Strengthening Capacity and Transparency at DYRS Amendment Act of 2025

Joshua A. Miller, PhD

Research & Advocacy Director Open City Advocates November 13, 2025

Good morning, Chairman Parker and members of the Committee. My name is Joshua Miller, and I serve as Research & Advocacy Director for Open City Advocates. Thank you for the opportunity to testify today regarding the proposed legislation that would shift certain reporting responsibilities to the Department of Youth Rehabilitation Services.

I want to speak to you today about why independent monitoring and evaluation of juvenile justice facilities is not merely beneficial but essential. While the Strengthening Capacity and Transparency at DYRS Amendment Act of 2025 is a valuable stopgap, it’s inadequate to the needs of independent oversight, and we would again ask you to restore funding for a juvenile justice facilities monitor.

Agencies are often hostile to their independent oversight, and would of course prefer to police themselves. But I want to use a case study that is directly relevant: the Maryland Department of Juvenile Services’ responses to ongoing reports from the Maryland Juvenile Justice Facilities Monitoring Unit about the conditions at the Thomas J.S. Waxter Children’s Center in Maryland.

DC’s Recent Example: The Pattern of Discounting and Distraction

We should start with DC’s own recent experience. The Behavioral Health Services at New Beginnings report released in October 2025 by the Office of Independent Juvenile Justice Facilities Oversight demonstrates precisely why independent oversight cannot be replaced by agency self-reporting. This report was released even as OIJJFO’s funding lapsed on October 1, 2025, one of the office’s final acts before closure.

The report, prepared by Dr. Terry Lee (a nationally recognized expert in juvenile behavioral health who has consulted with juvenile justice systems across the country), identified critical gaps through comprehensive record review of 17 youth. The findings included:

MAYSI-2 screening administration: Missing documentation for 5 of 17 youth, with no explanation for why screenings were absent.

Suicide precaution monitoring: Compliance with certain monitoring requirements dropped from 100% in 2020 to just 21%.

Independent diagnostic evaluations: Court-ordered psychological and psychiatric evaluations existed for 16 of 17 youth, providing “thorough and extensive assessments” with specific diagnoses and treatment recommendations. But Dr. Lee found “no evidence” that these independent evaluations informed treatment planning at New Beginnings.

Problem lists and treatment plans: In 15 of 16 cases where independent evaluations existed, at least one diagnosis identified by independent evaluators was either not identified at New Beginnings or not included on the problem list. Specifically:

Trauma excluded from problem lists in 7 cases despite extensive trauma histories
Conduct Disorder or Depressive Disorders diagnosed for 8 youth but not added to problem lists
Parent-child relational issues identified for 10 youth but never added to problem lists
Substance use disorders missing from problem lists for 4 youth
Low cognitive functioning or learning disorders should have been included for 14 youth but were not

Treatment plan updates: Despite repeated high-risk behaviors, treatment plans were not updated in 16 applicable cases; documentation consistently stated updates were “not required.”

DYRS’s Response: Reframing Substance Problems as Documentation Problems

DYRS’s response to these findings demonstrates a pattern that agencies commonly follow when confronted with independent oversight: address procedural and documentation issues while discounting substantive concerns about program effectiveness.

When Dr. Lee found “no evidence” that independent diagnostic evaluations informed treatment planning, DYRS responded: “Independent evaluations are consistently referenced in each youth’s NB Success Plan, which integrates diagnostic and treatment recommendations into individualized programming.”

This directly contradicts Dr. Lee’s finding. But rather than acknowledge the substantive problem (that diagnoses of trauma, learning disorders, depression, and substance abuse documented by independent evaluators were not being addressed in treatment), DYRS reframed it as a documentation visibility issue: “DYRS acknowledges that these linkages were not always visible in EHR documentation and will implement a documentation crosswalk to explicitly reflect the source of diagnostic inputs within each plan.”

The corrective action addresses documentation, not treatment. It promises to better document connections that the independent reviewer found did not exist.

Similarly, when the report identified that treatment plans lacked specific interventions and were not updated despite repeated high-risk behaviors, DYRS responded that “increased clarity in documenting group modalities and individualized adaptations is needed.” Again: framing a substance problem (plans aren’t individualized and don’t respond to behaviors) as a documentation problem (we need better clarity in recording what we’re already doing).

