Police Department Accreditation: A Hollow Enterprise?

Under current accreditation metrics, being an accredited agency has little to no predictive value regarding the professionalism or preparedness of a department. It can, in fact, be harmful to an agency and community by providing a misleading valuation of an agencies condition and its officers’ knowledge, skills, and abilities. More important than an accreditation designation is a law enforcement agencies commitment to the evolution of policy and practices that improve officer performance and community outcomes day to day. An agency cannot go wrong by fostering a culture committed to 1) crafting or adopting policies which reflect best practices, 2) evaluating and revising policies which prove to be unattainable, ambiguous, or otherwise impractical, 3) identifying and addressing policy versus practice incongruence, 4) meaningfully training department personnel to understand and perform to the standard for which they will be held accountable, and 5) examining the merit of high liability training programs as it relates to decision making and skill performance in scenario-based evolutions and through body worn or in-car camera review. This type of department would pass even unscheduled accreditation audits. Conversely, if these things are not done, if an agency from top to bottom does not embrace a culture of commitment to fulfilling the intent behind an accreditation program’s standards, then it is a hollow enterprise. Using human and financial resources to pass an audit becomes merely feel-good theater which can be dangerous for officers and the community.

What it takes

The fact is that substantial, or meaningful compliance to standards and policy are the result of agency wide buy-in, especially from police command and extending to the local government. It is developing an agency culture which promotes understanding the practical impact of and “why” of policies. It means adopting meaningful training which replicates, as closely as possible, real-world encounters to improve decision making by officers. It means making a commitment to developing better officers which will provide better services and maintain higher level skill sets. These cannot be determined through scheduled inspections or by reviewing yearly firearms qualification scores.

Scheduled inspections are very similar to scheduled Child Protective Services or probation home visits – where the house is always clean, the parent(s) are not high, and the children put on a happy face for a few hours. Qualification scores are often achieved after several attempts or by instructors removing constraints to get people through – such as relaxing the time constraint or by coaching officers during the qualification (this is especially true of the special “command level” qualifications). Neither of these give meaningful insight into the dynamics of an agency or abilities of officers. Surprise visits and pulling a person in to qualify “cold” would provide more valuable insights.

What is measured gets managed.

Training

High liability areas are arguably the biggest cause for concern. Even when agencies are compliant with yearly mandates for defensive tactics, less-lethal tools, and firearms training – what does that training look like? Too often training does not replicate, and thereby has minimal value in preparing for and improving outcomes for officers’ real-world encounters. The training is performed in isolation. CEW training in some jurisdictions can mean merely deploying two cartridges into a cardboard cutout. Baton training can be no more than a classroom refresher followed by swinging the baton at a bag while yelling “Get on the ground.” This type of training is minimally useful at best and generally more counterproductive. Real world violent encounters are rapidly evolving and the most important component for officers is the decision-making process which moves the event to a successful conclusion. This can mean adjusting force application and moving between weapon systems or force options fluidly as the situation demands or adapting the use of a weapon for novel contexts.

Decision making is critical. If a call comes in that a subject committed a violent crime and was armed, would you chase the person without, at least, your sidearm? If the subject ran into a river, chased by several officers and detectives, would you expect a supervisor and a senior patrol officer to leave their sidearm and duty belt, respectively, on the riverbank and then continue pursuit? Of course not, most officers could not even imagine that scenario unfolding. But this happened. Those decisions could have had catastrophic consequences – fortunately, it worked out for the officers. Just as problematically, during the shooting, one of the armed officers gave up his service pistol to the unarmed supervisor– leaving that officer without a firearm mid-engagement.

The moral of the story is that, regardless of how well you can shoot, it won’t matter if you don’t have your weapon – either because a decision was made to leave it behind or to give it up to someone else. Alarmingly, this event never led to an evaluation of the firearms training program for adjustments to training, or even for the purpose of improving at the officer or agency level – this event happened at an accredited agency.

