U.S. Department of Justice Federal Bureau of Prisons PROGRAM REVIEW DIVISION Washington. DC 20534 July 15, 2024 MEMORANDUM FOR ASSISTANT INSPECTOR GENERAL INVESTIGATIONS DIVISION FROM: External Auditing Branch SUBJECT: Status Update to the Office of Inspector General's (OIG) Final Report dated June 26, 2023: Investigation and Review of the Federal Bureau of Prisons' Custody, Care, and Supervision of Jeffrey Epstein at the Metropolitan Correctional Center in New York, New York The Federal Bureau of Prisons (FBOP) appreciates the opportunity to provide a response to the Office of the Inspector General's above referenced memorandum received on April 22, 2024. The FBOP has completed its review of the analysis and offers the following status update regarding the analysis and its recommendations. Recommendation One: The BOP should implement a process for assigning a cellmate following suicide watch or psychological observation, with criteria for exceptions based on the particular individual or security considerations. OIG Analysis: The BOP's update is responsive to the recommendation. In a previous update, the BOP reported that RSD and CPD were collaborating on a memo to provide guidance to the field on a process to ensure psychologists make recommendations regarding housing, including the presence of a cellmate, for individuals in custody following suicide watch or psychological observation. The BOP further reported that this process will include exemptions based on individual or security considerations. The BOP has now indicated that this guidance has been drafted and is under review. Accordingly, the OIG will consider whether to close this recommendation after the BOP (I) finalizes the guidance referenced in its update, and (2) provides the finalized guidance to the OIG for review. EFTA00141295

FBOP's Response: The FBOP Reentry Services Division (RSD) and Correctional Programs Division (CPD) have collaborated to draft guidance. This guidance is currently under review. FBOP will provide further updates as the draft guidance is reviewed and approved as needed. Recommendation Two: The BOP should establish procedures to ensure inmates at high risk for suicide and for whom a cellmate is recommended will continue to have a cellmate until the recommendation is changed or rescinded, including establishing a contingency plan for cellmate re-assignment, with criteria for exceptions based on the particular individual or security considerations. OIG Analysis: The GOP's update is responsive to the recommendation. In a previous update, the BOP reported that RSD and CPD were collaborating on a memo to provide guidance to the field on procedures to ensure communication regarding the requirement of a cellmate for individuals following suicide watch or psychological observation when recommended by a psychologist. The BOP further reported that this memo will include a procedure for exemptions based on individual or security considerations. The BOP has now indicated that guidance has been drafted and is under review. Accordingly, the OIG will consider whether to close this recommendation after the BOP (1) finalizes the guidance referenced in its update, and (2) provides the finalized guidance to the OIG for review. FBOP's Response: RSD and CPD have collaborated to draft guidance. This guidance is currently under review. FBOP will provide further updates as the draft guidance is reviewed and approved as needed. Recommendation Three: The BOP should evaluate its current process for obtaining and documenting approval for social or legal visits while an inmate is on suicide watch or psychological observation, which allows for institution-specific variations in the process, and provide guidance on standard components that each institution should include in its process to mitigate security issues that can arise when an inmate is on suicide watch or psychological observation. OIG Analysis: The GOP's update is responsive to the recommendation. In a previous update, the BOP reported that it was evaluating its process for obtaining and documenting approval for social and/or legal visits while an inmate is on suicide watch or psychological observation. The BOP has now reported that while it currently does not have guidance on these issues, new guidance has been drafted and is under review. Accordingly, the OIG will consider whether to close this recommendation after the BOP (1) finalizes the guidance referenced in its update, and (2) provides the finalized guidance to the OIG for review. FBOP's Response: RSD and CPD have collaborated to draft guidance. This guidance is currently under review. FBOP will provide further updates as the draft guidance is reviewed and approved as needed. Recommendation Four: The BOP should evaluate its methods of accounting for inmate whereabouts and wellbeing and make changes as may be appropriate to improve those methods through policy, training, or other measures. EFTA00141296

OIG Analysis: The GOP's update is responsive to the recommendation. Accordingly, the OIG will consider whether to close this recommendation after the BOP (1) finalizes the program statement update referenced in its update; and (2) provides the finalized program statement to the OIG for review. FBOP's Response: Program Statement 5500.14, Correctional Services Procedures Manual, is being modified to improve FBOP methods for accounting for inmate whereabouts and wellbeing. Because revisions to Programs Statements must follow the normal FBOP development and Union negotiation process, they are subject to change. Recommendation Five: BOP policy should clarify what is required of a Lieutenant when conducting a round. OIG Analysis: The GOP's update is responsive to the recommendation. Accordingly, the OIG will consider whether to close this recommendation after the BOP (1) finalizes the program statement update referenced in its update; (2) provides the finalized program statement to the OIG for review; and (3) provides a description of the training referenced in its update, sample training materials for OIG to review, and confirmation that the training is in effect. FBOP's Response: Program Statement 5500.14, Correctional Services Procedures Manual, is being modified to clarify what is required of a Lieutenant when conducting a round. Because revisions to Programs Statements must follow the normal FBOP development and Union negotiation process, they are subject to change. However, FBOP intends for the updated policy to include clarification for Lieutenants to conduct trainings sessions, via in-person required rounds and shift briefings daily. These trainings will cover topics such as cell searches, minor emergency mock discussions, and other correctional services training needs as assessed by local correctional services supervisors. This will allow for individual assessment and training to be tailored to the needs of each individual facility while also remaining in conformance with current training requirements. Training topics and formats will be documented on the Daily Lieutenant Logs and reviewed by the Captain to assess and implement specific local correctional training needs. Therefore, although no specific training curriculum will be developed, the training requirement and supervisory review will be in effect with the issuance of the updated program statement. Recommendation Six: The BOP should continue to develop and implement plans to address staffing shortages at its prisons. OIG Analysis: The BOP's update is responsive to the recommendation. The OIG will continue to monitor the GOP's progress regarding staffing shortages at its prisons. At the GOP's request, the OIG will not consolidate this recommendation. In addition, per the OIG's communications with the BOP over email, we believe that certain information that the BOP has provided or will provide to Congress and the Government Accountability Office (GAO) will facilitate the resolution and closure of this recommendation. Accordingly, we will consider whether to close this recommendation after the BOP (1) provides the OIG all contractor and BOP work product that has been submitted to the GAO in response to the GAO Staffing Audit recommendations, including the August 2022 assessment by the contractor on staffing incentives and the EFTA00141297

information BOP submitted to GAO in March 2023 related to the assessment; (2) provides the OIG an update on the contractor's or BOP's analysis of staffing incentives since March 2023, whether submitted yet to GAO or not; (3) provides the OIG any reports submitted to Congressional appropriation committees related to staffing; (4) implements the staffing tool for all BOP professions; and (5) provides an analysis of whether the new incentives mentioned in its update above have made an impact on the staffing shortage, and what additional proposals, including any legislative proposals to address pay rates in certain localities, are being considered by the BOP to fully address the staffing shortage. FBOP's Response: FBOP appreciates OIG's determination to not consolidate the analysis of this recommendation with that of Recommendation 5 from the OIG's Limited-Scope Review of the Federal Bureau of Prisons' Strategies to Identify, Communicate, and Remedy Operational Issues, Report Number 23-065 (Limited-Scope Review), at FBOP's request. OIG indicates that it will consider whether to close this recommendation after FBOP does the following: (1) OIG requests all contractor and FBOP work product that has been submitted to the GAO in response to the GAO Staffing Audit recommendations, including the August 2022 assessment by the contractor on staffing incentives and the information FBOP submitted to GAO in March 2023 related to the assessment. FBOP now provides the requested information. Please see the following attachments: "Attachment 1 Staffing_GAO 21-123," "Attachment 2 Staffing_GAO 21-123," "BOP Staffing Current State Assessment FINAL," "FINAL Incentives Playbook_All Resources_June 13," "Fully executed contract 2_Redacted," "Interviews and Survey Results," "NTT DATA Response to BOP Staffing Risk Management 04062021 Final," "SOW-BOP Staffing Risk Management_l," and "STATEMENT OF WORK." (2) OIG requests that FBOP provide an update on the contractor's or FBOP's analysis of staffing incentives since March 2023, whether submitted yet to GAO or not; The FBOP is currently analyzing the agency's usage and effectiveness of both recruitment and retention incentives. This analysis is ongoing. Therefore, FBOP will provide its analysis to OIG when completed. (3) OIG requests any reports submitted to Congressional appropriation committees related to staffing. See the following attachments: "FY23 BOP Vacancies at Facilities CRPT Package," "FY 2023 BOP CRPT Vacancies at BOP Facilities — Attachment," and "FY 2023 CRPT BOP FSA Implementation Q2 Hill Letters Package - WF220990." (4) OIG requests that FBOP implements the staffing tool for all BOP professions. Currently, the Automated Staffing Tool is a workforce planning tool that remains in development and testing. Position recommendations for the following departments have been completed and remain in ongoing testing and feedback stages: Correctional Services, Correctional Systems, Chaplaincy Services, Education, Food Service, Health Services, ITDD, Recreation, Safety, and Unit Management. EFTA00141298

All other disciplines are tentatively scheduled to be completed by October 2024. It is anticipated that the workforce planning tool will be fully utilized beginning in October 2024. (5) OIG requests FBOP to provide an analysis of whether the new incentives mentioned in its previous status update have made an impact on the staffing shortage, and what additional proposals, including any legislative proposals to address pay rates in certain localities, are being considered by the BOP to fully address the staffing shortage. Additional time will be required to determine the effect of those incentives implemented during the current fiscal year. However, it should be noted the FBOP was approved for nation-wide direct-hire authority by the Office of Personnel Management (OPM) on May 13, 2024. This will assist the FBOP in filling vacancies in the future. FBOP is working with the Department of Justice on a nationwide special salary rate request for our institution positions. Recommendation Seven: The BOP should evaluate its cell search procedures and make changes as may be appropriate to improve those procedures through policy, training, or other measures. OIG Analysis: The BOP's update is partially responsive to the recommendation. The update for Recommendation 5 is related to Lieutenant Rounds and not cell searches. The update does not indicate that the BOP has or will evaluate its cell search procedures and make any necessary changes to improve those procedures through policy, training, or other measures. The update only addresses the logging of cell searches within TRUSCOPE rather than evaluating its cell search procedures. The OIG will consider whether to close this recommendation after the BOP (1) completes the evaluation of using TRUSCOPE to log cell searches; (2) otherwise evaluates its cell search procedures and makes any appropriate changes to improve those procedures; and (3) provides a description of the training referenced in its response, sample training materials for OIG to review, and confirmation that the training is in effect. FBOP's Response: FBOP's Correctional Programs Division has evaluated current policy and training as related to cell searches. FBOP has concluded that cell search requirements, including appropriate documentation requirements via TRUSCOPE, are clearly outlined in two separate current policies: Program Statement 5500.15, Correctional Services Manual, and Program Statement 5521.06, issued January 2, 2018; and the Searches of Housing Units, Inmates, and Inmate Work Areas, issued on June 4, 2015. In addition to the general requirements for conducting cell searches contained in the above program statements, an institutional supplement is required for Security Inspections at each institution detailing specific local procedures. Locally, specific post orders are developed which include search requirements and documentation requirements. Current policy and training are adequate to convey the specific requirements for conducting cell searches. Further review indicates that specific training exists for conducting cell searches and is included in the below training curriculums. Initially, all staff receive specific training on cell searches during Introduction to Correctional Techniques, Phase I. Additionally, in January 2020, Back to Basics training was implemented as mandatory training for all institution employees. Back to Basics is an annual in-person training which includes a set curriculum with practical exercises. The sections listed below specifically include cell searches and practical exercises. EFTA00141299

• (Initial) Introduction to Correctional Techniques (ICT) Phase I, Tab 22: Conducting Searches. See attachment "ICTPhasel-Tab 22-IG." • (Annual) Back 2 Basics Managing Housing Units Part I - Conduct searches of the housing unit to include cell searches. See attachment "7-B2B-Managing Housing Units Part I-Lesson Plan-FY2024." • (Annual) Back 2 Basics Managing Housing Units Part 2 - Conduct searches of the housing unit to include cell searches (Practical Exercise). See attachment "8-B2B- Managing Housing Units Part II-Lesson Plan-FY2024." Therefore, because FBOP has demonstrated completion of its evaluation of using TRUSCOPE to log cell searches and its evaluation of cell search procedures, and has provided a description of training referenced, including confirmation that the training is currently in effect, FBOP now respectfully requests closure of this recommendation. Recommendation Eight: The BOP should enhance existing policies regarding institutional security camera systems to ensure they specifically state that such systems must have the capacity to record video and that BOP institutions must conduct regular security camera system functionality checks. OIG Analysis: The BOP's update is responsive to the recommendation. Accordingly, the OIG will consider whether to close this recommendation after the BOP (1) finalizes the policy updates referenced in its update; and (2) provides the finalized policies to the O1O for review. FBOP's Response: FBOP is currently in the process of making modifications to Program Statement 4200.12, Facilities Operations Manual; and Program Statement 5500.15, Correctional Services Manual, to include protocols and ensure accountability regarding various aspects of the FBOP's camera systems including but not necessarily limited to functionality, documentation, and repair. Because revisions to Programs Statements must follow the normal FBOP development and Union negotiation process, they are subject to change. FBOP will provide further updates pertaining to these revisions as they become available. To ensure immediate action, a joint memorandum (from FBOP's Administration Division and Correctional Programs Division) was sent to all CEOs addressing the Security Camera Monthly Report. The new report is now in use and became effective June 1, 2024. See attachments "Camera Report Implementation signed" and "Security Camera Report Template." EFTA00141300

FY2024 BACK 2 BASICS Instructor Guide LESSON: MANAGING HOUSING UNITS, PART I LENGTH: 1 Hour 30 Minutes (Recommended) INSTRUCTOR-TO-PARTICIPANT RATIO: 1:10 OBJECTIVES: Given the specific and general post orders of a housing unit, participants will be able to: • Discuss the objectives and expectations of post orders • Perform duties of a correctional post • Account for inmate work detail • Account for inmates on a pass system (if applicable) • Locate an absentee inmate • Conduct rounds in the housing unit • Conduct a fire and security check in the housing unit • Conduct searches of the housing unit to include cell searches • Identify procedures for confiscating and disposing of contraband • Conduct a bed book audit METHOD OF ASSESSMENT: • Knowledge Checks • Group Discussion PREREQUISITES: Back 2 Basics, Overview and Expectations INSTRUCTOR MATERIALS: • Lesson Plan • Copy of General and Specific Post Orders for local housing unit(s) • A Day in the Life of TRUSCOPE, PDF • Daily Security Check/Inspection Form, local • Inmate Accountability, Supplement • Security Inspections, Supplement • Inmate Personal Property, Institutional Supplement • Commissary List, local • List of authorized items for inmate personal property • Census Check Report, local example • Change Sheet, local example • Detail Roster, local example • Outcount, local example • Sample photocopies showing front and reverse of Inmate Picture Card • Sample photocopies of Bed Book pages Back 2 Basics 1 Managing Housing Units, Part I EFTA00141301

FY2024 BACK 2 BASICS Instructor Guide • Search log • Toolbox/Carrier with screwdrivers (Phillips and flathead) • Mirror • Flashlight • Keys to area(s) being searched • Probing devices • Metal detector • All other additional tools used to conduct area and cell searches STUDENT MATERIALS: Participant Manual, one (1) per participant, to include: • One (1) copy for each shift of Specific Post Orders, Housing Unit — local institution • One (1) copy for each shift of Special Post Orders, Housing Unit — local institution • List of authorized items for inmate personal property • Commissary list, local • Daily Fire and Security Inspection Form, local • Pencil(s) Group Resource Manual, one (1) per group, to include: • Inmate Accountability, Institution Supplement • Inmate Personal Property, Institution Supplement • Title and Location of Post Orders Form • Post Order Review Sheet • A Day in the Life of TRUSCOPE, PDF • All Program Statements located in the housing unit post orders, local • All Institution Supplements located in the housing unit post orders, local • Any other documentation to include local procedures that may be used to support the lesson Activities, one (1) copy for each group, to include: • Activity #1— Locating an Absentee Inmate • Activity #2 — Conducting Rounds in the Housing Unit • Activity #3 — Conducting Fire and Security Checks • Activity #4 — Conducting Searches of the Housing Unit and Inmate Cells REFERENCES: • P.S. 3420.11, Standards of Employee Conduct • P.S. 5270.09, CN-1 Inmate Discipline Program • P.S. 5270.11, Special Housing Units • P.S. 5500.14, CN-1, Correctional Services Procedures Manual • P.S. 5500.15, Correctional Services Manual • P.S. 5521.06, Searches of Housing Units, Inmates, and Inmate Work Areas Back 2 Basics 2 Managing Housing Units, Part I EFTA00141302

FY2024 BACK 2 BASICS Instructor Guide • P.S. 5566.06, CN-1, Use of Force and Application of Restraints • P.S. 5580.08, Inmate Personal Property • P.S. 5580.09, Inmate Property Claims • Introduction to Correctional Techniques (ICT) Phase I, Tab 17: Counts, Checks, and Accountability Resources • Introduction to Correctional Techniques (ICT) Phase I, Tab 22: Conducting Searches • SENTRY General Use Technical Reference Manual • Inmate Accountability, Institution Supplement, various institutions • Inmate Personal Property, Institutional Supplement, various institutions APPENDIX: No POWERPOINT: No RECOMMENDED INSTRUCTORS: Housing Unit Officer and Captain or Lieutenant. SPECIAL NOTES: It is critical to review the lesson plan thoroughly prior to delivery. Be prepared with all local information and documentation to present at times indicated throughout the lesson. Back 2 Basics 3 Managing Housing Units, Part I EFTA00141303

FY2024 BACK 2 BASICS Instructor Guide LOGISITCS: This course, Managing Housing Units, is divided into two (2) parts, Part I and Part II. Participants must complete both parts to receive training credit. Part I of this lesson should be conducted at a common area for employees only. The area should be a confined area for open discussion about sensitive issues and topics. Examples of areas to conduct Part I include a training center, a classroom, or a visiting room. Part II of this lesson should be conducted inside a housing unit. The purpose of Part II of the lesson will be to conduct or assist with at least one (1) or all of the following practical exercises as indicated by the Warden: • Area search • Cell search • Irregular Round • Bed Book Audit • Fire and Security Check PRIOR TO INSTRUCTION: 1. Read all components of the curriculum (i.e., lesson plan and activities.) 2. Refer to the Warden or other delegated official for the specific location of Part I and Part II of the lesson. Consider the approximate time it will take to move from the location of Part I to the location of Part II (if applicable). Plan accordingly. 3. Print all documents to represent your local facility for the Participant Manual. 4. Print all documents to represent your local facility for the Group Resource Manual. 5. Prepare for instruction. This includes addressing the following: • Number of Participants: Determine how many participants will be in attendance. • Participant Manual: Using the number of participants in the class, copy the number of student packets you will need (one per participant) to conduct the training. Note: Since participants will not be writing on these manuals, you may use them again for other scheduled classes of Managing Housing Units. • Group Resource Manual: Determine how many groups of five (5) participants will be in the class. Make copies, one (1) for each group, to conduct the training. Note: Since participants will not be writing on these manuals, you may use them again for other scheduled classes of Managing Housing Units. • Activities: Copy the number of activities needed; that is, one (1) activity for each group. Participants will write on these activity sheets, therefore, you will need to make additional copies for other scheduled classes of Managing Housing Units. 6. Take all printed materials to the training site identified for Part I of this course. Back 2 Basics 4 Managing Housing Units, Part I EFTA00141304

