rig partment of Just
ice
hts Divis
ion
United S
tates Att
orney’s
Central
O
District
of Califo ffice
rnia
August

31, 2021

Similar concerns are seen at other Wellpath
facilities. In March 2022, the Louisville
Metro Corrections director announced his
retirement after two no confidence votes related to seven
suicide and drug overdose deaths within six months at Louisville’s jail.65

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

Concerns at Wellpath facilities have arisen as early as
intake into a facility when patient screening occurs.
At one Wellpath facility in California, the U.S. Justice
Department observed that incarcerated persons were
“routinely” examined beyond 14 days of admission—”
or not at all”—in violation of facility policy.
After an eighth death, Kentucky ACLU’s interim president said there was need for a
“thorough review” of Wellpath, which was contracted to provide healthcare at the jail. “There
is clear indication something is wrong with their screening process,” she stated. “We have to,
as a community, investigate and hold Wellpath responsible for the care they are providing for
people in custody.”66
In additional types of care, the Justice Department found that the San Luis Obispo jail also
“failed to provide a medical screening system that ensures adequate diagnosis and treatment
of serious medical conditions and continuity of care,” including for serious medical conditions
like HIV and hypertension, and care for pregnant women.67
In other counties where Wellpath provides services, officials have noted the cost-saving
effects from not transferring patients outside the jail. In Isabella County, Michigan, the
Sheriff wrote in a memo to the finance department, “Wellpath has been successful in
keeping the emergency room and other medical visits to a minimum.” Included with the
memo are documents suggesting that in this county, Wellpath attempts to achieve fewer
offsite visits by providing more on-site nurse, doctor, and mental health hours than its
competing bidders.68
In a proposal to Fort Bend County, Texas, Wellpath includes a section in their budget
proposal dedicated to the assumption that their model will decrease off-site costs. The
proposed 2020 budget assumes that off-site costs will fall by more than a quarter percent to
pre-2017 levels.69
In April 2022, an agreement was announced for Wellpath to provide healthcare at the jail
in Muscogee County, Georgia. Working with Wellpath “will cut our medical cost of us going
outside and we can have those services provided here on the inside,” said the county sheriff.
“Over the next five years it’s going to cut outside medical cost.”70

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

V. Difficulty accessing care at Wellpath facilities
Beyond intake an early screening, persons served by Wellpath have faced additional
difficulties accessing care. In San Luis Obispo County, the Justice Department observed
“Neither of the Jail’s two channels for prisoners to notify staff about medical concerns—
medical request forms and healthcare grievances—function properly.”71
In reviewing medical request forms, “medical staff frequently overlook prisoners’ concerns,
fail to provide prompt care, or fail to provide care at all.” Patients at the facility have
encountered obstacles when attempting to raise concerns: “the Jail routinely fails to give
prisoners grievance forms, or provide them timely, even after repeated requests.” For the
grievances that were completed, “a significant proportion raise medical issues, including
missed or unfilled medications, failure to provide follow-up care, and inability to access care
through the sick call slip process.”72
At the San Luis Obispo
facility, a Wellpath
administrator used a
meme while presenting
on the grievance process,
which read, “Stop whining
and find something to
do.” The report authors
noted, “Wellpath and
its staff appear not to
take seriously prisoner
grievances or the
grievance process as a
mechanism for prisoners
A slide from a presentation created by a Wellpath administrator.
to raise legitimate
(Source: Justice Department Investigation of the San Luis Obispo County Jail)
73
medical concerns.”
The Justice Department also identified failures to provide adequate specialty care, ancillary
services, and follow-up treatment and care. Specialty care appointments, laboratory draws,
and other tests “are frequently ‘rescheduled’ for no discernable or documented reason,
resulting in very long delays or the failure to perform tests or deliver follow-up care entirely.”
The report also noted, “Wellpath also refuses treatment for chronic conditions when prisoners
are purportedly to be released soon, even though many of them have release dates weeks or
months away or requested treatment months earlier.”74
Medical records from a 2021 lawsuit describe the facility medical charges policy for one
Texas facility where Wellpath provides services. The facility charges a $10 health service
fee for a nurse sick call; $15 for referrals to a physician or dentist; and each prescription
includes a $3 charge. Facility patients are still charged $10 if they choose not to be seen
after submitting a sick call.75

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

VI. Wellpath’s inconsistent and harmful medication practices
Wellpath facilities have also been accused of medication mismanagement. In January 2022,
the Disability Law Center in Massachusetts issued a report on Bridgewater State Hospital,
where it has conducted oversight for almost eight years, finding “Wellpath is now subjecting
[persons served] to all forms of restraint and seclusion in unsanctioned circumstances,
particularly the use of manual holds, seclusion, and chemical restraint.”76
The DLC report also describes a “culture of intimidation” at the facility. One individual
reported that Wellpath staff would “supply the disturbance”—through offensive comments or
by instigating conflict—in order to justify the use of chemical restraints.77
In July, Disability Law Center published a follow-up report on Bridgewater, identifying
involuntary medication administration absent emergencies and a “significant number of
[emergency treatment orders] administered for reasons that do not comply” with state law.”
“Wellpath continues to use vague terms, which often lack any reference to harm whatsoever”
to justify restraints and seclusion.78 In May 2022 at Norfolk City Jail in Virginia, a Wellpath
psychiatrist resigned citing disagreements over issues at the jail, including what he perceived
to be overmedication of people incarcerated at the facility.79
In San Luis Obispo, the Justice Department reported “systematic problems with medication
management” which were “extremely dangerous to prisoners whose health is threatened
by serious medical conditions, and—as noted with respect to patients with HIV infections—
increases the risk of developing medication resistance.” Medication mismanagement at
the jail included delayed medication or not provided at all;80 wrong dosages or ineffective
combinations of medications81; and psychiatric staff mismanagement.82
The Justice Department report included specific examples. In March 2019, one San Luis
Obispo patient was transferred to a county psychiatric facility. When she was transferred
back to the jail in April, mental health staff did not continue her on medication she was
taking at the psychiatric facility. A week later, mental health staff noted signs of mental health
deterioration. Another patient sent to the psychiatric facility in March 2019 had to wait eight
days to speak with a psychiatrist after returning to the jail, and another five days to receive
prescribed psychotropic medications. A clinician noted that during this time, the patient
“articulated apparent delusions.”83
In August 2019, a “psych tech” at the jail administered “a high one-time dosage of an antipsychotic that could have caused an overdose.” According to the report, despite exhibiting
signs of overdose, there is no indication the man was physically evaluated, and a psychiatric
nurse practitioner did not evaluate him until a week after the high dosage of medication.84
In another example from an Iowa jail, in 2021 Wellpath was sued for allegedly refusing to
administer prescribed mental health medication.85 In one such case, Wellpath agreed in a
settlement to finally provide prescribed mental health medication to an incarcerated man.86

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

VII. Wellpath’s inadequate staffing and oversight
Inadequate staffing is one contributing factor to Wellpath’s issues in providing care. “Wellpath
fails to provide adequate staffing to prevent delays in medical care that place prisoners at
substantial risk of serious harm,” observed the Justice Department in San Luis Obispo’s jail.87
The investigators noted inconsistencies in reported hours, for example a nurse practitioner
who reported an average of 18.7 and 13.4 hours per calendar day in July and August
2019. In an interview, the nurse said she had worked about 50 hours per week during this
time, substantially less than reported.88 “No matter the actual number of service hours,
as illustrated above and below,” the Justice Department wrote, “existing staffing appears
inadequate to ensure timely access to various types of care.”89
In San Luis Obispo’s jail, “[t]he onsite Health Services Administrator told us that she assigned
the psychiatrist 50% more patients per day than the psychiatrist felt comfortable seeing.”
Additionally, “[t]he psychiatric nurse practitioner said that previously she sometimes had as
many as 30 patients on her list per day even though she could only see between 10 and 12.”90
In May 2022, a Wellpath-contracted psychiatrist resigned after six months after disagreements
with the Norfolk Sheriff’s Office in Virginia, including over the number of patients he examined
each week, according to a report by The Virginian-Pilot. The psychiatrist stated that he was
asked to see a minimum of 50 patients per week in the nine hours he was contracted to

