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The Accreditation Con - a Broken Prison and Detention Facility Accreditation System That Puts Profits Over People, December 2020

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THE ACCREDITATION CON:

A Broken Prison and Detention
Facility Accreditation System
That Puts Profits Over People

Prepared by the Office of Senator Elizabeth Warren
December 2020

I.

Executive Summary

The criminal legal and immigration systems in the United States are broken. The criminal system
incarcerates too many people, locks them away for too long, and fails to provide the formerly
incarcerated with the necessary tools and support to successfully return to their communities
upon release. The immigration system is similarly in shambles. Instead of providing refuge to
vulnerable immigrants fleeing poverty and violence, including children and families, the Trump
Administration is turning them away or throwing them into unsanitary and overcrowded facilities
with little to no standards.
There is one group that benefits immensely from these flawed systems: private prison
companies. Federal, state, and local taxpayers spend billions of dollars propping up the private
prison industry that profits off the backs of prisoners and detainees. These companies are driven
by incentives that reward locking up more people in worse conditions, prioritizing their bottom
line over the safety and well-being of incarcerated and detained individuals, corrections and
immigration professionals, and communities.
Report after report has identified the problems with the private prison and detention facilities.
Privately-run facilities often have worse conditions than government-run facilities, and, due in
part to the large sums they pour into lobbying campaigns, oversight of private prisons and
detention facilities has been so weak that, in many cases, it appears to be nonexistent. As a result,
private prisons generally escape accountability for flagrant health and safety violations.
Despite these problems, private prison companies insist that they are well-regulated and meet
high standards.1 In particular, they point to the accreditation of their facilities as evidence that
their facilities meet or exceed relevant health and safety standards.
In order to better understand the accreditation process, and assess private prison companies’
claims that accreditation provides a guarantee of adequate appropriate conditions in their
facilities, Senator Elizabeth Warren opened an investigation of the American Correctional
Association (ACA), the nation’s largest accreditor of prisons and immigration detention
facilities, and its relationship with the three largest private prison companies that receive ACA
accreditation: CoreCivic (formerly Corrections Corporation of America), GEO Group (GEO),
and Management & Training Corporation (MTC). This report details the findings of that
investigation. It reveals that the ACA’s private prison accreditation system is riddled with
conflicts of interest, lacks transparency, and is subject to zero accountability even though
millions in taxpayer dollars to flow to the ACA and private prison companies. These problems
put the health and wellbeing of incarcerated and detained individuals, the staff and employees
who work in those facilities, and our communities at risk.2

1

Exhibit C: Response from Management & Training Corporation; Exhibit D: Response from GEO Group.
For example, some of the worst COVID-19 outbreaks in the country happened in communities with private prison,
where incarcerated individuals became ill, and then workers, incarcerated individuals who were released, and
visitors were exposed to the virus due to unsanitary conditions, spreading it into the community beyond. CBS News,
“CDC report details extent of coronavirus outbreaks in U.S. jails and prisons,” Justin Carissimo, May 6, 2020,
https://www.cbsnews.com/news/coronavirus-outbreaks-jails-prisons-cdc-report-covid-19/.

2

1

Key findings include:
•

The ACA’s dual role as an advocate for the private prison industry and the
organization responsible for overseeing conditions at facilities run by private prison
companies creates an irreconcilable conflict of interest. The ACA advocates for and
lobbies on behalf of private prisons, supporting the prison-industrial complex and acting
as the “the voice for corrections.”3 At the same time, the ACA receives a significant
portion of its revenue by providing accreditation and other services to the same
companies on whose behalf it advocates. Although the ACA purports to rigorously
evaluate conditions at prison and detention facilities in its accreditation process, it relies
on the same companies it accredits for a huge portion of its revenue.

•

The ACA accreditation process is a rubber stamp. It is almost impossible for a
facility to fail an ACA audit. The ACA grants facilities three months’ advance notice of
audits; provides facilities with “technical assistance,” including “standards checklists”
and an “audit readiness evaluation” that help a facility know when to schedule its audit
and what to expect; and, at a facility’s request, will conduct a “mock audit” to help the
facility prepare.4 If problems persist despite these ample opportunities to correct—or
hide—them, the ACA Commissioners can ignore audit finding altogether and allow a
facility that failed its audit to receive accreditation, rendering these standards toothless.

•

Serious problems persist at ACA-accredited facilities. Neither the ACA nor the
private prison companies Senator Warren’s office contacted could provide a single,
recent example of a prison or detention facility that had been denied accreditation – even
when the facility had a public record of safety, health, or security violations.5 Prisons
that have been the sites of multiple riots, failed to provide safe and adequate food or
medical care to incarcerated individuals, or, in one instance, was described by a federal
judge as “paint[ing] a picture of such horror as should be unrealized anywhere in the
civilized world,” have all been accredited and reaccredited by the ACA.6 The ACA has
also accredited facilities that have proven unprepared to respond to the coronavirus
pandemic 2019 (COVID-19), including the Elkton Federal Correctional Institution, an

3

ACA, “The History of the American Correctional Association,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/About_Us/Our_History/ACA_Member/AboutUs/AboutUs_H
ome.aspx?hkey=0c9cb058-e3d5-4bb0-ba7c-be29f9b34380.
4
American Correctional Association, “Consultant Manual,” 2012,
http://www.aca.org/aca_prod_imis/Docs/Standards%20and%20Accreditation/ACA%20Consultant%20Manual%202
012.pdf.
5
The ACA provided information revealing that the last prison or detention center to have been denied accreditation
was in March 2014. Prior to that, only three facilities had been rejected, according to the ACA, in November 2012,
May 2010, and May 2007. Exhibit A: Response to Sen. Warren from the American Correctional Association;
Exhibit B: Information provided on a call between ACA Leadership and Sen. Warren’s staff, August 2019.
6
ACLU, “A Picture of Such Horror as Should Be Unrealized Anywhere in the Civilized World,” Margaret Winter,
Mar. 29, 2012, https://www.aclu.org/blog/smart-justice/mass-incarceration/picture-such-horror-should-beunrealized-anywhere-civilized.

