U.S.DepartmentofJustice
Office oftheInspectorGeneral

A Review of the Federal Bureau of Prisons’
Selection of Muslim Religious Services
Providers

Office of the Inspector General
April 2004

A REVIEW OF THE BUREAU OF PRISONS’ SELECTION OF
MUSLIM RELIGIOUS SERVICES PROVIDERS
I.

INTRODUCTION

This report describes the Office of the Inspector General’s (OIG)
review of the Federal Bureau of Prisons’ (BOP) policies and procedures for
the selection of individuals who provide Islamic religious services to
federal inmates. On March 10, 2003, Senator Charles Schumer wrote a
letter to the OIG requesting that we examine the BOP’s process for
selecting Muslim chaplains based on concerns that the BOP relies solely
on two Islamic groups to endorse its Muslim chaplains, the Islamic
Society of North America (ISNA) and the Graduate School of Islamic and
Social Sciences (GSISS). Schumer noted that the ISNA and the GSISS
allegedly are connected to terrorism and promote Wahhabism, which
some consider an exclusionary and extreme form of Islam. In addition to
Senator Schumer, Senators Jon Kyl and Dianne Feinstein expressed
similar concerns and asked the OIG to examine these issues as they
relate to the BOP.
In response to these requests, we reviewed the recruitment,
endorsement, selection, and supervision of Muslim chaplains and other
Muslim religious services providers who work with BOP inmates. We
also examined the roles the ISNA, the GSISS, and other organizations
have in the endorsement of chaplain candidates.
During this review, the OIG interviewed the BOP’s ten Muslim
chaplains, the BOP detailee to the Federal Bureau of Investigation’s (FBI)
National Joint Terrorism Task Force (NJTTF), and officials at BOP
Headquarters who are responsible for religious services providers,
including the Chief of the Chaplaincy Services Branch and the Senior
Deputy Assistant Director (SDAD) of the Correctional Programs Division.
We also interviewed FBI counterterrorism officials and representatives of
the U.S. Commission on International Religious Freedom at the U.S.
Department of State (Commission).
In addition, we visited low, medium, and high security BOP
institutions, where we interviewed prison officials, examined the
chaplaincy programs, and observed Muslim religious services. These
facilities included the Federal Correctional Institution (FCI) in Fort Dix,
New Jersey; the FCI in Fairton, New Jersey; the United States
Penitentiary (USP) in Allenwood, Pennsylvania; and the USP in
Lewisburg, Pennsylvania. We also met with analysts specializing in
Middle East affairs at the Congressional Research Service, including the
author of the December 2003 report, The Islamic Traditions of

Wahhabism and Salafiyya, and representatives of the Department of
Defense (DOD) OIG regarding its examination of the DOD’s chaplaincy
selection process.
This report describes the results of our review. It first provides a
brief background on Islam, Wahhabism, and the BOP’s provision of
religious services to inmates. It then describes the BOP’s selection of
Muslim chaplains and other religious services providers, including their
recruitment, application process, and security screening. We next
discuss BOP endorsing organizations, their relationships with the BOP,
and the steps the BOP and FBI have taken to assess whether these
organizations are extremist or affiliated with terrorists. The report then
examines issues related to the supervision of religious services providers
once they are allowed into BOP correctional institutions. Finally, the
report provides our analysis and recommendations.
In sum, our review revealed deficiencies in how the BOP selects
and supervises Muslim religious services providers. These problems
include:
•

the BOP typically does not examine the doctrinal beliefs of
applicants for religious service positions to determine whether
those beliefs are inconsistent with BOP security policies;

•

the BOP and the FBI have not adequately exchanged information
regarding the BOP’s Muslim endorsing organizations;

•

because the BOP currently has no national Islamic organizations
willing or able to provide endorsements for its Muslim chaplain
candidates, the BOP’s hiring of new Muslim chaplains is effectively
frozen, resulting in a shortage of Muslim chaplains within the
BOP;1

•

the BOP does not effectively use the expertise of its current Muslim
chaplains to screen, recruit, and supervise Muslim religious service
providers;

1 With regard to the ISNA and the GSISS, the BOP currently is not accepting
endorsements from the ISNA, and the GSISS has never provided endorsements to the
BOP. Our review did not independently examine these organizations’ sources of funding
or whether they have terrorism-related connections. This type of counterterrorism
review would be conducted by the FBI. However, the OIG has prepared a classified
addendum to this report that provides more information about organizations and
individuals that were determined by the FBI to be “of interest.” This classified
addendum has been given to members of Congress and BOP officials.

2

II.

•

once contractors and certain volunteers gain access to BOP
facilities, ample opportunity exists for them to deliver inappropriate
and extremist messages without supervision from BOP staff
members;

•

BOP inmates often lead Islamic religious services, subject only to
intermittent supervision from BOP staff members, which enhances
the likelihood that inappropriate content can be delivered to
inmates; and

•

within the BOP’s chapels, significant variations exist in the level of
supervision provided by correctional officers.
BACKGROUND
A.

Islam

Islam is a monotheistic faith that arose in the early 7th century in
the Arabian city of Mecca. Adherents of the Islamic faith are called
Muslims and follow the teachings of Muhammad ibn Abdallah. Although
the origins of Islam were in the Middle East, today the majority of
Muslims are not Middle Eastern.
Over time, divergent interpretations of Islam evolved and led to the
development of differing Islamic sects and doctrines. The current major
Islamic denominations include Sunni Islam, constituting approximately
85 percent of all Muslims; Shiite Islam, practiced largely in Iraq and Iran;
and Sufism, a “mystical” form of Sunni Islam. There is no ecclesiastical
hierarchy in Islam to resolve disputes between sects or determine whose
teaching is accurate.
Wahhabism is a form of Sunni Islam. It is practiced all over the
world and is the predominant religion in Saudi Arabia. Wahhabism has
many connotations and means different things to different people. It
generally refers to a movement that seeks to purify the Islamic religion of
any innovations or practices that deviate from the 7th century teachings
of the Prophet Muhammad, as interpreted by Muhammad ibn Abd
al-Wahhab, who lived in the 18th century in Saudi Arabia, Iraq, and
Iran.2
Most Muslims who adhere to Wahhabism refer to themselves as
“Salafis,” meaning “Unitarians,” because al-Wahhab emphasized the
transcendental unity of God. The term “Salafi” literally means “one who
See Febe Armanios, The Islamic Traditions of Wahhabism and Salafiyya,
Congressional Research Service, Dec. 22, 2003, at 1.
2