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

In April 2022, one recently unionized Wellpath worker at a
pretrial facility in Bakersfield, California, said in a press
release “We are overworked and not compensated fairly.”
The mental health technician continued, “The understaffing
does not allow for my coworkers and I to take off to care for
our mental health.”
work: an average less than 11 minutes per appointment. In emails reviewed by The Pilot,
psychiatrist’s Wellpath supervisor informed him that the request was based on the schedule of
the jail’s previous psychiatrist, who saw 50 to 60 patients per week.91
In April 2022, one recently unionized Wellpath worker at a pretrial facility in Bakersfield,
California, said in a press release “We are overworked and not compensated fairly.” The
mental health technician continued, “The understaffing does not allow for my coworkers
and I to take off to care for our mental health.”92 In nearby Stanislaus County, which won
new contract rights addressing staffing levels, one registered nurse stated in another press
release by the union, “The issue of short-staffing is important to all of us and is the reason
why we formed a union two years ago.”93
In Sonoma County, California, the National Union of Healthcare Workers sent a letter to
county officials in April, outlining a number of issues related to understaffing at the county
jail. At the time, nurses estimated 300 cases that had gone more than 14 days without being
addressed by a healthcare professional. And despite Wellpath’s recent contract renewal
with the county, only 59% of registered nurse hours that Wellpath was contracted to fill were
staffed from the end of 2021 to March 2022. Nurses reported working shifts alone, despite
requirements that Wellpath have six nurses in the jail per day shift.94
At the Louisville jail in Kentucky, where at least 8 people died by suicide at from 2008 to
2019, two incident reports from early February 2022 indicate there was no mental health staff
on site. “After 5 p.m., there is nobody. On the weekends, there is nobody,” said the head of
the jails’ staff union.95
The actions of jail staff can sometimes highlight the need for medical staff. Recently in
North Carolina, a grand jury indicted a Wellpath nurse for involuntary manslaughter at a
facility where the company provides care.96 The grand jury declined to indict five detention
officers for the death of the man, who died while they restrained him in a prone position.
An attorney for the nurse stated that the “only time” she touched him “was to take his vitals
and perform CPR”.97

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

VIII. COVID-19 response from Wellpath and H.I.G. Capital
In July 2020, PESP discussed COVID-19 outbreaks reported at 10 facilities where Wellpath
provides care, including facilities in Massachusetts, Kentucky, California, and others.98 At one
facility in Arkansas, nurses described understaffing issues that could leave Wellpath prison
infirmaries hundreds of sick calls behind.99
The Financial Times reported that a court-ordered inspection in Shelby County, Tennessee,
“concluded that ‘the Wellpath Covid-19 response plan is inadequate to protect … vulnerable
inmates.’”100 The investigation also noted that Wellpath employs a ‘non-test’ strategy for
managing COVID-19 at the jail.101
In April 2020, PESP joined partner organizations in asking that private equity firms invested
in prison and detention service companies to halt those companies’ predatory practices
during the COVID-19 pandemic. As part of that effort, a letter was sent to H.I.G. Capital
regarding Wellpath and TKC Holdings.102 In a response letter, H.I.G. objected to accusations
that it engaged in “predatory behavior” or using the pandemic “as an opportunity to further
exploit incarcerated people”—saying that these descriptions were “insulting and couldn’t
be further from the truth.”103 A response letter was sent to H.I.G.104 highlighting COVID-19
cases impacting incarcerated
persons and staff in Florida,105
Massachusetts,106 New Jersey,107
Michigan,108 and Louisiana.109 The
response also noted understaffing
issues at Wellpath facilities,
and additional concerns over
correctional service provider
TKC Holdings, an H.I.G. portfolio
company.110
In 2021 in Polk County, Iowa, a
Wellpath social worker agreed to
a $65,000 settlement after being
fired in the pandemic’s early
months, allegedly for criticizing
how the facility handled COVID-19
restrictions, characterizing the
protocols as “a clusterf---” and
alleging that patients with mental
illness were being poorly treated.111
According to county data released
two days after her firing in May
2020, at least 89 patients and nine
staffers at Polk County Jail had
tested positive for the virus.112

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

IX. Wellpath’s expansion beyond correctional settings
Despite concerns surrounding Wellpath’s healthcare services in correctional settings, the
company has expanded into additional settings. In May 2022, the New Hampshire Executive
Council approved a two-year, $52 million no-bid contract with Wellpath to provide psychiatric
care for children at Hampstead Hospital.113 Calls on the government body to seriously
reconsider the Wellpath proposal came from five organizations, including Disability Rights
Center-NH, New Futures, NAMI New Hampshire, New Hampshire Legal Assistance, and
Waypoint of New Hampshire.114
“[W]e do not believe this company is qualified to provide in-patient psychiatric care to children
experiencing mental health crises,” the letter read, “Other than juvenile detention centers,
we have been unable to locate any inpatient psychiatric treatment facilities serving children
that are operated by the company.”115 Wellpath was one of four companies to submit bids to
provide behavioral healthcare at the hospital, and scored second to Dartmouth Health.116
In support of the proposal, a New Hampshire Health and Human Services Associate
Commissioner expressed reassurance by Wellpath’s prior work at the Alaska Psychiatric
Institute, for a period of 18 months from February 2019 to August 2020.117 The facility has 61
beds, 10 of which are in the adolescent unit.118 The Alaska facility treats children ages 13-18,
whereas New Hampshire’s Hampstead hospital cares for children ages 5-17.119
Alaska hired Wellpath in February 2019 to overcome hospital dysfunction including
threatened loss of federal funding sources.120 In April, the state announced its intent to end
the 5-year contract by December 2019. According to the state health commissioner, “There’s
so many questions and skepticism surrounding this contract, it’s important for us to resolve
those questions, that our process aligns with our intentions.”121 Wellpath’s Alaska contract
would eventually end in August 2020. According to health department spokesperson at the
time, Wellpath helped “stabilize” the facility, and “the need for … services decreased.”122
Wellpath’s New Hampshire children’s hospital proposal was also reviewed by the state
attorney general’s office, which concluded that “Wellpath does not appear to have an unusual
amount of litigation or pose any substantial risk of inadequate care.” The review was based
on data from the last five years, provided by Wellpath from psychiatric hospitals where it
provides services, as well as online database searches relating to the same facilities.123
Wellpath has also recently opened clinics serving the general public, which are dedicated to
treating opioid addiction and other substance use disorders. In April 2021, Wellpath opened
a treatment center in Winston-Salem, North Carolina, providing in-person and telehealth
services.124 In May 2022 the company announced a second North Carolina clinic providing inperson and telehealth addiction recovery services to members of the public.125 The following
month, Wellpath announced a clinic in Newport News, Virginia, where medication assisted
treatment and addiction counseling are available to formerly incarcerated persons as well as
the general public.126