2

ACA-accredited facility where there were “people walking around looking like the living
dead,” and others with major outbreaks in Yazoo City, Danbury, Glenville, Fort Worth,
Coleman, La Tuna, Tallahassee, and Fairton.7
•

The ACA failed to adapt to COVID-19: Rather than shifting its oversight of prisons
and detention facilities to address major health and safety concerns during COVID-19,
the ACA has “greatly reduced its auditing of correctional facilities.”8 The ACA has also
refused to adapt its standards to incorporate new, COVID-19-era standards, claiming that
because it couldn’t have its yearly conference, it is not able to adopt new standards.9

Private accreditation of federal, state, local, and private prisons and detention facilities is
ineffective, dangerous, and wasteful, and provides no indication of quality. The federal
government should not outsource oversight of its prisons and detention facilities, nor should it
pay for or rely on external organizations’ accreditations. The Department of Justice (DOJ) and
the Department of Homeland Security (DHS) should immediately stop relying on the ACA to
accredit its facilities and establish a rigorous, independent, and transparent process for oversight
and assurance of quality at these facilities.

7

The Marshall Project, “‘I Begged Them To Let Me Die’: How Federal Prisons Became Coronavirus Death Traps.”
Keri Blakinger and Keegan Hamilton,” Jun. 18, 2020, https://www.themarshallproject.org/2020/06/18/i-beggedthem-to-let-me-die-how-federal-prisons-became-coronavirus-death-traps.
8
Exhibit I: Letter from ACA to Sen. Warren, Jul. 29, 2020.
9
Exhibit I: Letter from ACA to Sen. Warren, Jul. 29, 2020.

3

II.

Introduction: The Role of Accreditation in the Private Prison Industry

The ACA is the primary accreditor for federal, state, and local private prisons and detention
facilities.10 According to the ACA, the purpose of accreditation is “to improve facility operations
through adherence to clear standards relevant to all areas/operations of the facility, including
safety, security, order, inmate care, programs, justice, and administration.”11 As of June 2020,
the ACA has accredited over 1,500 facilities in at least 49 states, the District of Columbia, and
Puerto Rico.12
As part of the accreditation process, the ACA audits public and private prisons and detention
facilities, providing them with a stamp of approval and all “the benefits accruing from
accreditation.” For for-profit prison and detention companies, the main benefit of accreditation is
the access it provides to sizeable government contracts. 13 Accreditation is one of the key
indicators that federal, state, and local governments rely on to show that the prisons and
detention centers with which they contract are of adequate quality, and it makes those facilities
and the private companies that own and operate them eligible to compete for lucrative federal,
state, and local government contracts.
For example, the U.S. Bureau of Prisons (BOP) requires ACA accreditation for all companies
with which it contracts to operate private prisons.14 As of December 2015, the BOP contracted
with 14 facilities to hold over 22,000 individuals, approximately 12% of the federal prison
population.15 All facilities were operated by CoreCivic, GEO, or MTC.16 In addition to the
federal government, according to the ACA’s Executive Director James Gondles, all 50 states
require accreditation as part of their contracting process with private prisons.17
Those sizeable contracts are often claimed by one of three private prison companies: CoreCivic,
GEO, and MTC, which collectively control three quarters of the private correctional and
10

ACA, “The History of the American Correctional Association,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/About_Us/Our_History/ACA_Member/AboutUs/AboutUs_H
ome.aspx?hkey=0c9cb058-e3d5-4bb0-ba7c-be29f9b34380; Exhibit A: Response to Sen. Warren from the American
Correctional Association; Exhibit B: Information provided on a call between ACA Leadership and Sen. Warren’s
staff, August 2019.
11
ACA, “The History of Standards and Accreditation,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards___Accreditation/About_Us/ACA_Member/Standar
ds_and_Accreditation/SAC_AboutUs.aspx?hkey=bdf577fe-be9e-4c22-aa60-dc30dfa3adcb
12
ACA, “Accredited Facilities,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards_and_Accreditation/SAC_AccFacHome.aspx?Websi
teKey=139f6b09-e150-4c56-9c66-284b92f21e51&hkey=f53cf206-2285-490e-98b7-66b5ecf4927a&CCO=2;
Exhibit B.
13
Exhibit E: From multiple contracts written by the ACA and signed by a private prison owner and operator.
14
Federal Bureau of Prisons, “Contract Prisons,” https://www.bop.gov/about/facilities/contract_facilities.jsp
15
Department of Justice Office of the Inspector General, “Review of the Federal Bureau of Prisons’ Monitoring of
Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf. The number of contract prisons has
since reduced to 12. Bureau of Prisons, “Contract Prisons,”
https://www.bop.gov/about/facilities/contract_facilities.jsp.
16
Department of Justice Office of the Inspector General, “Review of the Federal Bureau of Prisons’ Monitoring of
Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf.
17
Exhibit B: Information provided on a call between ACA Leadership and Sen. Warren’s staff, August 2019.

4

detention industry and generate millions in profits each year. GEO manages or owns
approximately 135 correctional and detention facilities worldwide and generated $2.3 billion in
revenue and almost $145 million in net profits in 2018.18 As of December 2018, CoreCivic
owned or operated over 75 correctional and detention facilities and generated almost $1.8 billion
in revenue and close to $160 million in profits in 2018.19 MTC manages close to two dozen
correctional facilities in the United States.20
ACA accreditation is also a central component in the immigration detention system. While
Immigration and Customs Enforcement (ICE) has its own detention standards, the agency
“incorporate[s] many ACA practices and requirements… into ICE detention standards for single
adults.”21 Furthermore, although ICE does not require ACA accreditation, it does “encourage” it,
helping to steer additional money into the ACA’s pockets through private contract facilities.22
Private prison companies use accreditation both to gain access to hefty government contracts and
as a shield against criticism that their facilities lack important safeguards. In response to
complaints and public reports about poor conditions at their facilities, CoreCivic, GEO, and
MTC responded by pointing to the facilities’ ACA accreditation scores.23 For example:
•