3

follows the Prophet Muhammad and his companions,” and also can be
used to describe all Muslims, not just Wahhabis. According to one
Islamic scholar, “[w]ahhabism, in its present form, is a particular
orientation within Salafism. . . . It is fair to say that all puritanical groups
in the Muslim world are Salafi in orientation but not necessarily
Wahhabi.”3
Fifteen of the 19 September 11 hijackers were from Saudi Arabia,
and all of them are believed to have been Wahhabis. In the United
States, Wahhabism has been equated with radicalism and terrorism in
some newspaper articles, books, and public discourse. For instance, in
his 2002 book, The Two Faces of Islam, journalist Stephen Schwartz
wrote that, “Wahhabism exalts and promotes death in every element of
its existence: the suicide of its adherents, mass murder as a weapon
against civilization, and above all the suffocation of the mercy embodied
in Islam.”4
However, not all experts agree that “Wahhabism” and “Salafism”
are inherently synonymous with violence, terrorism, or radicalism. For
example, FBI counterterrorism officials told us that Wahhabism is not
inherently violent or terroristic, but has been manipulated for violent or
terroristic ends. In addition, representatives from the Commission noted
to us that many Wahhabis/Salafis throughout the world are doctrinally
rigid, but peaceful.
The BOP’s ten Muslim chaplains, representatives from the
Commission, and counterterrorism experts at the FBI also stated that
radical Islam can be found in many different sects of Islam, not just in
Wahhabism/Salafism. Several of the Muslim chaplains said that
prominent Wahhabis have publicly condemned terrorism, suicide
bombers, and Usama Bin Laden. Similarly, representatives from the
Commission said that Islamic extremism is not so much the result of a
particular doctrine as it is the result of an individual’s school of learning
or associations with groups that espouse hate, extremism, and violence.
In addition, FBI counterterrorism experts and representatives from the
Commission stated that other Islamic sects, such as extreme Shiite
Islam, could be just as radical and as much of a terrorism threat as
extreme Wahhabism/Salafism.

See Khaled M. Abou El Fadl, And God Knows the Soldiers: The Authoritative
and Authoritarian in Islamic Discourses 5 n. 5 (2001).
3

4

See Stephen Schwartz, The Two Faces of Islam 180 (2002).

4

B. Islam in Federal Prisons
1.

Number of Muslim Inmates, Chaplains, Contractors
and Volunteers

The BOP houses approximately 150,000 inmates in 105 BOP
facilities nationwide.5 According to the Chief of the BOP’s Chaplaincy
Services Branch, approximately 9,000 inmates, or about 6 percent of the
inmate population, seek Islamic religious services. While Muslim
inmates are not required to report which sect of Islam they identify with,
inmate self-reporting indicates that Muslim inmates generally can be
classified into four groups: Sunni, Shiite, Nation of Islam, and Moor
Science Temple of America. Approximately 85 percent of BOP inmates
who identify themselves as Muslim are Sunni or Nation of Islam. In
contrast, less than 1 percent of the Muslim inmates – many of whom are
from Middle Eastern countries – are Shiite. The Nation of Islam is a
U.S.-based group that follows the teachings of Elijah Muhammad. The
Moor Science Temple of America is a very small group and, according to
the SDAD of the BOP’s Correctional Programs Division, not very active in
BOP institutions.
The BOP provides Muslim inmates with religious services through
BOP chaplains, contractors, and volunteers. Since 2001, 10 BOP
chaplains, or a little more than 4 percent of the BOP’s total chaplains,
are Muslim. According to the BOP, it currently is experiencing a “critical
shortage” of Muslim chaplains. The Chief of the Chaplaincy Services
Branch said a critical shortage of chaplains exists when there is 1
chaplain of a certain faith for every 700 inmates of that faith BOP-wide.
Currently, there is 1 Muslim chaplain for every 900 Muslim inmates.
When a Muslim chaplain is not available in a prison, Muslim inmates’
religious services are provided by Muslim volunteers, contractors, or
inmates.
Muslim contractors are compensated by the BOP to provide
certain Islamic services to inmates. Volunteers are not compensated by
the BOP and are classified into two groups: Level 1 and Level 2
volunteers. Level 1 volunteers are authorized to enter a particular BOP
institution less than four times a year and must be supervised by a BOP
staff member at all times. Level 2 volunteers have greater access to
institutions and, according to the BOP, need only be supervised
intermittently because they have completed more thorough background
investigations than Level 1 volunteers. As of September 6, 2003, there
were 56 Muslim contractors and 108 Muslim Level 2 volunteers
These numbers do not include contract facilities or halfway houses, which are
responsible for providing religious services to the BOP inmates housed there.
5

5

throughout the BOP. BOP officials could not provide us with the
number of Level 1 volunteers.
2.

Radical Islam in Prisons

Radicalization of Islamic inmates is not a recent phenomenon.6
Prison systems throughout the world have been and continue to be
breeding grounds for radicalism, recruiting grounds for extremist
movements, and facilities for the planning and training of radical
activities.7 For example, radicalization has been a serious concern for
decades in France, where more than half of the penitentiary inmates are
Muslim. According to some accounts, thousands of French inmates have
been indoctrinated in the principles of a holy war against “the Western
powers and the Jews who manipulate them,” in the words of one
pamphlet circulating in French prisons.8 It also has been reported that
radicalized inmates have built an extensive and highly organized
“terrorist university” in French prisons by using smuggled tapes, books,
and pamphlets to spread anti-Western and anti-Semitic messages.9
Concerns regarding the radicalization of Muslim inmates in prisons
were heightened after former inmates Richard Reid and Jose Padilla were
arrested for allegedly attempting to commit terrorist acts against the
United States. Reid, convicted for attempting to blow up an American
Airlines flight from Paris to Miami with explosives in his shoes, had
converted to Islam in a British prison and left the prison with radical
leanings. British officials suspect he was radicalized in part by extreme
Islamic clerics who visited and preached at the prison. Jose Padilla,
arrested for attempting to detonate a dirty bomb in the United States,
converted to Islam after serving time in a Broward County, Florida, jail
where authorities suspect his Islamic radicalization began.
Radicalization is distinguishable from terrorist recruiting. In this report, we
use “radicalization” to mean the process by which inmates who do not invite or plan
overt terrorist acts adopt extreme views, including beliefs that violent measures need to
be taken for political or religious purposes. “Terrorist recruitment,” on the other hand,
is used to mean the solicitation of individuals to commit terrorist acts or engage in
behavior for a terrorism purpose. These definitions are derived in part from definitions
provided to us by the BOP detailee to the FBI’s NJTTF.
6

7 See Gregory R. Copley, The Intelligence and Management Challenge: Handling
Radical, Terrorist and Politicized Prisoners, Defense and Foreign Affairs Strategic Policy,
Jan. 2002, at 10.
8 See, e.g., Frank Viviano, French Prisons: Extremist Training Grounds,
San Francisco Chron., Nov. 1 2001, at A4.
9

Id.