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

X. Wellpath’s expansion into new locations
Continuity between Wellpath and its predecessor companies can sometimes be seen in the
career trajectories of company executives and associates. Wellpath’s CEO, Jorge Dominicis,
who has led the company since its formation in 2018, also led controversial Correct Care
Solutions from 2014, and was previously a GEO Group executive.127 When Dominicis became
CEO of CCS, his predecessor Gerard Boyle became executive chairman, and served on
Wellpath’s board until 2019128—the same year he was indicted on federal bribery charges.129
Boyle was chief executive of CCS until becoming executive chairman in 2014. After the
company’s acquisition, Boyle served on Wellpath’s board until 2019.130 He started his career
as a prison guard and by the early 1990s had become superintendent of Bridgewater State
Hospital, the Massachusetts facility recently examined by Disability Law Center. Boyle later
led Prison Health Services, which became part of Corizon Health,131 among the largest private
healthcare providers in U.S. correctional facilities.132 (Corizon is now known as YesCare.)
In another example from October 2021, Grand Prairie Healthcare Services—in partnership
with Wellpath—entered a $590 million contract to provide healthcare to Michigan’s county
jails.133 Grand Prairie is owned by Dr. Deann Rieger, who is the former chief medical
officer for Correct Care Solutions (one of the companies that was merged into what is now
Wellpath).134 According to Rieger, Grand Prairie will be the sole medical provider for the
state’s 10,000 county patients, and Wellpath will provide nonclinical support such as human
resources, finances, and legal services.135
A public information officer for the Michigan Department of Corrections stated that the Grand
Prairie contract scored highest in a review of proposals, based on experience in crisis
intervention, providing weekend and night shift care for prisoners, and its medication practices
that could lower pharmacy spending. According to a Wellpath executive, the agreement would
save the state up to 20% compared to the previous correctional care provider, Corizon.136
Other recent contracts with Wellpath have come from facilities ending previous contracts.
For example, in February 2022, Alachua County, Florida, began a $20 million contract with
Wellpath to provide services in the county jail through 2025, replacing Corizon health.137 In
April 2022, 1,400 patients in Delaware County, Pennsylvania were transferred from GEO
Group to county responsibility, with Wellpath providing health services for the county.138 In
July 2022, Sherburne County, Minnesota, approved an agreement with Wellpath to take
effect in September, replacing Minnesota-based MEnD Correctional Care.139
Other facilities have contracted with Wellpath after difficulty finding an alternative. After two years
unable to find bidders to provide healthcare at the county jail, in October 2021 the St. Joseph
County Council in Indiana entered a three-year, $2.9 million annual contract with Wellpath. The
Wellpath contract will annually cost the county about $300,000 more than it paid on its own
staff in 2021.140 In June 2022, Ventura County, California, approved a five-year agreement with
Wellpath, with NaphCare being the only other company to submit a proposal to the county.141

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XI. Wellpath’s political activities
Wellpath makes political donations through Wellpath PAC, known as Correct Care PAC until
2019. The political action committee’s largest contributions were in 2015 and 2016, when it
contributed $5,000 to Jeb Bush’s Right to Rise PAC and to the Republican Party of Kentucky.
According to the FEC’s online disbursements data, Correct Care/Wellpath PAC has made
more than 100 disbursements since 2015, including vendor fees, contributions to other
PACs, and contributions to political candidates for legislative, judicial, and executive positions
at state and local levels.142

i. Virginia – Bribery and corruption
In another large donation during the 2015-16 election cycle, Correct
Care PAC donated to $4,000 to Bob McCabe for Sheriff in Norfolk,
Virginia.143 In October 2019, Wellpath founder Gerard Boyle was
indicted on federal bribery charges, along with McCabe.144 Additionally,
in a 2020 news report, associates commented that his local ties
and position as board chairman helped Wellpath win contracts with
Massachusetts state and county jails, as well as with Bridgewater. Sheriff McCabe had also been
a reference while the company was seeking business in Massachusetts: “As a client, I feel valued
and this sets CCS apart from your competitors,” McCabe wrote in a proposal document.145

VA

In 2021, Boyle pleaded guilty for engaging in the 13-year bribery scheme, which he had started
at Correct Care Solutions (CCS) before the company was consolidated into Wellpath.146
According to allegations, from 2004 to 2016, Boyle provided Sheriff Robert McCabe with
cash, travel, a loan, entertainment, gift cards, personal cards, and campaign contributions, in
exchange for official actions that favored Boyle’s company, including contract extensions and
renewals worth approximately $3.2 million per year, as well as inside bidding information.147

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ii. New Orleans
In the 2021-22 election cycle, Wellpath PAC has donated $2,000 to the
Committee to Re-Elect LaToya Cantrell.148 Cantrell is currently mayor of
New Orleans, and was a non-voting member of a selection committee
that in April 2022 selected Wellpath’s $104 million proposal to provide
healthcare at the city jail in New Orleans.149 The contract renewal faced
opposition from Orleans Public Defenders, Orleans Parish Prison Reform
Coalition, and a group of more than 100 doctors and medical students.150

LA
NEW
ORLEANS

The newly elected Orleans Parish Sheriff151 won on a platform that included removing
Wellpath from the jail. “Tear up the contract with the jail’s healthcare provider, Wellpath, LLC,
an organization that is the subject of long-standing criticism and dozens of public and private
lawsuits in multiple states, including Louisiana, for charges of neglect, health violations
and religious discrimination, and instead partner with public health organizations to provide
medical care.”152
The city committee voted unanimously to begin negotiating a new contract with Wellpath.
“This is their business. They are a correctional medical company,” said the deputy director of
New Orleans EMS, one of the committee members. He continued, “LSU, this is part of their
portfolio. Wellpath, this is their portfolio.” The committee member did note the criticisms, “We
have heard from the public not too many positive things about Wellpath, around the services
that they provide and just the general feeling of where they are now in the jail.”153
Criticisms of Wellpath in New Orleans go back to at least 2019. “We don’t really have faith
that this group knows how to properly care for people in jail,” said the executive director of
the Orleans Parish Prison Reform Coalition. “There should have been more effort from the
city of New Orleans to look for different health care providers and I’ll even say to look for a
local provider,” she said at the time. “We outsource many services in New Orleans to people
who are out of town, when we could look in town and see what we have and actually work
with people who are connected to the community.”154
The company was chosen over rival bidder LSU Health, a division of the state university
focused on health sciences. The local university was the only other entity to meet the
December proposal deadline. A supervising attorney for the Orleans Public Defenders
commented, “I understand that LSU’s proposals may have its flaws, but Wellpath has proven
of the course of the last decade that they cannot provide adequate care.”155
Wellpath was a sponsor for the recent 152nd Congress of Corrections, which took place in
New Orleans in early August 2022.156 According to the Prison Policy Initiative, Louisiana
“locks up a higher percentage of its people than any democracy on earth.”157

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iii. Texas
In 2015-16, Correct Care PAC gave $1,000 on the Gary Cutler Campaign
Fund, for sheriff of Hays County, Texas.158 In July 2019, Hays County began
contracting with Wellpath to provide the county juvenile detention center
with a licensed vocational nurse, a registered nurse, and a physician.159
In April 2022, the county approved a new and expanded contract
with Wellpath for medical services at its jail and the juvenile detention
center. Under the contract, Wellpath provides intake screenings, health
assessments, dental care, on-site emergency visits, on-site blood draw
procedures, as well as telehealth services and outpatient services as needed.160