FY2024 BACK 2 BASICS Instructor Guide SPECIAL NOTE: Accountability of Materials: All materials should be collected, accounted for, and removed from the location when training and/or practical exercises are conducted in the presence of inmates. Absolutely NO materials should be in circulation for Part II of this lesson. AT THE TRAINING SITE: 1. Identify locations for small groups (and group discussion). Place a Group Resource Manual in each group location. 2. Identify the seating of the groups. Place a Participant Manual at each seat. 3. Once all participants have arrived, divide the participants into groups of five (5). It is highly recommended that each small group be a mixture of at least one (1) employee in correctional services (any grade) plus a combination of other disciplines. 4. Allow groups to form and settle in their seats before you begin instruction. Back 2 Basics S Managing Housing Units, Part I EFTA00141305

P12024 BACK 2 BASICS Instructor Guide I. INTRODUCTION For this module of Back 2 Basics, we will be reviewing policy and procedures for effectively performing duties when managing a housing unit. Note: Refer to the Participant and Group packets. Note: Describe the logistics of the training. This should include start time, stop time, breaks, location change (if applicable), etc. Note: Ask if there are any questions before continuing. Address all questions. II. POST ORDERS A. General Post Orders Note: Instruct participants to look at their individual packets for specific post orders. Post Orders describe all procedures and any special instructions regarding a specific post. Per Program Statement, Correctional Services Procedures Manual, post orders must be based on Bureau and institution policies, must state each post's duty hours, and must be prepared under the Captain's supervision and direction. Note: Discuss procedures for reviewing and signing post orders in the Lieutenant's office. Discussion: What is the procedure if there is no opportunity to review post orders? In these cases, it is the responsibility of the employee to inform the employer of the fact they have not been able or afforded the opportunity to read such orders. The employer will then advise the employee of the general requirements of the post and answer any questions. Employees assuming posts under these circumstances still have the responsibility of exercising sound correctional judgment based upon their training and experience and will make reasonable efforts to read the post orders as soon as practicable. Note: Refer to the Group Resource Manual. Ask them to take a look at the Title and Location of Post Orders and Post Order Review Sheet noting the areas where signatures are needed. Ask if there are any questions before continuing. Each post order will contain instructions regarding the immediate action an employee should take in an emergency situation. These "first responder" instructions should contain specific action steps including, but not limited to, containment, employee protective considerations, and emergency reporting protocols. Particular requirements regarding assaultive inmates, suicides, fires, evacuation routes, and other "immediate" response emergency situations are addressed and are consistent with the corresponding Emergency Plan. Back 2 Basics 6 Managing Housing Units, Part I EFTA00141306

Pi'2024 BACK 2 BASICS Instructor Guide B. Specific Post Orders Note: Refer to the Group Resource Manual as needed for the next section. All post orders contain five (5) separate sections in the following order: Section 1: Activities listed chronologically with responsibilities clearly defined. Section 2: Special instructions relating to the specific post. Section 3: General Post Orders - applicable to all posts. Section 4: List of Program Statements and Institution Supplements relevant to the post. Section 5: Employee Signature sheet. Post orders and log books are confidential documents and should never be left unattended or in an area accessible to inmates. They must be secured at all times when not in use by employees. Knowledge Check: Where are the Post Orders located in housing units at this institution? Knowledge Check: Where should you log pertinent information regarding inmates? Note: Ask if there are any questions regarding Post Orders. Upon completion of discussion, continue with instruction. III. ASSUMING DUTIES OF A CORRECTIONAL POST Discussion: What are some of the first things you must do upon arriving? A. Begin Logging Documentation According to the Correctional Services Procedures Manual and our identified post orders, you must begin logging documentation in TRUSCOPE. Items that must be logged upon assuming the post include: • Date • Shift • Base count of the unit (number of inmates) • Your name (printed legibly) • Key ring number • Number of keys • Equipment • Details about the fire alarm panel (indicating if it is operational) Back 2 Basics 7 Managing Housing Units, Part I EFTA00141307

FY2024 BACK 2 BASICS Instructor Guide Knowledge Check: What should you do if the fire alarm panel is not operational? B. Contact Control In addition to logging in the details of equipment, you should contact Control and, with their approval, • conduct a test of your radio/body alarm, and, • verify the unit count. C. Dial in with the Operations Lieutenant Once the base documentation is logged, you may contact the Operations Lieutenant or dial in for a briefing. It is at this time you should address any questions or concerns you may have about the shift. Note: Discuss local procedures for contacting Operations Lieutenant upon assuming duties. IV. ACCOUNTABILITY OF INMATES ON DETAIL Accounting for inmate work detail is a crucial part of inmate accountability as all departments and locations throughout the institution are responsible. If an inmate on your work detail is missing, the inmate is considered 'absent' and you should follow all procedures for locating the absentee inmate. Each detail supervisor should carry the updated and current electronic printout with them throughout the day. Note: Refer to your institution's procedures for printing and collecting Detail/Crew Kit Cards. A. Detail/Crew Kit Cards The Detail Crew Kit on BOPWARE will automatically be updated to reflect new admissions and any job or quarter's changes via SENTRY. Each crew kit has current detail cards on all inmates assigned to the detail. The printouts are never to be left unattended or in an area accessible to inmates. At a minimum, crew kit cards provide: • Names of the inmates; • Register number; • Current photo (a new photo must be made whenever an inmate's appearance changes); • Job assignment; • Quarters assignment; • Custody level; and • Any special conditions. Back 2 Basics 8 Managing Housing Units, Part I EFTA00141308

FY2024 BACK 2 BASICS Instructor Guide Inmates will never be allowed to handle detail/crew kits and/or the cards assigned to the kits. Note: Discuss how to identify an inmate that is on the posted picture file. The inmate is identified with an asterisk. Note: Discuss local procedures for reporting discrepancies in detail/crew kit cards. Note: Discuss the shift/responsibility for collecting the detail/crew kits for your local institution. Note: Discuss the specific location where the detail/crew kits can be found in the housing units (e.g., top drawer in desk of officer's station, etc.). B. Detail Accountability Checks Detail accountability checks are conducted to identify inmates in unauthorized areas, and to determine the presence and accuracy of detail cards (crew kit cards). AM/PM census checks will be documented on Daily Fire and Security Inspection Reports. You must conduct an AM/PM census of all inmates assigned to your area during each work period. Any discrepancies found during the census will be recorded on the inspection report and must be reported to the Operations Lieutenant immediately. C. Excusing Inmates from Detail Knowledge Check: Who can authorize excusing an inmate from work? The Associate Warden overseeing the department maintains the sole authority to "lay in" a Work Detail. Detail Supervisors are not authorized to release inmates from their assigned details prior to the end of normal working hours. As an additional note, Detail Supervisors will not make sick call appointments for inmates. V. LOCATING AN ABSENTEE INMATE If you are responsible for managing the housing unit, it is your responsibility to locate the inmate on your work detail. With that in mind, make proper notifications and take appropriate action against the inmate right away. Knowledge Check: What are the steps to take if inmates are missing or absent from their work? Note: Allow input from employees before continuing. Back 2 Basics 9 Managing Housing Units, Part I EFTA00141309

FY2024 BACK 2 BASICS Instructor Guide Per Program Statement 5500.14, inmates who are missing or absent from their work details should be located in the following manner: 1. Take immediate action to locate the inmate if the inmate does not report to work as scheduled within ten (10) minutes or fails to return from an appointment. 2. Exhaust all avenues of locating the inmate by calling appointments, the inmate's assigned housing unit, visiting room (if applicable), and Health Services. If the absent inmate cannot be located after ten (10) minutes, notify the Lieutenants Office. At this point, the Lieutenants Office will assume responsibility for locating the inmate. 3. The Lieutenant will ensure proper notifications are made and proper action is taken when the inmate is found. Note: Discuss the following in as much detail as needed for your location. A. Daily Change/Transfer Sheet The Daily Change/Transfer Sheet is a SENTRY generated list which denotes changes in an inmate's status. This sheet must be published each regular work day. It includes changes in the following: • Housing unit; • Job assignment; • Medical idle; and/or, • Convalescence which exceeds one (1) day. Note: Identify where and how employees can locate the Daily Change/Transfer Sheet in your local housing units. B. Inmate Callouts The Call-Out sheet lists appointments inmates have with employees and is produced by SENTRY. As you know, it lists the reporting time and physical area where inmates are scheduled to report. The Call-Out sheet is made available to employees and posted in the inmate housing units. The employee who places the inmate on call-out must ensure the requested inmate arrives at the specified time. Discussion: Who is responsible for ensuring the inmate arrives to the callout at the specific time? Note: Identify where and how employees can locate the Inmate Callouts in your local housing units. Back 2 Basics 10 Managing Housing Units, Part I EFTA00141310

FY2024 BACK 2 BASICS Instructor Guide C. Sick Call Discussion: What are times and days for Sick Call? For Sick Call, inmates will report to the Health Services Department. When an inmate, for medical reasons, is excused from work, Health Services employees will issue two (2) copies of the Medical Idle Authorization to the inmate. The inmate will retain one copy of the idle and deliver the second copy to the Housing Unit Officer. Knowledge Check: Who is responsible for notifying the work supervisor of the inmate's idle status? The Unit Officer will notify the work supervisor of the inmate's idle status. Once an appointment is made, the inmate will return to their unit until the assigned appointment. Inmates will return to Health Services during the assigned movement and remain there until released by the Health Services employees. D. SENTRY Discussion: What are the SENRY functions that may be used for locating an inmate? Some of the most notable options include PP42/PP44, Current Assignments and PP37, History. Note: Discuss any additional SENTRY options, as needed or mentioned by employees. VI. ACTIVITY #1— LOCATING AN ABSENTEE INMATE Note: Distribute the worksheet for Activity #1 — Locating an Absentee Inmate, one (1) per group. Facilitate the activity using the instructor notes provided. Upon completion, continue instruction. VII. CONDUCTING ROUNDS A. Irregular Rounds Every employee is responsible for the custody, control, supervision, and accountability of all inmates in their area of responsibility and supervision. Housing unit posts should make irregular rounds of the units they are assigned. Although there are no scheduled rounds when moves are open, it is imperative to make rounds for the security and orderly operation of the institution once moves are closed and the unit is locked. Upon completion of each round, notification of completion and any additional notes should be logged Back 2 Basics 11 Managing Housing Units, Part I EFTA00141311

FY2024 BACK 2 BASICS Instructor Guide into TRUSCOPE. Note: Discuss any additional local procedures for conducting rounds. B. Rounds During Lock Down Status in the Housing Unit Per policy, when inmates are in lock down status, rounds must be conducted at least once in the first 30 minute period of the hour (example, 12:00 a.m. — 12:30 a.m.) followed by another round in the second 30 minute period of the same hour (example, 12:30 a.m. — 1:00 a.m.). This ensures that an inmate is observed at least twice per hour. These rounds are to be conducted on an irregular schedule and no more than forty (40) minutes apart. Note: Clearly define lock down status as applicable to housing units during normal operations. VIII. ACTIVITY #2 — CONDUCTING ROUNDS IN THE HOUSING UNIT Note: Distribute the worksheet for Activity #2 — Conducting Rounds in the Housing Unit, one per group. Facilitate the activity using the instructor notes provided. Upon completion, continue instruction. IX. CONDUCTING FIRE AND SECURITY CHECKS Each detail supervisor or departmental employee will conduct a daily security and fire inspection of their assigned area. The result of these inspections will be submitted on your local Daily or Weekly Security and Fire Inspection Report. Employees will use TRUSCOPE to log in the time conducted and findings, if applicable. The areas listed on the Daily Security and Fire Inspection Report should be completed at the conclusion of each manned shift. Knowledge Check: When should the Daily Fire and Security Checks be conducted? Note: Provide any feedback and/or procedures for your local facility. A. Fire and Security Inspection Report, Daily While managing a housing unit, you will be expected to perform the fire and security inspection in accordance with outlined procedures. Upon completion of the inspection, you will document your findings in TRUSCOPE noting any discrepancies found, along with the action taken to address the problem. If the discrepancy is considered significant or major, you will contact the Lieutenant's office immediately. Note: Refer to the Participant Manual for the Daily Fire and Security Inspection Report. Back 2 Basics 12 Managing Housing Units, Part I EFTA00141312

FY2024 BACK 2 BASICS Instructor Guide Discuss how to document findings once the inspection is completed. B. Security Work Orders/Requests If you find a safety or sanitation issue which requires corrective action, you should note the problem on the form and submit a written work request to get the problem fixed. Note: Identify the location of the work order form and the local procedures for submission. C. Memoranda A memorandum is used to document safety issues encountered during your checks. Discussion: Who should receive a copy of this memorandum? X. ACTIVITY #3 — CONDUCTING FIRE AND SECURITY CHECKS Note: Distribute the worksheet for Activity #3 — Conducting Rounds in the Housing Unit, one (1) per group. Facilitate the activity using the instructor notes provided. Upon completion, continue instruction. XI. CONDUCTING SEARCHES OF THE HOUSING UNIT A. Searches of the Housing Unit The inspection of a housing unit is primarily designed to detect contraband, prevent escapes, maintain sanitation standards, and to eliminate fire and safety hazards. Frequent and irregular searches should be conducted of all inmate living areas to include: • Cells • Cubicles • Storage rooms • Supply rooms • Common areas • Plumbing accesses • Walls • Plumbing fixtures • Showers, to include drains • Additional locations not mentioned above The employee assigned to the area will be responsible for noting the date, time, results, and name of searching employee according to local procedures. Searches of the inmate living areas will be conducted frequently and properly documented in TRUSCOPE. Back 2 Basics 13 Managing Housing Units, Part I EFTA00141313

FY2024 BACK 2 BASICS Instructor Guide Note: Identify how searches of the housing unit should be documented at your local facility. Approaches to conduct searches in all areas of the housing unit include: 1. Visual A visual inspection must be conducted inside the unit for items such as bent or spread bars, broken welds, cracked or cut bars, and any sign of steel filings. Any other evidence of tampering or weakness such as fresh paint or discolored areas is to be thoroughly investigated. 2. Bar Tapping Accurate bar taps call for the use of a mallet to tap security bars and frames to set up vibrations which, by their deviation from normal sound, would indicate tampering or weakness. All housing unit bars within the institution will be tapped weekly, and this information should be recorded accordingly. Note: Discuss procedures for recording bar taps at your local institution. 3. Metal Instrument A thin instrument such a putty knife can be passed along frames or bars to locate cuts or depressions which might indicate tampering. The instrument can also be used as a probe to uncover cuts filled with soap, putty, or other substances. Knowledge Check: How often are bar taps completed? Note: Explain the location and/or procedures for obtaining tools used for conducting searches. 4. Mirror A mirror is an effective instrument for examining areas that would ordinarily be difficult to inspect. A mirror may be used to inspect any area that ordinarily would be difficult to observe during a routine visual inspection. Knowledge Check: What areas in the housing units are best searched using a mirror? B. Searches of Inmate Cells Employees may search an inmate's housing area and any personal items contained within an area, without prior notice, inmate approval, or inmate's presence. An inmate will be removed from the cell and searched prior to the cell search. When conducting the cell search, all items Back 2 Basics 14 Managing Housing Units, Part I EFTA00141314

P12024 BACK 2 BASICS Instructor Guide in the cell should be carefully searched and, as nearly as possible, returned to their original order upon completion. When conducting a cell search, particular attention must be paid to the following: • Plumbing facilities • Ventilation ducts • Beds • Bedding • Chairs • Commissary items • Books • Additional items/locations not mentioned above False shoe bottoms, secret compartments and hollow legs are possibilities for concealing contraband. Discussion: What are some other common areas for concealing contraband that have not been mentioned? The employee searching the cell will be responsible for noting the date, time, inmate's name, inmate's register number, cell/room number, results, and name of searching employee in TRUSCOPE. Identify how cell searches should be documented at your local facility. C. Contraband Here are only a few items of contraband and locations it may be commonly found in the housing units: • Cell phones hidden in doors • Cell phones hidden inside of soda cans • Cell phones hidden in soap • Cigarettes hidden in all areas of inmate cells • Tattoo Kits hidden in soda cans • Contraband safes made out of Ramen Noodles • Handcuff Keys made from inhalers • Homemade intoxicants in all areas of the housing units • Homemade tobacco pipes • Officer safety items hidden as contraband • Secret contraband storage spaces • Shanks created from printer cartridges Back 2 Basics 15 Managing Housing Units, Part I EFTA00141315

FY2024 BACK 2 BASICS Instructor Guide • Tobacco and other items hidden in Bibles Note: Discuss additional contraband items and locations. When conducting searches of inmates, housing units, and cells, it is important to be familiar with items inmates may and may not have. When in doubt, you can refer to the local Commissary List and/or the Inmate Personal Property List. You may also ask the inmate to provide a receipt of purchased items. Note: Inform participants to refer to the local Commissary Sheet and/or Inmate Personal Property List in the Participant Manual as needed. Knowledge Check: What would you do if you found an item you suspected was contraband but wasn't completely sure? 1. Areas Approved for Inmate Property Storage Inmates in the general population housing units will be issued specific locations for the storage of personal property, for example, lockers. Items authorized outside of the areas may include items such as: • One (1) mesh laundry bag • Footwear • Issued clothing Property storage may not be in offices of the unit team or the correctional supervisor except in temporary, emergency situations. Note: Discuss specific locations in your location for property storage. Discuss any special instructions (e.g., shoes should be stored under the bunks). 2. Confiscation and Disposal of Contraband Confiscated contraband will be disposed of in accordance with institution procedures. Exceptions from these procedures can only be made upon written authorization of the Warden or his designee. Note: Discuss local procedures for recovering contraband. Include procedures for • excess property • hard contraband • cash or negotiable instruments • postage stamps Back 2 Basics 16 Managing Housing Units, Part I EFTA00141316