6

According to the FBI, it is likely that terrorist groups such as
al-Qaeda will attempt to radicalize and recruit inmates in the United
States.10 FBI counterterrorism officials stated that inmates are logical
targets for terrorist recruitment because they may be predisposed to
violence, feel disenfranchised from society, desire power and influence,
seek revenge against those who incarcerated them, be hostile towards
authority and the United States, or cling to a radical or extremist Islamic
“family.” In addition, prisons have large populations of non-Arab Muslim
inmates who are increasingly valuable for terrorism recruitment, since
they may not receive the same level of scrutiny as Middle Eastern
Muslims. Moreover, an FBI counterterrorism analyst told us that the
immense wealth associated with extreme Wahhabism/Salafism makes
the religion appealing to inmates who are seeking financial support and
assistance after they leave prison.
Inmates can be radicalized in many ways, including through the
delivery of anti-U.S. sermons, exposure to other radical inmates, or the
distribution of extremist literature. According to an Ohio state
correctional official, radicalization has led some inmates in state prisons
to become members of terrorist groups, including the Islamic-militant
group Hizballah and the Irish Republican Army.11 While radicalization
does not necessarily lead inmates to join terrorist organizations, it can,
upon their release, lead them to attend and serve in radical mosques or
obtain religious education overseas in locations that provide further
opportunities for radicalization and terrorist recruitment.
The SDAD of the BOP’s Correctional Programs Division said that
he does not believe there is widespread terrorist radicalization or
recruiting occurring in BOP facilities, but he recognized that many
inmates are vulnerable to radicalization and terrorist recruitment. FBI
counterterrorism officials stated that they believe some BOP inmates are
being radicalized because they are leaving BOP facilities with extreme
Islamist views. While these officials said they were unsure precisely how
radicalization is occurring, they believe that some Muslim contractors
and volunteers are radicalizing inmates in prisons in the United States.
The ten BOP Muslim chaplains we interviewed said they have not
witnessed inmates being radicalized by contractors or volunteers. The
BOP staff and managers we interviewed also asserted that staff
10 John S. Pistole, Assistant Director of the FBI Counterterrorism Division,
Statement for the Record Before the Subcommittee on Terrorism, Technology, and
Homeland Security of the Senate Judiciary Committee (October 14, 2003).

See statements by Phil Vermillion, the security threat group investigator for
Ohio’s state prison system, reported by The Associated Press, FBI Agent Warns Prison
Officials of Al Qaeda Recruitment (Sept. 20, 2003).
11

7

chaplains, contractors, and volunteers were not the cause of inmate
radicalization. The BOP staff said they were confident that if a chaplain,
contractor, or volunteer was delivering inappropriate messages, the
prison would soon learn about it and the individual would be removed
from his or her position.
The BOP Muslim chaplains stated that some inmates are
radicalized in prison by other inmates. Numerous other BOP staff
members also told us that the real threat of radicalization comes from
inmates, not chaplains, contractors, or volunteers. One Muslim chaplain
stated that at his prison some Islamic extremist inmates told other
inmates that if they were going to convert to Islam, they had to overthrow
the government because “Muslims aren’t cowards.” Other chaplains told
us that convicted terrorists from the 1993 World Trade Center bombing
were put into their prisons’ general population where they radicalized
inmates and told them that terrorism was part of Islam. Another
chaplain said that he has observed some inmates from foreign countries
politicize Islam and radicalize inmates, who in turn radicalize more
inmates when they transfer to other prisons.
In addition to terrorist radicalization and recruitment, the Muslim
chaplains noted a version of Islam they call “Prison Islam.” They
explained that Prison Islam, which is unique to the prison environment,
results when inmates follow Islam without direction or analysis – inmates
distort Islam to encompass prison values such as gangs and loyalty to
other inmates. The chaplains said they frequently have to oppose Prison
Islam in their institutions because it threatens prison security.
The Muslim chaplains said that Prison Islam especially thrives in
institutions that do not have a staff chaplain, contractor, or volunteer to
lead inmates’ Islamic services such as the Juma prayer, which is the
obligatory, group prayer held midday on Fridays. According to the
Muslim chaplains, in these institutions Muslim inmates often lead Juma
services, and inmates who promote Prison Islam or engage in
radicalization have the opportunity to teach and lead other inmates
without the countervailing influence of a mainstream Muslim chaplain,
contractor, or volunteer. In fact, the growth of Islamic radicalism in
French prisons has been attributed in part to the control that inmates
exercise over most of the institutions’ religious practices.12
The BOP provides official guidance to institutions’ chaplains
regarding inmate-led services. The BOP’s Technical Resource Manual
014.01, issued in June 1995, states that:
See Frank Viviano, French Prisons: Extremist Training Grounds, San Francisco
Chron., Nov. 1 2001, at A4.
12

8

Normally inmates are not permitted to lead religious
programs. When an inmate faith group meets which is
different from the Chaplains’ own, and when there is no
community representative available to lead the group on a
volunteer or contractual basis, inmates may conduct or
lead these programs only under the supervision of the
Chaplain. This supervision entails eye contact with the
group and at least periodic presence in the program area
by the Chaplain.13
While BOP officials acknowledged to us that religious services led
by inmates are a security concern, they said that the lack of Muslim
chaplains, contractors, and volunteers makes inmate-led services a
necessity in some BOP facilities. The Chief of the Chaplaincy Services
Branch suggested that the BOP could reduce concerns about inmate-led
services by having inmates read sermons written by one of the BOP
Muslim chaplains or by a Muslim outside of the prison and screened by
the chaplaincy.
With respect to Wahhabism/Salafism, the BOP chaplains said they
believed that any chaplain, contractor, or volunteer who identified
himself as a Wahhabi/Salafi would be too narrow-minded and sectarian
to be able to teach in a pluralistic, prison environment.14 They also said
that strict Wahhabism would not survive in prisons because it is too
exclusionary to appeal to the inmates.15 In addition, they stated that
pure Wahhabism poses a security threat to the prisons because it does
not tolerate religious pluralism.
C.

Provision of Religious Services in the BOP
1.

Chaplaincy Services Branch

The BOP Central Office is composed of eight divisions. One of the
divisions, the Correctional Programs Division, is responsible for security
Technical Reference Manuals provide guidelines, optional assistance, best
practices, and “how-to” information that may be needed or useful to accomplish the
objectives or requirements of Program Statements. They are not “directives” or “policy,”
but technical and instructional in nature.
13

14 The chaplains clarified that because “Wahhabi” means different things to
different people, a person who is labeled by others as a Wahhabi might not be narrowminded and sectarian. However, they agreed that if a Muslim identifies himself as a
Wahhabi, then he would hold views contrary to the BOP’s position of religious
pluralism.

The chaplains stated that inmates who identify themselves as Wahhabis or
Salafis generally espouse Prison Islam rather than true Wahhabism or Salafism.
15

9

and custody issues, providing services to inmates, and developing policy
in these areas.16 The Correctional Programs Division coordinates
inmates’ religious services through the Chaplaincy Services Branch.
According to the Chief of the Chaplaincy Services Branch, the provision
of religious services to inmates is required by law to accommodate
inmates’ free exercise of religion. She stated that religious services are
essential to the security and orderly running of BOP institutions because
it provides inmates with direction, guidance, and a sense of purpose, and
helps them to be productive, disciplined, and compliant.
The Chaplaincy Services Branch is required to provide
opportunities for inmates to pursue individual religious beliefs and
practices in accordance with law, federal regulations, and BOP policy.
The Chaplaincy Services Branch’s central office is located at BOP
Headquarters. It provides staffing, training, policy, procedures, and
technical assistance to regional and field chaplains. However, it does not
supervise regional or field chaplains and has only advisory authority over
BOP regional and field decisions, except when governed by BOP policy,
procedures, or reference manuals.
The BOP has one Regional Chaplain in each of its six regions. The
regional chaplains oversee one to five chaplains in each facility in their
regions. Within each institution, a supervisory chaplain manages the
institution’s chaplaincy staff. As of March 5, 2004, there were
approximately 240 chaplains BOP-wide.
Under prevailing federal case law, inmates are not entitled to a
chaplain of their faith group, denomination, or sect.17 As a result, all
BOP chaplains, regardless of their own faiths, are expected to minister to
inmates of all faith traditions, including those who have no faith
tradition. The Chief of the Chaplaincy Services Branch stated that
chaplains must be willing to accommodate the free exercise of religion for
all inmates, which means they must respect, appreciate, and understand
the faith traditions of the inmates, and they must actively provide
inmates opportunities to mature spiritually within their own faith
traditions.
Chaplains are supposed to plan, direct, and supervise all aspects
of the institutions’ religious programs and have access to all areas of the
institutions to minister to inmates and staff. They are responsible for
leading worship services, providing religious education, offering pastoral
counseling, conducting crisis intervention, supervising religious services
16

An organization chart of the BOP is attached to this report as Appendix A.