TX

In other parts of Texas, Correct Care made numerous donations to sheriff races. In 201516, Correct Care PAC gave $500 to Sheriff Johnny Brown in Ellis County, Texas.161 Online
job listings indicate that Wellpath is responsible for licensed vocational nurses at Wayne
McCollum Detention Center in Ellis County.162
In 2015-16, Correct Care PAC gave $1,000 to Rand Henderson for Sheriff in Montgomery
County, Texas. In 2019-20, Wellpath PAC gave $3,500 to the Rand Henderson campaign.
Henderson’s campaign has also received $1,050 from Wellpath PAC during the 2021-22
cycle.163 Wellpath provides behavioral health services at Montgomery County Mental Health
Treatment Facility.164
Texas Congressmembers John Culberson and Henry Cuellar were the only candidates
to receive contributions from Correct Care PAC in 2017-18. Otherwise, in this election
cycle records indicate that the PAC spent funds on itself, to go towards various luncheons,
receptions, and six golf tournaments.165
In 2019-2020, Wellpath PAC spent $1,000
on Friends of Trever Nehls, candidate for
sheriff of Fort Bend County, Texas. In 2016,
Correct Care PAC spent $600 on Trevor’s
brother Troy Nehls.166 Troy Nehls served as
sheriff in Fort Bend County before winning
the 2020 election to represent Texas’s 22nd
Congressional District.167 In his first month
in office, Troy objected to the 2020 electoral
college count.168 In January 2022, he entered
an entire episode transcript of The Joe Rogan
Experience into the Congressional Record.169
Fort Bend County entered an agreement
with Correct Care Solutions in 2017,170 and
Wellpath provides services at Fort Bend
County Jail.171

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iv. Georgia
In 2015-16, Correct Care PAC contributed $4,000 to four sheriff races in
Georgia, including $1,500 for Jeffrey Mann the race in DeKalb County.172
Correct Care and Wellpath have provided services to DeKalb County for
more than a decade at about $9 million a year.173 Before the company
became part of Wellpath, Correct Care Solutions was hired in the county by
Thomas Brown, who was county sheriff from 2001 to 2014.174

GA

In 2021, DeKalb County Detention Center came under scrutiny when correctional officers
placed responsibility of an patient’s death on Wellpath staff. The day before the man died,
officers claim they alerted medical staff two times that the man was experiencing intense
hernia pain and could barely walk. “I feel like it could have been reported,” said an officer
who reported the man’s pain to a nurse. “But I don’t think medical perceived it as being
serious.”175
Former DeKalb County Sheriff Brown has also worked as a consultant with Wellpath, and
helped introduce the company to sheriff’s offices in other Georgia counties, including Cobb,
Cherokee counties. Brown has introduced the company to the sheriff’s office in Rockdale
County,176 where Correct Care PAC contributed $500 to the sheriff’s race in the 2015-16
election cycle.177
Elsewhere in Georgia, in the 2019-20 election cycle Wellpath PAC spent $600 on a golf
outing for Ira Edwards for Sheriff’s campaign committee, in Athens-Clarke County, Georgia.178
One local publication noted that Edwards’ campaign also received also support from
correctional contractors Securus Technologies, Global Tel Link, and Apps Auburn.179
In the 2021-22 election cycle, Wellpath PAC has given $2,500 to Patrick Labat for Sheriff,
in Fulton County, Georgia.180 The county terminated its contract with Correct Care Solutions
after five people died in a span of 75 days in 2017.181 In 2018, Fulton County signed a
contract with private healthcare provider NaphCare.182 The county signed a new contract with
NaphCare in 2022.183
In November 2021, Wellpath entered an agreement with Cobb County, Georgia—one of the
counties introduced to Wellpath by former DeKalb County Sheriff Brown—to provide 24-hour
mental health services for detainees at the county jail, including an onsite psychiatrist during
the day, and psychiatric nurses and licensed practical nurses to provide 24-hour coverage.
Wellpath started providing services at the jail in 2020.184 “Our jails across this country have
become surrogate psychiatric hospitals. The needs are absolutely immense,” said Wellpath’s
vice president of mental health services.185
In January 2022, Wellpath announced a new partnership with Lowndes County, Georgia. The
one-year agreement includes comprehensive medical, enhanced mental health, and dental
services, as well as implementation of an electronic medical record system at the jail.186

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According to the Wellpath website, the Georgia Department of Corrections “has announced
its intention to award the Healthcare Comprehensive Contract for GA DOC locations to
Wellpath.” An included map indicates that GA DOC has facilities in the counties where
Wellpath contributed, including DeKalb, Athens-Clarke, Fulton, and Rockdale counties.187

v. Other states
In addition to contributions mentioned above, in 2021-22 Wellpath PAC
has contributed $420 to the races for sheriff in Cayuga County, New York;
Monmouth County, New Jersey; and Chesapeake County. Virginia; Wellpath
PAC has also donated to races for county executive in Westchester County,
New York; and for the South Carolina governor’s re-election campaign.188
Wellpath PAC has also contributed to Craig
Greenberg for Mayor of Louisville, Kentucky. In
March 2022, the Louisville Metro Corrections director
announced his retirement after two no confidence
votes related to 7 suicide and drug overdose deaths
within six months at Louisville’s jail, where Wellpath
provides services.189

21

NY
NJ
VA

KY

SC

Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

XII. Recommendations for federal authorities, H.I.G. Capital, state and
local decisionmakers, and prison authorities.
In 2016 when the Obama Administration made the decision to phase out the federal use of private
prisons, it was noted that private prisons “simply do not provide the same level of correctional
services, programs, and resources; they do not save substantially on costs; and … they do not
maintain the same level of safety and security.”190 The same concerns apply to private prison services.
In order to ensure safety and security in prisons, the federal government should end contracts
with prison service contractors, such as Wellpath and YesCare. Reuters reviewed deaths in
more than 500 jails from 2016 to 2018, and found that “those relying on one of the five leading
healthcare contractors had higher death rates than facilities where medical services are run by
government agencies.”191
We also renew an earlier call for H.I.G. to exit its investments in Wellpath, TKC Holdings, and
all investments in incarceration and detention service providers. Investments in companies
profiting from incarceration and detention of people only exacerbate existing problems, fueling
the expansion and concentration of companies that provide often subpar services at high costs,
draining money from low-income and minority communities.192
H.I.G. Capital’s limited partners, many of which are public retirement systems, should also
consider limiting future investment with the private equity firm. H.I.G. remains active in prison
services, and in acquiring healthcare providers, despite fraud allegations, a bankruptcy, and
thousands of lawsuits involving its portfolio companies.193 This creates regulatory, legal, and
reputational risk for H.I.G.’s limited partners.
State and local officials who negotiate contracts with prison healthcare providers should place
accountability measures on servicers it contracts with. For example, in June 2022, Ventura County,
California, approved a five-year agreement with Wellpath in which the company must pay penalties
if it does not meet standards for patient care spelled out in the contract. Per the agreement, Wellpath
must pay the county $1,500 every time a patient showing symptoms is not evaluated by a mental
health professional within 24 hours of arrival at a jail. Wellpath must also pay a $25,000 if the county
jails are not accredited to national commission standards within an 18-month timeframe.194
Prison and jail authorities should monitor Wellpath providers to ensure the company meets
contractual obligations. Additionally, the company and its staff should be trained on and utilize all
appropriate tools that are available. For example, in San Luis Obispo Jail, “Wellpath’s medical
record system has the capability to create alerts for prisoners who have a risk of suicide,” but
“Wellpath does not consistently create these medical alerts for prisoners placed in safety cells due
to suicidal behavior,” creating risk for facility staff and incarcerated persons.
When prisons, jails, and detention centers contract out healthcare services, those services become
less accountable to democratic concerns and demands from residents, incarcerated people, families,
and communities. Private equity’s ownership of prison service providers only amplifies these
concerns. Authorities, incarcerated people, and other stakeholders must scrutinize private equityowned healthcare providers in jails, and work to mitigate harms caused by these companies.195