FY2024 BACK 2 BASICS Instructor Guide Note: Discuss local procedures for identifying and logging contraband recovered during searches. XII. ACTIVITY #4 — CONDUCTING SEARCHES OF THE HOUSING UNITS AND INMATE CELLS Note: Distribute the worksheet for Activity #4 — Conducting Searches of the Housing Units and Inmate Cells, one (1) per group. Facilitate the activity using the instructor notes provided. Upon completion, continue instruction. XIII. CONDUCTING BED BOOK AUDITS Knowledge Check: When should employees conduct a bed book audit? Note: Allow participants to provide feedback. Provide feedback for your local facility. A minimum of one (1) bed book audit will be conducted every 24-hour period to ensure the accuracy of inmate assignments. Note: Provide information on where/how the Bed Book is retrieved/located at your local facility. The Bed Book contains the following information for each inmate: • Inmate's name • Register number • Cell location • Job assignment • Custody level • Any additional information (e.g., medical information) Bed Book Cards are strictly confidential and should never be viewed by inmates. A. Procedures for Conducting a Bed Book Count At least two (2) employees will conduct bed book audits. Inmates must be positively identified using printed pictures, by asking the inmates to state both their name and register number. Both employees must agree the inmate matches the picture, name, and register number on the bed book card. Inmates must also be in their assigned cell as documented in the bed book and unit SENTRY roster. The first employee will carry the SENTRY roster while the second employee will carry the Bed Book picture roster. Upon completing count, both officers verify all inmates are present, compare the numbers with each of the counting employee, and identify any inmates not Back 2 Basics 17 Managing Housing Units, Part I EFTA00141317

FY2024 BACK 2 BASICS Instructor Guide present in the housing unit. Note: Discuss local procedures for conducting a Bed Book Count. Employees will then call Control Center and verify this information. B. Updating an Inmate's Picture Card Discussion: What issues warrant the update of a picture card? When conducting a Bed Book count, you may discover that an inmate has changed their physical appearance. If this is the case, the following standard operating procedures should occur: 1. Find correct inmate Picture Card on file. 2. Write and submit a memorandum to the Unit Team requesting a new picture be taken and explain why. 3. Use reverse side of Picture Card to note changes in the inmate's physical appearance. 4. Return Picture Card file to proper secure location. Knowledge Check: Who can request the update of a picture card? Any employee can submit the request for an inmate's picture card to be updated. The same procedures mentioned above will apply to any employee submitting the request. 1. Locate inmate's Picture Card. 2. Record information from inmate's Picture Card into assigned bed/cell slot in unit Bed Book. 3. File inmate's Picture Card with your unit cards. XIV. SUMMARY In summary, managing a housing unit has many complex duties and responsibilities. The Back to Basics training program has been designed to revisit those fundamental tasks that depend on the overall safety and security of the institution as a whole. Back 2 Basics 18 Managing Housing Units, Part I EFTA00141318

FY2024 BACK 2 BASICS Instructor Guide ACTIVITIES Part I Managing Housing Units Back 2 Basics 19 Managing Housing Units, Part I EFTA00141319

FY2024 Instructor Guide Group Discussions: Challenges and Solutions Time Frame: 15 minutes each (Recommended) Objectives: Given a topic of discussion, participants will be able to: • Discuss challenges and possible solutions for the given topic for managing housing units. Instructor Materials: • Pencils • Copies of worksheets, one (1) per group, to include: o Activity #1— Locating an Absentee Inmate o Activity #2 — Conducting Rounds in the Housing Units o Activity #3 — Conducting Fire and Security Checks o Activity #4 — Conducting Searches of the Housing Units and Inmate Cells Instructor Notes: 1. Divide the participants into groups of five (5) participants per group. 2. Pass out the Group Discussion worksheet for the identified activity. 3. Announce the topic to the groups. Instruct all participants to take ten (10) minutes discussing the challenges they face with the given topic and write up to four (4) of them down on the worksheet provided. Once they have identified the challenges, groups can discuss the possible solutions, noting any talking points in the space provided under the solutions heading. 4. Upon completion of the discussion, groups should appoint a lead speaker who will share findings with the class. 5. After the ten (10) minutes of discussion time is complete, allow groups to share their answers with the class. Debrief: Take time shortly after conducting this activity to reflect on how it went, how engaged the participants were, and what questions were raised, if any. Make any notes that may need further discussion regarding your institution. Back 2 Basics 20 Managing Housing Units, Part 1 EFTA00141320

FY202.1 Instructor Guide 1 2 3 4 Back 2 Activity #1 — Locating an Absentee Inmate Group Discussion Directions: Discuss challenges and solutions regarding locating an absentee inmate using Daily Change/Transfer Sheet, Inmate Callouts, Detail Crew Kits, Sick Call, and SENTRY. Write the discussion points for each challenge and the group's solution in the space provided. Be prepared to discuss with the class. You may use past experiences as examples. CHALLENGE SOLUTION To include past experiences, interferences, or To include ideas and past experiences recurring issues (if applicable) 21 Managing Housing Units, Pan 1 EFTA00141321

I Y2024 Instructor Guide 1 2 3 4 Back 2 a Activity #2 — Conducting Rounds in the Housing Unit Group Discussion Directions: Discuss challenges and solutions regarding conducting rounds on any given shift. Write the discussion points for each challenge and the group's solution in the space provided. Be prepared to discuss with the class. You may use past experiences as examples. CHALLENGE SOLUTION To include past experiences, interferences, or To include ideas and past experiences recurring issues (if applicable) 22 Managing Housing Units, Pan 1 EFTA00141322

FY2024 Instructor Guide Activity #3 — Conducting Fire and Security Checks Group Discussion Directions: Discuss challenges and solutions regarding conducting daily fire and security checks at your local facility. Write the discussion points for each challenge and the group's solution in the space provided. Be prepared to discuss with the class. Refer to the Daily Fire and Security Inspection Report in your Participant Manual as needed. You may use past experiences as examples. CHALLENGE SOLUTION To include past experiences, interferences, or To include ideas and past experiences recurring issues (if applicable) 1 2 3 4 imok p S Back 2 Basics 23 Managing Housing Units, Part 1 EFTA00141323

FY202.1 Instructor Guide Activity #4 — Conducting Searches of the Housing Unit and Inmate Cells Group Discussion Directions: Discuss challenges and solutions regarding official counts and census and accountability checks. Write the discussion points for each challenge and the group's solution in the space provided. Be prepared to discuss with the class. You may use past experiences as examples. CHALLENGE SOLUTION To include past experiences, interferences, or To include ideas and past experiences recurring issues (if applicable) 1 2 3 4 p S Back 2 Basics 24 Managing Housing Units, Part 1 EFTA00141324

FY2024 BACK 2 BASICS Instructor Guide LESSON: MANAGING HOUSING UNITS, PART II LENGTH: As Identified per activity INSTRUCTOR-TO-PARTICIPANT RATIO: As indicated for each activity OBJECTIVES: Given the content discussed in the lesson titled, "Back 2 Basics, Managing Housing Units, Part I," participants will be able to: • Conduct an area search of the housing unit • Conduct a cell search in a housing unit • Conduct a round in the housing unit • Conduct a bed book audit • Conduct a Fire and Security Check METHOD OF ASSESSMENT: • Performance-Based Evaluation PREREQUISITES: • Back to Basics, Overview and Expectations • Back to Basics, Managing Housing Units, Part I INSTRUCTOR MATERIALS: As indicated per activity STUDENT MATERIALS: As indicated per activity REFERENCES: Back to Basics, Managing Housing Units, Part I APPENDIX: No POWERPOINT: No RECOMMENDED INSTRUCTORS: Captain and/or Lieutenant as delegated plus one (1) additional supporting employee to assist in the oversight of individual activities. Back 2 Basics 1 Managing Housing Units, Part II EFTA00141325

FY2024 BACK 2 BASICS Instructor Guide SPECIAL NOTES: The attached activities will take place in an inmate housing unit at the local facilities. Individual activities chosen and the desired number to conduct will vary for each institution. All options are at the discretion of the Warden for each respective facility. Managing Housing Units, Part I must be completed prior to conducting the activities identified in this portion of the lesson. PRIOR TO INSTRUCTION: 1. Gather all critical information needed to effectively conduct the activity(ies). This includes: • Number of employees participating in the activity(ies). • Location of housing unit where activity(ies) will be conducted. • Location of inmates while the activity(ies) are being conducted (i.e., whether inmates will be relocated to a different area such as Recreation, inmates will be locked in their cells, etc.). • Specific activity(ies) to conduct with the employees. 2. Review all activities in detail, considering the information mentioned above. 3. Gather all student materials as indicated for each activity. 4. Take all materials, if applicable, to the identified housing unit. SPECIAL NOTE: Accountability of Materials: All materials should be collected, accounted for, and removed from the location when training and/or practical exercises are conducted in the presence of inmates. Absolutely NO materials should be in circulation for Part II of this lesson. Back 2 Basics 2 Managing Housing Units, Part II EFTA00141326

FY2024 BACK 2 BASICS Instructor Guide Activity #1: Conduct an Area Search of the Housing Unit Time Frame: 30 minutes Instructor to Participant Ratio: 1:30 Objectives: Given a Daily Fire and Security Inspection Report, a Commissary List, and a list of Inmate Personal Property for the local facility, participants will be able to: • Successfully complete an area search for a housing unit. Instructor Materials: • Pencils • Copies of Daily Fire and Security Inspection Report, local, one (1) per group of two (2) participants • Copies of Commissary List, local, one (1) per group of two (2) participants • Copies of Inmate Personal Property, local, one (1) per group of two (2) participants • Identified tools needed to conduct the search Instructor Notes: 1. Divide the participants into groups of two (2) participants per group. 2. Pass out one (1) Daily Fire and Security Inspection Report, one (1) Commissary List, and one (1) Inmate Personal Property List per group. 3. Inform employees to refer to the Fire and Security Inspection Report as needed. 4. Refer to local guidance for details to conduct the search. Debrief: Take time shortly after conducting this activity to reflect on items noted, found, and documented. Make any notes that may need further discussion regarding your institution. Back 2 Basics 3 Managing Housing Units, Part II EFTA00141327

FY2024 BACK 2 BASICS Instructor Guide Activity #2: Conduct a Cell Search in a Housing Unit Time Frame: 15 minutes Instructor to Participant Ratio: 1:10 Objectives: Given a Commissary List and a list of Inmate Personal Property for the local facility, participants will be able to: • Successfully complete a cell search for a housing unit. Instructor Materials: • Pencils • Copies of Commissary List, local, one (1) per group of two (2) participants • Copies of Inmate Personal Property, local, one (1) per group of two (2) participants • Identified tools needed to conduct the search Instructor Notes: 1. Divide the participants into groups of two (2) participants per group. 2. Pass out one (1) Commissary List and one (1) Inmate Personal Property List per group. 3. Initiate the evaluation by assigning the participant to search a designated area. 4. Observe the participant. Limit interaction with the participant. Do not coach nor answer questions which would give the participant an advantage. 5. The following sequence of steps should be stressed while evaluating the performance of each participant: 6. Obtain required search tools. 7. Plan a systematic search process: 8. Verbally describe the plan for searching the area. 9. Look over the area to be searched; establish an overall impression; identify suspicious circumstances. 10. Select a starting point. 11. Inspect the area and all contents. 12. Follow described search strategy. Ensure the participants: • Search the cell; check all movable or installed items and equipment; use tools as appropriate; take notes of unusual circumstances or needed repairs. • Continue search after contraband is found. • Leave cell as it was found. • Confiscate and remove contraband. Back 2 Basics 4 Managing Housing Units, Part II EFTA00141328

FY2024 BACK 2 BASICS Instructor Guide • Document the search. • Optional, prepare Work Requests. Debrief: Take time shortly after conducting this activity to reflect on items noted, found, and documented. Make any notes that may need further discussion regarding your institution. Back 2 Basics S Managing Housing Units, Part II EFTA00141329

FY2024 BACK 2 BASICS Instructor Guide Activity #3: Conduct an Irregular Round in a Housing Unit Time Frame: 15 Minutes Objectives: Given local guidance, participants will be able to: • Conduct a successful round in the housing unit. Instructor Materials: • Pencils • Computer with TRUSCOPE Instructor Notes: 1. Divide the participants into groups of three (3) participants per group. 2. Provide specific guidance to groups on how to conduct an effective round of the housing unit. Note areas that may need closer inspection. 3. Upon completion, instruct one (1) of the three (3) participants to record their findings in TRUSCOPE. Debrief: Take time shortly after conducting this activity to reflect on how it went, how engaged the participants were, and what questions were raised, if any. Make any notes that may need further discussion regarding your institution. Back 2 Basics 6 Managing Housing Units, Part II EFTA00141330

FY2024 BACK 2 BASICS Instructor Guide Activity #4: Conduct a Bed Book Audit Time Frame: 1 Hour Objectives: Given specific instruction, participants will be able to: • Effectively conduct a bed book audit of inmates in the housing unit. Instructor Materials: • Pencils • Picture Card File, Electronic or Paper • SENTRY Roster • Memorandum (if applicable) Instructor Notes: 1. Retrieve the inmate bed book. 2. Print the SENTRY roster of inmates in the housing unit. 3. Provide additional guidance to employees, if needed. 4. Instruct the employees to conduct the bed book audit of the housing unit. Back 2 Basics 7 Managing Housing Units, Part II EFTA00141331

FY2024 BACK 2 BASICS Instructor Guide Activity #5: Conduct a Fire and Security Check of the Housing Unit Time Frame: 30 minutes Instructor to Participant Ratio: 1:30 Objectives: Given a Daily Fire and Security Inspection Report local facility, participants will be able to: • Successfully complete a daily fire and security inspection for a housing unit. Instructor Materials: • Pencils • Copies of Daily Fire and Security Inspection Report, local, one (1) per group of two (2) participants Instructor Notes: 1. Divide the participants into groups of two (2) participants per group. 2. Pass out one (1) Daily Fire and Security Inspection Report, one (1) Commissary List, and one (1) Inmate Personal Property List per group. 3. Inform employees to refer to the Fire and Security Inspection Report as needed. Inform them to consider the following: • Inspect safety items • Check light fixtures, wiring, and outlets for damage, tampering, overloading. • Check access routes for obstructions. • Check waste receptacles for improper/unsafe disposal. • Check smoke detectors/alarms/signaling devices for damage or malfunction. • Check firefighting equipment and SCBA for damage or malfunction. • Check personal safety equipment for wear and damage. • Check for the presence of contraband. • Inspect sanitation items • Check trash receptacles for cleanliness, overflow, and proper disposal. • Check structure/fixtures for dirt and damage. • Check living areas/furnishings/carpets for dirt, stains, and damage. • Check bathrooms/showers/plumbing for dirt, obstructions, and adequate supplies. • Check for signs of infestation (insects, rodents). • Inspect security items • Check gates/doors/windows for damage and tampering. Back 2 Basics 8 Managing Housing Units, Part II EFTA00141332

FY2024 BACK 2 BASICS Instructor Guide • Check manholes/tunnels/access points for damage and tampering. • Check interior structure/features for tampering. • Check for the presence of contraband. • Check fences/perimeter walls for damage and tampering. • Check building walls/roofs for damage and tampering. • Check locks for damage, tampering, and proper operation. • Use the mallet to tap bars and grills. • Use a putty knife to check space between walls and fixtures. • Use a flashlight to check dark areas. 4. Refer to local guidance for additional details needed to conduct the search. Debrief: Take time shortly after conducting this activity to reflect on items noted, found, and documented. Make any notes that may need further discussion regarding your institution. Back 2 Basics 9 Managing Housing Units, Part II EFTA00141333

The goal of the Automated Staffing Tool (AST) is to address BOP's staffing challenges by providing an updated, standardized, and transparent view of staffing guidelines and an interactive way for BOP leadership to assess staffing levels based on evolving mission needs. Challenges with Current Staffing Guidelines • Guidelines are based on a static formula that assumes Correctional Officers work 210 days a year; not inclusive of extended leave (e.g., military leave, training requirements, etc.) • Development and implementation of guidelines are not standardized across divisions • Current guidelines do not account for additional, mission critical requirements (i.e., institution specific characteristics, distance to external resources, etc.) AST Prototype Capabilities  Built on criteria including institution specific characteristics validated by BOP Central Office and MXRO Region Subject Matter Experts  Replace and standardize outdated 2016 Staffing Guidelines  Provide transparent centralized view of recommended Custody staff by institution  Improve over time with more features and additions (Iterative prototype) • DI PARI MI NI ()) RISI K flIII RA ARIA Al/ (TI PRISON, (NOR) Ye Staffing Tool (NW-A/Lin. Noon Piotot)pe) OM. 16 3.771 ,omoNentled NM W Onopire 4. 0 0,0 IRO • MO 2000 HO P0,00. 90. MINIM= Non 1.100/ I M AST Mid-Atlantic Custody Prototype screenshot Next steps include incorporating post-level baseline data EFTA00141334

FEDERAL BUREAU of PRISONS Risk Analysis of Overtime, Augmentation, and Incentive Payment Apri l 2022 EFTA00141335

Table of Contents r Overview Executive Summary Background & Current Processes Summary of Approach Overtime & Augmentation Analysis Correlation Chart Section 1: Overtime Usage, Connections Current Usage of Overtime (Overall Snapshot, Reasons for Overtime) Connection: Augmentation Not Associated with Overtime Connection: Incidents Not Associated with Overtime Connection: Leave (Sick & AWOL) Associated with Overtime Connection: Vacancies Not Associated with Overtime BOP's Overtime Tool Section 2: Augmentation Usage, Connections Overview: Overtime and Augmentation Current Usage of Augmentation (Overall Snapshot) Connection: Incidents Not Associated with Augmentation Connection: Leave (Sick and AWOL) Not Associated with Augmentation Connection: Vacancies Not Associated with Augmentation Section 3: BOP Incentive Analysis Summary of BOP Incentives Overview of Insights Recruitment & Relocation Incentive Usage Retention Incentive Usage - Findings and Insights Connection: Retention Incentives Not Associated with Staff Separations Connection: Unclear if Current Retention Incentives are Cost Effective Connection: Retention Incentives VaryAcross Institutions, Vary Within Institutions Case Study: North Central Region (NCR) Psychology Services Appendix Summary of Analysis & Findings Recruitment Incentive Usage Summary Relocation Incentive Usage Findings OBJECTIVE To review and analyze the risks associated with BOP's increased usage of overtime and augmentation and analyze the effectiveness of recruitment, relocation and retention incentives. EFTA00141336