•

In 2015, prisoners at a MTC-operated BOP facility protested over “[the] lack of medical
care… [and] awful conditions like overcrowding, overflowing toilets, and disgusting
food.”24 MTC responded to questions about the incident by pointing to its ACA
accreditation as evidence that medical services were acceptable, claiming that the ACA
gave the facility “a score of 100 percent on mandatory standards and 99.6 percent on nonmandatory standards.”25
Responding to reports of miserable conditions in a Texas GEO facility where the Idaho
Department of Correction sent hundreds of incarcerated individuals—including prisoners
forced to “remain[] inside in cramped conditions for two months without being allowed
outside,” a spokesman for the Idaho Department of Correction said, “it should be noted
that there were enough indoor recreation areas available in the facility so that it met all

18

Securities and Exchange Commission, “Form 10-K – The GEO Group, Inc.,” FY2018,
https://www.sec.gov/Archives/edgar/data/923796/000119312519050054/d663410d10k.htm.
19
Securities and Exchange Commission, “Form 10-K – CoreCivic, Inc.,” FY2018,
https://www.sec.gov/Archives/edgar/data/1070985/000156459019004033/cxw-10k_20181231.htm.
20
MTC, “Corrections,” August 2019, https://www.mtctrains.com/wpcontent/uploads/2019/08/Corrections_Division_Overview.pdf.
21
Exhibit F: Response from ICE to Senator Warren.
22
Exhibit F: Response from ICE to Senator Warren.
23
Idaho Press, “Leaking roofs, abscessed teeth, little time outside: Idaho prisoners describe Texas facility,” Tommy
Simmons and George Prentice, Dec. 1, 2018, https://www.idahopress.com/news/local/leaking-roofs-abscessed-teethlittle-time-outside-idaho-prisoners-describe/article_7acb74bd-80af-5c58-a929-fc345080f8cc.html; Prison Legal
News, “Betraying the Promise of Accreditation: Quis Custodiet Ipsos Custodes,” Gary Hunter, Jul. 6, 2016,
https://www.prisonlegalnews.org/news/2016/jul/6/betraying-promise-accreditation-quis-custodiet-ipsos-custodes/.
24
Vice, “Anatomy of a Texas Prison Uprising,” John Washington, Jun. 24, 2015,
https://www.vice.com/en_au/article/jmamdx/anatomy-of-a-texas-prison-uprising-624.
25
Prison Legal News, “Betraying the Promise of Accreditation: Quis Custodiet Ipsos Custodes,” Gary Hunter, Jul.
6, 2016, https://www.prisonlegalnews.org/news/2016/jul/6/betraying-promise-accreditation-quis-custodiet-ipsoscustodes/.

5

•

III.

[ACA] and Texas state standards even before the outside recreation areas were
created.”26
In response to a CoreCivic shareholder proposal for regular third-party audits of
CoreCivic facilities, CoreCivic argued that such audits were unnecessary since “nearly all
of the Company’s secure correctional and detention facilities are accredited by the
[ACA].”27
Findings: The ACA Accreditation Process Fails to Ensure that Prisons and
Immigration Detention Facilities Meet Critical Health and Safety Standards

Senator Warren’s investigation reveals that the ACA’s accreditation system for prisons and
detention facilities lacks transparency and accountability and is littered with conflicts of interest.
This flawed system allows the major private prison operators to bankroll the prison trade group
while benefitting from the ACA’s stamp of legitimacy on their facilities – regardless of the
conditions in those facilities.
1. The ACA Acts as Both A Representative of Private Prisons and A Guarantor of
Their Quality, Presenting an Irreconcilable Conflict of Interest
a. Financial Conflicts of Interest
The ACA has two primary and conflicting functions: accreditor and trade association. As an
accreditor, the ACA is responsible for providing private prisons and detention facilities with a
key stamp of approval that is often required by their contracts with federal, state, and local
governments. At the same time, the ACA serves as the primary lobbying group for private
prisons – acting as the “the voice for corrections” – and relies on the fees paid by the corrections
facilities it accredits for a large chunk of its revenue.28
Documents obtained as part of Senator Warren’s investigation reveal that, from 2014 to 2018,
the ACA received over $48 million in revenue.29 Almost half— $21.9 million—came from
accreditation fees and payments,30 13% ($2.79 million) of which came from just three private
prison operators: CoreCivic, GEO, and MTC.31 Those documents also reveal that the ACA rakes
in millions in accreditation fees from private prisons and detention facilities and federal, state,
and local governments.32
26

Idaho Press, “Leaking roofs, abscessed teeth, little time outside: Idaho prisoners describe Texas facility,” Tommy
Simmons and George Prentice, Dec. 1, 2018, https://www.idahopress.com/news/local/leaking-roofs-abscessed-teethlittle-time-outside-idaho-prisoners-describe/article_7acb74bd-80af-5c58-a929-fc345080f8cc.html.
27
Securities and Exchange Commission, “Response to Shareholder Proposal,” Feb. 13, 2017,
https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/2017/alexfriedmanncorecivic021317-14a8.pdf.
28
ACA, “Vision Statement,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/About_Us/Our_Mission/ACA_Member/AboutUs/MissionStat
ement_home.aspx?hkey=7a39e689-8de2-47d4-a7d4-93cce9442142.
29
Exhibit A.
30
Exhibit A.
31
Exhibit A.
32
Exhibit A; Exhibit F. The ACA also received funding from foreign governments for accreditation and training
outside of the U.S. In fact, two of its top clients are the Kingdom of Saudi Arabia and the United Arab Emirates,

6

•
•
•
•

From 2014 to 2018, the BOP paid the ACA almost $1.9 million for accreditation of
public, government-run facilities.33
Through contracts with the U.S. Army, the ACA has been paid over $150,000 for the
accreditation of domestic facilities and confinement facilities in South Korea and
Germany.34
The ACA provides accreditation for at least three U.S. Navy facilities in California,
South Carolina, and Virginia, as well as two U.S. Marine Corps facilities in Okinawa,
Japan.35
From 2014 to 2018, the Texas Department of Criminal Justice paid the ACA $1.75
million and the Florida Department of Corrections paid nearly $900,000 for
accreditation.36