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Endnotes
1 “Executive Order on Reforming Our Incarceration System to Eliminate the Use of Privately Operated Criminal Detention Facilities,” The White House,
January 26, 2021, https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/26/executive-order-reforming-our-incarceration-system-to-eliminate-the-use-of-privately-operated-criminal-detention-facilities/.
2 “Phasing Out Our Use of Private Prisons,” United States Department of Justice, August 18, 2016, https://www.justice.gov/archives/opa/blog/phasing-out-ouruse-private-prisons.
3 “Under Biden, Private Detention Isn’t Ending—It’s Changing Form,” In These Times, accessed September 14, 2022, https://inthesetimes.com/article/biden-private-detention-prisons-immigration-ice.
4 Jacob Swanson and Mary Fainsod Katzenstein, “Turning Over the Keys: Public Prisons, Private Equity, and the Normalization of Markets Behind Bars,” Perspectives on Politics 19, no. 4 (December 2021): 1247–57, https://doi.org/10.1017/S1537592721002218.
5 “Platinum Equity Still Owns Prison Phone Company Securus as It Embarks on Fundraising - Private Equity Stakeholder Project PESP,” accessed September 19,
2022, https://pestakeholder.org/news/platinum-equity-still-owns-prison-phone-company-securus-as-it-embarks-on-fundraising-2/.
6 “Report: HIG Capital’s Prison Food and Commissary Store Racket,” Private Equity Stakeholder Project PESP, November 26, 2019, https://pestakeholder.org/
reports/report-hig-capitals-prison-food-and-commissary-store-racket/.
7 “Jails and Prisons Served by H.I.G. Capital-Owned Wellpath Face COVID-19 Outbreaks, Deaths, Concerns Regarding Staffing Levels,” Private Equity Stakeholder
Project PESP, July 8, 2020, https://pestakeholder.org/news/jails-and-prisons-served-by-h-i-g-capital-owned-wellpath-face-covid-19-outbreaks-deaths-concernsregarding-staffing-levels-2/.
8 “Worth Rises — The Prison Industry: Mapping Private Sector Players,” Worth Rises, accessed September 14, 2022, https://worthrises.org/theprisonindustry2020.
9 “The Federal Bureau of Prisons’ Reimbursement Rates for Outside Medical Care | U.S. Department of Justice Office of the Inspector General,” accessed September 19, 2022, https://oig.justice.gov/reports/federal-bureau-prisons-reimbursement-rates-outside-medical-care.
10 Rupert Neate, “Welcome to Jail Inc: How Private Companies Make Money off US Prisons,” The Guardian, June 16, 2016, sec. US news, https://www.theguardian.
com/us-news/2016/jun/16/us-prisons-jail-private-healthcare-companies-profit.
11 677 Huntington Avenue Boston and Ma 02115 +1495‑1000, “A Human Rights Framework for Advancing the Standard of Medical Care for Incarcerated People
in the United States in the Time of COVID-19,” Health and Human Rights Journal (blog), June 9, 2022, https://www.hhrjournal.org/2022/06/a-human-rights-framework-for-advancing-the-standard-of-medical-care-for-incarcerated-people-in-the-united-states-in-the-time-of-covid-19/.
12 Jason Szep et al., “Special Report: U.S. Jails Are Outsourcing Medical Care — and the Death Toll Is Rising,” Reuters, October 26, 2020, sec. Healthcare & Pharmaceuticals, https://www.reuters.com/article/us-usa-jails-privatization-special-repor-idUSKBN27B1DH.
13 “The Federal Bureau of Prisons’ Reimbursement Rates for Outside Medical Care | U.S. Department of Justice Office of the Inspector General.”
14 “Prison Health Care Costs and Quality,” The Pew Charitable Trusts, October 18, 2017, http://pew.org/2gzL9eF.
15 “Fact Sheet: Private Equity-Owned Firms Dominate Prison and Detention Services,” Private Equity Stakeholder Project PESP, September 17, 2018, https://
pestakeholder.org/reports/fact-sheet-private-equity-owned-firms-dominate-prison-and-detention-services/.
16 American Correctional Association, “152nd Congress of Correction,” August 4, 2022, https://www.aca.org/ACA/ACA_Conference/Event_Details.aspx.
17 “Revolutionary Healthcare Staffing Platform SnapNurse Announces Strategic Investment as It Crosses $200 Million in Revenue,” December 16, 2020, https://
www.businesswire.com/news/home/20201216005184/en/Revolutionary-Healthcare-Staffing-Platform-SnapNurse-Announces-Strategic-Investment-as-it-Crosses-200-Million-in-Revenue.
18 “TridentUSA Sees Bankruptcy Plan Approved After Settlements,” accessed October 5, 2022, https://news.bloomberglaw.com/bankruptcy-law/tridentusa-sees-bankruptcy-plan-approved-after-settlements.
19 American Correctional Association, “152nd Congress of Correction.”
20 “Advocates Ask Private Equity Firms to Exit Investments in Prisons and Detention,” Private Equity Stakeholder Project PESP, February 10, 2019, https://pestakeholder.org/news/advocates-ask-private-equity-firms-to-exit-investments-in-prisons-and-detention/.
21 “About Wellpath Care,” Wellpath, accessed September 10, 2022, https://wellpathcare.com/about/.
22 “H.I.G. Capital -,” accessed September 10, 2022, https://higcapital.com/portfolio/company/403.
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org/reports/report-hig-capitals-and-wellpaths-correctional-healthcare-investment-risks/.
24 “U.S. Justice Department Finds That Conditions at the San Luis Obispo County Jail Violate the Constitution,” August 31, 2021, https://www.justice.gov/usao-cdca/pr/us-justice-department-finds-conditions-san-luis-obispo-county-jail-violate-constitution.
25 “Pain And Profits: Sheriffs Hand Off Inmate Care To Private Health Companies,” accessed September 10, 2022, https://www.wbur.org/news/2020/03/24/jailhealth-companies-profit-sheriffs-watch.
26 “Hampstead,” Wellpath, accessed September 19, 2022, https://wellpathcare.com/hampstead/.
27 “H.I.G. Capital - Correct Care Solutions and Correctional Medical Group Companies Join Forces to Deliver Best-in-Class Healthcare,” H.I.G. Capital, October 1,
2018, https://higcapital.com/news/release/correct-care-solutions-and-correctional-medical-group-companies-join-forces-to-deliver-best-in-class-healthcare.
28 “25137930-Gtcr_healthcare_leadershipnewsletter_fall_2017.Pdf,” accessed October 23, 2022, https://www.gtcr.com/wp-content/uploads/2020/06/25137930-gtcr_healthcare_leadershipnewsletter_fall_2017.pdf.
29 “HIG Capital’s and Wellpath’s Correctional Healthcare Investment Risks.”
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https://www.pogo.org/document/2018/10/list-of-federal-lawsuits-filed-against-correct-care-solutions-and-companies-it-has-acquired.

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Private Equity Firms Rebrand Prison Healthcare Companies, But Care Issues Continue