Executive Summary This document highlights the bureau of Prisons' usage of overtime, augmentation and incentives (from 2017-2021) to uncover potential drivers of, and effectiveness of, usage. Key Takeaways Trends of both Overtime and Augmentation have both been increasing over time, disputing the hypothesis that they are used to substitute each other 85% of incentive payments are focused on retention incentives S Retention incentives do not appear to reduce staff separations 3 EFTA00141337

Background & Current Processes In response to staffing issues, the Government Accountability Office (GAO) published a report in Feb. 2021 outlining shortfalls across the bureau. This analysis seeks to satisfy the recommendation of the bureau to conduct a risk assessment of its overtime and augmentation use on its staff, inmates, and institution security, and assess the outcomes of the incentives it utilizes. Overtime Augmentation Incentives CURRENT PROCESS • Overtime reports can be pulled from the Roster Scheduling Software that is viewable at the Central, regional, and local level • The Roster Scheduling Program makes improvements on some current processes associated with assigning overtime (e.g., current training certifications are captured in program, so it is clear who is qualified for a shift, and Overtime Authorization forms are automatically saved in the system) • Correctional Programs Division (CPD) developed a separate Overtime Tool housed in SAS that tracks overtime spending by institution, region, and overall agency • The Overtime Tool is accessible at the regional level. Regional leaders have the authority to share this information at the local level (usually institution Wardens and Captains). The report used for the Overtime tool is updated by local administrators on a monthly basis • The responsibility of tracking augmentation is at the local level; how accurately the augmentation time code is utilized depends on each institution • Some institutions utilize an augmentation log to track the reason and the frequency of staff augmentation to provide transparency to institutional staff • Posts that are augmented for part of a shift may not get coded as being augmented, potentially resulting in an under-reporting of the practice • Wardens request incentives from their respective regional office who approve incentives at their own discretion • Funding for incentives comes from an institution's operational budget • There does not appear to be a standard policy bureau-wide that articulates reasoning behind retention incentive variances (for the same position at the same institution) or ties current retention incentives to quantifiable metrics defined in terms of an agencys goals (per OPM's guidance) • Incentives are sent to Staffing and Employee Relations (SERS) to be reviewed annually as required by OPM OBJECTIVES OF ANALYSIS O Uncover risks associated with increased use of overtime hours per staff Uncover risks associated with increased use of augmentation hours per staff Analyze the usage of recruitment, relocation, and retention incentives 4 EFTA00141338

Summary of Approach Our approach centered on testing several hypotheses to best uncover potential risks associated with BOP's increased use of overtime and augmentation and usage of incentives. Section 1: Overtime Risk Analysis Section 2: Augmentation Risk Analysis Section 3: Incentive Usage Analysis Data Inputs Hypotheses Analyses Conducted Limitations • Overtime and Augmentation hours for all BOP staff by institution and region (FY17-FY21) • Inmate related incidents by institution and region (FY17-FY21) • Sick and AWOL leave by institution and region (FY19-FY21) • Vacancies across all institutions (FY21) • Overtime and Augmentation usage are used to substitute each other (I.e., as one increases, the other decreases) • The institutions with the highest overtime and augmentation usage are the most short-staffed • Institutions with high levels of overtime and augmentation experience more safety incidents • Institutions with increased usage of overtime and augmentation utilize more sick leave and absent without leave (AWOL) 1. Review BOP's current overtime and augmentation per staff yearly trend overall and regionally 2. Review BOP's current overtime hours by custody and non-custody staff 3. Test relationship of overtime and augmentation between inmate incidents, sick & AWOL usage, and vacancies with regression analysis (The strength of relationships is scored using R2. In statistics, R2 is the proportion of the variation in the dependent variable that is predictable from the independent variable. For the purposes of these analyses, an R2 value of .50 or greater is considered a strong relationship) 4. Review BOP's current Overtime Tool to address gaps and opportunities for improvement • Unable to retrieve workplace injuries date to test relationship with overtime and augmentation • Vacancy data was limited to 2021 and could not assess prior years • Unable to retrieve number of programs delayed/cancelled to test relationship with augmentation • Per-person hiring, relocation and retention incentive spending for FY17-FY21 across all 122 BOP institutions • BOP exit survey data 2016-2020 • Cost to hire* • Retention incentives reduce staff separations • Retention incentives are connected to hard-to-fill locations and positions 1. Review summation of incentives given to staff 2. Breakdown recruitment, relocation, and retention incentives by percent of staff and the top positions receiving them 3. Analyze retention incentive variance of top BOP positions receiving incentives 4. Calculate average retention incentive spending per staff 5. Test relationship between separation rate and retention incentive spending with regression analysis • Unable to retrieve cost associated with hiring new staff at BOP to compare to cost of staffing incentives *Source: Automati _D_ata_Pro_cessing_CADP) 5 EFTA00141339

Overtime & Augmentation Analyses Correlation Chart This chart encompasses the three types of analyses conducted against Overtime and Augmentation data. Analyses that proved a correlation are accompanied with a check mark, while analyses that did not show a correlation are accompanied with an X. Analyses Conducted Against Overtime and Augmentation Data Inmate Incidents Sick Leave and Absent Without Leave (AWOL) Usage Vacancies Correlation with Overtime? s/ x Correlation with Augmentation? x x x When Overtime and Augmentation were compared against one another, it did not appear that overtime and augmentation are used in substitution. 6 EFTA00141340

Overtime Risk Analysis EFTA00141341

Current Usage of Overtime - Overall Snapshot A review was conducted using overtime usage data from 2017-2021 to assess the usage trend across all institutions. Below are the initial observations of usage overall and by region. Average Overtime Hours per Staff 250 183 194 182 200 135 C 150 93 100 50 201/ 2018 2019 fiscal Year 2020 2021 300 250 200 ii 150 100 so Average Overtime Hours per Staff by Region MXR NCR NER SCR SER Region WXR ■ 2017 ■ 2018 ■ 2019 2020 ■ 2021 Key Findings • Overtime usage (hours) has increased significantly from 93 hours per staff in 2017 to 182 hours per staff in 2020* • While the overtime usage has gone down minimally from 2020, the 2021 average is approximately 95% higher from its 2017 average • The region with the highest overtime usage (hours) per staff in 2020 is South Central, but the Western region had the highest percent increase from 2017 to 2020 • In 2021, the top 5 institutions with the highest Overtime per staff were and Big Spring FCI, Brooklyn MDC, Coleman Complex, Forrest Complex, and Yazoo City Complex and the highest vacancies were Beaumont, Butner Complex, Florence Complex, Thomson USP, and Yazoo City Complex *The increose of overtime from 2019,2020 could hove been due to COVID-19 8 EFTA00141342

Current Usage of Overtime - Reasons for Overtime A review was conducted using overtime usage data from 2017-2021 to assess the usage trend across all institutions. Below are the initial observations of overall usage broken out by reasons for overtime (custody, outside hospital, other). Overtime Hours Total Overtime Hours by Reason 4,000 3,500 3,000 2,500 2,000 1,822 1,763 500 3,392 3,220 2,345 2017 2018 2019 2020 2021 Fiscal Year yo Custody —0— Outside Hospito —0— Other Key Findings • Custody overtime hours of 963 thousand in 2017 was relatively low compared to outside hospital hours of 1,822 thousand* However, over the years the gap between the two has been closing In 2019, custody overtime hours surpassed outside hospital by 22% In 2021, custody overtime hours surpassed outside hospital by 37% Other reasons for overtime have remained relatively low compared to custody and outside hospital, however it would be beneficial to understand the full reasons for overtime *This dato is solely based on reported ovenim hours in towl and not on the full reasoning behind use of overtime 9 EFTA00141343

Connection: Augmentation Not Associated with Overtime An analysis of overtime was conducted using overtime hours and augmentation hours for individual institutions for the time period of 2019. The purpose was to test the hypothesis of: Overtime and Augmentation usage are used to substitute each other (I.e., as one increases, the other decreases). Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. Overtime Hours 43 500 400 -,E 300 200 100 0 Overtime and Augmentation R2 = 0.2036 • • • •• • • • • • II • • 0 5 10 15 20 25 30 Thousands Augmentation Hours 0 250 200 150 100 50 Average Overtime and Augmentation Hours Per Staff 183 194 182 7 10 10 14 13 • • 2017 2018 2019 2020 2021 Fiscal Year -•-•Overtime .0 —.Augmentation Key Findings • Assessing augmentation and overtime by fiscal year 2019, the R2 value is .20 - Meaning it is not significant enough to conclude that there is a strong relationship • Although the relationship is not strong, it is leaning towards a positive one. Since institutions have anecdotally relayed that overtime and augmentation are used to substitute each other, it would be anticipated that they would have a negative relationship (as one increased, the other decreases) • When assessing the 5-year usage trend analysis for overtime and augmentation, they both follow the same trend—both have increased over time Connection It does not appear that overtime and augmentation are used in substitution. 10 EFTA00141344

Connection: Incidents Not Associated with Overtime Risk analysis of overtime was conducted using overtime hours and inmate incidents data, for individual institutions for the time period of 2019. The purpose was to test the hypothesis of: Institutions with high levels of overtime experience more incidents. Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. 250 200 150 50 0 Overtime and Inmate Incidents R2 = 0.2882 • • • • • • I • • • • • • 0 50 100 150 200 250 300 350 400 450 Thousands Overtime Hours Key Findings • Assessing at the incidents and overtime by fiscal year, the R2 value is .29 - Meaning it is not significant enough to conclude that there is a strong relationship • While an increase in overtime use can lead to incidents, it cannot be concluded that it is a direct affect of overtime with the data provided • Additionally, it is acknowledged that incidents represent an extreme outcome of increased institution safety risks— meaning that there might still be increased safety risks with increased overtime usage, even if those do not connect to an increase in incidents Connection There does not seem to be a relationship between inmate incident and staff overtime. ,Inmate incident data is a consolidated report o allegations, verified assaults, and minor incidents for inmate-on-inmate and inmate-on-staff incidents. Time period of 2019 was used to factor out COV1D.19. he strength of relationships is scored using R2. In statistics, R2 is the proportion of the variation in the dependent variable that is predictable from the independent variable. For the purposes of these analyses, an R2 value of .50 or greater is considered a strong relationship. 11 EFTA00141345

Connection: Leave (Sick & AWOL) Associated with Overtime Risk analysis of overtime was conducted using overtime hours of all institutions and leave, usage during the same time period of 2019. The purpose was to test the hypothesis of: Institutions with increased usage of overtime utilize more sick leave and absent without leave (AWOL). Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. Key Findings • Assessing the leave and overtime by institutions, the R2 value is .52 - Meaning it is significant enough to conclude that there is a strong relationship • There is a positive relationship between overtime and leave usage meaning when overtime is high, a similar pattern can be seen with leave usage (Although it cannot be said for certain it is a one-for-one relationship of overtime and leave usage as other factors such as staff tenure need to be considered) • An increase of overtime could mean that more staff call out, which could be a result of burn out or decreased morale Connection Instances of institutions with increased usage of overtime could be an indicator of increased sick and AWOL leave usage. ,This analysis includes sick and AWOL leave hours. Time period of 2019 was used to factor out COVID-19. 12 EFTA00141346

Connection: Vacancies Not Associated with Overtime Risk analysis of overtime was conducted using overtime hours of all institutions and vacancies during the same time period of 2021. The purpose was to test the hypothesis of: The institutions with the highest overtime usage are the most short-staffed. Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. C 3 250 200 150 100 so 0 .50 Overtime and Vacancies R2 = 0.1874 • • • so 100 150 200 250 300 350 400 • • • • • 0 Overtime Hours 450 500 Thousands Key Findings • Assessing the vacancies and overtime by institutions, the R2 value is .18* - Meaning it is not significant enough to conclude that there is a strong relationship • There does not seem to be a relationship between overtime hours and vacancies • Since overtime is used to supplement the shortage of staff, there might be other driving factor(s) leading to increase overtime use (i.e., staff callouts) *The weak relationship between Overtime and Vacancies could be due to a position not being filled as a result of a staff member on extended leave or staffing guidelines not being the most up to date Connection Vacancies are not directly associated with overtime hours. *The regression analysis was based on availability of v cancy data 13 EFTA00141347

BOP's Overtime Tool BOP created a tool in SAS to retroactively track overtime spending budget of its facilities going back as far as 2009. Below is an overview of its current capabilities and the opportunities for improvement. Current Capabilities and Features High-level coding of reasons for overtime (Custody, Outside Medical, Other) Ability to filter by agency, regionally, and facilities to drill down further Track overtime spending regionally and/or by facilities to assess spending against their allocated budget Access to Regional Directors for awareness on overtime spending Data pulled from local administrators that pull from financial system (UFMS) on a monthly basis EFTA00141348

Augmentation Risk Analysis EFTA00141349

Current Usage of Augmentation - Overall Snapshot A review was conducted using augmentation usage data1 from 2017-2021 to assess the usage trend across all institutions. Below are the initial observations of usage overall and by region. 15 10 0 x 7 2017 Average Augmentation Hours per Staff 14 10 10 2018 2019 Fiscal Year 2020 13 2021 20 is 10 S Average Augmentation Hours per Staff by Region 111111111 g olid 1101 101 MR NR • 2017 • 2018 ■ 2019 2020 ■ 2021 Key Findings • Following a similar pattern of overtime, augmentation usage (hours) has also increased significantly from 7 hours per staff 2017 to 13 hours per staff 2021 • While the augmentation usage has gone down minimally from 2020, the 2021 average is approximately 86% higher from its 2017 average The region with the highest augmentation in 2021 is North Central, but the Western region had the highest percent increase from 2017 to 2021 In 2021, the top 5 institutions with the highest Augmentation per staff were and Berlin FCI, Sheridan FCI, Thomson USP, Waseca FCI, and Williamsburg FCI and the highest vacancies were Beaumont Complex, Butner Complex, Florence Complex, Thomson USP, and Yazoo City Complex 'Augmentation data might be underrepresented as its dependent on the augmentation code input 17 EFTA00141350

Connection: Incidents Not Associated with Augmentation Risk analysis of augmentation was conducted using augmentation hours and incidents, data for individual institutions for the time period of 2019. The purpose was to test the hypothesis of: Institutions with high levels of augmentation experience more incidents. Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. 250 200 • • • •• • • • Augmentation and Incidents • • S.• • • • so • • • • • •• • • • • • di r. fles de OF °OS •• • 0 • • • • 0 2 4 6 • Augmentation Hours R2 = 0.1299 • • • • 10 12 14 16 Thousands Key Findings • Assessing at the incidents and augmentation by fiscal year, the R2 value is .13 - Meaning it is not significant enough to conclude that there is a strong relationship • There does not seem to be a relationship between augmentation hours and number of incidents that are inmate driven • Although, there is no relationship found, there could be a risk to safety of institutions as incidents are only one factor considered. Connection There does not seem to be a relationship between inmate incident and staff augmentation. ,Inmate incident data is a consolidated report on allegations. assaults, and minor incidents for inmate-in-inmate and inmate-on-staff. Time period of 2019 was used to factor out COV1D.19. 18 EFTA00141351

Connection: Leave (Sick and AWOL) Not Associated with Augmentation Risk analysis of overtime was conducted using augmentation hours of all institutions and leave, usage during the same time period of 2019. The purpose was to test the hypothesis of: Institutions with increased usage of augmentation utilize more sick leave and absent without leave (AWOL). Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. Leave Hours 1 2 20 18 • 0 -C 16 14 12= • • • 10 • • • • • 8 • • • • 0 • 6 • • Augmentation and Leave • • • • • • • • • : • • • a i • I % . 45 *t e e • 4 • • 40. • • 2 R2 = 0.0892 • • • • 0 0 2 4 6 8 10 12 14 16 Thousands Augmentation Hours Key Findings • Assessing at leave and augmentation by institutions, the R2 value is .09 - Meaning it is not significant enough to conclude that there is a strong relationship • There does not seem to be a relationship between augmentation hours and leave usage • Since augmentation might be underreported (it is unplanned and does not impact operational budget the way that overtime does), the leave usage relationship could be understated as it would be anticipated that augmentation would follow a similar trend of overtime and leave Connection There does not seem to be a relationship between sick and AWOL leave usage and staff augmentation. ,Leave in this analysis includes sick and AWOL leave hours. Time period of 2019 was used to factor out COVID.19. 19 EFTA00141352

Connection: Vacancies Not Associated with Augmentation Risk analysis of overtime was conducted using augmentation hours of all institutions and vacancies during the same time period of 2021. The purpose was to test the hypothesis of: The institutions with the highest augmentation usage are the most short-staffed. Real world data significance requires R2 > .50 for consideration. Each blue dot represents an institution. 250 200 150 a., 100 50 0 -50 Augmentation and Vacancies R2 = 0.1293 • • • • • - • • • • • t 0 5 10 15 20 25 Augmentation Hours I housanc, Key Findings • Assessing the vacancies and augmentation by institutions, the R2 value is .13 - Meaning it is not significant enough to conclude that there is a strong relationship • There does not seem to be a relationship between augmentation hours and vacancies • Since augmentation is used to supplement the shortage of staff, there might be other driving factor(s) leading to increase augmentation use (i.e., staff callouts) Connection Vacancies are not directly associated with augmentation hours. The regression analysis was based on availability of va ancydata 20 EFTA00141353

Incentive Usage Analysis EFTA00141354

Summary of BOP Incentives BOP offers Recruitment, Relocation, and Retention incentives to its staff. Below is a high-level overview of BOP incentive spending from FY17 - FY21. • BOP spent $19.9M on a total of 2,612 recruitment incentives • BOP spent a minimum of $3.6K and a maximum of $42.7K per employee for recruitment incentives • The top positions receiving recruitment incentives include GS 5/6 Correctional Officers ($9.5M), GS 7 Senior Officers ($3.4 M), and RNs ($2.1 M) • BOP spent $7.3M on a total of 544 relocation incentives • BOP spent a minimum of $4.5K and a maximum of $43K per employee for relocation incentives • The top positions receiving relocation incentives include Lieutenants ($2.6M), Health Services Administrators ($199K), and GS-8 Senior Officer Specialists ($231 K) • BOP spent $166.6M on a total of 21,744 retention incentives • BOP spent a minimum of $826 and a maximum of $43K for retention incentives • The top positions receiving retention incentives include GS8 Senior Officer Specialists ($17.7M), GS7 Senior Officers ($14.6M), and RNs ($16.8M) •Relocation incentives are separate from relocation reimbursement. A relocation incentive is compensation offered in addition to relocation reimbursement. This analysis did not examine relocation reimbursements. 23 EFTA00141355