Each accreditation expires after three years, at which point facility operators must pay again for
re-accreditation.37 MTC paid the ACA between $12,150 and $18,225 each for 11 accreditations,
$146,300 total, in 2018.38 MTC also inexplicably paid an additional $8,100 for the ACA to
accredit its corporate office, despite the facility being purely administrative and containing zero
detainees.39 Neither CoreCivic nor GEO disclosed the exact amount that they had paid the ACA
for accreditation, but ACA records indicate that from 2014 through 2018, the companies were
two of the five top-paying clients for accreditation.40 In that 5-year span, CoreCivic paid the
ACA $867,580 for accreditation alone, while GEO spent $1,429,599 on accreditation.41
But in addition to serving as accreditor, the ACA is a major trade association and lobbyist for the
corrections industry. In that role, the ACA has lobbied Congress on criminal justice, corrections,
and detention-related issues,42 including mentally ill offenders, the Second Chance Act, and
which respectively paid the ACA over $300,000 and $150,000 combined in the last five years. Exhibit A and call.
Under the Merida Initiative, a partnership between the U.S. and Mexican governments to fight organized crime and
violence, which has cost taxpayers billions of dollars, the ACA receives funding to accredit Mexican detention
facilities. Exhibit B; Department of State, “Merida Initiative,” https://2009-2017.state.gov/j/inl/merida//index.htm.
33
Exhibit A; Exhibit B
34
Exhibit A; Exhibit B.
35
Exhibit B.
36
Exhibit A.
37
ACA, “Frequently Asked Questions,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards___Accreditation/About_Us/FAQs/ACA_Member/S
tandards_and_Accreditation/Standards__FAQ.aspx?hkey=b1dbaa4b-91ef-4922-8e7d281f012963ce#:~:text=Reaccreditation%20is%20a%20continuation%20of,audit%20and%20another%20accreditatio
n%20hearing.
38
Twelve of these were re-accreditations for facilities that had received initial approval in the past. Exhibit C.
39
Id. and Exhibit H: phone call with MTC representative at 2:22 on September 23, 2019.
40
Exhibit A, page 12 of 17.
41
Id.
42
See e.g., https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=D7C19E49-9B12-48B4-B783DA433C77DF8D&filingTypeID=60; see e.g.,
https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=90C1F6E4-C36F-4295-948212D9EE23736F&filingTypeID=60; see e.g.,
https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=D0746609-2234-45CB-845B8A9E7D1B91A8&filingTypeID=78
.

7

justice reinvestment.43 Since 2000, the ACA has spent over $1 million lobbying Congress.44 The
ACA has not disclosed specific federal lobbying activities since 2011, but evidence suggests it
lobbied as recently as 2018.45
The ACA’s role as both an advocate for the private prison industry and an oversight body for
that same industry presents an irreconcilable conflict of interest. This conflict is exacerbated by
the additional financial support the ACA receives from private prison and detention companies
unrelated to accreditation. From 2014 through 2018, for example, the ACA received $12.6
million in revenue – 26% of its total revenue – from its annual conferences.46 Many private
prison companies provide funding and sponsorship for these conferences, including the three
largest private facility operators. For example, at the ACA’s 2018 annual conference, CoreCivic
and GEO sponsored the ticket-only E.R. Cass Banquet, an event open to sponsors willing to shell
out $25,000, while MTC sponsored a giveaway that included two tablets and a new car, available
to sponsors who contributed at least $5,000.47 Though the ACA has since taken the information
for its 2018 conference down, a similar booklet for its 2019 Conference remains online, showing
that the three large private prison companies remained major sponsors.48 Finally, CoreCivic,
GEO, and MTC are sponsors for the ACA’s upcoming 2021 annual conference.49
Documents obtained by Senator Warren’s office also reveal that the ACA requires facilities
seeking accreditation to attend its annual conference.50 According to contract request forms
provided by MTC, the ACA requires a panel hearing before granting accreditation, and the ACA
only holds these panel hearings at its biannual conferences.51 This appears to indicate that the
ACA is leveraging its role as accreditor to funnel additional revenue through its conferences.

United States Senate, “Lobbying Report: American Correctional Association,” 2010,
https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=90C1F6E4-C36F-4295-948212D9EE23736F&filingTypeID=60.
43
See e.g., https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=D7C19E49-9B12-48B4-B783DA433C77DF8D&filingTypeID=60; see e.g.,
https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=90C1F6E4-C36F-4295-948212D9EE23736F&filingTypeID=60; see e.g.,
https://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=D0746609-2234-45CB-845B8A9E7D1B91A8&filingTypeID=78.
44
See United States Senate, “Lobbying Disclosure Database Search Results,” Accessed Jul. 21, 2020, search
“American Correctional Association” under Registrant Name,
https://soprweb.senate.gov/index.cfm?event=selectFields&reset=1.
45
ProPublica, “American Correctional Association Form 990,” FY 2017,
https://projects.propublica.org/nonprofits/display_990/131977456/09_2019_prefixes_0620%2F131977456_201809_990_2019092016669736.
46
Exhibit A.
47
http://register.aca.org/DOCS/Conference/COC2018/2018%20Minneapolis%20Program%20Book_FINAL_WEB.P
DF(accessed September 2019).
http://www.aca.org/ACA_Prod_IMIS/DOCS/2018%20Marketing%20Kit.pdf (accessed September 2019).
48
American Correction Association’s 149th Congress of Correction, Aug. 1-6, 2019, https://user3imepyw.cld.bz/2019-ACA-Boston-Program-Book-149th-COC/28/.
49
Exhibit J: ACA Conference Details.
50
Exhibit C; Exhibit E.
51
Exhibit C.