The decisions made that day may have been different if, in the years leading up to this incident, the accreditation process included three things: training content review (what is being taught, how it is being taught), randomly generating a list of officers to run through use of force scenarios and reviewing body camera footage of force events. Evaluating these things would provide substantially better insight into the type and quality of training, decision making, and officer performance at an agency. If accreditation required these components, it would drive an agency to constantly critique use of force events, identify areas of concern, and address them through meaningful training. There is no question that this would keep officers and the public safer.

Policy

If the goal of accreditation is for an agency to proscribe and adhere to standards as laid out in department policy – and driven by accreditation standards, it is important that those policies be evaluated more thoroughly. Specifically, policy should be evaluated for actual versus intended impact on service delivery and for actual levels of compliance by personnel. It is well established that the more rules you have, the wider the gap is between policy and practice. How large a gap is important for any meaningful analysis of a policy's validity, as measured by officer compliance and resultant impact to the community.     

For example, a common departure from policy starts right at the beginning of shift for many agencies. Officers are generally instructed to get out onto the street as quickly as they can following a briefing or roll call.  Those who take too long are chastised by both other officers and supervisors.  However, many agencies that utilize fleet vehicles require several activities before using the vehicle. Vehicles must be thoroughly searched, to include removing the seats in the transport area to ensure that no contraband remains in the car, an officer must ensure the car has all the mandatory equipment/supplies (biohazard bag with all the contents, proper number of flares, evidence collection materials, shotgun, etc.), a check of all lights and fluid levels is required, and documentation of new scratches/dents must be submitted. Officers are also expected to be on the street in ten minutes.  It goes without saying that most of this is just not done, and no one knows what is missing until they need it. If it is not observed, what value does the policy have? Is there a better way to frame when and how vehicles are inspected? While the intent of the policy is understood, its practical application is problematic.

The second piece of evaluating policy is to examine if it serves its intended purpose, which is to provide direction for a specific subject area. A use of force policy in Virginia contains the verbiage “Officers shall only use force when no other viable option is available and non-physical options are not viable or have been exhausted.” This provides no meaningful direction. Humans have limited attentional capacity, it would be impossible, then, to identify every viable option to conclude that they had been exhausted. Further, the use of the word “viable,” coupled with the directive “shall,” begs for the force applied to be examined in hindsight and every event most certainly would be. This is a subjective review of the application of force, and it could be argued that every use of force is outside of policy based on this verbiage. Attorneys go to school and are specifically trained in finding or developing alternative theories which are beneficial to their clients. This provides them with endless possibilities. It also provides an impetus for inaction by officers. Indeed, the author asked supervisors at the agency about this policy and was not given any definitive explanation of what this meant.

That same use of force policy also contains, “In all cases where force is used, only the minimal degree of force which is necessary to overcome resistance shall be used.” How is one to know what the minimal amount of force to overcome resistance is in the moment? Or even in retrospect? This is especially problematic when parsing degrees of force. While this language is concerning, the inclusion of the mandate that “… officers should use only those tactics/techniques in which they have been trained and which are approved by the Virginia Department of Criminal Justice Services.” This can mean a wide range of different techniques as they evolve over time – so what is the standard? It will be different for, essentially, every cohort coming out of a regional academy, or from outside agencies. The author called DCJS and asked if there was a list and was informed that there was not one. A list has still not been disseminated to officers employed by this agency as of this writing.  A meaningful accreditation audit would find this particular use of force policy to be woefully inadequate for providing officers direction in force application or understanding how it would be reviewed in the aftermath of a force incident. This is an example of how administratively driven content, which may be appealing in theory, has no real utility in application. That is bad policy. A truly accredited agency would fix this issue by either changing the policy or providing more resources to officers so that they could meaningfully understand the policy and thereby comply with it.

What is accreditation?

As an example, Virginia Law Enforcement Accreditation outlines 190 standards that serve as a blueprint for agency policy. These standards are then assigned to one of four general subject areas: Administration, Operations, Personnel, and Training. An assessment team reviews each of the applicable standards for “proof” of compliance during a scheduled event. This broadly means that assessors will conduct an agency walkthrough, assess a static display of vehicles and equipment, observe and question officers during a ride along, and review files to show compliance with standards.

