"We strongly support the Department’s inclusion of minimum staff-to-youth ratios in the Prison Rape Elimination Act (PREA) juvenile facility standards. Requiring minimum staffing ratios reflects what we now know about the best ways of preventing and detecting sexual misconduct, as well as the many tragic examples of what can happen when facilities fail to adequately supervise youth in their care. The proposed standard reflects a practical approach to the widespread problem of sexual victimization in facilities that house youth. By establishing a minimum level of direct supervision, agencies and facilities will be better equipped to prevent and detect the red flags associated with victimization. When implemented alongside other tools to combat sexual misconduct such as staff training, youth education, supervision of staff, and reporting mechanisms, the minimum staff-to-youth ratios will present the best opportunity to protect youth from sexual misconduct."