8

And the price tag is hefty. Booths cost upwards of $2,000, and, according to MTC, individual
attendance costs approximately “$300 per person.”52
Finally, private prison and detention facility owners and operators pay tens of thousands of
dollars in additional fees to the ACA, including fees for individual certifications provided by the
ACA; individual and organizational membership; job postings on the ACA’s website; and study
materials and exams for certifications.53 For instance, MTC paid the ACA over $21,000 for
certification preparation materials and exams from 2014 to 2019.54
b. Conflicts of Interest for Key Personnel on ACA Boards and Committees
The conflicts of interest in the accreditation process are exacerbated by the fact that key
executives from the major private prison companies also serve on ACA boards and committees.
The ACA is headed by a 19-member Board of Governors, an seven-member Executive
Committee, a nearly 30-member Commission on Accreditation for Corrections (CAC), and a 20member Standards Committee.55 The Board of Governors includes several representatives from
the private prison industry, including “one each from GEO and CoreCivic.”56 The Executive
Committee includes Derrick Schofield, who currently serves as an Executive Vice President at
GEO, and Gary Mohr, a former consultant and managing director for CoreCivic.57 The Standards
Committee also includes “one [member] each from GEO and CoreCivic,”58 and the former Chair
of the Standards Committee, Harley G. Lappin, is now a member of the Board of Directors at
CoreCivic.59Moreover, the CAC includes a Managing Director of Operations for CoreCivic and
GEO’s Reentry In-Prison Treatment Vice President.60
2. The ACA Accreditation Process is Unreliable and Misleading
Funded in large part by the companies it audits, the ACA produces unreliable and deceptive
accreditation results. A review of available evidence suggests that that accreditation has little to
52

Exhibit J: ACA Conference Details; Exhibit C; Exhibit E.
Exhibit C.
54
Exhibit C.
55
Exhibit A; ACA, “Committee on Standards,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards___Accreditation/Standards/Standards_Committee/
ACA_Member/Standards_and_Accreditation/Standards_Committee/Standards_Committee.aspx?hkey=795105de6a67-4769-b58a-0de6df7e8324; ACA, "The Commission on Accreditation for Corrections,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards___Accreditation/About_Us/CAC/ACA_Member/St
andards_and_Accreditation/SAC_Commission.aspx?hkey=90da0502-afd8-4685-97c2-b8c7e1c803d3.
56
Exhibit A.
57
ACA, “Executive Committee,” Accessed Aug. 25, 2020,
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/About_Us/ACA_Leadership/Executive_Committee/ACA_Me
mber/AboutUs/Executive_Committee.aspx?hkey=4c649acc-56f4-41e9-a04f-47585e7f8064; GEO Group, “GEO
Care Leadership Team,” Accessed Aug. 25, 2020, https://www.geogroup.com/geo_care_leadership_team; Nashville
Post, “Ex-CCA exec to run Ohio correction department,” Jan. 13, 2011,
https://www.nashvillepost.com/business/blog/20455273/excca-exec-to-run-ohio-correction-department.
58
Exhibit A.
59
CoreCivic, “Board of Directors,” http://www.Ameri.corecivic.com/investors/board-of-directors
60
GEO, “How In-Prison Reentry Programs Prepare Inmates for Life After Prison,” Apr. 9, 2019,
https://www.georeentry.com/in-prison-reentry-program-prepares-inmates-life-after-prison/; LinkedIn, “Todd
Thomas,” https://www.linkedin.com/in/todd-thomas-38555533/.
53

9

no correlation with detention facility conditions and practices, and therefore little to no value
whatsoever.
a. The ACA’s Rubber Stamp
The ACA’s accreditation process lacks rigor, ignores serious health and safety problems, and
acts as a rubber stamp for private prisons and detention facilities.
Information obtained by the office of Senator Warren reveals that virtually all private prison
companies that pay the required fees are accredited, no matter how bad conditions may be at a
facility. This appears to be because the accreditation tests themselves are designed to make it
nearly impossible for facilities to fail.
The first step in the accreditation process is for facilities to conduct a “self-evaluation report,”
judging themselves on whether their “levels of expected compliance are sufficient for
accreditation,” and reporting the results to ACA accreditors.61 Facilities also self-report
“significant incidents.”62 The contents of these reports are not disclosed to the public or any
“external parties.”63
Next, a facility must request an audit. When the ACA conducts an audit, it evaluates a facility for
compliance with the ACA’s mandatory and non-mandatory standards.64 But the ACA grants
facilities three months advance notice of an audit, allowing facilities to prepare before inspectors
arrive.65 The ACA also provides facilities with “technical assistance,” including “standards
checklists” and an “audit readiness evaluation” that help facilities know when to schedule its
audit – essentially, providing the answers to the test in advance.66 And, at a facility’s request, the
ACA will conduct a “mock audit” to help the facility prepare for the actual audit.67 When the
audit is complete, inspectors file a report with its findings.68
Even if problems persist despite these ample opportunities to fix—or hide— them, the ACA
Commissioners can completely ignore the audit results and allow a facility to receive
accreditation even if it fails to meet minimum standards, rendering the standards toothless.69 The
ACA even recognizes specific circumstances in which non-compliance may not even require a
61

ACA, “Manual of Accreditation: Policy and Procedure,” Mar. 15, 2017, pp. 28,
http://www.aca.org/ACA_Prod_IMIS/docs/standards%20and%20accreditation/ALM-1-3_15_17-Final.pdf.
62
Id.
63
American Correctional Association, “Consultant Manual,” 2012,
http://www.aca.org/aca_prod_imis/Docs/Standards%20and%20Accreditation/ACA%20Consultant%20Manual%202
012.pdf.
64
American Correctional Association, “Consultant Manual,” 2012, p. 22,
http://www.aca.org/aca_prod_imis/Docs/Standards%20and%20Accreditation/ACA%20Consultant%20Manual%202
012.pdf.
65
Id. at 29
66
Exhibit A.
67
American Correctional Association, “Consultant Manual,” 2012, p. 40,
http://www.aca.org/aca_prod_imis/Docs/Standards%20and%20Accreditation/ACA%20Consultant%20Manual%202
012.pdf.
68
Id. at 30.
69
ACA, “Manual of Accreditation: Policy and Procedure,” Mar. 15, 2017, pp. 28,
http://www.aca.org/ACA_Prod_IMIS/docs/standards%20and%20accreditation/ALM-1-3_15_17-Final.pdf.