See Cruz v. Beto, 405 U.S. 319, 322 n. 2 (1972); Weir v. Nix, 114 F.3d 817,
Cir. 1997); Blair-Bey v. Nix, 963 F.2d 162, 163-64 (8th Cir. 1992).

17

820

(8th

10

and meetings, enabling faith groups to observe holy days and other
religious practices, and accommodating the legitimate religious needs of
inmates.
In addition, chaplains oversee religious contractors and volunteers.
Contractors and volunteers are brought into institutions to perform a
specific religious service or function, such as a worship service, group
prayer, scripture study, or religious lecture.
BOP staff repeatedly emphasized to us that the provision of
religious services in its institutions is important to the maintenance of
security in the facility. For example, according to a lieutenant at the FCI
in Fort Dix, New Jersey, which has the largest inmate population of any
BOP facility, the religious services department “absolutely plays an
important role in maintaining security.” A BOP chaplain also stated to
us that religious services “diffuse a lot of frustrations and anxieties and
angers; it provides inmates with internal controls that otherwise they
would not have.”
2.

Duties Performed by Muslim Chaplains,
Contractors, and Volunteers

Muslim chaplains are responsible for providing faith-specific
services for Muslim inmates, including Koranic studies, holy day
observances, and presiding at Juma prayer. Muslim chaplains also are
responsible for pastoral counseling and administrative duties. While
they are not required to perform sacraments, rituals, or worship services
for other faith groups, they are required to counsel inmates of all faiths
and supervise the contractors, volunteers, or inmates who lead the
religious services for other faith groups. See BOP’s “Position Description:
Chaplain” and BOP Program Statements 3939.07 and 5360.08.
Muslim contractors also lead Koranic studies, preside at Juma
prayers, and provide counseling to Muslim inmates. The contractors
provide services on a “per session” basis. They can offer sessions on a
weekly basis or as infrequently as once a quarter, depending on the
needs of the institution. Inmates must register in advance to participate
in the contractor-led sessions. Contractors do not have general access to
inmates and cannot leave the area to which they are assigned without
notifying a staff member.
Muslim volunteers offer many of the same services as contractors,
but they are not paid and are not required to come into the institution for
a certain number of sessions. Volunteers’ services include providing
occasional seminars, presiding over Juma prayers, leading Koranic
studies or scholastic discussions, and serving as guest speakers for

11

Ramadan or other religious observances. As with contractors, inmates
must register in advance to participate in the sessions offered by
volunteers. Volunteers do not have general access to inmates and
cannot leave the area to which they are assigned without being escorted
or notifying a staff member, depending on whether they are Level 1 or
Level 2 volunteers.18
According to the Chief of the Chaplaincy Services Branch, Muslim
chaplains, contractors, and volunteers all are responsible for presenting
the basic, mainstream principles of Islam and correcting misinformed or
misled Muslim inmates. They also are responsible for ensuring the
security of the institution, which includes addressing and countering
Prison Islam and inmates’ radicalization efforts. One of the BOP Muslim
chaplains we interviewed asserted that contractors and volunteers have a
stabilizing effect on Muslim inmates because they bring fresh opinions
and societal experiences into the institutions, and inmates do not see
them as part of the “police” like they see the chaplains. He said that
fewer contractors and volunteers in the prisons make inmates feel more
isolated and alienated, and leads to the germination of unsophisticated
Islam, including radicalization and Prison Islam. Other chaplains also
said that volunteers and contractors help to control radicalization,
prevent misconceptions about Islam, and keep inmates from delivering
their own sermons, taking their own interpretations of Islam, and
controlling religious activities.
D.

BOP Policies Regarding the Provision of Religious
Services

The BOP has implemented various policies and procedures
regarding religious practices, activities, and services in its institutions.
These policies and procedures apply to all religious chaplains,
contractors, and volunteers, regardless of faith. According to the Chief of
the Chaplaincy Services Branch, the policies and procedures are
intended to guarantee inmates’ free exercise of religion while ensuring
the security of the institutions. She said that Muslim chaplains are
supposed to minister to inmates of all faiths and accommodate all
Islamic denominations, and that all Islamic religious services providers
are prohibited from endorsing one sect over others, teaching sect-specific
doctrine, or imposing their own ideas on the inmates.

18 As described on page 5, the difference between Level 1 and Level 2 volunteers
is that Level 1 volunteers are authorized to enter a particular BOP institution less than
four times a year and must be supervised by a BOP staff member at all times, while
Level 2 volunteers have greater access to institutions and, according to BOP personnel,
need only be supervised intermittently.

12

The SDAD of the Correctional Programs Division stated that
inmates are allowed to practice religions with extreme doctrinal views as
long as their religious teachings do not violate the law or BOP policy.
According to the SDAD, the main security policy guiding the provision of
religious services in the BOP is that religious groups and religious
services providers cannot: 1) advocate violence; 2) make statements
against the United States, including statements that support or condone
terrorism; or 3) discriminate against other inmates or exclude them from
their services, whether based on race, religion, or other discriminatory
factors. See BOP Program Statements 3420.09, 3730.04, and 5360.08.
In addition to these restrictions, BOP Program Statement (P.S.)
5360.08, Religious Beliefs and Practices, explicitly prohibits the following
religious practices and activities:
•
•
•
•
•
•
•
•
•
•
•
•
•

Proselytizing,
Profanity;
Consumption of alcohol;
Paramilitary exercises;
Self-defense training;
Animal sacrifice;
Casting of spells or curses;
Nudity;
Sexual acts;
Self-Mutilation;
Use or display of weapons;
Ingestion of illegal substances; and
Encryption.

The SDAD said that if a group’s practices or doctrine violate any of
these policies or procedures, the group is banned from BOP facilities.
Similarly, if a religious services provider violates any of these policies or
procedures, the BOP will consider dismissing the provider from the BOP.
III.

SELECTION OF MUSLIM CHAPLAINS, CONTRACTORS, AND
VOLUNTEERS
A.

How Personnel Needs Are Identified

According to the BOP, personnel needs for all religious services
providers, including Muslim chaplains, contractors, and volunteers, are
identified based on what institutions need to accommodate inmates’
religious beliefs and practices, as allowed under the First Amendment,
the Religious Freedom Restoration Act (RFRA), the Code of Federal
Regulations, other Public Laws, and BOP policy.