As a practical matter, this type of exercise is nothing more than a dog and pony show that can bear little resemblance to day-to-day operations or practices. The best vehicles, the best personnel, and a time-consuming scramble to clean the department and find “proofs” for the auditors are the norm at many agencies. Indeed, the author reviewed an agency audit for a department in Virginia with over 450 personnel. It showed that only one (yes, one) ride along was conducted and it was with a junior supervisor. How can this even remotely indicate the professionalism, readiness, and compliance with standards or policy throughout the agency?

In the Virginia model for accreditation, an agency must show that it has a policy conforming to – at a minimum – components of each of the previously mentioned standards and that the agency complies with the policy. Documentation of such compliance is considered a “proof.” A proof can be paperwork showing that one officer complied with the policy. How does showing that (a) a department has a policy and (b) that it was documented as being followed on one – yes, one – occasion, even remotely provide a measure of meaningful agency compliance, readiness, or effectiveness? Departments can, and have, provided a “proof” that department mandated training was conducted when the reality was that the “proof” only represented a small fraction of that agency and does not speak to the efficacy of the training.

The true measure of an agency’s commitment to standards and observance of them on a day-to-day basis can only be evaluated unannounced or in a more random fashion. As an example, in Virginia, accreditation standard PER.06.01 outlines, in part, that an agency requires an annual written performance evaluation of each employee. The author had none in the last five years of service. Moreover, some quick phone calls to members of the same agency determined that not one officer contacted had consistent yearly evaluations in recent memory, with one employee claiming to never having had one. Others have had two in five years while another had only one in five years, after requesting one be done. While this is a less than scientific method of determining actual compliance, it should certainly be a cause for concern at the agency.

Performance evaluations are essential for developing personnel. Letting an officer know their strengths and encouraging them to continue to exercise them, as well as outlining areas for improvement and goals to work towards are critical for employee development and better community interaction. A haphazard approach to performance evaluations, and the limited employee feedback and development experienced because of that approach, should alarm an agency that is looking to bolster public confidence in their professionalism. The current model of assessment, however, re-accredited this agency and checked off that the yearly evaluation showed proof of compliance.

Conclusion

Law enforcement accreditation programs are designed to communicate to the public that an agency has met and is compliant with the professional standards outlined by the accrediting body. It is a mechanism created to promote public confidence in law enforcement by ensuring, among other things, that members of the agency have the appropriate level of training. Governing bodies and indeed, agency leadership often tout accreditation as a reflection of their law enforcement agency’s professionalism and commitment to the community they serve. In this way, being designated as an accredited agency has become more important for some municipality or law enforcement leadership than achieving the standards that being accredited should represent. What follows is a shell game to achieve or maintain a title rather than to uphold a standard. In turn, the pursuit of accreditation as a metric for professionalism can become dangerous to the agency and community. Without substantial changes in how accreditation is measured, the man-hours and money spent pursuing it would be better spent elsewhere. The current approach to auditing an agency is a disservice to communities and departments alike –  it can oversell officers, and agencies, as having a level of expertise and professionalism that they may not in fact possess – which is dangerous for all parties.

About the Author 

Brian N. O’Donnell retired as a Lieutenant with the City of Charlottesville, Virginia, Police Department. He served as an infantry officer in the United States Marine Corps and served with the Charlottesville police department for 25 years. He has a B.A. in economics from Northwestern University and an M.S. in Criminal Justice from Liberty University. O’Donnell is a 2016 graduate of the University of Virginia’s National Criminal Justice Command College, earned the Advanced Specialist designation by the Force Science Institute in 2018, and became an IADLEST National Certified Instructor in 2020.

O’Donnell has worked in patrol, as a SWAT member, as a detective with a regional narcotics task force, and as a full-time Task Force Officer with the FBI’s Joint Terrorism Task Force. HIs supervisory duties included: patrol Sergeant, patrol Shift Commander, Commander of the Strategic Policing Bureau, and the Training and Firearm’s Units Supervisor.