Non-Responses to Systemic Recommendations

Most tellingly, DYRS provided no response whatsoever to five major programmatic recommendations in the report:

Transform into a fully recovery-based rehabilitation program with consideration of obtaining outside consultation from experts with experience in program reform
Establish grand rounds where complex cases can be presented and outside experts provide training
Expand treatment services to meet the full range of needs, including longer evidence-based substance abuse treatment, services tailored to youth with cognitive limitations, and enhanced family engagement
Create transitional opportunities for youth to practice skills in less restrictive environments before discharge, including potentially weekend passes to acclimate to community living
Develop and publish discrete outcome measures to assess program effectiveness, including recidivism rates by length of time in community and changes in risk assessment from admission to discharge

For each of these recommendations, the OIJJFO report notes: “DYRS did not respond to this recommendation in its comments on the draft version of this report.”

These unremarked recommendations cut to the heart of whether New Beginnings actually rehabilitates youth. The report noted that of 30 youth who successfully completed the program in 2023 and were released, at least 21 (70%) have recidivated. DYRS responded to technical compliance findings about screening administration and documentation, but not to questions about whether their rehabilitation model works.

Would DYRS Have Self-Reported These Findings?

The question this Council must confront: Would DYRS have disclosed these specific gaps without independent evaluation?

We can examine the record. These findings emerged from case reviews conducted during a period when DYRS was testifying at Council budget and performance oversight hearings. Yet DYRS testimony did not highlight that suicide precaution monitoring had declined from 100% to 21% compliance. It did not report that court-ordered diagnostic evaluations showing trauma, learning disorders, and substance abuse were not informing treatment plans. It did not disclose that treatment plans were consistently marked as not requiring updates despite repeated high-risk behaviors.

In its response to the independent report, DYRS stated that “many of the identified concerns were already known to DYRS and have been or are being addressed through corrective measures.” If the agency was aware and addressing these problems, why weren’t they disclosed in testimony to this Council?

The answer is structural, not personal. The report reveals documentation that wasn’t readily retrievable, forms maintained in paper format and stored in ways that led to lost or misplaced records, coverage impacted by extended staff absences requiring temporary reassignments. These are exactly the kinds of operational gaps that agencies (focused on daily operations, managing staffing challenges, working within resource constraints, and struggling with overcrowding) may not recognize as patterns requiring systematic attention.

Independent oversight provides the longitudinal perspective and structural distance necessary to identify what needs to be addressed. It serves as eyes and ears for youth who cannot advocate for themselves while detained. And crucially, it creates public documentation that this Council, advocates, and families can use to demand accountability.

Yet DC allowed this oversight capacity to lapse just as it was demonstrating its value

A Case Study Directly Relevant to DC: Maryland’s Thomas J.S. Waxter Children’s Center

The DYRS response to independent oversight might seem like an isolated example of institutional defensiveness. But we have a case study that shows what happens when this pattern plays out over 15 years: the Thomas J.S. Waxter Children’s Center in Maryland.

This case is directly relevant to this Council’s current deliberations because DYRS is actively negotiating to acquire or lease a Maryland detention facility. We learned this through Director Abed’s October testimony to this very committee.

Learning About Waxter: What Testimony Reveals vs. What Independent Oversight Reveals

Director Abed’s presentation appropriately focused on the strategic rationale: addressing capacity challenges, proximity to New Beginnings, the potential benefits to DC youth. This is what agency testimony is designed to do: present the case for a proposed course of action.

But understanding whether that specific facility is actually fit for purpose required something Director Abed’s testimony could not provide: independent monitoring data.

When we began researching the facility that matched Director Abed’s geographic description (approximately three miles from New Beginnings in Laurel, Maryland), we discovered that Maryland’s independent Juvenile Justice Monitoring Unit had been documenting conditions at the Thomas J.S. Waxter Children’s Center for nearly two decades. And what those independent reports revealed was a facility that operated for 15 years after state oversight bodies formally recommended its immediate closure.

Let me be clear about what we learned, not from advocacy groups, not from media investigations, but from Maryland’s own official oversight body, an independent unit housed in the Attorney General’s office.

The Documentary Record from Independent Monitors

In March 2007, Maryland’s Independent Juvenile Justice Monitor issued a special report concluding that Waxter had “outlived its usefulness” and was “virtually impossible to improve the physical plant sufficiently to make it suitable for a secure detention program.” The recommendation was unequivocal: close the facility at “the earliest possible date.”

The facility remained open for 15 more years.