13

The need for BOP chaplains also is determined in part by the
chaplain-inmate ratio BOP-wide. Because BOP chaplains are hired to
accommodate the religious beliefs and practices of all inmates, the BOP
considers qualified applicants of all faiths for all chaplain vacancies.
However, when there is a critical shortage of chaplains of a certain
religion, the Chief of the Chaplaincy Services Branch said that the BOP is
more likely to select qualified chaplain candidates of that religion rather
than candidates of other religions. Moreover, whenever possible, the
BOP does not place chaplains of the same faith in the same institution.
See BOP’s “Qualifications and Job Requirements for Chaplaincy.”
The BOP does not attempt to match chaplains of particular
denominations or sects to particular institutions. For example, even if a
particular prison has a large Sufi Muslim inmate population, the BOP
does not attempt to place a Sufi Muslim chaplain in that prison.
According to the Chief of the Chaplaincy Services Branch, matching
chaplains’ denominations or sects to those of the inmates requires the
BOP to discriminate in hiring based on candidates’ religion and doctrinal
beliefs. Currently, the BOP does not require chaplain candidates to
report their denominations or sects because the BOP considers it
irrelevant to job performance. In addition, according to the Chief of the
Chaplaincy Services Branch, denomination or sect matching would
potentially undermine the BOP’s expectation that chaplains minister
pluralistically, focus on the basic principles of their faiths, and not
impose their denomination’s or sect’s doctrinal beliefs on inmates. Under
prevailing case law, the BOP’s refusal to provide a religious leader for
every sect in a prison does not violate the inmates’ constitutional right to
the free exercise of religion.19
Chaplain vacancies are determined by each institution, but the
BOP does not hire chaplains for specific sites. For example, the BOP
does not announce a chaplain vacancy in the USP in Atlanta, Georgia.
Instead, it hires chaplains and then places them where needed
throughout the BOP.
By contrast, contractors and volunteers are recruited and selected
by individual institutions to address the particular needs of inmates in
that institution. The BOP attempts to accommodate inmates’ religious
needs by providing them sessions with a contractor or volunteer of that
faith. For example, a prison with a large Shiite Muslim population can
determine it needs a Shiite contractor or volunteer, rather than a Muslim
contractor or volunteer from another sect. However, this is not currently
19

163-64.

See Cruz, 405 U.S. at 322 n. 2; Weir, 114 F.3d 817; Blair-Bey, 963 F.2d at

14

being done in the BOP partly because, according to the Chief of the
Chaplaincy Services Branch, the BOP has difficulty determining the
denominations or sects of inmates.
B.

How Candidates Are Recruited and Selected
1.

Recruitment

The BOP does not advertise for chaplaincy positions by specific
faith groups. Instead, BOP chaplain vacancies are announced
continuously on the BOP website, the U.S. Office of Personnel
Management (OPM) website, and websites such as
http://www.usajobs.com. The BOP also advertises chaplaincy vacancies
with religious organizations and recruits at job fairs, theology speaking
engagements, and conferences. Some chaplain candidates have applied
to work for the BOP after serving as contractors in the institutions.
Our review determined that each of the current BOP Muslim
chaplains was recruited or referred by another BOP Muslim chaplain.
According to the Chief of the Chaplaincy Services Branch, Muslim
chaplains are the BOP’s most effective and reliable resource for recruiting
qualified Muslim chaplain candidates. However, the BOP Muslim
chaplains we interviewed stated that because BOP management had not
adjusted the chaplains’ schedules to account for recruiting
responsibilities, they were unable to dedicate time to recruiting new
chaplain candidates even though they wanted to.
In addition to recruiting other chaplains, BOP Muslim chaplains
have recruited Muslim contractors and volunteers. Muslim contractors
also are recruited through the BOP website, Muslim organizations’
websites, the government’s contracting website (www.fedbizopps.gov),
and newspaper advertisements. Similarly, chaplains and volunteer
coordinators recruit Muslim volunteers locally. The Chief of the
Chaplaincy Services Branch said that when an institution determines
that it needs a Muslim contractor or volunteer, it often will contact a
local mosque or Islamic center for recommendations. One Muslim
chaplain said that this was the best way to find qualified, reliable
contractors and volunteers. The Chief of the Chaplaincy Services Branch
also said that BOP staff might contact another BOP prison with a strong
Muslim religious program to seek assistance from chaplains, contractors,
or volunteers in that program.
According to the Chief of the Chaplaincy Services Branch, the BOP
has had difficulty meeting institutions’ demand for Muslim chaplains, in
part because it is difficult to find candidates who meet all the personal,

15

academic, and professional requirements to be a chaplain.20 As a result,
the BOP currently has three Muslim chaplains less than it needs to
overcome its critical shortage of Muslim chaplains.21
The Chief of the Chaplaincy Services Branch also stated that the
BOP does not have enough Muslim contractors and volunteers to provide
Islamic services for all Muslim inmates. According to BOP officials, there
are several reasons why the BOP has had difficulty recruiting and
maintaining Muslim contractors and volunteers. First, the remote
locations of many BOP institutions makes it difficult for contractors and
volunteers to get to those institutions. Second, the BOP does not have a
program or strategy for recruiting Muslim contractors and volunteers.
The BOP Muslim chaplains suggested that the BOP should make a
greater effort to reach out to Muslim organizations and communities to
develop local contacts and encourage Muslims to serve in BOP
institutions. They said that currently the Chief of the Chaplaincy
Services Branch is the only person in the BOP who is reaching out to
Muslims. Third, according to the BOP Muslim chaplains, the BOP does
not provide its Muslim chaplains adequate time to recruit contractors
and volunteers, even though they have strong connections to the Muslim
community. Fourth, one Muslim chaplain noted that the BOP does not
provide volunteers incentives to work in the prisons, such as
reimbursement for gasoline when they visit rural facilities. Fifth,
according to the Muslim chaplains, recruitment of Muslim volunteers has
slowed after the September 11 terrorist attacks because Muslims fear
they will be scrutinized or investigated if they become involved with the
government. Sixth, according to the Chief of the Chaplaincy Services
Branch, the Islamic community does not have the programs or precedent
for prison ministry in the United States that other religions have.
Recruitment difficulties present a special problem because the BOP
needs many Muslim contractors and volunteers to lead Juma prayers
and other Islamic services that must occur at the same time on the same
days (i.e., Juma prayers must be held shortly after 12:30 p.m. on
Fridays). One chaplain, contractor, or volunteer can only provide these
services in person to one group of inmates at the appointed time. For
example, in an institution that has four facilities, a Muslim chaplain,
contractor, or volunteer is needed in each facility at the same time on
Fridays to provide Juma prayer. If there is only one chaplain, contractor,
20

Process.”

These requirements are discussed below in section III (B)(2), “Application

The BOP has determined a critical shortage of chaplains exists when there is 1
chaplain of a certain faith for every 700 inmates of that faith BOP-wide. Using this
standard, the BOP needs 13 Muslim chaplains to eliminate its critical shortage.
Currently, it has only ten Muslim chaplains and approximately 9,000 Muslim inmates.
21

16

or volunteer available, inmates in three of the facilities either will lead
themselves in the prayer or will not receive the prayer service that day.
This shortage of Muslim chaplains, contractors, and volunteers means
inmates are left to lead and direct each other in Islam, which may affect
prison security because extremist inmates could use these services to
radicalize and recruit other inmates.
2.