10

“Plan of Action” to ensure that facilities take steps to achieve compliance with the accreditation
standards, including when a facility simply has “an unwillingness to request funds from
a…funding source.”70
Finally, the CAC makes the ultimate decision on whether or not to accredit a facility. The
process for making this decision is entirely secret. Accreditation decisions do not include a
public justification, and while inspections result in a report for CAC staff, that report is not made
public.71 According to the ACA, it “does not disclose... specific information in the [facility’s]
self-evaluation report, visiting committee report…or information discussed in the hearing.”72
This opaque, closed-door process makes it essentially impossible to understand the basis of the
CAC’s ultimate decision.
In response to Senator Warren’s inquiry, the ACA wrote that “agencies…have all of [the
accreditation] records” and “are free to make those documents publicly available.”73 But this
does not appear to be true. When asked for accreditation records,74 ICE stated that
“[a]ccreditation reports and other related documents are not provided to ICE,”75 and that the
ACA only provides “the date of audit and the certificate of accreditation,” while withholding
details from at least some agencies.76 The BOP claimed that it “does not maintain a copy of the
ACA audits at private contract facilities.”77
After facilities receive accreditation, they are off the hook for three years. The ACA allows
facilities to “conduct annual self-reporting” in the off years, judging their own compliance and
submitting their own summary of significant incidents.78 According to the ACA, the
accreditation process provides no guarantee of quality once complete: “[O]nce a correction
facility is accredited or re-accredited by ACA, it does not become ACA’s responsibility to
monitor or enforce compliance.”79

70

American Correctional Association, “Consultant Manual,” 2012, p. 21,
http://www.aca.org/aca_prod_imis/Docs/Standards%20and%20Accreditation/ACA%20Consultant%20Manual%202
012.pdf.
71
American Correctional Association, “Welcome to the Standards and Accreditation Department,”
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards___Accreditation/ACA_Member/Standards_and_Ac
creditation/SAC.aspx?hkey=7f4cf7bf-2b27-4a6b-b124-36e5bd90b93d; Prison Legal News, “Betraying the Promise
of Accreditation: Quis Custodiet Ipsos Custodes,” Gary Hunter, Jul. 6, 2016
https://www.prisonlegalnews.org/news/2016/jul/6/betraying-promise-accreditation-quis-custodiet-ipsos-custodes/.
72
ACA, “Manual of Accreditation: Policy and Procedure,” Mar. 15, 2017, pp. 15,
http://www.aca.org/ACA_Prod_IMIS/docs/standards%20and%20accreditation/ALM-1-3_15_17-Final.pdf.
73
Exhibit A.
74
Office of Senator Elizabeth Warren, “Letter to the Department of Homeland Security,” May 31, 2019,
https://www.warren.senate.gov/imo/media/doc/2019-0531%20Letter%20to%20DHS%20on%20Accreditation%201.pdf.
75
Exhibit F.
76
See Exhibit F.
77
Exhibit G: BOP Response.
78
ACA, “Manual of Accreditation: Policy and Procedure,” Mar. 15, 2017, pp. 49, 51,
http://www.aca.org/ACA_Prod_IMIS/docs/standards%20and%20accreditation/ALM-1-3_15_17-Final.pdf; Prison
Legal News, “Betraying the Promise of Accreditation: Quis Custodiet Ipsos Custodes,” Gary Hunter, Jul. 6, 2016
https://www.prisonlegalnews.org/news/2016/jul/6/betraying-promise-accreditation-quis-custodiet-ipsos-custodes/.
79
Exhibit A.

11

The primary result of the flawed ACA accreditation process is a system that ignores major
problems and gives private facilities a free pass, putting the well-being of detainees, prisoners,
and corrections professionals at risk. According to the ACA, it has accredited or reaccredited
dozens of federal facilities since 2014. 80 Not a single facility was denied accreditation during
this time period.81 Since 2007, the ACA identified only four instances in which it denied
accreditation, and at least two of the facilities have since received accreditation.82
Similarly, MTC reported that its facilities received 40 accreditations or reaccreditations between
mid-2014 and mid-2019, and that no facility had ever been denied accreditation. In fact, MTC
claimed that “it would be unusual that any facility would be denied. The standards for
accreditation are provided ahead of time and an audit would not be requested by the
operator…until the facility meets the required standards.”83 All MTC facilities received a score
of 100% on all mandatory practices and all but one received a score above 98% on all nonmandatory practices.
And in 2008, a former employee for Corrections Corporation of America – now known as
CoreCivic – stated unambiguously that “I was the person who doctored the ACA accreditation
reports for” the private prison company.84
b. Accredited Facilities with Dangerous Conditions
The flaws in the ACA’s accreditation process are most obvious when evaluated next to
confirmed reports of abysmal and dangerous conditions in ACA-accredited prisons or detention
facilities across the country. Numerous facilities managed under contract with the BOP, and
therefore subject to BOP’s accreditation requirements, have had major problems in the last
decade.
For example, in late 2008 and early 2009, the Reeves County Detention Complex (Reeves), in
Pecos, Texas, which is managed by GEO, experienced riots in all three of its compounds, caused
in part by “low staffing levels” at the facility.85 In 2015, the U.S. Department of Justice (DOJ)
Office of Inspector General (OIG) found that GEO had “failed to comply with contractual
requirements in the areas of billing and payment, correctional and health services staffing, and
internal quality control” at its Reeves Compounds I and II.86 The OIG found “no minimum
staffing requirements [in place] for the institution” between January 2007 and March 2009,

80

Exhibit A.
Id.
82
American Correctional Association, “Search ACA Accredited Facilities,” search conducted on September 24,
2019,
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards_and_Accreditation/SAC_AccFacHome.aspx?Websi
teKey=139f6b09-e150-4c56-9c66-284b92f21e51&hkey=f53cf206-2285-490e-98b7-66b5ecf4927a&CCO=2#CCO.
83
Exhibit C.
84
Prison Legal News, “Betraying the Promise of Accreditation: Quis Custodiet Ipsos Custodes,” Gary Hunter, Jul.
6, 2016 https://www.prisonlegalnews.org/news/2016/jul/6/betraying-promise-accreditation-quis-custodiet-ipsoscustodes/.
85
Department of Justice Office of the Inspector General, “Review of the Federal Bureau of Prisons’ Monitoring of
Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf.
86
Id.
81