Overview of Insights BOP's investment in staff incentives has increased from 2017, but this investment does not appear to have strong correlations to reducing staff separations. Staff separations are not associated with incentive spending There is no strong correlation between incentive spending and staff separations (R2=0.004) Overall, incentive spending has increased since FY17 Across all types of incentives, payments have increased from $22.5M in FY17 to nearly $62M in FY21 Recruitment spending has increased and has primarily targeted entry level Correctional Officers Recruitment spending has remained at $6.9M and has focused on bringing in new Correctional Officers Relocation incentives are seldomly used Relocation incentives only account for $7.3M and account for only 3.5% of all incentive spending Most incentive money is spent on retention incentives Out of the total $193M on all incentives, $166.6M was spent on retention incentive, representing 85% of total spent Retention incentive compensation can fluctuate for the same position at the same institution Some positions at the same institution can range as much as 19% in retention incentives EFTA00141356

Recruitment & Relocation Incentive Usage BOP has increased spending for recruitment and relocation incentives since FY17. Summary below reflects the years of FY17 - FY21. Recruitment 600% increase in total spending for recruitment incentives (from $980K in FY17 to $6.9M in FY21). 700% increase in recruitment incentive payments to GS 5/6 Correctional Officers since FY17. 2.8% of staff received recruitment incentives across all regions. The Western Region distributes the greatest number of recruitment incentives (5% of all staff receive a recruitment incentive). 21 4 2X more total incentive spending from FY17 to FY21. Total spending across all incentives has more than doubled in the last five years, from $21 M to $51M. Relocaticm 4% of total incentive spending was spent on relocation incentives. $2.4M in relocation incentives for Lieutenants. Lieutenants received more in relocation incentives than any other position in corrections. 544 total relocation incentives distributed. USP Thomson distributed the greatest number of relocation incentives (67 total). 25 EFTA00141357

Retention Incentive Usage - Findings and Insights Retention incentives offer compensation to entice existing staff to continue employment with BOP and delay separation or retirement. 60% 50% s 40% O 30% 13 • 20% 10% 0% MXR % of BOP Staff on Retention Incentives NCR NER SCR SER WXR I ■ 2017 ■ 2018 ■ 2019 ■ 2020 ■ 2021 Sum of incentive 6 5 Top 10 Positions w/ Greatest Retention Incentive Sum Id hill niii Ind ..Id ..6 ■201i • 2018 • 2019 e 2020 • 2021 Key Fin dings Retention incentives are used frequently, especially in the Western region and focus on Senior Officer Specialists • Retention incentives are used frequently Retention incentives were used 21K times from FY17-FY21 • The Western region uses the most retention incentives About half of all retention incentives used in FY17-FY21 focused on the Western region • The position that receives the largest amount of retention spending is GS-8 Senior Officer Specialists $17.7M was spent for GS-8 Senior Officer Specialists from FY17- FY21 SR DIETER REGISTERED SR OFFCER MC LEVEL LIEUTENANT COOK FRAIN CORRECTIONAL DRUG ABUSE NITNCE MAR QUAL SPECIALIST NJRSL ICORRICINMS PRACTMCAER OFFICER IGS FROG COORD FRAM IIAPRNAT A (CORRECTIONS GSM) (CUNICALI OSA) ',maim GSM) CONE NORSE 26 EFTA00141358

Connection: Retention Incentives Not Associated with Staff Separations Retention incentive spending does not appear to correlate to trends of staff separations. Ln • ra 0 .c Dollars per Staff 12 10 a 6 4 2 0 MXR Average Retention Incentive Spending Per Staff NCR 1 SCR 1 SER 1 WXR Separation Rate 10% 9% 8% 7% 6% 5% 4% 3% 2% 1% 0% Separation Rate vs. Retention Incentive Spending R2 =0.004 • • • • • •• • • da• • • • • SM 10M 15M 20M Sum of Retention Incentive Spending Key Findings Retention incentives do not appear to reduce staff separations • Average per staff spending is highest in the Mid-Atlantic and lowest in the Western Region However, the Western region spends the most in total on retention incentives. The Mid-Atlantic region spends almost double on retention incentives per staff compared to the Western region • Retention incentives do not appear to be effective at reducing staff separations There is no strong correlation between incentive spending and staff separations— the R2 value is.004- Meaning it is not significant enough to conclude that there is a strong relationship £sch dot reprearrts per year per regeir 27 EFTA00141359

Connection: Unclear if Current Retention Incentives Are Cost Effective It is unclear what level of retention incentive are cost effective relative to the cost of hiring. 200 180 160 140 120 100 so 60 40 20 0 Cost to Hire vs. Cost of Correctional Officer Retention Incentives Cost to Hire* ($4.1 K) (1K, 2K] (2K, 38) (38, 481 (4K, 5K) (5K, 6K) (6K, 7K) (7K, 8K] (88, 98] Retention incentive $ Amount Percentage of Respondents 60% 40% 20% 0% Does Access to Retention Incentives Best Describe your Reason for Leaving your Current Position? (BOP Exit Survey Data) • • 2017 2018 2019 SAO Respondents% ii•Non•Retirement % —Ko—Voluntary Retirement % 2020 Key Findings BOP may be using retention incentives when it may be more cost-effective to hire new staff • BOP uses retention incentives when it may be cheaper just to hire new staff. However, BOP should further investigate its own per capita cost of hiring External research indicated that the cost to hire new employee was $4.1 K. However, a deeper analysis of BOP's cost of hiring is required to understand at what cost point incentives make sense to retain staff. • Nearly half of non-retirement staff separations exit survey respondents cite their inability to receive a retention incentives as their reason for leaving However, survey response rate was limited with only 433 respondents from FY17-FY20 *Source• Automatic Data Processing (ADP) EFTA00141360

Connection: Retention Incentives Vary Across Institutions The percentage of retention incentives offered for specialized positions vary, but retention incentives remain relatively consistent for Correctional Officers. 50% 45% 40% 35% t 30% C 0 "E. 25% a., a, cc 20% 15% 10% 5% 0% A.. 4%* k. Oct ISSt U t k BOP • • Positions ! w/ Largest Retention • % Range (FY17-FY21) • 39 I I 1 • • • ..t. C. .„.k. Cs ot kt. AE. . S. st., k- se & 2" 3. c, V POD W 0 (-) 0 W 044 14. POD C.• Q. Nt. 4 jz A o 4, t (. (... q. ,t% se: ,...§.- .4-• -% S' .4 k -i-f ( GI 2.4 2 V 4t" (,) 4;7 C' 4> A ct- 0 O. e .3* 2 2' .2 0 0 000 C.; 42 0 0 1/4 0 4. -P. 4 (40(.7 A. 1 I € *Please note that as of Summer 2021, Chief Dental 0 t BOP Position Officers no longer receive incentives due to Title Key Findings Retention incentives vary within BOP positions • Assistant Food Service Administrators retention incentives have the largest retention incentive variance 124 retention incentives given to Food Service Administrators ranged from 1% to 32%, but most were between 5-15% • Most Correctional Officers who receive retention incentives are awarded between 10-15% of their salary 674 Correctional Officers were awarded retention incentives from FY17-FY21 Connection For your awareness, retention incentives vary for the same position across institutions, but they also vary for the same position at the same institution. 29 EFTA00141361

Connection: Retention Incentives Vary Within Institutions Retention incentives can vary for the same position, even within the same institution. Associate Warden at FCI Jesup 30% 25% 20% 15% 10% 5% 0% Drug Abuse Prog Registered Nurse at Coord. At Memphis FCI FCI Tucson 1 ae/ Minimum Maximum Minimum Maximum Minimum Maximum Incentive Incentive Incentive Incentive Incentive Incentive *The Associate Warden at FCI Jesup was only temporarily assigned and was soon thereafter appointed to Chief Psychologist Key Findings Retention incentives can vary up to almost 20% for the same position for the same institution • Variation in retention incentives indicates that BOP may benefit from incentive policy standardization Although most positions at each institution have similar retention incentives, there still exists variation for the same position at the same institution. Without clear guidance on why such variation exists, it is recommended that the bureau further investigate why this is the case. • Ranges were observed across all disciplines within various institutions There are nearly 60 positions at BOP that have a range of retention incentives for the same position at the same institution EFTA00141362

Case Study: North Central Region (NCR) Psychology Services The North Central Region recently evaluated its own incentive structure for positions in its Psychology Services division. NCR created a transparent, standardized retention incentive scheme to better retain staff that may offer a path forward for the rest of BOP. $168K Amount of money saved applying model to current staff Challenge NCR psychologists eligible for incentive award after licensure Incentives at BOP have been distributed at the Warden's discretion and as a result, has caused a lack of standardization of retention incentives across BOP. The Psychology Services Administrator for the North Central Region (NCR) was tasked with analyzing the incentive structure for the entire region. The evaluation found that the current incentives model resulted in a wide range of incentive payments offered for similar positions across the region. $1.13M Estimated costs for NCR psychology services applied to current staff Solution The goal of this model is to create a system of retention that retains highly qualified staff and motivates entry level staff to gain the knowledge, skills, and abilities to promote into positions of increasing levels of difficulty and responsibility in the agency. The model applies retention incentives through a standardized and transparent incentive scheme for all staff. The model relies on both specific "institutional factors" and specific individual factors (location, difficulty filling positions, security level, level of specialization, department head) to determine incentive amount. It also requires that staff be licensed to receive an incentive. Impact Anecdotally, some retention incentive recipients reported that they will delay their retirement as a result of the new incentive structure. Although the number of staff receiving incentives increased from 66 to 132 out of 137 staff, the new structure saves $168K. Additionally, it also promotes psychology licensure by requiring licenses to be eligible to receive a retention incentive. EFTA00141363

33 EFTA00141364

Summary of Analysis & Findings Below is summary of all findings informed by the analysis conducted. OVERTIME AUGMENTATION INCENTIVES • Overtime usage (hours) has increased significantly from 2017 to 2020 • In 2019, standard custody surpassed outside hospital by 37% for the reasons for working overtime • It cannot be concluded that incidents, are a direct affect of overtime • Institutions with increased usage of overtime could be an indicator of increased sick and AWOL leave usage 00 • The 2021 average augmentation usage is approximately 86% higher from the 2017 average • Incidents are not associated with augmentation hours • Sick and AWOL leave usage is not associated with augmentation hours • Vacancies are not directly associated with augmentation hours Recruitment Relocation Retention • GS-5/6 Correctional Officers receive the most recruitment incentives • Lieutenants received $2.4M more in relocation incentives than the next position from FY17- FY21 • 85% of incentive payments are focused on retention incentives 'Inmate incident data is a consolidated report of allegations, verified assaults, and minor incidents for inmate•on•inmate and inmate-on-staff incidents. 34 EFTA00141365

Summary of Incentives BOP has increased spending for all types of incentives since FY17. 70% 60% SO% 2 40% 46 30% 20% 10% 0% MXR % of BOP Staff Receiving Incentives by Region I NCR mmffil Hi NER KR KR %RR Region ■ 2017 ■ 2018 ■ 2019 ■ 2020 ■ 2021 C O 3 Sum of Incentive $20 $18 $16 $14 $12 $10 $8 $6 S4 $2 S. Incentive Money Spent Across BOP Regions 'Aka • 2017 • 2018 • 2019 ■ 2020 ■ 2021 Key Findings Incentive spending has grown over time since 2017 • The western region gives out more retention incentives than other regions More staff in the Western region receive more incentives, however, the middle Atlantic region spends the most on average ($11.25K) per staff since 2017 • BOP staff have increasingly been awarded incentives From FY17-FY21, more and more BOP staff have been given some form of staffing incentives across all regions • BOP has steadily increased incentive payments since FY17 From FY17-FY21, total spending across all incentives has more than doubled from $21M to $51M MXR NCR NER SCR SER WXR 35 EFTA00141366

Recruitment Incentive Usage-Findings and Insights Recruitment incentives are used to attract new staff for employment with BOP. 8% 7% 6% 5% 4% e. 3% 2% 1% 0% % of BOP Staff on Recruitment Incentives MXR SER WXR NCR NER SCR • 2017 • 2018 • 2019 • 2020 • 2021 Sum of Incentive €54.0 2 $3.5 $3.0 $2.5 $2.0 $1.5 $1.0 $0.5 Hill Ell ..III ...I. ...I S. .3. ,■ .. c. er .s ,,,,,, ,..., e t ■ 2017 • 2018 • 2019 __... - _. a —in ■ 2020 ...,c± et. .44 • 2021 _,., ,,, ....- ' 4 .. e C . . ▪ 4. e Nit cr e S . o e C q. \P , S i I S, .C. . .1/4> s 40? 4e i's> c° S • 0 PP cT Key Findings Recruitment spending has increased and has primarily targeted entry level Correctional Officers • BOP has steadily increased recruitment incentive payments since FY17 More incoming staff have received recruitment incentive payments from FY17-FY21. Total spending for recruitment incentives has increased from $980K in FY17 to $6.9M in FY21 • BOP staff have increasingly been awarded recruitment incentives From FY17-FY21, more and more BOP staff have been given some form of staffing incentives across all regions • GS-5/6 Correctional Officers receive the most recruitment incentives New Correctional Officers have seen the sharpest increase in recruitment incentives with incentive payments totaling $9M 36 EFTA00141367

Relocation Incentive Usage-Findings and Insights Relocation incentives offer compensation to existing staff who are encouraged to relocate to other BOP institutions. 1% 0% - - MXR % of BOP Staff on Relocation Incentives NCR NER SCR SER WXR • 2017 ■ 2018 s 2019 is 2020 ■ 2021 Sum of Incentive $1.0 $0.8 $0.6 $0.4 $0.2 5- Top 10 Positions w/ Greatest Relocation Incentive Sum _I... _I-I HUI.WI DRUG ABUSE POULTICE PACT COURD MGR El .1 _ dl .1.a_ CH POOR SR DI FCER SWART SPECIALIST CHAPLAIN (CORRECTIONS GSOT HLTH SRVCS SRI:ROLA FACIL MGR *MAR (CORRECT= GS DT TIM UNIT MGR • 2017 • 2018 • 2019 s 2020 • 2021 Key Findings Relocation incentives* are rarely used and focus on Lieutenants • The number of BOP staff receiving relocation incentives has remained relatively low BOP seldomly uses relocation incentives to attract new Correctional Officers or other non-custody staff • Lieutenants receive the lion share of relocation incentives Lieutenants received $2.4M more in relocation incentives than the next position from FY17-FY21 *Relocation incentives are separate from relocation reimbursement. A relocation incentive is compensation offered in addition to relocation reimbursement This analysis did not examine relocation reimbursements. 37 EFTA00141368

Deloitte. Current State Assessment of Staffing Data, Processes, and Calculations F Bureau of Prisons Human Resources Management Division March 2022 1 EFTA00141369

Table of Contents Executive Summary 4 Background Information 5 Project Background 5 Corrections Landscape 6 BOP Values 7 Methodology 7 Field Research Design 7 Focus Group Design 8 Field Research Analysis 9 Field Research Assumptions 10 Data Analysis Methodology 10 Data Limitations 11 Hire: Acquire BOP Staff 12 Introduction to the Hiring Process 12 Promotions and Succession Planning 14 Strengths of Current Hiring and Succession Planning 1S Scope of Challenges and Associated Risks of Current Hiring and Succession Planning 16 Train: Acclimate BOP Staff 18 Introduction to Correctional (ICT) Training 18 BOP Mentorship Program Error! Bookmark not defined. Strengths of Current Acclimation Programs 19 Scope of Challenges and Associated Risk of Current Acclimation Programs 19 Manage: Allocation of BOP Staff 21 Key Metrics of Current Staff 21 History of BOP's Current Staffing Formula 21 Strengths of Staffing Formula 22 Risks of Staffing Formula 22 Staffing Guidelines for CPD, HSD, and RSD 23 Risks and Challenges for Staffing Guidelines 26 Rosters and Scheduling at BOP 27 Union Considerations 28 Strengths of Scheduling 28 2 EFTA00141370

Risks and Challenges of Scheduling 28 Overtime and Augmentation Usage 29 Retain: Minimize Staff Attrition 32 Retention Incentives 32 Exit Survey Data 32 Strengths of Retention 33 Risks and Challenges of Retention 33 Recommendations 37 Recommendations Overview 37 Recommendation #1: Develop Automated Staffing Tool to Establish a Reliable Source for Determining Staffing Levels 37 Recommendation #2: Invest in Workforce Planning Capabilities to Improve Succession Planning 39 Recommendation #3: Conduct Cost Benefit Analysis of 8-Hour vs. 12-Hour Shifts to Optimize Staff Allocation 40 Other Recommendations 41 Conclusion 42 Appendix 42 Appendix A: Field Research Themes 42 Appendix B: Focus Group Questions 42 Appendix C: Competitive Job Landscape 43 Appendix D: Key Definitions 45 Appendix E: Time-On-Post (TOP) Formula 46 Appendix F: Document Review 47 3 EFTA00141371

Executive Summary Since July 2021, the Deloitte team has conducted nine focus groups at five institutions (FDC Philadelphia, FCC Allenwood, FCI Edgefield, FCC Butner, and FCI Three Rivers) and 30 interviews with Executive Staff, resulting in over 750 datapoints across five regions (North Central, South Central, Southeast, Mid-Atlantic, and Northeast). Findings from the field research, in conjunction with additional data analysis and stakeholder engagement, helped formulate and solidify recommendations to address the Bureau of Prisons (BOP)'s most pressing staffing challenges. Tasked with both protecting society by confining inmates in a humane and secure way, and with assisting offenders to become law-abiding citizens, BOP has a vital mission. The ability of the Bureau to achieve its mission is predicated upon attracting and retaining employees with interpersonal skills, empathy, and the ability to operate successfully in a corrections environment. Data was collected and synthesized to be relevant to, and reflective of, BOP's vision for providing the most efficient, safe, and humane correctional services and programs in America. This report uncovers several key challenges the Bureau faces today: • Current hiring practices are falling behind projected retirements • Current recruitment strategies make it difficult to hire clinical and mental health professionals (e.g., MDs, MLPs, psychologists, RNs)' • ICT training needs continued investment and accountability to provide the exposure and practice needed for staff to feel ready their first day on the job • The supplemental onboarding programs appear to be inconsistently executed • BOP's staffing formula requires additional scheduling variables (e.g., accrued personal time off, military deployments, or expanded training requirements) to properly estimate staffing needs and maximize its ability to allocate resources across its 122 federal institutions • Overtime and augmentation has increased over the years, but a deeper quantitative analysis is required to understand associated risks • Current staffing guidelines are developed for each discipline independently rather than using a standard process across the Bureau • More shift transitions are required using the standard 8-hour shift schedule, which may result in increased mandatory OT and a reduction of days off for staff • BOP's compensation and retention incentives require additional analysis to understand effectiveness compared to market standards • Negative media has affected officers' sense of pride, both internally and externally Prioritized recommendations below and highlighted throughout this report aim to mitigate these challenges: • Develop an Automated Staffing Tool to establish a reliable source for determining staffing levels • Invest in workforce planning capabilities to improve succession planning • Conduct cost benefit analysis of 8-Hour vs. 12-hour shifts to optimize staff allocation Hard-to-fill positions can vary by position and location. For example, one BOP institution may strive to fill medical positions while another institution located in a rural area finds it more difficult to hire Correctional Officers. 4 EFTA00141372