During those 15 years, Maryland’s Juvenile Justice Monitoring Unit documented in annual reports submitted to the Maryland General Assembly (with specific evidence from multiple reports between 2007 and 2020):

Infrastructure failures causing extreme temperatures that led to respiratory illnesses among detained girls. Climate control systems that created condensation coating walls and floors, producing mold growth throughout the facility. Girls routinely complained about the smell. Multiple reports documented that detained youth developed respiratory issues as a direct result of mold exposure.

Structural deterioration including holes in floors, water leaking through walls and doors, and windows so coated with dirt they blocked natural sunlight.

Plumbing breakdowns creating the persistent smell of raw sewage throughout the facility. Showers that were constantly broken with no hot water available.

Fire safety hazards. The facility’s complex locking system meant staff could not evacuate youth quickly in an emergency. Girls themselves documented in a 2010 report: “If there was an emergency, like a fire, we would be injured because the staff can’t work the keys fast enough to let us out in time.”

Chronic infestations of rats and bugs in conditions multiple reports described as “dirty” and “bug-ridden.”

These weren’t hidden conditions. Maryland’s own DJS Secretary, Donald DeVore, stated in 2009: “I’d like to blow it up.” His chief of staff called the physical plant “atrocious.” The Juvenile Justice Monitoring Unit’s 2024 report described the facility as “wholly decrepit.” A monitoring unit official stated in 2009: “No one should have to live there. No one should have to work there.”

DJS Director Sam Abed, who served in that capacity from 2011 to 2023, finally closed the facility in January 2022.

Maryland’s Pattern of Agency Responses: 15 Years of Documented Denial

Here’s what makes this case study particularly instructive for today’s hearing: Maryland’s Department of Juvenile Services had access to the same information the independent monitors had. They operated the facility. They knew the conditions. And yet, year after year, when the Juvenile Justice Monitoring Unit issued its reports, DJS responses followed a remarkably consistent pattern.

I have reviewed DJS’s official responses to JJMU reports from 2008 through 2024. Let me share what that pattern looks like in their own words.

Questioning Monitor Expertise (2008)

In 2008, one year after JJMU’s special report recommending immediate Waxter closure, DJS responded:

“There are various areas within the report where we may feel the JJMU either does not have the expertise in a defined area or the understanding of the operations of the facility to adequately identify findings… Because of these longstanding problems with much of the reporting, DJS does not feel these reports are as useful as they could otherwise be.”

Escalating to Formal Complaints (2009)

By 2009, DJS had escalated beyond contesting findings to filing a formal complaint. The JJMU Director noted in her transmittal letter:

“The agency’s response to this year’s Annual Report is in the form of a letter of complaint to President Miller and Speaker Busch… Apparently, DJS has abandoned our agreed process, and instead, written directly to President Miller and Speaker Busch regarding the draft 2009 Annual Report.”

After reviewing DJS’s objections, the JJMU Director concluded: “The three statements objected to in the letter are all factually accurate and based on data provided to the Monitor’s Office by the Department of Juvenile Services.”

Let that sink in for a moment: DJS contested findings that were derived from data DJS itself provided.

Direct Accusations of Misinformation (2010)

In January 2010, Secretary DeVore wrote directly to the Maryland General Assembly:

“Despite these and other efforts, the reports generated by the JJMU continue to contain incorrect and misleading information that does not accurately represent the work of DJS.”

This was the same year Secretary DeVore told the Baltimore Sun he’d like to “blow up” Waxter. He knew the facility was atrocious. Yet the official response to independent monitoring was to accuse monitors of producing “incorrect and misleading information.”

Verbatim Repetition: The “Biased or Subjective” Script (2016-2019)

From 2016 through 2019, DJS used the exact same language in four consecutive annual responses. Word for word:

“The Department continues to urge the JJMU to adopt nationally-recognized standards and audit tools to ensure objective and credible evaluations of Department facilities… Using objective standards would assist the JJMU in reducing any biased or subjective recommendations and provide a consistent framework for its evaluations.”

Four consecutive years. The same accusation of bias. The same suggestion that independent monitors needed to adopt “objective” standards.

Meanwhile, DJS’s 2016 response also stated:

“The Department of Juvenile Services (DJS) has its own auditing tools and practices to ensure that staff and administrators are adhering to the Department’s policies… All of the aforementioned offices have standardized procedures and tools to ensure that the results of their efforts are objective and measurable.”

The implication was clear: DJS’s internal auditing was objective; independent oversight was biased and subjective.