31 “HIG Capital’s and Wellpath’s Correctional Healthcare Investment Risks.”
32 Jonathan Hemingway, “TKC Holdings Completes Upsized $320M Pay-in-Kind-Toggle Term Loan; Terms,” S&P Global Market Intelligence, February 8, 2022,
https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/tkc-holdings-completes-upsized-320m-pay-in-kind-toggle-term-loanterms-68800135.
33 “HIG Capital’s Prison Food and Commissary Store Racket.”
34 Office of Attorney General Maura Healey, “Mental Health Center to Pay $4 Million under AG Settlement for Illegally Billing MassHealth for Unlicensed Patient
Care | Mass.Gov,” Mass.gov, February 8, 2018, https://www.mass.gov/news/mental-health-center-to-pay-4-million-under-ag-settlement-for-illegally-billing-masshealth-for-unlicensed-patient-care.
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Allegations of Unnecessary Drug Testing,” U.S. Department of Justice, April 15, 2020, https://www.justice.gov/usao-edpa/pr/florida-based-laboratory-pain-clinic-and-two-former-executives-agree-pay-41-million.
38 “After Millions in Settlements, H.I.G. Capital Faces Multiple Health Care Fraud Suits,” Private Equity Stakeholder Project PESP, May 12, 2021, https://pestakeholder.org/news/after-millions-in-settlements-h-i-g-capital-faces-multiple-health-care-fraud-suits/.
39 “Private Equity Health Care Acquisitions - October 2020,” Private Equity Stakeholder Project PESP, November 12, 2020, https://pestakeholder.org/news/private-equity-health-care-acquisitions-october-2020-2/.”
40 “Private Equity Health Care Acquisitions – December 2020,” Private Equity Stakeholder Project PESP, January 6, 2021, https://pestakeholder.org/news/private-equity-health-care-acquisitions-december-2020-2/.
41 “H.I.G. Capital’s Companies Mired in Regulatory and Headline Risk,” Private Equity Stakeholder Project PESP, June 21, 2021, https://pestakeholder.org/news/h-ig-capitals-companies-mired-in-regulatory-and-headline-risk/.
42 “HIG Capital’s and Wellpath’s Correctional Healthcare Investment Risks.”
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44 “Jails and Prisons Served by H.I.G. Capital-Owned Wellpath Face COVID-19 Outbreaks, Deaths, Concerns Regarding Staffing Levels.”
45 “U.S. Justice Department Finds That Conditions at the San Luis Obispo County Jail Violate the Constitution.”
46 Civil Rights Division, “Investigation of the San Luis Obispo County Jail” (U.S. Department of Justice, August 31, 2021), https://www.justice.gov/usao-cdca/
press-release/file/1429106/download.
47 “Public Report: Efficacy of Service Delivery Reforms at Bridgewater State Hospital (BSH) and Continuity of Care for BSH Persons Served” (Disability Law Center,
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home/20220516005378/en/Leading-Healthcare-Group-Forms-YesCare-Debuting-New-Vision-and-Leadership.
50 “Flacks Group Acquires Corizon Health Inc., the Premier Correctional Healthcare Company in the U.S.,” Corizon Correctional Healthcare, June 30, 2020, https://
www.corizonhealth.com/Corizon-News/flacks-group-acquires-corizon-health-premier-correctional-healthcare-us.
51 Joel Stinnett, “Brentwood-Based Corizon Health Is Bought by Investment Firm Flacks Group.,” Nashville Business Journal, June 30, 2020, https://www.bizjournals.com/nashville/news/2020/06/30/miami-firm-buys-brentwood-health-care-company.html.
52 U.S. Attorney’s Office, Eastern District of Virginia, “Co-Conspirator of Former Norfolk Sheriff Pleads Guilty to Bribery Scheme,” United States Department of
Justice, October 7, 2021, https://www.justice.gov/usao-edva/pr/co-conspirator-former-norfolk-sheriff-pleads-guilty-bribery-scheme.
53 “Pain And Profits.”
54 “Investments,” Flacks Group, accessed September 19, 2022, https://flacksgroup.com/investments/.
55 “Private Equity-Owned Health Care Providers Could Exacerbate COVID-19 Outbreaks Concerns at Jails, Prisons, and Detention Centers,” Private Equity Stakeholder Project PESP, April 13, 2020, https://pestakeholder.org/news/private-equity-owned-health-care-providers-could-exacerbate-covid-19-outbreaks-concerns-atjails-prisons-and-detention-centers/.
56 Jimmy Jenkins, “Federal Judge Considers Independent Monitor For Prison Health Care Case,” KJZZ, June 19, 2018, https://kjzz.org/content/659949/federal-judge-considers-independent-monitor-prison-health-care-case.
57 “Whistleblower Says Corizon Health Administrators Directed Him To Cheat Arizona Prison Monitors,” KJZZ, January 23, 2019, https://kjzz.org/content/752172/
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58 Rachel Weiner, “Arlington Cuts Ties with Jail Health-Care Provider,” Washington Post, October 25, 2021, https://www.washingtonpost.com/local/legal-issues/
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59 Elizabeth Weill-Greenberg, “Corizon, The Prison Healthcare Giant, Stumbles Again,” The Appeal, February 8, 2019, https://theappeal.org/corizon-the-prisonhealthcare-giant-stumbles-again/.
60 “U.S. Justice Department Finds That Conditions at the San Luis Obispo County Jail Violate the Constitution.”
61 Civil Rights Division, “Investigation of the San Luis Obispo Jail,” 23.

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62 Administrative Office, “County Officials Work with US Department of Justice to Review Jail Services,” County of San Luis Obispo, November 7, 2018, https://
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64 Civil Rights Division, 11.
65 Krista Johnson, “‘Unacceptable’: Rally Urges Changes at Metro Corrections Following 8 Deaths within Months,” The Courier-Journal, accessed September 10,
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66 Johnson.
67 Civil Rights Division, “Investigation of the San Luis Obispo Jail,” 11.
68 Sheriff Michael Main, “Isabella County Sheriff’s Office Medical Inmate Contract” (Isabella County Sheriff’s Office, September 3, 2020).
69 County of Fort Bend, “First Amendment to Inmate Health Services Agreement Pursuant to FBC RFP 17-065” (State of Texas), accessed October 24, 2022, https://
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70 “Muscogee County Jail Signs Contract with New Medical Provider,” accessed September 10, 2022, https://www.wtvm.com/2022/04/04/muscogee-county-jailsigns-contract-with-new-medical-provider/.
71 Civil Rights Division, “Investigation of the San Luis Obispo Jail,” 12.
72 Civil Rights Division, 12.
73 Civil Rights Division, 12.
74 Civil Rights Division, 17.
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76 “Efficacy of Service Delivery Reforms at BSH,” 16.
77 “Efficacy of Service Delivery Reforms at BSH,” 25.
78 “Public Report: Efficacy of Service Delivery Reforms at Bridgewater State Hospital (BSH) and Continuity of Care for BSH Persons Served” (Disability Law Center,
Massachusetts, July 2022), 14, https://www.dlc-ma.org/wp-content/uploads/2022/07/DLC-BSH-Report-July-2022-Final.pdf.
79 “Norfolk City Jail Psychiatrist Resigns amid ‘out of Control’ Prescription Drug Abuse from Jail-Issued Medications,” accessed September 10, 2022, https://news.
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80 Civil Rights Division, “Investigation of the San Luis Obispo Jail,” 12.
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82 Civil Rights Division, 20.
83 Justice Department report, p. 21.
84 Justice Department report, pp. 21-22.
85 Mardi Link, “Court Testimony Exposes Wellpath’s Jail Medication Policies,” Traverse City Record-Eagle, July 16, 2021, https://www.record-eagle.com/news/
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86 U.S. District Court, Michigan Western, “Patson V. Grand Traverse, County Of Et Al,” accessed October 24, 2022, https://advance.lexis.com/document/documentlink?crid=22cb88b0-f66e-4a11-ad3f-be1052166405&pdpermalink=79cfbdce-8d9b-43fc-a905-6ac38b908243&pdmfid=1519360&pdisurlapi=true.
87 Civil Rights Division, “Investigation of the San Luis Obispo Jail,” 18.
88 Civil Rights Division, 14–15.
89 Civil Rights Division, 19.
90 Civil Rights Division, 28.
91 “Norfolk City Jail Psychiatrist Resigns amid ‘out of Control’ Prescription Drug Abuse from Jail-Issued Medications.”
92 “More Wellpath Employees Join NUHW,” National Union of Healthcare Workers, accessed September 10, 2022, https://nuhw.org/more-wellpath-employeesjoin-nuhw/.
93 “NUHW Members Successfully Lobby Lawmakers to Hold Wellpath Accountable,” National Union of Healthcare Workers, accessed September 10, 2022, https://
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94 “‘It’s Scary in There’: Delayed, Denied Medical Care a Chronic Issue at Sonoma County Jail,” Santa Rosa Press Democrat, July 8, 2022, https://www.pressdemocrat.com/article/news/its-scary-in-there-delayed-and-denied-medical-care-a-chronic-issue-at-s/.
95 Jared Bennett, “Experts: Inadequate Mental Health Resources, Policies Contribute to Louisville Jail Suicides,” Kentucky Center for Investigative Reporting,
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96 Michael Levenson and Vimal Patel, “Grand Jury Indicts Nurse, but Not Jail Officers, in Death of Black Man,” The New York Times, April 6, 2022, sec. U.S., https://
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97 Hannah Sarisohn and Claire Colbert CNN, “North Carolina Grand Jury Indicts Nurse but Not Corrections Officers in Death of Jailed Black Man,” CNN, accessed
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98 “Jails and Prisons Served by H.I.G. Capital-Owned Wellpath Face COVID-19 Outbreaks, Deaths, Concerns Regarding Staffing Levels.”
99 Anna Stitt, “COVID-19 Inside Arkansas Prisons: The Death of Derick Coley,” KUAR Little Rock Public Radio, June 10, 2020, https://www.ualrpublicradio.org/
local-regional-news/2020-06-09/covid-19-inside-arkansas-prisons-the-death-of-derick-coley.
100 “US Prisons in a Hole as Pandemic Slows Inmate Flow,” Financial Times, July 6, 2020.