Application Process
a.

Muslim Chaplains

In order to be considered for a chaplain position in the BOP,
candidates must meet certain personal and professional requirements.22
First, the applicant must be a citizen or resident of the
United States or a country that has diplomatic relations or treaties with
the United States. Second, the applicant ordinarily must be younger
than 37 to be appointed to a BOP position. However, the Department of
Justice (DOJ) has waived this age requirement for Muslim chaplain
applicants because of the critical shortage of Muslim chaplains in the
BOP. See 5 U.S.C. § 3307. Third, applicants must provide adequate
documentation of their religious and ministerial role within their religious
community. This documentation is required in lieu of formal ordination
or recognition by ecclesiastical institutes, which do not exist in Islam.
Fourth, applicants must pass a physical examination and Physical
Abilities Test, which are designed to measure the physical requirements
necessary to perform essential functions in a correctional setting. Fifth,
applicants must report the professional, civic, and religious organizations
in which they hold membership.
With respect to professional requirements, applicants must have
earned a bachelor’s degree from an accredited college with at least 120
hours of instruction. In addition, applicants must have a Master of
Divinity degree from an accredited residential seminary or theology
school, or have successfully completed 90 semester hours of graduate
study that include: 1) 20 semester hours of pastoral ministry; 2) 20
semester hours of theology, ethics, or philosophy of religion; 3) 20
semester hours of religious history or world religions (which demonstrate

The BOP’s table depicting the application and security screening requirements
for chaplains, contractors, and volunteers is attached as Appendix B.
22

17

an understanding of religious pluralism); and 4) 20 semester hours of
religious writings or language study.23
In addition to these academic requirements, applicants must have
at least two years of full-time pastoral experience in a ministry setting
after they have completed their academic preparation. They also must
sign a “Candidate Certification and Authorization” form certifying that
they will minister to inmates of other faiths.
Finally, an applicant must provide three personal references,
recommendations from previous employers, and an endorsement from a
national organization that has completed the paperwork required by the
BOP to endorse chaplain applicants (“endorsing organization”). The
applicant must have been associated with the endorsing organization for
at least two years prior to the endorsement. The endorsement must
attest to the applicant’s suitability for correctional ministry, verify the
applicant’s ability to minister in a pluralistic environment to inmates of
all faiths, support the applicant’s candidacy, and provide assurance that
the applicant has no past or present legal or moral barrier to being a
religious leader.
Obtaining an endorsement from a national Islamic organization
presents special challenges for Muslims because, unlike other religions,
there is no national Islamic decision-making body to recognize official
Islamic religious leaders or authorize them to minister to others. The
BOP Muslim chaplains explained that in Muslim countries the
government, not organizations, endorses religious leaders. They said
that Muslims in the United States have created national organizations to
unify and represent them, such as the Islamic Assembly of North
America, the Islamic Circle of North America, and the ISNA. However,
the chaplains noted that these organizations are not as large, organized,
or established like other religions’ organizations, such as the Catholic
Church or the Southern Baptists, and several of the organizations have
received scrutiny for allegedly advocating radical beliefs or supporting
terrorism.
At this time, the ISNA is the only Islamic organization that has
completed the paperwork required by the BOP to endorse chaplain
applicants. Other organizations can apply to be endorsers for Muslim
chaplains, but none has submitted the requisite paperwork. However,
the BOP has not hired a Muslim chaplain since 2001, and in 2003 it
stopped accepting ISNA-endorsed chaplain candidates until the FBI
The GSISS offers an academic program that fulfills the BOP’s educational
requirements for graduate study in Islam. The GSISS is discussed below in section IV,
“Endorsing Organizations.”
23

18

provides the BOP with any information on the ISNA.24 This has resulted
in a freeze on hiring Muslim chaplains. The GSISS never has endorsed a
Muslim chaplain, contractor, or volunteer for the BOP.25
Despite the difficulties in obtaining national endorsements from
Islamic organizations, the BOP requires Muslim chaplain candidates to
provide a national endorser like all other chaplain candidates. Most of
the BOP’s Muslim chaplains told us they supported the requirement for a
national endorser because, they said, it has led to the hiring of highcaliber chaplains and it is an effective way for the government to further
screen candidates. However, a few of the chaplains believed that the
BOP should require local endorsers instead of national endorsers
because some national organizations have been discredited, and national
organizations do not know chaplain candidates as well as local
organizations do. This issue is discussed further in section IV(A), “Role of
Endorsers for Staff, Contractors, and Volunteers.”
Once the chaplain candidate has completed the application packet,
obtained all required recommendations, and received a national
endorsement, the applicant sends the application to the central office of
the Chaplaincy Services Branch. Only applicants with complete
application packets are considered for chaplaincy vacancies.
b.

Muslim Contractors

When a BOP institution determines it needs a religious contractor,
it completes a Determination of Need form indicating the purpose of the
contract, description of service required, special qualifications necessary,
estimated cost of services, and an explanation for why the existing
chaplains cannot perform the services. Based on the Determination of
Need, the BOP advertises for contractors and issues a Statement of Work
(SOW). Contractors apply for advertised positions by submitting
proposals for services based on the requests in the SOW.
In order to be eligible for a contractor position, applicants must
have resided in the United States for three of the past five years and be a
citizen or resident of the United States or a country that has diplomatic
relations or treaties with the United States. If a contractor is a foreign
national, the BOP does not grant the contractor access to BOP
24 The ISNA is discussed in more detail in section IV, “Endorsing Organizations.”
The BOP has stopped accepting endorsements from all Islamic organizations until it
receives information on those organizations from the FBI and determines whether to
continue using those organizations as endorsers.

The GSISS is discussed in more detail in section IV, “Endorsing
Organizations.”
25

19

computers. Contractors also must demonstrate that they have the
knowledge of their religion and ministry experience necessary to
adequately provide the services requested. As with chaplain candidates,
contractor applicants must provide adequate documentation of their
religious and ministerial role within their religious community.
In addition, contractor applicants must have a letter of
endorsement from a local religious organization or clergy member that
verifies the applicant is authorized to perform the services requested.
Generally contractors do not receive endorsements from national
organizations like the ISNA, but approximately five Muslim BOP
contractors or volunteers have been endorsed by the ISNA. The GSISS
never has endorsed a Muslim BOP contractor.
Unlike chaplain candidates, contractor applicants are not asked to
report the professional, civic, and religious organizations in which they
hold membership. They also are not required to have particular
academic credentials or pastoral experience. However, local BOP
institutions often impose these requirements on their own. For example,
a February 2003 SOW issued by the FCI in Victorville, California,
required applicants to have a minimum of three years of documented,
continuous, full-time experience as an Islamic minister and a
Baccalaureate Degree from an accredited college or university, with a
major in some form of religious studies.
Contractors submit their proposals directly to the institutions
requesting contractor assistance. The facility’s Human Resource
Management and Business Office staff determine which proposal is
selected.
c.

Muslim Volunteers

Muslims interested in volunteering in the BOP apply directly to
specific institutions, generally through a volunteer coordinator. Muslim
volunteers must provide a letter of endorsement from a local Islamic
organization or clergy member that verifies the volunteer is authorized to
perform the services requested. According to the Chief of the Chaplaincy
Services Branch, volunteers must also have verifiable religious
credentials, but no specific academic training is required. The ISNA has
endorsed approximately five of the BOP’s Muslim volunteers or
contractors, but the GSISS has not endorsed any.