Dismissing Youth Testimony (2017-2019)

In multiple responses, DJS argued:

“Objective standards would also reduce the JJMU’s need to rely on unverified youth statements as the sole basis for some of the findings. While youth statements may provide some insight, they must also be viewed in context.”

And in 2017:

“Statements from youth, as helpful as they may be for feedback purposes, cannot form the basis of any conclusions for audit purposes.”

This is particularly noteworthy because detained youth documented in the 2010 ACLU report “Caged Birds Sing” that conditions at Waxter included windows so dirty they blocked sunlight, the smell of raw sewage, and fears about fire evacuation. DJS’s response framework suggested these youth statements couldn’t form the basis for oversight conclusions.

Challenging the Value of Longitudinal Data (2019)

By 2019, DJS added a new contestation:

“COMPARING CURRENT FACILITY INCIDENT DATA TO PREVIOUS YEARS IS OF LIMITED UTILITY… Due to the ever-changing populations at DJS facilities, comparing a facility data point from a previous year to a current DJS facility data point is of limited utility.”

In other words: don’t track patterns over time; don’t compare current performance to past baselines; each year’s data should be evaluated in isolation.

This argument came during the same period when JJMU was documenting that conditions at Waxter (documented as unfit in 2007) remained unfit in 2019.

The Pattern Breaks: What Acknowledgment Looks Like (2023)

In February 2023, under new Secretary Vincent Schiraldi, DJS issued its first response under the Moore administration:

“DJS does not take issue with many of the findings expressed in the JJMU report, and shares the concern that, despite improvements in some areas in recent years, conditions of confinement in DJS detention and commitment facilities are quite concerning and need to be improved substantially.”

This marked the first time in over a decade that DJS acknowledged independent monitoring findings without questioning methodology, accusing bias, or contesting data interpretation.

Notably, this acknowledgment came after Waxter had closed. After 15 years of operation following official condemnation. After girls had suffered through conditions that all parties eventually agreed were “wholly decrepit.”

What This Pattern Reveals About Power

Let me be direct about what that methodological debate actually means.

When DJS argued that “statements from youth cannot form the basis of any conclusions for audit purposes,” they weren’t making a technical point about research design. They were making a power claim: don’t believe the children.

Juvenile detention facilities operate as closed systems. Youth can’t leave. They can’t freely call family or advocates. They depend entirely on staff for food, medical care, education, safety.

In that environment, youth testimony is often the only window into what’s actually happening. When girls at Waxter told JJMU monitors about mold that made them sick, about being so cold they couldn’t sleep, about smelling sewage, about fearing they’d die in a fire because staff couldn’t work the locks fast enough, DJS’s response was to argue those statements didn’t meet audit standards.

This is often how institutional failures can go unrecognized: by discrediting the only witnesses who see everything.

Independent oversight exists precisely because detained youth lack credibility in the eyes of the system detaining them. Monitors serve as outside eyes and ears for young people who have no other recourse. When agencies argue that monitors rely too heavily on youth statements, what they’re really arguing is that independent oversight should only use data the agency provides and considers reliable.

That makes independent oversight toothless.

Maryland showed us what happens when agencies can contest methodology while youth suffer: 15 years of operation after condemnation. Fifteen years of girls living in conditions that adults knew were unfit. Fifteen years of documented respiratory illness, structural failure, and hazardous conditions.

The monitors weren’t perfect. But they believed the girls. And eventually, after 15 years of pressure, the facility closed.

That’s not a bug in independent oversight. That’s the entire point.

The Pattern Across Jurisdictions: Why This Is Structural, Not Personal

This is not about whether agency officials are well-intentioned. This is about structural incentives and institutional resistance to external accountability.

Throughout those 15 years (with documented evidence from 2007 through at least 2020):

DJS questioned monitor expertise
Accused independent oversight of producing “incorrect and misleading information”
Used verbatim language about “biased or subjective recommendations”
Dismissed youth testimony as insufficient basis for findings
Argued against longitudinal data comparison
Emphasized their own internal “objective and measurable” auditing

Throughout those 15 years (with documented evidence from 2007 through at least 2020):

Independent monitors documented mold causing respiratory illness
Girls lived with extreme temperatures and the smell of raw sewage
Structural failures compounded
Fire safety hazards persisted
Waxter remained open

The facility only improved when political and public pressure (informed by independent monitoring) made continued operation untenable.