The visual below illustrates an overview of the current state assemement of the staffing lifecyle at BOP. Staffing at BOP Mission Needs Appropriate staffing ratios ro ensure safety and security of staff and Inmates Sufficient hiring processes to identify and retain Correctional Officers long- term Effective resource management. staff allocution and standardized processes institutions adequately staffed sth a skilled workforce to fulfill their unique missions Identified Challenges Across the Employee Lifecycle • Current hiringpractices are falling behind projected retirements • Current recruitment strategies make it difficult to hire specialized roles • Negative media ha: affected officers' sense of pride • Naad to measure effectiveness a retention incentive.. and market competitiveness • Limited exposure and practice at tramings • mentors* program appears inconsbtently executed • &Maur shift schedule requires additional shift changes Ina 2A-hour staffing environment • Staffing formula does not account ai dynamic factors Proposed solutions Develop an Automated Staffing Tool to establish a reliable source far determining staffing leech Invest in woaforce planning capabilities to proacnwly forecast retirements, promotions. and staff aim Conduct a cost-benefit analysis of &hour vs. 12. hour shifts to optimize staff allocation Conduct bather wage and 65-Level analysis to benchmooi compensation Ex .ected Outcomes 1 Improved processes at 8Oe that address current staff and constraints 0 Decreased level of vacancies and reduced dine to hire Igt'e arsine LmlotAvnInTWOnWerte(0. turtling.* -,,Moduling to effectively allocate Correctional • ',nesse* obtain and main quality staff Background Information Project Background The Bureau of Prisons has faced significant challenges related to staffing, recruiting, and retaining employees, which has impacted the employee experience. The COVID-19 pandemic further exacerbated these challenges as facilities became a focal point of the public health crisis. In response to staffing issues and a declining employee experience, the Government Accountability Office (GAO) published a report in February 2021 outlining shortfalls across the 122 federal correctional institutions titled, Opportunities Exist to Better Analyze Staffing Data and Improve Employee Wellness Programs. Following the release of the report and to respond to its findings, BOP hired Deloitte/NTT Data team, which will be referred to as the 'Deloitte team', as an objective third-party to examine and recommend solutions to the Bureau's challenges. Since July 2021, the Deloitte team has evaluated BOP's staffing challenges, employee experience, and staff safety and support offerings to develop this Current State Assessment, with the goal of improving staffing processes, job satisfaction and retention. The team addressed six of the seven GAO recommendations, utilizing the following three to specifically shape our focus group design:2 • (GAO Recommendation 1) The Director of BOP should develop and implement a reliable method, or 2 United States Government Accountability Report No. GAO-21-123. 2021. 5 EFTA00141373

amend existing methods, for calculating staffing levels at BOP institutions. • (GAO Recommendation 2) The Director of BOP should develop and implement a plan for analyzing data to help identify and address the causes and potential impacts of staffing challenges on staff and inmates. • (GAO Recommendation 6) The Director of BOP should develop and implement a method to routinely collect and evaluate employee feedback on its Employee Assistance Program such as leveraging existing tools or creating new ones, as applicable. As of January 2022, the Deloitte team completed an assessment of BOP's current workforce landscape through intensive research including interviews with BOP leadership, institution site visits, and focus groups with BOP staff. Data collected was used to develop recommendations in alignment with BOP's mission and core values. Corrections Landscape Almost 2 million individuals in the United States are incarcerated, 153,000 of which fall into the Bureau of Prisons' population.' Despite the decline in inmate population from its 2013 peak of 220,000,4 inadequate staffing levels continue to produce a strain on staff and inmates. Due to its critical mission and complex operating environment, Correctional Officers require interpersonal skills and ability to be successful in a correctional environment; however, an ongoing challenge for federal institutions has been recruiting and retaining these employees. As of May 2021, nearly one-third of federal Correctional Officer positions were vacant across the United States.' Various factors can curb potential hires from entering or remaining in the workforce: work with dangerous individuals leading to risk of injury, both physical and emotional; staff safety and support stressors such as exposure to crisis situations and trauma; a negative public perception of the work; and mandatory overtime and augmentation. The high rates of turnover—whether from burnout, retirement, or local job competition— often leads to a less safe environment for officers and inmates and, in turn, can create a cycle of forcing institutions to implement mandatory overtime and augmentation to ensure critical needs are met. To address these challenges, the Bureau announced a National Hiring Initiative in February 2021 to search for qualified external candidates with diverse skills and experiences, even after hiring 3,800 staff in 2020. 6'7 In April 2021, Director Carvajal testified before the Senate Judiciary Committee about these efforts, adding that a 5% retention incentive was offered to staff eligible to retire in 2019 in hopes that they would continue working at BOP, The Bureau has also advocated for closing older facilities and reallocating their staff—following best practices from state prisons such as South Carolina which closed six prisons and saved $491 million in averted spending and reduced operating costs — and are considering closings elsewhere. Along with increased public scrutiny and rapidly evolving mission mandates, the operating environment of the Bureau is very complex. 9 Today's staffing crisis is affecting more than just federal corrections; the strain of understaffing has been felt across state level institutions and other industries as well. The COVID-19 pandemic has triggered a "Great a Federal Bureau of Prisons: Population Statistics. https://www.bop.gov/about/statistics/population_statistics.jsp. °Federal Bureau of Prisons: Past Inmate Population Totals. https://www.bop.gov/about/statistics/population_statistics.jspgold_pops. s Cooks, Nurses Guard Inmates with US Prisons down 6K Officers. https://appnews.com/ankle/business-health-coronavirus-pandemk-prisons-government-and- politics-8811t926b1901336310581c28d826916. °Federal Bureau of Prisons: National Hiring Initiative. https://www.bop.gov/resources/news/pdfs/20210210_press_release_hiring.pdf. 'Federal Bureau of Prisons: BOP Hiring Frenzy. https://www.bop.gov/resources/news/20210210_hiring_frenzy.jsp. a Federal Bureau of Prisons: Statement. https://www.bop.gov/resources/news/pdfs/statement_2021041S.pdf. 9 The Pew Trusts: Data Trends- South Carolina criminal justice reform. https://www.pewtrusts.orgfen/research-and-a nalysis/fact-sheets/2017/09/data-trends- south-carolina-criminal-justice-reform. 6 EFTA00141374

Reassessment" of work in America—people are reassessing what they want to do and how they want to work. 10.11 Particularly in a strong labor market, it is imperative that BOP understands how organizations are competing to recruit and retain employees. BOP Values BOP's core values, mission, and vision were used to frame recommendations in this report to support the long- term staff safety and support of the BOP workforce12: Mission: It is the mission of the Federal Bureau of Prisons to protect society by confining offenders in the controlled environments of prisons and community-based facilities that are safe, humane, cost-efficient, and appropriately secure, and that provide work and other self-improvement opportunities to assist offenders in becoming law-abiding citizens. Vision: The Federal Bureau of Prisons, judged by any standard, is widely and consistently regarded as a model of outstanding public administration, and as the best value provider of efficient, safe, and humane correctional services and programs in America. Core Values: • Courage, we forge new paths, challenging the status quo, and make difficult decisions to rise above adversity. • Respect, we embrace diversity and recognize the value and dignity of staff, inmates, and the general public. • Integrity, we demonstrate uncompromising ethical conduct in all our actions. • Correctional Excellence, we are correctional workers first, committed to the highest level of performance. Recommendations outlined in this Current State Assessment focus on tangible actions for BOP staff and reflect BOP's vision for providing the most efficient, safe, and humane correctional services and programs in America. Methodology A combination of qualitative and quantitative data was used to support findings. The data analysis conducted for this report was based on the data made available to the Deloitte team. Field Research Design The team conducted five site visits comprised of nine focus groups as well as 30 interviews with leaders across BOP. Interviewees were selected based on gender, location, and position to provide a diverse representation of BOP staff.13Additionally, with the advice of Central Office and the National Union, questions covered topics most applicable to the GAO recommendations: staffing, leadership, recruiting, retention, employee experience, Employee Assistance Program, Crisis Support Team, mental health, wellness, and staff crisis prevention and response. The interview questions were tailored based on the participant's division and leadership title.14.15 " The Washington Post: Why America has 8.4 million unemployed when there are 10 million job openings. https://www.washingtonpost.comfbusiness/2021/09/04/ten-million-job-openings-labor-shortage/. n The Washington Post: It's not a 'labor shortage.' It's a great reassessment of work in America. https://vAvw.washingtonpost.comfbusiness/2021/05/07/jobs- report-la bor-shortage-a nalysis/. 12 Federal Bureau of Prisons:About Our Agency. https://www.bop.goviaboutiagency/agencypillars.jsp "All interviews were with a Leadership member (see Leadership in "Definitions" section for a more accurate description). "The interview topics depended on the interviewee's position. For example, a CST Leader's questions would focus predominantly on CST, but every CST Leader received the same standardized questions. I, Each interview lasted roughly 60 minutes. The ten virtual interviews were conducted either over the phone, over Zoom, or through Microsoft Teams. 7 EFTA00141375

The interviews were structured around previously mentioned topics and utilized open-ended questions to allow interviewees to provide sufficient details on each topic and adequately capture perspectives. Interview responses were documented verbatim and grouped according to similar themes (Appendix A). Additionally, responses were anonymously itemized and did not include any identifying information, to protect interviewee data. Key takeaways from the interviews were placed by theme into a quantitative research database (Figure 1) to assess data from interviews and institution visits.16 The database was organized by the following: Interview Number, Date, Office, Position, Comment, Theme, Sub-theme, and Categorized Responses and were used to add a deeper level of understanding during the analysis of responses. 17 Furthermore, a categorized response was used to label and sort responses. For example, if a comment notes that, "Career advancement relies upon movement between institutions," then the categorized response would be "relocate for career." Using this framework of grouping together alike sentiments created a practical analysis that quantifies categorized responses, themes, and sub- themes, which led to clear and concise insights. alSin coo° Ova tea fl ea Ea. SSA Can , YO Wan* laaa labga Yap mat iamb* alas asap Figure 1: Quantitative research database used by the team to analyze interview responses. Focus Group Design Focus group participants were identified based on gender, position, and tenure with the Bureau to gain a diverse group of attendees.18 All participants volunteered their time to partake in the focus group. Additionally, with the approval of HRMD and the National Union, an agenda of activities and questions was developed (Appendix B) to prompt BOP staff members to speak openly and honestly about their employee experience related to staffing, well-being, leadership, and culture. The same questions were used for every focus group to ensure questions were standardized and insights were clear and accurate.19 The team conducting the interviews consisted of two facilitators and two notetakers. Participants were asked to keep focus group conversations confidential and were notified that all responses would remain anonymous. Facilitators worked together to make sure that all responses were recorded correctly?' The team analyzed the focus groups using a method similar to the interview data analysis (Focus Group Number, Date, Office, Position, Comment, Theme, Sub-theme, and Categorized Responses). The team standardized the focus group questions across institutions and tagged the question with the response, which allowed for an accurate cross-sectional 16 The team made the research database through Microsoft Excel. The team analyzed the data by using the pivot table function. "The model is for internal third-party use only, therefore none of the information within the database will be attributed to a specific individual. Additionally, themes and sub-themes are explained within "Definitions." "The focus groups consisted of only Bureau of Prisons' staff members and supervisors. The team did not allow high level institutional leaders (such as the Captain and Lieutenant) to participate in the focus groups. " Each focus group lasted roughly 90 minutes. Some focus group questions changed over time, dependent on additional information learned during prior institutions. 2° Notetakers cross checked each other's notes before implementation into the research database. 8 EFTA00141376

analysis of data covering all focus groups (Figure 2).21 For this report it is important to note that focus group participants did not answer every question and sometimes had more than one response per question. For example, the question, "What do you love about working at the Bureau of Prisons," resulted in 222 total responses from 90 focus group participants. Therefore, the focus group responses are not mutually exclusive. For example, during the question, "What are the bugs of the job," 40 participants mentioned "training" or "training needs improvement" as a "bug." This does not mean that 50 out of the 90 participants believe the opposite is true. Just like the interviews, focus groups were a free-flowing conversation meant to lead to insights and uncover underlying root causes. The data can be sorted by any focus group question to find trends through the themes, sub-themes, and categorized responses. Additionally, the 'quantity' was labelled within the database, reflecting the number of focus group participants that agreed on a response. The database is a conglomerate of all the different themed responses from every stage of field research. This research database was used to gain collective insights across institutions to inform recommendations to BOP. 110=-CZMI • C=LZ:MI = • C== 1 a la • •r -414.• ten &W. c..4s erns San was, dia.. 0 , SIM ••••• see. .4,••••• (ce 0,1 WV. •4••••• tips Yere. Sen. diarwan. •••••••••• Figure 2: Quantitative research database used by the team to analyze focus group responses. Field Research Analysis After inputting the focus group and interview responses into the research database, a cross-sectional analysis was applied that proved to be beneficial during the research process. For example, instead of looking at responses as a whole, the interview data could be used to segment out and compare responses from Wardens to responses from Lieutenants. Moreover, the same logic could be used for focus group data; responses were compared across different institutions and regions nationwide. This comparison technique uncovered the major themes identified within the field research and underlying root causes for BOP to address. The team used Carl Jung's word association test which is based on the idea that asking for one-word responses from participants can reveal subconscious ideas.22 One-word associations were used during focus groups and participants were asked, "What is the first word you think of when you hear EAP?' Responses were sorted by labelling each either positive or negative. A positive response exemplifies a sentiment that views EAP as a beneficial program, while a negative response is a sentiment that criticizes EAP. Additionally, "I don't know" responses were categorized as a negative since it represented unawareness of the program. Using this technique to classify responses, in conjunction with additional data points, provided clear insights into the awareness and perception of EAP at BOP. " The team reflected changes made with focus group questions into the research database. "Cad Jung's Word Association Test. https://exploringyourmind.comicari-jung-word-association-test/. 9 EFTA00141377

Once the themes, sub-themes, and categorized responses were finalized, outside sources were used to aid in problem solving and ensure best practiced were utilized. Subject matter experts in mental health within law enforcement agencies were brought in to discuss both staffing and EAP related issues. In addition, organizations with similar problems were researched to identify what worked and what did not work in these similar circumstances. Connecting both quantitative and qualitative data, recommendations—supported by key insights—were compiled to address BOP's needs.23 Field Research Assumptions Findings of the field research consider several assumptions outlined below: 1. The participants responded to all questions asked with honesty and to the best of their knowledge. 2. The institutions visited were representative of Bureau of Prisons as a whole, even though five out of 122 institutions and five out of six regions were visited. 3. The participants for virtual interviews selected were representative of their discipline or department. 4. The focus group participants selected consisted of a representative sampling amongst the majority of disciplines. 5. COVID-19 had a large impact from the beginning of the pandemic (March 2019) to present day. 6. While the team used a consistent approach across all divisions, disciplines, regions, and locations, categorizing data into themes involves a level of subjectivity. Data Analysis Methodology In addition to the field research, the team collected a combination of qualitative and quantitative data to provide a holistic analysis. The data analysis conducted for this report was reliant on the availability of BOP's data. Data that was provided included: • Retention incentives • Recruitment incentives • Relocation incentives • Overtime and augmentation hours • Leave hours • Eligible and mandatory retirements • Exit survey results • Current staffing levels The documents reviewed included Staffing Guidelines for CPD, HSD, and RSD to better understand current staffing at BOP. Additionally, the team reviewed BOP's Human Capital Plan to understand how they plan for critical and future staffing needs? The analyses were primarily focused on institutional staff rather than Central and Regional staff members, given the scope of this report. The team conducted analyses using both external and internal data. The analysis of external data included using publicly available data from Bureau of Labor Statistics (BLS) and OPM's Fedscope tool to compare entry level n It is important to note, the team did not quantify all themes found within the field research. The team used some of the themes for qualitative purposes, such as using impactful quotes and unpacking specific sentiments. 2. BOP Human Capital Operating Plan_FY21_Q4 10-2021 - BOP Internal Document. 2021. 10 EFTA00141378

Correctional Officer wages. To depict the high-level overview of the current BOP workforce, the team analyzed staffing level data from 2021, calculating the representation of Correctional Officers in BOP's workforce. To understand overtime and augmentation hours recorded by BOP, the team took the total overtime and augmentation hours and divided this number by the total staff, resulting in the average overtime and augmentation hours per staff member. This process was then replicated, and trends were tracked for the past 5 years—which showed an increase over time. Data for staff incentives were similarly trended for the past 5 years by depicting the number of retention incentives offered to staff, broken out by region. Additionally, the team identified the top 10 positions receiving incentives. The retirement analysis was created based the current workforce's retirement data to project the number of staff that will be eligible to retire and reach a mandatory retirement age in 5 years. To assess leave, usage hours were broken out by type of leave. Many of the analyses used 5-years' worth of data to get a more accurate trend while accounting for external variables such as COVID- 19. Data Limitations Due to limitations of availability of certain data elements, the team made several assumptions during the data analysis process. Given the limited non-public data available at the time of this report, GS 6 (the GS scale is the predominant pay scale within U.S. civil service) was assumed as the entry level BOP Correctional Officer. OPM's Fedscope tool enables a comparison of publicly available wages, but it does not offer state and federal Correctional Officers salary data below GS 6. Additionally, for the wage analysis, federal Correctional Officers were assumed to be BOP Correctional Officers. For the exit survey data, the team assumed the reasons for staff resignations were representative of BOP staff as a whole. When analyzing the incentives data, positions deemed similar were grouped together and based on the team's understanding of job titles. 11 EFTA00141379