12

“because the BOP had sought to reduce costs.”87According to public reporting, the Reeves III
compound had a riot in December 2008, while riots at the Reeves I and II compounds occurred
in late January 2009.
Internal Department of Homeland Security (DHS) investigations at ACA-accredited contract ICE
detention facilities have found a host of violations to ICE detention standards, including braided
bedsheet nooses hanging in dozens of cells,88 packages of chicken leaking blood in refrigerators,
spoiled meat, and long-expired food.89 Another investigation found that ICE’s mechanisms for
holding facility contractors accountable were applied rarely and inconsistently, and that ICE
frequently issued waivers to deficient facilities rather than forcing them to comply with
standards.90
Despite these issues, the ACA accredited Reeves I and II on January 11, 2009 – just weeks after
riots at Reeves III, and weeks before additional riots at Reeves I and II.91 Furthermore, in its
communication with Senator Warren’s office, the ACA did not even have a clear record of these
problems, noting that the organization “believes [the riot] was after the facility’s accreditation on
January 11, 2009” (emphasis added).92 The facilities have all since received re-accreditation.93
In February 2011, incarcerated individuals at another facility—GEO’s Big Spring Correctional
Center (Big Spring) in Texas—“physically assaulted prison staff,” reportedly after a lackluster
response to a medical emergency “that resulted in the death of an inmate.”94 The facility received
ACA accreditation in August 2009 and re-accreditation in August 2012, January 2014, and
August 2016.95 The ACA continues to avoid responsibility for accrediting the facility despite
these problems.96
At a third facility, CoreCivic’s Adams County Correctional Facility (Adams) near Natchez,
Mississippi, 250 incarcerated individuals rioted in 2012 due to the low quality of food and

87

Id.
Department of Homeland Security, “Management Alert – Issues Requiring Action at the Adelanto ICE Processing
Center in Adelanto, CA, Sept. 27, 2018, https://www.oig.dhs.gov/sites/default/files/assets/Mga/2018/oig-18-86sep18.pdf.
89
Department of Homeland Security, “Concerns about ICE Detainee Treatment and Care at Four Detention
Facilities,” Jun. 3, 2019, https://www.oig.dhs.gov/sites/default/files/assets/2019-06/OIG-19-47-Jun19.pdf.
90
Department of Homeland Security Office of Inspector General, “ICE Does Not Fully Use Contracting Tools to
Hold Detention Facility Contractors Accountable for Failing to Meet Performance Standards,” January 29, 2019,
https://www.oig.dhs.gov/sites/default/files/assets/2019-02/OIG-19-18-Jan19.pdf.
91
See Exhibit A; see Department of Justice Office of the Inspector General, “Review of the Federal Bureau of
Prisons’ Monitoring of Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf.
92
Exhibit A.
93
American Correctional Association, “Search ACA Accredited Facilities,” search conducted on September 24,
2019,
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards_and_Accreditation/SAC_AccFacHome.aspx?Websi
teKey=139f6b09-e150-4c56-9c66-284b92f21e51&hkey=f53cf206-2285-490e-98b7-66b5ecf4927a&CCO=2#CCO.
94
Department of Justice Office of the Inspector General, “Review of the Federal Bureau of Prisons’ Monitoring of
Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf.
95
Exhibit A.
96
See Exhibit A.
88

13

medical care, and reportedly poor treatment from prison staff.97 A correctional officer was killed
and 20 people were injured.98 But Adams received ACA accreditation in January 2011 and reaccreditation in January 2014 and August 2016, scoring 100% at least once.99
And at a fourth BOP facility— MTC’s Willacy County Correctional Center (Willacy) in
Raymondville, Texas—incarcerated individuals “set fires and caused extensive damage to the
prison.”100 The BOP terminated their contract with the prison as a result.101 The facility had
received accreditation just one year earlier, in January 2014.102
Problems at private facilities under contract with DHS also reveal failures in the ACA
accreditation process. In May 2018, the DHS OIG conducted an unannounced inspection of
GEO’s Adelanto ICE Processing Center in Adelanto, California.103 The OIG found “significant
health and safety risks,” including “nooses in detainee cells[,] improper and overly restrictive
segregation[, and] untimely and inadequate detainee medical care.”104 After Senator Warren
wrote to GEO about this facility in November 2018,105 GEO responded by noting that they
received ACA accreditation in 2014 and re-accreditation in 2017, with “a score of 99.6%.”106
GEO provided no explanation for why conditions were so poor in the facility despite its ACA
accreditation.
Similarly, a December 2017 investigation by the DHS OIG found systemic health, safety, and
security violations at several privately-run immigration detention facilities accredited by the
ACA.107 The Stewart Detention Center (Stewart) in Lumpkin, Georgia, run by CoreCivic, and
the Otero County Processing Center (Otero), in Chaparral, New Mexico, run by MTC, both
violated standards regarding the “segregation and lock-down of detainees.”108 Detainees at
Stewart reported excessive waits for urgent medical care and the OIG observed “bathrooms that
were in poor condition” at both facilities, including a lack of hot water and water leaks

97

Department of Justice Office of the Inspector General, “Review of the Federal Bureau of Prisons’ Monitoring of
Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf.
98
Id.
99
Exhibit A; CCA, “CCA Facilities Earn Reaccreditation at Summer Congress of Corrections,” Bethany Davis,
Aug. 26, 2016, http://www.correctionscorp.com/insidecca/cca-facilities-earn-reaccreditation-at-summer-congressof-corrections.
100
Department of Justice Office of the Inspector General, “Review of the Federal Bureau of Prisons’ Monitoring of
Contract Prisons,” August 2016, https://oig.justice.gov/reports/2016/e1606.pdf.
101
Id.
102
Exhibit A.
103
Department of Homeland Security, “Management Alert – Issues Requiring Action at the Adelanto ICE
Processing Center in Adelanto, CA, Sept. 27, 2018, https://www.oig.dhs.gov/sites/default/files/assets/Mga/2018/oig18-86-sep18.pdf.
104
Id.
105
Office of Senator Elizabeth Warren, “Letter to GEO Group,” Nov. 15, 2018,
https://www.warren.senate.gov/imo/media/doc/2018-1116%20Letter%20to%20GEO%20Group%20re%20Compliance%20with%20Immigration%20Detention%20Standar
ds.pdf.
106
Exhibit F: ICE response.
107
Department of Homeland Security, “Concerns about ICE Detainee Treatment and Care at Detention Facilities,”
Dec. 11, 2017, https://www.oig.dhs.gov/sites/default/files/assets/2017-12/OIG-18-32-Dec17.pdf.
108
Id.