Not because agencies voluntarily acknowledged problems. Not because internal auditing identified systemic failures. But because structurally independent oversight made the evidence impossible to dismiss indefinitely.

You cannot fix problems you do not acknowledge. And agencies rarely acknowledge their own most serious failures without independent verification forcing that acknowledgment.

The Same Official, Different Jurisdictions, Similar Patterns

It’s important to note that the same official now leading DYRS played a role in both cases. Sam Abed served as Maryland’s Secretary of Juvenile Services and was in that position when Waxter finally closed in January 2022, ending 15 years of operation after official condemnation. By 2022, the political and public pressure had become impossible to ignore.

Now, as Director of DYRS in DC, we see similar patterns emerging:

Maryland DJS (2008-2021): Contested independent findings, reframed substance problems as documentation issues, questioned monitor methodology, dismissed youth testimony
DC DYRS (2025): When independent monitors found “no evidence” that diagnostic evaluations informed treatment, the response reframed it as a documentation visibility issue promising “a documentation crosswalk to explicitly reflect the source of diagnostic inputs”

This is not a personal critique of Director Abed. This demonstrates precisely why the issue is structural, not individual. Even officials who eventually did the right thing in one context (closing Waxter) can follow problematic patterns in another when faced with institutional pressures: overcrowding, resource constraints, staffing challenges, and the daily urgency of operations that makes systemic reform difficult to prioritize.

The pattern is the same because the incentives are the same:

Agencies have limited resources and competing priorities
Public acknowledgment of failures creates political vulnerability
Daily operational pressures take precedence over long-term programmatic reform
Documentation fixes are easier than service delivery transformation
Youth voices lack credibility within the system detaining them

This is exactly why independent oversight cannot be replaced by agency self-reporting. The structural dynamics that made Maryland DJS contest findings for 15 years while girls lived in hazardous conditions are the same dynamics now operating in DC as DYRS responds to independent findings about treatment effectiveness.

And now, Director Abed is negotiating to potentially reopen the very facility that Maryland finally closed as unfit. Without robust independent oversight, this Council and the DC public will have no independent verification of whether that facility has been remediated to acceptable standards, no ongoing monitoring of conditions, and no structural mechanism to ensure youth voices are heard.

What Independent Monitoring Provides

Independent oversight gives us four things that agency self-reporting cannot:

First: Authoritative documentation that advocates, attorneys, legislators, and the public can cite in legal and policy work. When Maryland’s monitoring unit documented conditions at Waxter, those findings carried weight precisely because they came from a statutorily independent body within the Attorney General’s office, not from advocacy groups with an agenda, not from media with narrative preferences, but from an office with the legal authority and professional obligation to assess conditions objectively.

Second: Longitudinal tracking showing whether conditions improve or decline over time. The Behavioral Health Services Report’s value came partly from comparing current performance to a 2020 baseline. That comparison revealed declining compliance in key areas. Information essential for accountability but only available because independent monitors had established that baseline years earlier.

Third: Credibility that comes from structural independence. When findings come from an office that doesn’t report to the agency it monitors, doesn’t compete for the same budget allocation, and has statutory authority to access facilities and records, those findings carry a different weight than agency self-assessments.

Fourth: Protection for youth who cannot advocate for themselves while detained. Young people in secure facilities have limited ability to report problems or challenge conditions. Independent monitors serve as eyes and ears for youth who have no other recourse.

DC’s Current Juncture

Before I address this Council’s choices regarding oversight, let me be clear about Open City Advocates’ position on the underlying issue: We do not believe DC should be acquiring, leasing, or building additional detention capacity.

The answer to overcrowding at the Youth Services Center is not more facilities. The answer is increased diversion, robust prevention programs, and addressing young people’s needs in the community where they live. Every young person currently detained can and should be quickly transitioned back into community-based services that are more effective, more humane, and less costly than incarceration.

However, we recognize that DYRS is actively pursuing facility acquisition in Maryland. That is the reality this Council must address. And if this Council does not restore independent oversight while DYRS negotiates to reopen a facility that Maryland closed as unfit, you will be repeating Maryland’s mistake: allowing agencies to make facility decisions without independent accountability.

This Council faces a choice. You can restore and strengthen independent monitoring to ensure that if DYRS proceeds with facility acquisition despite our objections, those facilities are subject to rigorous independent evaluation before, during, and after youth are housed there. Or you can continue allowing independent oversight to lapse while shifting reporting responsibilities to the agency with the greatest institutional interest in presenting favorable assessments.