Hire: Acquire BOP Staff Introduction to the Hiring Process The first interaction that a new employee has with the Bureau is through the recruitment and hiring process. BOP is working to address the first goal in its HC Operating Plan—to replenish talent pipeline for mission critical occupations—through a new national marketing campaign.n The Bureau's current workforce is rapidly approaching retirement—which makes it even more critical to refill the talent pipeline now than ever before. The Bureau faces the following challenges related to hiring staff: • Current hiring practices are falling behind projected retirements • Current recruitment strategies make it difficult to hire clinical and mental health professionals (e.g., MDs, MLPs, psychologists, RNs)26 Like many other agencies, hiring at BOP follows federal government-wide personnel "They are management laws. External candidates that are hired into the Bureau as Correctional promoting staff, Officers enjoy a steady career progression where they can be hired at any level from GS 5 to but they do not GS 7 depending on a candidate's experience. Hiring candidates at GS 5 allows BOP to pull have the staff to from a broader and more diverse pool of eligible candidates. The typical GS 5 hire has 3 backfill years of managerial or supervisory experience or holds a bachelor's degree. However, over positions." - the last two years during the COVID-19 pandemic, BOP has more commonly hired at the GS Focus Group 7 level. One Warden stated that it is not uncommon to hire a Correctional Officer at the GS Participant 5 level and have them apply for the GS 6 level within the year. Candidates at the GS 6 or 7 — level must have specialized experience. For example, specialized experience at the GS 6 level would include working as a police officer, while specialized experience at the GS 7 level would include experience time in the correctional field. Candidates can also substitute years of experience with a master's degree in a related field of study. BOP is required by law and the federal hiring process known as competitive examining to notify the public about job vacancies; screen applications against minimum qualification standards; apply selection priorities such as veterans' preference; and assess applicants' relative competencies or knowledge, skills, and abilities against job- related criteria to identify the most qualified applicants.21 BOP uses USAJOBS.gov as its primary site to post jobs, but also utilizes other recruitment platforms such as recruitmilitary.com and indeed.com. BOP is required by the Office of Personnel Management to hire new employees within 80 days. According to the GAO report in February 2021, "BOP's time-to-hire has ranged from an overage of 82 days (in fiscal year 2016) to an overage of 96 days (in fiscal year 2017) from fiscal years 2015 through 2020. In fiscal year 2020, BOP's overage time-to-hire was 91 cloys."28 The hiring process involves a variety of stakeholders and many checks and balances (Figure 3). Employees familiar with the hiring process have attributed delays to a number of items including a lengthy background check/e-QIP process, required medical screenings, and credit check complications. 74 BOP Human Capital Operating Plan_FY21_Q4 10-2021 - BOP Internal Document. 2021. Hard-to-fill positions can vary by position and location. For example, one BOP institution may strive to fill medical positions while another institution located in a rural area finds it more difficult to hire Correctional Officers. "Office of Personnel Management. https://www.opm.gov/policy.data-oversight/hiring-information/competitive-hiring/KompetitveExamining. n United States Government Accountability Report No. GAO-21-123.2021. 12 EFTA00141380

A Vacancy at institutton Local HR klentilln need to RI vacancy Is the Regional Director the selecting official for this position (e.g., UNICOR Department Head, Case Management Coordinator, Genera' Foreman)? Regional HR Send Vacancy Posting Materials c 3 Days < 15 Days 7o-:s to vacancy on USAJOBS Evaluates candidate qualifies 'ons and develops list of qualified andidates 1 Local HR < 20 Days < 5 Days <17 Days Candidates given Core Value Assessment Interview candidates Choose Candidate to hire Perform background check, drug, physical test Onboard new hire Estimate of 87 Days Figure 3: Normal hiring process flow for Institution Staff Under the normal hiring process, the need to fill a vacancy is first identified by the local institution, who submits vacancy posting materials to the Consolidated Staffing Unit (CSU). If the selection official for the position is the Regional Director (e.g., supervisory and managerial-level positions), however, the Regional Office will submit vacancy posting materials to CSU. The Consolidated Staffing Unit will post the job opening on USAJOBS and eventually present a list of qualified candidates to the local Human Resources (HR) staff, who then administer the Core Value Assessment, conduct interviews, and select candidates. The overall timeline can be expeditated for positions that qualify for direct hire authority in accordance with OPM policy whereby "OPM is authorized to permit agencies to use direct hire authority for positions where OPM has determined that there is either a severe shortage of candidates or a critical hiring need for such positions."29 BOP can also submit a written request to OPM for specific positions. 29 United States Government Accountability Report No. GAO-21-123. 2021. 13 EFTA00141381

A Hard.to.fIll Vacancies at Institution Local HR dam mine. need to apply for Direct Flea Authority 0DHA) Subm.1 lustrfication mmo) I Submit, IOS011aitlOn to DOI on OOP's behalf 1 001(02%2On aPINOVOl to Panonnel OirectOrS Offir. 1 consolidated Staffing Unit (HRAIO) notified COCA HR notified J Posts job vacancy on USAION Auttiorded to accept and (*Made, applications under DHA Evaluates Candidate clualifica101nS and determines list of candidates Candidata'. swan Corevalue Assessment Interview Candidates • Choose Candidate to hire Perform oackground check clot& physical LOU [,louts S7 Days c 20Dast <s Days '17 Clays Figure 3.1: Process of obtaining Direct Hire Authority (DHAJ approval and hiring Direct hire authority expedites the typical hiring process associated with the competitive examining hiring process by eliminating competitive rating and ranking procedures and veterans' preference (Figure 3.1). To obtain Direct Hire Authority (DHA) for specific positions, the local institution submits justification for DHA to the Personnel Directors Office within HRMD. The justification is reviewed and submitted to DOJ on behalf of BOP and submitted by DOJ to the Office of Program Management (OPM), who decides on DHA request approvals. If OPM approves the institution's request for DHA, the approval is relayed back to the Personnel Directors Office, who informs the Staffing and Employee Relations (SERS) office within HRMD. Then, SERS notifies CSU and the local HR. As with the normal hiring process, it is at this point that CSU posts the job on USAJOBS. The next step differs from the normal process in that the local institution is now authorized to accept and consider applications, evaluate candidate qualifications, determine a list of candidates to move forward, and complete the pre-employment process. Direct Hire Authority remains for one year from date of approval. As an agency, BOP has applied for direct hire authority twice (October 2019 and March 2020). If BOP is granted DHA, they can exercise that authority for two years. In one instance, OPM decided that there was a lack of sufficient evidence to show a critical hiring need and severe shortage of candidates.3° However, requests for direct hire authority have been granted to specific institutions, such as USP Thomson, which received 25% retention bonuses and direct hire authority for staff in September 2021.31 Promotions and Succession Planning The application and selection process for internal candidates follows the same process as external candidates, with a few exceptions. Merit-based promotions are not required to complete interviews or the pre-hiring questionnaire. Since these positions do fall under the competitive hiring process, a candidate must meet thresholds for time-in-grade and necessary experience, and they must apply to be considered for the position. The application packet that candidates submit includes: their resume; performance evaluation from the last 13 months; performance awards they have received over the last 5 years; and responses to an assessment regarding their skillsets. 30 United states Government Accountability Report No. GA0-21-123. 2021. 11 Thompson Prison employee named AFGE 2021 Oficer of the Year. httos://actimes.cominews/loca Vthomson-oreson-emoloyee-named-afee-2021-officer-of-the- year/article 4154e34a-e6d1-Sf78-9a01-93fc0950f096.html 14 EFTA00141382

BOP provides an opportunity for staff to relocate to develop skills and learn best practices from other institutions. Some focus group participants appreciated that leaders were selected internally. However, others expressed frustration around the perception that promotion was predicated on a willingness to relocate and that the entire hiring process was centralized in Grand Prairie. Forty participants commented on the hiring process, stating it was too slow and that new hires are not prioritized based on quality. According to institution leadership and focus group respondents, relocation is often encouraged to achieve career progression at the supervisory level. Some field research participants noted that the positives of a culture of relocation enabled exposure to different institutions and an ability to share best practices across the Bureau. At institutions that were self-described as "homestead" institutions, participants described transitioning into positions such as teacher or social worker to progress their salary while staying local. In addition, they also cited the Grand Prairie HR specialists' lack of functional knowledge about institutions as prohibiting their ability to qualify for desired positions (i.e., resumes were tossed out if they did not contain specific key words). Unlike other positions, which are posted when they are vacant, promotion to the Associate Warden and Warden positions follows a cyclical pattern. The announcements are posted twice a year and Executive Staff meet quarterly, and as needed, to review Associate Warden and Warden vacancies across the Bureau. Staff generally must serve as an Associate Warden at least twice to be eligible for promotion to Warden. Regional Directors make recommendations for Warden roles, however the BOP Director makes the ultimate selection. Succession planning at BOP to backfill positions is mostly focused on mandatory and confirmed eligible retirements. HRMD provides a report on the number of projected mandatory retirements to each new Assistant Director or Regional Director. Each Regional Office has access to see all eligible and mandatory retirements within their region coordinated by the Consolidated Benefits Unit (CBU), however availability to support individual institutions may vary. In addition, every individual institution has a monthly HR workforce utilization committee meeting to discuss budget, succession planning, and upcoming staff transfers with the Warden. This meeting serves as an important step to backfill positions at the local level. After an employee decides to retire upon becoming eligible for retirement, they are assigned a benefits counselor who walks them through their retirement options. If the staff member makes the decision to retire and submits their completed application for retirement packet, CBU then notifies the local HR office—enabling the institution to begin backfilling the position. When an employee is six months away from their mandatory retirement, CBU sends a notification to both the employee and their institution's HR office. Given that the retirement is mandatory, the HR office can then begin backfilling the position. Strengths of Current Hiring and Succession Planning BOP offers a few unique long-term benefits such as student loan repayment, early retirement as a law enforcement agency, and family benefits (e.g., EAP counseling) that entice employees to remain at BOP after a few years of service.32 Additionally, healthcare for BOP retirees is also transferrable to retirement and covers family members until they reach the age of 26. A few interviewees noted that BOP's 2021 hiring initiative was successful at recruiting some candidates by offering financial waivers to pay off student loans. The National Recruitment Office has, in conjunction with a marketing partner, launched a new marketing campaign to promote a career in correctional services. The new marketing campaign, which began in October 2019, is focused on the overall BOP brand and features targeted ads for Correctional Officers, nurses, and social workers. According to BOP's National Recruitment Office, this marketing campaign has gathered 1,100 clicks on advertisements and nearly 300 applications using Facebook, Linkedln, and Google Search advertisements. In 31The term "early retirement" refers to the eligible retirement age for law enforcement personnel at age SO rather than age 62 for other civil service workers. 15 EFTA00141383

addition to the marketing campaign, the National Recruitment Office has built up its team of recruiters, providing full-time dedicated recruitment support for most positions. BOP has made a concerted effort to focus on recruiting teachers to help fulfill First Step Act requirements around educational programming. Another strength of the hiring process is the Bureau's proprietary Core Value Assessment (CVA). The CVA presents candidates with simulated, stressful security threats they are likely to encounter as a correctional worker. The objective of the assessment is to analyze their cultural fit with BOP by comparing their responses to hypothetical situations with BOP's core values. The CVA is a good attempt by BOP to attract quality candidates to serve as correctional workers. Scope of Challenges and Associated Risks of Current Hiring and Succession Planning Challenge: Current hiring practices are falling behind projected retirements As BOP is a law enforcement agency, most of its workforce is mandated to retire at the age of 57. The looming deadline to replenish its talent pipeline before it experiences a dramatic uptick in retirement (from 291 retirements in 2018 to 762 retirements in 2025 according to Figure 4) presents a hiring risk to BOP. 33 HRMD reports the number of upcoming eligible and mandatory retirements, however, workforce planning documentation at the enterprise-level does not consistently identify plans of action to backfill these predictable separations.34 The prioritization of which positions to backfill first are often based on the individual Warden and Regional Directors' discretion. To address this risk, it is recommended that the Bureau invest in more robust workforce planning capabilities to forecast rates of retirement for eligible employees in addition to mandatory retirements. An ability to better predict critical staffing shortages would enable the Bureau to present evidence- based applications for hiring exemptions or special salary rates to mitigate this threat. Number of BOP Staff Retirements by Year 900 800 700 600 ro 500 15 400 300 200 100 0 2018 2019 2020 2021 2022 2023 2024 2025 • MANDATORY 2 6 53 417 488 602 667 a ELIGIBILE 291 158 182 320 364 236 175 95 - Grand Total 291 160 188 373 781 724 777 762 Year Figure 4: Based on overage BOP retirements of age of 53 and over "BOP Retirement Data CY 2021-2026. HRMD Workforce Systems and Evaluation Section: BOP Workforce Planning Information. 2021. 16 EFTA00141384

Challenge: Current recruitment strategies make it difficult to hire clinical and mental health professionals (e.g., MDs, MLPs, psychologists, RNs)35 The Bureau's ability to hire specialized positions such as MDs, MLPs, psychologists, and RNs is another critical challenge that presents risk to the organization. Sentiments from field research indicated that Wardens may not have the specialized knowledge needed to best evaluate the technical skills of candidates applying for a specialized position. Furthermore, the National Recruitment Office does not currently have a full-time recruiter specifically dedicated to recruiting for medical positions. Subject Matter experts do provide input around the candidate selection process: they support the creation of position descriptions and the crediting plan-which rates the knowledge, skills, and abilities required for each job posting; and are included in panel interviews. However, HR has the primary responsibility of selecting candidates. Field research participants expressed the sentiment that local HR had selected candidates to interview that were unqualified for specialized positions, and excluded candidates known to contain the proper qualifications without explanation. Further involving SMEs during the selection process could be an area of exploration to improve recruitment efforts. The COVID-19 pandemic has further exacerbated the challenge of recruiting for highly sought-after HSD positions such as physicians, nurse practitioners, and physician's assistants. In addition to a national shortage of nurses, BOP is competing against local hospitals that often offer higher salaries and incentives. Individuals who graduate from nursing school may not immediately think of BOP as a viable career option, particularly in comparison to nearby hospitals. "I didn't know BOP was an option when I was in nursing school." — Focus Group Participant Current recruitment strategies at RSD would benefit from increased communication and coordination to ensure that BOP is consistently hiring quality candidates. Recruiters in Grand Prairie could benefit from trainings taught by subject matter experts that focus on how to identify necessary skills for psychologists. Although BOP's new national recruitment initiative has dedicated recruiters for medical personnel, RSD does not have a recruiter in the National Recruitment Office (NRO) that is dedicated to hiring psychologists. RSD psychology internships have also been a successful recruitment tool in the past, with many interns seeking out full time opportunities at BOP post-internship. However, these internships fall short of other similar public sector psychology programs who offer more desirable student loan repayment benefits. Some BOP stakeholders reported that BOP's student loan repayment program is simply not as generous as other similar psychology student loan repayment programs such as the Department of Veterans Affairs debt reduction program. In addition, BOP's program could become more competitive by the offering post-doctoral positions that many candidates are looking for. It is recommended that BOP re-invest in student loan repayment programs that are market-competitive and ensure consistent technical Subject Matter Expert input throughout the entire hiring process. ss Hard-to-fill positions can vary by position and location. For example, one GOP institution may strive to fill medical positions while another institution located in a rural area finds it more difficult to hire Correctional Officers. 17 EFTA00141385

9 Train: Acclimate BOP Staff Introduction to Correctional (ICT) Training After receiving an official offer letter and start date, a new hire's next major milestone is onboarding to BOP. Given the unpredictable, and potentially dangerous environment that institution staff face (regardless of their position), it is imperative that new hires feel ready to work on day one. New Mexico, for example, is one of several states that has proposed starting new training academies to solve their staffing shortages. Between inconsistent training, a struggling staffing rate and low compensation, most new officers leave within three years. 36 BOP Correctional Officer turnover saw an 1% increase from 2019 to 2020, and 17% of new hires across all departments left the Bureau within one year.37 The Bureau faces the following challenges related to staff onboarding: • ICT training needs continued investment and accountability to provide the exposure and practice needed for staff to feel ready their first day on the job • The supplemental onboarding programs appear to be inconsistently executed Introduction to Correctional Techniques (ICT) is a training all new correctional hires are required to complete when joining an institution. ICT is a five-week program for a total of 184 hours of instruction that is taught in two phases. However, day one is often a few months before starting ICT, which could create a challenge for new hires that then feel unprepared. Ideally, all Correctional Officers would complete ICT training before their first shift, but given scheduling constraints, this is not always the case. Phase I of ICT occurs in-person at an officer's assigned institution and focuses on security issues, contraband, emergency situations, ethics, sexual abuse prevention and intervention, worker's compensation limits and other location-specific issues. It also focuses on communication and de-escalation training to minimize assaults on staff or inmates. After new Correctional Officers learn policies in the classroom, they shadow an active Correctional Officer to go through day-to-day activities. Individual institution leadership also has the authority to determine necessary additional training on an individual basis. "Let's get away from 'I figured it out, you can figure it out too.' - Focus Group Participant ICT Phase II is a 17-day training for all disciplines to attend at the BOP Staff Training Academy. The first week is comprised of in-class trainings while the second week is on-the-job trainings (OJT), including working side by side with a seasoned staff member depending on their discipline. This phase has four main components: firearms, self- defense, a written academic test on policies and procedures, and the Physical Abilities Test (PAT). The training covers an array of topics, such as correctional supervision principles, national policy guidelines, interpersonal communication, and diversity and inclusion. The PAT measures an employee's ability to perform essential functions of a correctional worker. Completion of the program is required and must be completed within 120 days of entry-on-duty (EOD) under the discretion of the Staff Training Academy (STA) for continued employment of new law enforcement staff. Supplemental Onboarding Programs Some institutions have implemented onboarding programs to supplement ICT by pairing new staff with someone to mentor them through their initial year and beyond. The mentorship program is also available at all institutions for all Correctional Officers regardless of their tenure (i.e., it is not limited to new hires). In most cases, the level of *Many States Face Dire Shortage of Prison Guards. https://www.pewtrusts.orgientresearch-and-analysis/blogs/stateline/2016/03/01/many-states-face-dire- shortage-of-prison-guards. 37 BOP Exit Survey and Turnover Data. CY 2021-2026. 18 EFTA00141386