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101 Jessica Jaglois, “‘Inadequate and Harmful:’ Inspection Report Finds Issues with COVID-19 Response in Shelby Co. Jail,” https://www.actionnews5.com, accessed September 10, 2022, https://www.actionnews5.com/2020/07/01/inadequate-harmful-inspection-report-finds-issues-with-covid-response-shelby-co-jail/.”
102 “AFT, Worth Rises, Color of Change, PESP Call on Private Equity Firms to Halt Prison and Detention Companies’ Predatory Practices during the COVID-19 Pandemic.
103 H.I.G. Capital, “Letter to Worth Rises, PESP, Color of Change, and AFT,” April 13, 2020, https://pestakeholder.org/wp-content/uploads/2020/06/H.I.G.-Letterto-Tylek-4.13.20.pdf.
104 Worth Rises, Color of Change, and Private Equity Stakeholder Project, “Response Letter to H.I.G. Capital,” April 23, 2020.
105 Kathryn Varn, “Coronavirus Kills One, Infects Another, in Florida Sex Offender Treatment Center,” Tampa Bay Times, accessed September 24, 2022, https://
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106 Mike Pescaro, “Mass. Inmate Dies While Being Treated for Coronavirus – NBC Boston,” NBC Boston, April 3, 2020, https://www.nbcboston.com/news/coronavirus/mass-inmate-dies-while-being-treated-for-coronavirus/2101779/.
107 Monsy Alvarado, “Two Hudson County Jail Nurses Die from Coronavirus Complications,” North Jersey, April 6, 2020, https://www.northjersey.com/story/
news/hudson/2020/04/06/two-hudson-county-jail-nurses-die-coronavirus-complications/2954964001/.
108 Rudy Harper, “COVID-19 Claiming the Lives of Doctors Who Treat Inmates,” WXYZ Detroit, April 16, 2020, https://www.wxyz.com/news/coronavirus/covid-19claiming-the-lives-of-doctors-who-treat-inmates.
109 Taylor Feingold, “OPSO Says 46 Employees Have Tested Positive for COVID-19 | WGNO,” WGNO ABC, April 15, 2020, https://wgno.com/news/health/coronavirus/orleans-parish-sheriffs-office-update-regarding-covid-19-precautions-and-activities/.
110 Worth Rises, Color of Change, and Private Equity Stakeholder Project, “Response Letter to H.I.G. Capital,” April 23, 2020.
111 Jason Clayworth, “A Polk County Jail Whistleblower’s $65K Settlement,” Axios, November 30, 2021, https://www.axios.com/local/des-moines/2021/11/30/
polk-county-jail-whistleblower-covid-settlement-michaela-jens.
112 Philip Joens and Tyler J. Davis, “89 Inmates, 9 Staff Members at Polk County Jail Have Tested Positive for COVID-19,” The Des Moines Register, May 22, 2020,
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113 Annmarie Timmins, “After Assurances from AG, Council Approves Wellpath Contract for Hampstead Hospital,” New Hampshire Bulletin, May 4, 2022, https://
newhampshirebulletin.com/briefs/after-assurances-from-ag-council-approves-wellpath-contract-for-hampstead-hospital/.
114 Annmarie Timmins, “Organizations Call on Executive Council to Reconsider Wellpath Contract for Hampstead Hospital,” New Hampshire Bulletin, May 3, 2022,
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115 Disability Rights Center - NH et al., “NH Department for Health and Human Services’ Request to Enter into Sole Source Contract with Wellpath REcovery
Solutions to Operate a Children’s Psychiatric Hospital at Hampstead Hospital,” May 3, 2022, https://newhampshirebulletin.com/wp-content/uploads/2022/05/
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116 Annmarie Timmins, “Councilors, Advocates Raise Concerns about Company Chosen to Provide Care at Hampstead Hospital,” New Hampshire Bulletin, April
27, 2022, https://newhampshirebulletin.com/2022/04/27/councilors-advocates-raise-concerns-about-company-chosen-to-provide-care-at-hampstead-hospital/.
117 Timmins, “After Assurances from AG, Council Approves Wellpath Contract for Hampstead Hospital.”
118 “Alaska Psychiatric Institute,” Alaska Department of Family and Community Services, accessed September 10, 2022, https://dfcs.alaska.gov/api/Pages/default.
aspx.
119 Timmins, “After Assurances from AG, Council Approves Wellpath Contract for Hampstead Hospital.”
120 Michelle Theriault Boots, “After 18 Months and $12.5 Million, Wellpath Quietly Exits API,” Anchorage Daily News, August 23, 2020, https://www.adn.com/
alaska-news/2020/08/23/in-june-wellpath-quietly-exited-api-a-year-and-a-half-after-it-fell-into-crisis-how-the-alaskas-only-psychiatric-hospital-doing/.
121 Andrew Kitchenman, “State Ends Wellpath Contract to Run Psychiatric Institute, Could Open up Contract for Bids,” Alaska Public Media, April 24, 2019,
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122 Michelle Theriault Boots, “After 18 Months and $12.5 Million, Wellpath Quietly Exits API.”
123 Disability Rights Center - NH et al., “NH Department for Health and Human Services’ Request to Enter into Sole Source Contract,” May 3, 2022.
124 Carrie Hodgin, “Wellpath Community Care Centers of North Carolina Opens Winston-Salem Location,” WXII NBC 12, April 13, 2021, https://www.wxii12.com/
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125 Lesley Kolb, “Wellpath Opens Second Community Care Center in North Carolina to Treat Substance Use,” Wellpath, May 10, 2022, https://wellpathcare.
com/2022/05/10/wellpath-opens-second-community-care-center-in-north-carolina-to-treat-substance-use/.
126 “Newport News Jail Gets a Partner for Addiction Treatment Effort,” Daily Press, accessed September 10, 2022, https://www.dailypress.com/news/health/
dp-nw-wellpath-20220616-uuedhapndbdwrmdnt4erbi63bu-story.html.
127 “HIG Capital’s and Wellpath’s Correctional Healthcare Investment Risks.”
128 Joel Stinnett, “Former Correct Care Solutions CEO Gerard ‘Jerry’ Boyle Sentenced to Three Years in Prison - Nashville Business Journal,” Nashville Business
Journal, February 28, 2022, https://www.bizjournals.com/nashville/news/2022/02/28/jerry-boyle-sentenced-to-three-years-in-prison.html.
129 Scott Daugherty, “Executive Charged with Bribing Ex-Norfolk Sheriff for over a Decade Has His Travel Restricted — to Four States,” The Virginian-Pilot, October
28, 2019, https://www.pilotonline.com/news/crime/vp-nw-gerard-boyle-initial-appearamce-20191028-ahnnl25yrnaufi6hgsbpkdy5r4-story.html.
130 Joel Stinnett, “Former Correct Care Solutions CEO Gerard ‘Jerry’ Boyle Sentenced to Three Years in Prison - Nashville Business Journal.”
131 “Pain And Profits.”
132 Rudi Keller, Missouri Independent November 3, and 2021, “Trial Set to Begin in Dispute over $1.4 Billion Missouri Prison Health Care Contract • Missouri
Independent,” Missouri Independent (blog), November 3, 2021, https://missouriindependent.com/2021/11/03/trial-set-to-begin-in-dispute-over-1-4-billion-missouri-prison-health-care-contract/.
133 Emerson Wigand, “Controversial Provider Takes over Health Care for Mich. Prisoners,” The Detroit News, October 2, 2021, https://www.detroitnews.com/
story/news/local/michigan/2021/10/03/controversial-provider-takes-over-health-care-mich-prisoners/5956859001/.