20

3.

Security Screening
a.

Muslim Chaplains

In order to be selected as a BOP chaplain, candidates must pass a
criminal history check, which includes a fingerprint check, local law
enforcement checks for the past five years, and a record check through
the FBI’s National Crime Information Center (NCIC). Candidates also
must pass a drug screening urinalysis and provide the contact
information for their employers for the past five years. In addition, the
OPM contracts with the U.S. Investigations Services (USIS) to conduct
full investigative background checks on chaplain candidates. These
investigations are supposed to be completed within 120 days from the
date scheduled. Subsequent reinvestigations of chaplains are supposed
to be conducted by the OPM every five years. These security screening
requirements are standard for most federal government employees.
The OPM/USIS’s background investigation examines, among other
things, the chaplain candidate’s loyalty to the United States, contacts
with foreign countries, and any previous criminal activity. According to
the Chief of the Chaplaincy Services Branch, the investigations do not
specifically examine the candidates’ past sermons or performance in
religious settings to determine whether they have given radical messages
or made radical statements.
The BOP has experienced problems obtaining timely closure of
investigations from the OPM/USIS for all of its employees. In June 2002,
the BOP’s Security and Background Investigation Section wrote a formal
letter to the OPM regarding delinquent cases, and the OPM responded by
implementing a plan to address the backlog of cases. The BOP informed
us that since it took these steps, the OPM investigations are being closed
quicker. However, the BOP said that the OPM still has some cases open
until after new employees’ one-year probationary period has expired,
making it more difficult for the BOP to dismiss personnel whose
background investigations develop derogatory information.
Despite the OPM’s delays in conducting background investigations,
the BOP’s SDAD of the Correctional Programs Division said he is not
aware of any concerns or problems with the results or quality of the OPM
investigations. In addition, while OPM delays might affect the
background investigations of future Muslim chaplains, the current
Muslim chaplains’ background investigations already have been
completed.
In addition to background investigations, chaplain candidates also
receive a pre-employment screening interview and a panel interview. The

21

pre-employment screening interview is conducted by a Human Resources
specialist and covers the candidate’s employment history, financial
history, criminal history, driving record, and any dishonest conduct or
excessive use of force. A representative from Human Resources, a
Regional Chaplain, and at least one other manager conduct the panel
interview. While the panel interview is more in-depth than the
pre-employment screening interview, the questions are standard (the
Civil Service Questionnaire) and do not typically explore candidates’
doctrinal beliefs.
Although some of the BOP Muslim chaplains said they were asked
doctrine-related questions in their interviews, most said they were not.
However, many of the chaplains said that they were recruited by people
in the BOP who already knew their doctrinal beliefs. The Muslim
chaplains told us they believed there should be some process to discern a
candidate’s doctrinal beliefs, whether formally (through the interview) or
informally (by checking with staff familiar with the candidate), for
security purposes. For example, they stated that the BOP should know if
a Muslim candidate identifies himself as a Wahhabi/Salafi or identifies
himself with a particular school of thought rather than with Islam in
general because, in their view, these individuals would not be willing or
able to minister effectively to inmates of all faiths or of other Islamic
sects.
Currently, the BOP’s policy is not to ask chaplain candidates what
they believe or require them to provide a statement of faith. Rather, the
BOP relies on the certification of national endorsers that the candidates
are mainstream Muslims and capable of teaching in BOP institutions.
The Chief of the Chaplaincy Services Branch expressed concern to us
that asking such questions or requiring a statement of faith would place
the government in the position of approving or disapproving of a person’s
religion. She also said there would be no way to ensure the candidate
answered questions truthfully. Furthermore, she stated that, in her
view, candidates’ doctrinal beliefs are secondary to what they will commit
to do in the job.26
In addition to not asking Muslim chaplain candidates about their
religious beliefs, the BOP does not require a Muslim or other persons
knowledgeable of Islam to participate in chaplain candidates’ interviews.
However, eight of the ten Muslim chaplains said they were interviewed by
a Muslim. Some were interviewed by a BOP regional official who was
Muslim, and one chaplain said he was interviewed by another BOP

The OIG’s analysis of whether the BOP legally can screen chaplains’ doctrinal
beliefs is contained in section VI, “OIG Analysis.”
26

22

Muslim chaplain. The Muslim chaplains believed that the interview
process is not effective if candidates are not interviewed by a Muslim.
In response to questions about Muslim chaplain candidates being
interviewed by a person knowledgeable of Islam, the Chief of the
Chaplaincy Services Branch suggested that the BOP could create an
interfaith advisory board composed of chaplains of many faiths, including
Islam, to interview all of the BOP’s chaplain candidates, regardless of
faith.
The only method the BOP currently uses to screen chaplain
candidates’ doctrinal beliefs is the “Candidate Certification and
Authorization,” which the candidates sign pledging that they will minister
to inmates of all faiths. The Chief of the Chaplaincy Services Branch said
that Muslims with extreme Islamic views, like extreme Wahhabis/Salafis,
would not be willing to sign this statement, unless they were attempting
to infiltrate the prisons by misrepresenting their beliefs.
The BOP also does not ask candidates whether they have received
funds from foreign governments. The Chief of the Chaplaincy Services
Branch noted that chaplains are not currently asked this, even though
candidates for other, higher-ranking federal positions are. She believed
chaplains and chaplain candidates should be asked questions such as,
“Have you accepted gifts or funds from any foreign government?” by the
BOP or the OPM.
Finally, as discussed previously, the BOP requires chaplain
candidates to report their foreign travel. The SDAD of the Correctional
Programs Division said the BOP is interested in verifying chaplains’
foreign travel and soon will be able to use the State Department’s
databases for this purpose. The Chief of the Chaplaincy Services Branch
said that the BOP would not hire chaplain applicants who lie about their
foreign travel. In addition, she said that the BOP will not hire a chaplain
candidate who has spent a significant amount of time in a country that
does not have diplomatic relations or treaties with the United States, but
she did not define how much time was significant enough to preclude
hiring.27 She said that because Saudi Arabia has diplomatic relations
with the United States, she did not believe Muslim chaplain candidates
who have studied in Saudi Arabia should be excluded from BOP
positions. She also noted that Saudi Arabia is the religious center of
Islam and offers many professional schools that can prepare Muslims for
ministry.

As noted earlier, chaplain and contractor candidates must have resided in the
United States for three of the past five years.
27

23

b.