14

throughout Stewart.109 ICE confirmed that these facilities “had ACA accreditation at the time of
recent Office of Inspector General site visits/findings.”110
ACA-accredited private prisons used by state penal systems are also rife with problems. Three
prisoners escaped from MTC’s ACA-accredited Arizona State Prison – Kingman (Kingman) in
2010 and murdered two people during their attempted getaway.111 Then, in 2015, a series of riots
caused so much damage to the prison that the state had to transfer over 1,000 incarcerated
individuals to a different facility.112 Similarly, in 2012, a federal judge ruled that GEO’s ACAaccredited Walnut Grove Youth Correctional Facility (Walnut Grove) in Walnut Grove,
Mississippi “paints a picture of such horror as should be unrealized anywhere in the civilized
world.”113 GEO was forced to give up running the facility due to its failure to protect
incarcerated individuals from gang violence.114 Walnut Grove closed in 2016.115
ACA policies supposedly provide mechanisms for ensuring that private facilities meet minimum
health and safety standards. The ACA allows private facilities “to schedule a monitoring visit in
order to assist the facility in remedying any egregious failures,”116 and retains the “ultimate
power… to deny accreditation…or to revoke a facility’s accredited status.”117 Yet the ACA
indicated it has not ever revoked a facility’s accreditation following reports demonstrating
critical failures at accredited facilities. According to the ACA, “[its] records do not indicate that
[the] ACA took any specific actions subsequent to these incidents.”118 And every single one of
these facilities maintained their accreditation and were eventually re-accredited.119 ICE also
confirmed that it was “unaware of any such actions” taken by the ACA in response to these
problems at accredited facilities.120
The ACA has also accredited facilities that have proven unprepared to respond to the coronavirus
pandemic 2019 (COVID-19). An investigation by The Marshall Project revealed that staff at
federal prisons “ignored or minimized prisoners’ COVID-19 symptoms” and “felt pressured to
work even after being exposed to sick prisoners.”121 This includes Elkton Federal Correctional
Institution, an ACA-accredited facility where there were “people walking around looking like the
109

Id.
Exhibit F.
111
NY Times, “Escapes, Riots, and Beatings. But States Can’t Seem to Ditch Private Prisons.” Timothy Williams
and Richard A. Oppel Jr., Apr. 10, 2018, https://www.nytimes.com/2018/04/10/us/private-prisons-escapesriots.html?smid=pl-share&module=inline; AZ Central, “Ducey calls for investigation of Kingman prison riot,” Jerod
MacDonald-Evoy and Craig Harris, Jul, 4, 2015,
https://www.azcentral.com/story/news/local/arizona/2015/07/04/kingman-prison-experiencing-disturbanceabrk/29716859/.
112
Id.
113
Id.
114
Id.
115
Id.
116
Exhibit A.
117
Exhibit A.
118
Exhibit A.
119
Exhibit A.
120
Exhibit F.
121
The Marshall Project, “‘I Begged Them To Let Me Die’: How Federal Prisons Became Coronavirus Death
Traps.” Keri Blakinger and Keegan Hamilton,” Jun. 18, 2020, https://www.themarshallproject.org/2020/06/18/ibegged-them-to-let-me-die-how-federal-prisons-became-coronavirus-death-traps.
110

15

living dead.”122 Problems with medical care, quarantine procedure, testing protocol, and other
health and safety conditions were discovered at countless other facilities, including those in
Yazoo City, Danbury, Glenville, Fort Worth, Coleman, La Tuna, Tallahassee, and Fairton.123 All
of these facilities currently hold accreditation from the ACA.124
Further, the ACA has not adopted any specific protocols or procedures for ensuring the safety
and health of detainees, prisoners, or facility staff in the midst of COVID-19. 125 Prisons and jails
are amongst the hardest hit communities in the country, with 12 of the 15 largest COVID-19
“clusters” in the U.S. being correctional facilities—including all five of the largest clusters.126
Yet rather than exercising its role in holding facilities accountable for the health and safety of
detained individuals and correctional officers, the ACA has “greatly reduced its auditing of
correctional facilities.”127 And the ACA has failed to adopt new standards for the COVID-19 era,
claiming that its inability to hold a yearly conference somehow prevents it from incorporating
new standards into its audits.128
IV.

Conclusion

The ACA accreditation system is deeply flawed. The organization is riddled with conflicts of
interest and the accreditation process fails to provide any meaningful review or oversight. The
result has been the rubber-stamping of dangerous facilities and the waste of millions of taxpayer
dollars. To address these problems, the federal government, and state and local authorities,
should end their reliance on ACA accreditation and stop outsourcing oversight of its prisons and
detention facilities to for-profit organizations.
The U.S. criminal legal and immigration systems are broken from top to bottom. The private
accreditation system is one small, but important, piece of that problem – a crucial cog in a
system that consistently values profits over the dignity of individuals. Ending reliance on the
ACA’s corrupt accreditation process is one small but important step in reforming that system.

122

Id.
Id.
124
American Correctional Association, “Search ACA Accredited Facilities,” search conducted on September 24,
2019,
http://www.aca.org/ACA_Prod_IMIS/ACA_Member/Standards_and_Accreditation/SAC_AccFacHome.aspx?Websi
teKey=139f6b09-e150-4c56-9c66-284b92f21e51&hkey=f53cf206-2285-490e-98b7-66b5ecf4927a&CCO=2#CCO.
125
Exhibit I: Letter from ACA to Sen. Warren, Jul. 29, 2020.
126
The New York Times, “Coronavirus in the U.S.: Latest Map and Case Count,” Sarah Almukhtar et. al., June 23,
2020, https://www.nytimes.com/interactive/2020/us/coronavirus-us-cases.html#clusters.
127
Exhibit I: Letter from ACA to Sen. Warren, Jul. 29, 2020.
128
Exhibit I: Letter from ACA to Sen. Warren, Jul. 29, 2020.
123

16

 

 

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