S investment in the program appears to vary depending on the level of involvement from the Warden and training department leaders. Each institution has been provided a curriculum for the mentoring program that includes policies and procedures, but the success of the program depends on how effectively the teaching materials are used. Annual Training Requirements After a Correctional Officer's initial training and mentoring, all staff are required to complete 40 hours of training per year, focused on American Correction Association (ACA)-mandated topics and core annual topics determined by a BOP executive. After completing the core annual topics, the remaining training time is determined by the Warden and can be met through a variety of platforms including self-study, meetings, offsite training, experiential training, and/or computer modules. BOP utilizes an online learning management system known as the Bureau Learning University (BLU), to allow staff to complete some training requirements. Annual mandatory staff training includes firearms training, cardiopulmonary resuscitation (CPR) and automated external defibrillator (AED) and Information Security. The Bureau offers additional training for custody staff to grow more specific skillsets, such as a Marksman Observer and Witness Security training at the Staff Training Academy (STA), housed at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia. Strengths of Current Acclimation Programs BOP's standardized ICT training results in a consistent introduction to the organization and information sharing for new hires, regardless of their geographic region or position. BOP will soon launch a Bureau-wide Correctional Training Officer (CTO) program. The program will be led by officers at each institution who are selected by the Regional Director and receive training on how to best aid future trainees in improving their skills. Participants in the program will include Correctional Officers that are referred by a supervisor and officers that indicate they would like to improve their correctional skills. In addition to the initial ICT training, some institutions have implemented supplemental onboarding programs such as mentoring for new hires as a best practice. The mentorship program presents an opportunity to supplement onboarding in a safe environment. Scope of Challenges and Associated Risk of Current Acclimation Programs Challenge: ICT training needs continued investment and accountability to provide the exposure and practice needed for staff to feel ready their first day on the job "A three- month person is training a three- week person."— Focus Group Participant Focus group participants indicated that on-the-job, real-time training would position them to be more successful than ICT. Current ICT relies on PowerPoint training, misses opportunities for cross-departmental training, and is often led by less experienced staff. Moreover, COVID-19 restrictions have exacerbated training backlogs, preventing staff from obtaining requisite skills and attending additional training opportunities. The current scheduling process does not account for all training requirements—which creates a risk for instructors being selected based on availability rather than expertise or training capability. Focus group participants recommended adding the role of Field Training Officer, to create a permanent training instructor to facilitate ICT and additional training opportunities across the Bureau. Shortfalls of ICT can lead to staff turnover—exit surveys from 2016 to 2020 show 30% of staff state lack of training as a contributing factor to their decision to separate from BOP. One focus group commented that they would add crisis management training to the current curriculum, while another felt that BOP should offer incentives and invest in staff that are interested in growing professionally. To mitigate this risk, it is recommended that the Bureau consider incorporating all training hours into its scheduling process and evaluate the effectiveness of 19 EFTA00141387

9 current training curriculum, considering innovative techniques to improve Correctional Officers' preparation. BOP would also benefit from investing in external leadership training from OPM or external entities for the middle management positions (e.g., Lieutenants) that draw on industry best practices and support consistent learning across the Bureau. However, it is important to note that, much like other federal agencies, trainings are the first to get cut in funding due to budgetary constraints. Challenge: The supplemental onboarding programs appear to be inconsistently executed While staff will readily admit that the mentorship program is great in theory to supplement onboarding, they quickly cite challenges with how it is currently executed. Primarily, experienced staff who watch over new hires may not even be in the same discipline—limiting their ability to provide guidance and advice specific to the new hire's role. Additionally, due to staffing constraints, some mentors may not be able to participate in the program to the extent needed. It is recommended that BOP assess the impact of the current supplemental onboarding programs and explore how standardization of the programs might drive an improved talent experience for new hires. 20 EFTA00141388

Manage: Allocation of BOP Staff Key Metrics of Current Staff 40,000 35,000 30,000 25,000 N tol ▪2 0,000 tt 15,000 10,000 5,000 Total BOP Staff as of 2021 • Other Staff • Correctional Officers BOP Staff by Region: Correctional Officers V Other (as of 2021) 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 CC CC CC Z Z LLII Region CC CC X • Other Staff • Correctional Officers Figure 5 Total number of staff of SOP os of December 2021 Figure 5.1: As of December 2O21- CO represents Central Office (please see Appendix O1 Following a period of acclimation, a new employee joins the Bureau's workforce of approximately 37,000 staff members.38 Given the large proportion of Correctional Officers to staff in other disciplines (around 15,000 out of 37,000), this section will focus primarily on current staffing processes for Correctional Officers and recommendations to resolve staffing challenges. Additionally, staffing for the Health Services Division (HSD) and Reentry Services Division (RSD) will be examined due to their specialized skillsets and critical mission impact. The Bureau faces the following challenges related to allocation of staff: • BOP's staffing formula requires additional scheduling variables (e.g., accrued personal time off, military deployments, or expanded training requirements) to properly estimate staffing needs and maximize its ability to allocate resources across its 122 federal institutions • Overtime and augmentation has increased over the years, but a deeper quantitative analysis is required to understand associated risks • Current staffing guidelines are developed for each discipline independently rather than using a standard process across the Bureau • More shift transitions are required using the standard 8-hour shift schedule, which may result in increased mandatory OT and a reduction of days off for staff • Manual entry of changes to staff schedules in current roster system increases risk of human error History of BOP's Current Staffing Formula The challenges BOP faces today have developed over a long thirty-year history. Since 1992, BOP has calculated its staffing needs by estimating the number of working days that Correctional Officers should be available to work by subtracting an average number of days for training, sick days, holidays, and annual leave. The formula does not account for Correctional Officers accruing more paid time off over the course of their career or variations in training requirements. In 1992, BOP set the number of available working days for Correctional Officers to be 216 '18federal Bureau of Prisons: About Our Agency. https://www.bop.gov/aboutiagency/. 21 EFTA00141389

days to calculate necessary staffing levels. In 2011, the Correctional Programs Division (CPD) recommended changing the available working days from 216 days to 210 days to better reflect the reality on the ground. However, this change was not implemented until 2016. In 2013 and again in 2016, the Bureau updated guidance to ensure greater safety in housing units at high security facilities: • In 2013, guidelines were updated to include an additional Correctional Officer in the housing unit during late shifts at high security facilities. • In 2016, Congress mandated that a second Correctional Officer is required on all shifts in each housing unit at high security institutions and detention centers. In 2019, the Warden's Advisory Group (WAG) determined that 210 days did not accurately reflect the average number of days correctional services, human resources, and finance personnel were working, and was not a good foundation for calculating staffing needs. In 2020, the Correctional Services Branch (CSB) developed a new system to determine staffing levels by calculating how often a Correctional Officer is physically at their post, but the new system has not been approved. Today, staffing levels are still based on the assumption that Correctional Officers are available 210 days per year. Using this assumption, BOP calculates the required base number of in four steps as indicated below. Additional staff may be added to the calculation according to BOP's staffing guidelines which are described later.39 Below is a step-by-step process for how staffing levels at BOP are calculated today using the 210 number. The entire process is institution-specific. I Sum 2MultIply Sum the total number of 3•day, Muhl* by the number of days S-clay, and 7-day posts each post is manned. The result is the total number of man days. SO (Total Number of 7.day posts) x 364 • 18,200 20 (Total Number of 5-day posts) x 260. 5,200 10 (Total Number of 3-day posts) X 156 • 1,560 3sum sum the total number of man days across each type of posts 18,200 . 5,200 • 1,560 • 24,960 4 DivIde To find the total number of needed positions, dMde the total man days by 210. A remainder of 72 or more is one additional position. 24,960/ 210. 118 positions Figure 6 W Z mr Strengths of Staffing Formula Calculating the required number of Correctional Officers is straightforward with the simple formula above. The single formula has been standardized across the Bureau of Prisons for all Correctional Officers. The standardization of this approach provides a sense of clarity for all institutions to gauge their vacancy levels by finding the difference between authorized positions and their current staffing numbers. Risks of Staffing Formula Challenge: BOP's staffing formula requires additional scheduling variables (e.g., accrued personal time off, military deployments, or expanded training requirements) to properly estimate staffing needs and maximize its ability to allocate resources across its 122 federal institutions "Correctional Services Staffing Solutions PowerPoint - BOP Internal Document. 22 EFTA00141390

The availability of Officers to man their posts fluctuate from year-to-year making it difficult to accurately calculate how many positions an institution will need to remain secure. While the formula does provide an easy, standardized approach to determine staffing levels, it is not agile enough to adjust to an individual institution's needs. For example, the current formula does not account for Correctional Officers accruing more paid time off over their career or variations in training requirements. Field research indicated that institutions could have a low staff vacancy rate, but still struggle to staff while some Correctional Officers are on military deployment. Data analysis illustrates that overtime and augmentation have been increasing over the years and indicate the staffing formula struggles to provide BOP the estimates needed to accurately staff its institutions. "I feel like trainings are scheduled without thinking about staff scheduling." - Focus Group Participant New staffing guidelines were proposed and developed in February 2021. However, implementation of the new guidelines has been postponed until BOP responds and addresses GAO recommendations. The new 2021 staffing guidelines provide a manual formula that Captains can use to calculate maximum number of staff that could be on scheduled leave, but the process is labor intensive and optional. Additionally, the staffing formula cannot respond to emergent staffing requests such as border patrol, riots, or natural disasters and does not account for projected staff turnover or promotions. Therefore, the new formula does not improve estimation of staffing needs or full address BOP's staffing challenges. Staffing Guidelines for CPD, HSD, and RSD Building off the available 210 working days formula to determine the required number of staff, each division in BOP Central Office has developed guidelines on how to best allocate that number in each institution. The guidelines are written independently and provide guidance to Wardens when deciding the composition of their institution's workforce. Institutions are permitted to hire additional positions beyond the staffing guidelines if they submit a waiver to their Regional Office and receive approval. Correctional Programs Division Staffing Guidelines The CPD staffing guidelines use type of post, security level and shift type to determine composition and volume of Full Time Employee (FTE)'s for Correctional Officers. There is a standard structure for staff posts and a supplemental guide which adjusts for an institution's mission, physical layout, and other unique characteristics. The standard scheme includes a variety of positions and teams which include Captain, Lieutenant, Secretary, Correctional Officers and SIS Technician. Additional Correctional Officers may be afforded if an institution has more 7-day posts relative to 3-day posts. Each institution is also afforded supervisory Correctional Systems Officers (CSO) to help manage other officers. In February 2009, the Executive Staff approved a staff-to-inmate ratio of 1:225 for Correctional Systems Officers (CSOs) for stand-alone facilities, to include high, medium, low, minimum, and administrative security levels, regardless of population numbers. This ratio also applies to Care Level 3 and 4 facilities, complexes, medical centers, and those facilities with Residential Drug Abuse Programs (RDAPs). Institutions over 50 years old also require additional facility staff such as electricians, plumbers, and general maintenance to ensure the facility is functional. Correctional Officers comprise 35% of the workforce at Penitentiaries while low security institutions only require 30% of the workforce be Correctional Officers. The CPD guidelines assume that more dangerous inmates require more Correctional Officer attention. 23 EFTA00141391

How many clays does a post need to be staffed? 0 „ %t lop • 7 Days • S Days • 3 Days • I Day • 6 Days • 4 Days • 2 Oaw What Is the pwcentage of total awrectIonal Officer (GSA positions by security lever 0 Security Level • Minimum13M • Medium (12%) • Administrable (3310 • Low (30%) • High 135%) What are the different shifts?" • Mowing Watch (DAY) • Day Watch (DM) • Evening Watch (ENO 0 Shift • Early Watch (A/M) • Late Watch (NM) ComposihanandYdumrof FU% • base level staffing includes a variety of positions and teamsMIMI include Captain. Lieutenant Secretary. Correctional Olken (custody's and StSTechnnien Figure 7 Currently, BOP uses the above guidelines that were approved in 2016. However, CPD developed updated staffing guidelines in 2021 that have not been officially approved. The new guidelines define posts that are deemed critical to all institutions' safety and security and should only be left vacant if there is an emergency or inmate programming is modified to alleviate the staffing need. Differing from the current guidelines, the 2021 guidelines incorporate more variables including physical layout of the institution, in addition to security level, care level, and special institution missions. Additionally, it includes guidance on how to calculate annual leave schedules to help Captains develop their rosters and daily schedules. Captains can use the formula as needed on a weekly or quarterly basis, but calculating the formula is a manual, labor-intensive process rather than automatic. While these new guidelines take a step in the right direction, they still do not account for fluctuating factors such as accrued personal time off, military deployments, or even training requirements. Health Services Division Staffing Guidelines Aside from keeping institutions safe, BOP HSD provides healthcare to inmates. HSD staffing at BOP consists of clinical, administrative, and allied health personnel that are determined by an institution's security level, care level, and the number of inmates that are served. While higher security institutions always require more Correctional Officers, additional nurses are also required for care level 4 inmates who require a higher level of medical care such as oncology services. The type of institution also affects nurse staffing. For example, staffing is determined by admissions, discharges, and population for detention and transfer centers who operate 16 hours per day. Nurse staffing also depends on the number of inmates and whether the population is male or female. Internal BOP data affords female institutions additional health services staff due to higher service utilization rates and more psychosocial and preventive health needs. The standard composition and volume guidelines of FTEs for an institution's ambulatory care is designed to serve 1,500 care-level 2 inmates. For institutions with alternative medical missions, there are 3 supplemental staffing models which require additional staff above the base staffing model. 24 EFTA00141392

Each staffing model is further broken down to the following cntena: What type of institution is it? O Security Level • Camp (12-24 medical service hours)•• • Detention/Transfer Center (16 medical seance hours)•• What is the care level of the institution? • Care levels I. 2, 3.4 • Care Level O Inmate Population Composition and Volume of FIE's • Complex (16-24 medical service hours)•• • Low, Medium, or USP (12.16 medical service hours)•• How many inmates are served? • For detention and transfer centers, staffing is determined by admissions, discharges and population • For all other institutions, staffing is conditional on how many inmates reside there • Staffing is also conditional on whether the inmate population is male or female • Base level staffing includes a variety of positions and teams which include admin, clinical, and social workers 8OPS staffing guidelines for CPD, HSD and RSD are more complex than what is conveyed to Congress •Nine: Some institutions require lidditional tug for undue inasiorn of inpeoaly lase inmate population.. Additionally, some pot-vont ire f owned to b. font,. fed on nliofei Id *clue menu houn se not UNA bout blond, a is the den* that health tonnes is open to pethidine healthcare. Figure 8 Reentry Services Division Staffing Guidelines While HSD is required to provide healthcare to inmates, RSD is required to prepare inmates for reentry to society. RSD staffing guidelines include the psychology department and all other reentry services departments such as education, chaplaincy, and recreation. The Psychology department generally follows the same criteria as HSD to determine its staffing requirements. Base level staffing includes a Drug Abuse Program Coordinator, Drug Abuse Treatment Specialist, MAT Psychologist, and at least one Staff Psychologist, Psychology Services Secretary, or Psychology Services Technician. Outside of these positions, additional staff psychologists are determined by inmate-to-staff ratios that are based on an institution's security level. Outside of psychology, all other departments in RSD use inmate population numbers to determine the required number of staff with additional staff for various incremental increases in inmates. PSYCHOLOGY DEPARTMENT Criteria irclude institution security level, inmate volume, irmate gender and inmate care level BASE LEVEL STAFFING: Slag inOode Chug Alm. Program Coordinator. Dfug Abuse Treatment Specoliz MAT Psychologist at Mau 0(4 stag Peychoitou DtythOlOtyS•IV•COS Secretary of Pitshology Savicti Techncun Additional Staff Psychologists art determined by the lollomre Uff loom/sate rebut Ma High Stones 1:350 use Medium Security. 1:500 use Log Security: IMO use Lunen," Security: 1:700 Female Lana Minmurn Secunty. 1:250 Mak &Female Detention Centers 1:350 SUPPLEMENTAL STAFFING oxnxericoilinaw complexes nave addeonal psychologists for restr eted housing inmates. Higher inmate Ure lugs ago rotetstate acclioona psyCholopus Finage tense institution: ere staffedWith an acl0ttionel intik* venom <offline', PROGRAM AREAS Criteria include security level and inmate volume EDUCATION DEPARTMENT 9 stiff fee the F✓aterel 500 inmate population and I additional staff for every 200 inmates. I additional stall for special need populations. CHAPLAINCY SERVICES stall foe the basolong 500 inmate Population I aciciimmi staff for major med<al tulle's. special programs, or txenta programs. WOMEN AND SPECIAL POPULATIONS Only porrnned for temelfiand :peva, mission irnetutone I additional staff lo• each uncut reedental music" Figure 9 RECREATION MENT 6 scoff for the enemy, 500 inmate population. l additions :,an for everySOO inmate:. <ornifteret satellite program or non tentraged recreation area: REENTRY AFFAIRS I staff for the batelesel 500 inmate population. l additions sun for each facility of a complex or facility Ann any WO volunteer, 25 EFTA00141393

Risks and Challenges for Staffing Guidelines Challenge: Current staffing guidelines are developed for each discipline independently rather than using a standard process across the Bureau The biggest challenge with staffing guidelines for CPD, HSD and RSD is that they are currently created in siloes and do not provide a standard approach to developing staffing requirements across mission critical disciplines. Each institution requires adequate staffing in food services, maintenance, chaplaincy, and other departments to remain operational and in compliance regardless of an institution's inmate population. Initial staffing needs are determined at the Central Office level, but Wardens have the ultimate decision with input from Regional Directors. However, Wardens may have a misunderstanding of how to properly staff for other departments. This may result in an overemphasis of staffing roles in Correctional Services, and underemphasis of staffing roles in other mission critical divisions. The guidelines are also reliant on a different set of metrics than what is conveyed externally, resulting in disjointed messaging. Congress has a bottom-line inmate to staff ratio of 15:1, however staffing at BOP is a lot more complex and nuanced. To function, institutions need plumbers, chaplains, and teachers outside of Correctional Officers regardless of whether there is a single inmate, or an institution is at full capacity. Congress also does not take into account implications of the 2017 hiring freeze into BOP's current staffing challenges. According to GAO, BOP eliminated any positions that were vacant at the time of the hiring freeze, establishing a new maximum of authorized positions they could employ.GO In fiscal year 2018, BOP eliminated 5,100 authorized positions per DOJ's budget office recommendation.01 BOP officials stated that the elimination of these positions in 2018 has had negative long-lasting effects on staffing that is not fully understood by external stakeholders.02 Below is a graphic to describe the complexity of how staffing is measured and communicated, internally and externally. Individual Institutions • Reports overtime and augmerration usage to Regional Offices • Mentef es local recruitment needs • Requests incentives • mks for direchhire authority via justdication memos to HIND • Reports vacancies where RD is selecting official • klana:••• budget • ♦ Regional Office • Uses CPD and HSO's guidelines to provide guidance to local institutions for them to assess the number of staff authorized • Puts policies into practice decided by HRMD • assists witch recruitment efforts • Identities staffing challenges at instamions • Recommend incentive requests and sends to HRMD foe approval by Personnel office Corte( P•ogi a• Evaluates required staffing 'even for Correctional Job series (including Unit management Correctional Counseling) from formula based on number of (sous and a buffer for tin* off posts (t do training, vacation etc.) and reports to HMO Assents staffing eves and coordinates faring vacancies: writes polices across insittuttortS; approving incentive requests and submit direct.hire requests to DOJ Evaluates required staffing level for medical staff from guidelines based on patent volume. care level. and specialty and reports to HIND Reports required Inmate to staff ratio U.S. Legislate 0.5. Congress Staffing lamb measured and adjusted according to only in to staff ratios • United States Government Accountability Report No. GAO-21-123.2021. • United States Government Accountability Report No. GAO-21-123.2021. '2 United States Government Accountability Report No. GAO-21-123.2021. Figure 10 26 EFTA00141394