If this Council allows independent monitoring to remain defunded while considering legislation that shifts oversight to DYRS self-reporting, DC will lose the very tool that could prevent a Waxter-type situation from developing undetected.

Let me be concrete about what that means. Right now, DYRS is negotiating to acquire or lease a Maryland detention facility. We believe that facility is Waxter. DYRS has not confirmed or denied this. The public has no access to facility condition assessments, infrastructure reports, or remediation plans.

If we had robust independent oversight with clear mandates, you would not need to rely on advocacy groups doing documentary research to piece together a facility’s history. Independent monitors would be assessing the facility, reviewing infrastructure reports, and providing this Council with authoritative evaluations before any youth were transferred.

That is what independent oversight provides. That is what Maryland’s monitoring unit provided (imperfectly, incompletely, but persistently) for two decades. That is what DC’s Office of Independent Juvenile Justice Facilities Oversight was beginning to provide before its funding lapsed on October 1, 2025.

Addressing the Counterargument

Some might argue that DJS was right to contest JJMU’s methodology. Perhaps some of those technical disagreements were legitimate. Perhaps JJMU should have used more standardized audit tools. Perhaps youth grievances aren’t always reliable.

But here’s what that argument concedes: DJS spent 15 years debating methodology while girls lived in hazardous conditions.

If your defense is “the independent monitors used imperfect methodology,” you’re admitting that for 15 years, your response to documented facility failures was to critique the documentation rather than fix the failures.

That’s exactly why we need independent oversight. Not because monitors are infallible, but because without external accountability, agencies will always find reasons why this particular report, with this particular methodology, using these particular metrics, isn’t quite persuasive enough to justify urgent action.

Even if we set aside JJMU reports entirely, multiple independent sources documented the same conditions:

The ACLU’s 2010 “Caged Birds Sing” report based on girls’ own testimony
Maryland State Department of Education found special education violations so severe they issued formal findings
Baltimore Sun investigative reporting which interviewed former staff and detained youth
Legal complaints filed years later under the Child Victims Act compiling facility condition evidence
Secretary DeVore’s own 2009 statement: “I’d like to blow it up”

The eventual closure of Waxter and DJS’s own characterization of it as “wholly decrepit” proves the monitors were right about substance even if DJS had points about methodology.

Recommendations

Open City Advocates believes the answer to overcrowding is diversion, prevention, and community-based services, not facility expansion. However, given that DYRS is actively pursuing facility acquisition, I urge this Council to reject any legislation that weakens independent monitoring and evaluation of juvenile justice facilities. Instead, I urge you to:

Restore and strengthen independent oversight structures with clear statutory authority to access facilities, review records, and issue public reports.
If DYRS proceeds with facility acquisition, require independent assessment before youth are transferred, whether those facilities are acquired, leased, or built, whether in DC or Maryland. Independent oversight is the only tool that can prevent the acquisition of facilities like Waxter that other jurisdictions closed as unfit.
Mandate transparency regarding facility negotiations, requiring DYRS to disclose to this Council the location, condition, and assessment reports for any proposed detention facilities before finalizing agreements.
Establish baseline standards that any facility housing DC youth must meet, with independent verification of compliance before operations begin.
Learn from the Waxter case study: A facility that state officials themselves described as “atrocious,” “wholly decrepit,” and impossible to improve operated for 15 years after official condemnation. That happened in part because the political and operational pressures to keep the facility open outweighed the documented evidence of its inadequacy. Independent monitoring could not prevent that outcome, but it ensured that the public, the legislature, and advocates had documented evidence to demand accountability.

Conclusion

The question before this Council is not whether DYRS staff are dedicated professionals working hard to serve DC youth. The question is whether any agency can objectively assess its own performance gaps, acknowledge its own systemic failures, and document its own shortcomings without independent verification.

The Waxter case study (15 years of operation after official condemnation, with agency responses consistently contesting independent findings) demonstrates that the answer is no.

DC’s youth deserve the same standards Maryland’s youth were entitled to. And those standards required Waxter’s closure. Independent oversight serves a dual purpose: it can help prevent facilities from being acquired in the first place (by documenting their unfitness), and if facilities are acquired despite those warnings, it ensures conditions cannot deteriorate undetected for 15 years.

Don’t eliminate the very accountability mechanism that could prevent the next Waxter.