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134 Sheri Fink, “Do CIA Cables Show Doctors Monitoring Torture?,” ProPublica, May 28, 2009, https://www.propublica.org/article/do-cia-cables-show-doctors-monitoring-torture-528.
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136 Emerson Wigand.
137 Sarah Breske, “Alachua County Sheriff Implements New Jail Policies Following 2021 Death of Inmate’s Newborn,” WUFT News, May 12, 2022, https://www.
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138 Kathleen E. Carey, “Delaware County Retakes Control of Operations at George W. Hill Correctional Facility,” Delco Times, April 7, 2022, https://www.delcotimes.com/2022/04/07/delco-retakes-control-of-operations-at-george-w-hill-correctional-facility.
139 “Minnesota Counties Cut Ties with Inmate Health Care Provider after Its Owner’s License Is Suspended,” accessed September 14, 2022, https://www.
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141 “New Contract Promises Improved Mental Health Care at Jails,” accessed September 14, 2022, https://www.vcstar.com/story/news/2022/06/26/contract-promises-improved-mental-health-care-jails-ventura-county/7678721001/.
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145 “Pain And Profits.”
146 U.S. Attorney’s Office, Eastern District of Virginia, “Co-Conspirator of Former Norfolk Sheriff Pleads Guilty to Bribery Scheme.”
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150 Matt Sledge, “Huge, Controversial Contract for New Orleans Jail Health Care Undecided,” NOLA.com, March 15, 2022, https://www.nola.com/news/politics/
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151 “Vera New Orleans on the Election of Susan Hutson as Orleans Parish…,” Vera Institute of Justice, accessed September 20, 2022, https://www.vera.org/
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154 Steven Melendez, “The Prison That Care Forgot,” Antigravity Magazine, November 2019, https://antigravitymagazine.com/feature/the-prison-that-care-forgot/.
155 Matt Sledge, “Huge, Controversial Contract for New Orleans Jail Health Care Undecided.”
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159 Exsar Arguello, “County Contracts Medical Services for Juvenile Center,” Hays Free Press, July 17, 2019, https://haysfreepress.com/2019/07/17/county-contracts-medical-services-for-juvenile-center/.
160 Zara Flores, “Hays County Commissioners Approve New Contract with Wellpath for Health Services at Jail, Juvenile Detention Center,” impact, April 27, 2022,
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161 “WELLPATH PAC - Committee Overview.”
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167 Andrew Schneider and Katie Watkins, “GOP Candidate Troy Nehls Wins TX-22 In A Closely-Watched Race,” Houston Public Media, November 4, 2020, https://
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168 Barbara Sprunt, “Here Are The Republicans Who Objected To The Electoral College Count,” NPR, January 7, 2021, https://www.npr.org/sections/insurrection-at-the-capitol/2021/01/07/954380156/here-are-the-republicans-who-objected-to-the-electoral-college-count.
169 “Joe Rogan Experience #1757 - Dr. Robert Malone, MD Full Transcript,” Nehls, accessed September 20, 2022, https://nehls-admin.house.indigov.us/posts/
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170 County of Fort Bend, “Fort Bend Agreement Amendment.”
171 “Wellpath Jobs - Mental Health Professional At Fort Bend County Jail Jobs,” accessed September 20, 2022, https://wellpath.dejobs.org/mental-health-professional-at-fort-bend-county-jail/jobs-in/fort-bend-county-jail/new-jobs/?utm_medium=NLX&utm_campaign=US.jobs&utm_source=US.jobs-DE&vs=19.

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172 “WELLPATH PAC - Committee Overview.”
173 Andy Pierrotti, “DeKalb County Inmate Dies, Medical Staff Blamed by Officers,” 11Alive.com, November 11, 2021, https://www.11alive.com/article/news/
investigations/the-reveal/medical-staff-did-not-take-inmates-complaints-seriously/85-b3600969-f619-4113-b603-b2719a3a6731.
174 Tyler Estep, “Accusations Fly in Unusual Runoff Election for DeKalb Sheriff,” The Atlanta Journal-Constitution, July 17, 2020, sec. Local News.
175 Andy Pierrotti, “DeKalb County Inmate Dies, Medical Staff Blamed by Officers.”
176 Estep, “Accusations Fly in Unusual Runoff Election for DeKalb Sheriff.”
177

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178 “WELLPATH PAC - Committee Overview.”
179 Chris Dowd, “Sheriff Ira Edwards Has Accepted More than $9,000 from Prison Industry Contractors for Re-Election Campaign,” Athens Politics Nerd, April 16,
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180 “WELLPATH PAC - Committee Overview.”
181 Ben Brasch, “Fulton Commissioners OK Jail Contract, Field Big Asks from Sheriff,” The Atlanta Journal-Constitution, September 21, 2022.
182 Stephanie Rebman, “NaphCare Lands Contract for Health Services for Fulton County Jail,” Birmingham Business Journal, January 22, 2018, https://www.
bizjournals.com/birmingham/news/2018/01/22/birmingham-company-lands-contract-for-health.html.
183 Brasch, “Fulton Commissioners OK Jail Contract, Field Big Asks from Sheriff.”
184 Kristal Dixon, “Cobb County Jail Offers Mental Health Care to Detainees,” Axios, November 17, 2021, https://www.axios.com/local/atlanta/2021/11/17/georgia-cobb-jail-mental-health-care-detainees.
185 Larry Felton Johnson, “24/7 Mental Health Services for Detainees Takes Effect at Cobb Adult Detention Center,” Cobb County Courier, November 15, 2021,
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186 “Lowndes County Jail Partners with Wellpath,” accessed September 14, 2022, https://www.wtxl.com/news/local-news/lowndes-county-jail-partners-with-wellpath.
187 “Georgia DOC | Wellpath,” accessed September 19, 2022, https://wellpath.recruiting.com/georgia-doc.
188 “WELLPATH PAC - Committee Overview.” FEC.Gov, https://www.fec.gov/data/committee/C00568881/. Accessed 10 Sept. 2022.
189 Johnson, “‘Unacceptable.’”
190 Susan Heavey and Julia Edwards, “U.S. to Phase out Federal Use of Privately-Operated Prisons,” Reuters, August 18, 2016, https://www.reuters.com/article/
usa-prisions/u-s-to-phase-out-federal-use-of-privately-operated-prisons-idUSL1N1AZ1C2.
191 Jason Szep et al., “U.S. Jails Are Outsourcing Medical Care.”
192 “Advocates Ask Private Equity Firms to Exit Investments in Prisons and Detention.”
193 “Private Equity Health Care Acquisitions – December 2020.
194 “New Contract Promises Improved Mental Health Care at Jails.”
195 Civil Rights Division, “Investigation of the San Luis Obispo Jail,” 23.

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