Muslim Contractors

In order to be selected as a BOP contractor, candidates must pass
a criminal history check, which includes a fingerprint check, inquiries
with local law enforcement, and a records check through the FBI’s NCIC.
Candidates also must pass a drug screening urinalysis and provide
contact information for their employers for the past five years. According
to the Chief of the Chaplaincy Services Branch, the BOP began in
October 2003 to inquire about contractor applicants’ educational
background, countries visited, and naturalization numbers (if
applicable). As with chaplains, the Chief of the Chaplaincy Services
Branch said that the BOP would not hire applicants who have spent a
significant amount of time in a country that does not have diplomatic
relations or treaties with the United States.
According to BOP officials, contractor candidates are interviewed
by the program manager at the institution in which they will work.
These interviews are not standardized, and they also are not as in-depth
as the interviews of chaplain candidates.
As with chaplains, the BOP does not screen contractors’ doctrinal
beliefs or require that they provide a statement of faith. For example, the
BOP does not use contractors’ interviews to determine what candidates
believe or whether their beliefs could compromise security or violate BOP
policies.
In addition to not screening contractors’ doctrinal beliefs, the BOP
does not ask contractors to report the professional, civic, and religious
organizations in which they hold membership or whether they have
received funds from foreign governments. The BOP also does not require
contractors to submit lesson plans to the chaplains or an outline of what
they intend to cover during their services. The Chief of the Chaplaincy
Services Branch said that the contractors’ SOW and proposal describe
the number of sessions needed and what service the contractor would
provide.
The BOP Muslim chaplains we interviewed said that the BOP does
not consult them regarding the hiring of Muslim contractors or ask them
to interview contractor applicants. The chaplains said they have
witnessed some Muslim contractors bring distorted Islam into the
prisons, which causes problems for the BOP. They said that the BOP
does not select contractors based on doctrinal beliefs or lesson plans, but
mostly on who offers the services for the cheapest cost. As a result, they
said, the BOP has hired contractors who have taught things that pose a
security threat to the institutions.

24

In addition, the BOP does not require chaplains at prisons hiring
Muslim contractors to gather information from the local community on
contractor applicants. The Chief of the Chaplaincy Services Branch told
the OIG that if chaplains had time, she thought it would be beneficial for
them to examine applicants’ activities and reputations in their
communities and religious congregations before hiring them.
c.

Muslim Volunteers

In order to be selected as a BOP Muslim volunteer (Level 1 or
Level 2), applicants must pass a criminal history check, which includes a
fingerprint check, inquiries with local law enforcement, and a record
check through the FBI’s NCIC. Applicants also must disclose their
country of citizenship. In addition, according to the Chief of the
Chaplaincy Services Branch, the BOP began in October 2003 to inquire
about volunteer applicants’ educational background, countries visited,
and naturalization number (if applicable). She said this information is
used to further screen out potentially radical individuals. For example,
the BOP will not accept volunteers who have spent a significant amount
of time in a country that does not have diplomatic relations or treaties
with the United States.
Unlike chaplains and contractors, volunteers are not required to
pass a drug screening urinalysis or provide contact information for their
employers for the past five years. They also are not asked to report the
professional, civic, and religious organizations in which they hold
membership or whether they have received funds from foreign
governments.
Ex-offenders are eligible to serve as volunteers, but are subject to
more stringent security requirements. In addition to the standard
volunteer security requirements, ex-offenders must have no arrests for
three or more years after their release, must submit to a background
check in which they provide and verify their current employment or
academic status, and cannot be placed in a prison that houses inmates
who have separation orders against them. In addition, ex-offenders are
prohibited from entering protective custody units and must be escorted
at all times.
Level 2 volunteers must be interviewed prior to working with
inmates, but Level 1 volunteers are not interviewed. The prison’s
program manager conducts brief interviews for Level 2 volunteers at the
local prison.
The BOP does not screen volunteers’ doctrinal beliefs or require
they provide a statement of faith. The BOP also does not consult the

25

BOP Muslim chaplains regarding the screening of Muslim volunteers or
ask chaplains to gather information from the local community on
volunteer applicants. The Chief of the Chaplaincy Services Branch told
the OIG that she believed it would be beneficial for chaplains to examine
volunteers’ activities and reputations in their communities and religious
congregations.
d.

Security Screening Through the FBI

The FBI recently began providing additional information to the BOP
on contractors and volunteers that may not be available during an NCIC
check. This could include open investigations, terrorism-related
connections, or other information that did not result in an arrest or
conviction.
1.

National Joint Terrorism Task Force

All communications between the FBI and the BOP about the
radicalization of inmates are now channeled through the National Joint
Terrorism Task Force (NJTTF) in FBI Headquarters.28 The BOP detailee
to the NJTTF is the project manager for the NJTTF’s Correctional
Intelligence Initiative (CII), described below, and serves as the conduit for
the flow of information between the FBI and the BOP on counterterrorism
issues. For example, he said he exchanges information with FBI
intelligence analysts, searches FBI databases for information relevant to
BOP security, and assists in implementing initiatives for the purpose of
detecting and deterring inmate radicalization in the BOP. Almost all
information between the FBI and the BOP regarding the radicalization of
inmates is channeled through this BOP detailee to the NJTTF. However,
the SDAD of the Correctional Programs Division informed us that he
occasionally has spoken with unit chiefs at the FBI and the
Counterterrorism Division’s Deputy Assistant Director for Operational
Support about the radicalization of inmates.
During our review, we found that the exchange of information
between the FBI and the BOP on issues concerning the BOP’s selection of
Muslim religious services providers has not been entirely effective. We
28 The NJTTF was formed in July 2002 to allow for the direct exchange of
information among approximately 30 participating federal agencies. These agencies
include, among others, the Central Intelligence Agency, the DOD, the Internal Revenue
Service, the Department of Homeland Security, and the BOP. According to the FBI,
NJTTF members receive all intelligence and other information that their FBI
counterparts receive. The primary purpose of the NJTTF is to collect terrorism
information and intelligence and disseminate it to the FBI’s 56 local Joint Terrorism
Task Forces (JTTF), various terrorism units within the FBI, and partner agencies.
NJTTF members support the FBI’s counterterrorism mission by sharing their respective
agencies’ information and resources with the FBI and other NJTTF participants.

26

learned that the FBI had information about certain Islamic endorsing
organizations’ potential terrorism connections, but when we interviewed
senior BOP officials and the BOP detailee to the NJTTF in July and
August 2003, they did not know about the FBI information or the extent
of the FBI’s concerns about these organizations. This indicated that
despite the BOP detailee’s queries in FBI databases and discussions with
various FBI counterterrorism analysts, he was not obtaining information
critical to the BOP’s assessment of these endorsing organizations.
Moreover, the detailee’s work was not part of a larger coordinated effort
with the FBI to respond to the issues concerning the BOP’s selection of
Muslim religious services providers.29 The BOP detailee explained in
August 2003 that he had not contacted the Counterterrorism Division at
the FBI “in an organized way” and instead simply had conversations “on
a spot-individual basis” with FBI analysts.30
In addition, we learned that BOP and FBI officials did not meet to
discuss concerns about the BOP’s selection of Muslim chaplains,
contractors, and volunteers until December 16, 2003, after significant
congressional and media attention arose about these issues. On that
day, we conducted a follow-up interview of the SDAD of the Correctional
Programs Division. He said that shortly before our interview, he had met
for the first time with the Unit Chief of the NJTTF to discuss the BOP’s
selection process for religious services providers. Until that meeting,
which the Unit Chief of the NJTTF described as an annual meeting at
which BOP and NJTTF representatives discussed issues of mutual
interest, essentially all of the FBI’s and BOP’s communications about
issues pertaining to the selection of religious services providers were
exchanged solely through the BOP detailee to the NJTTF.
2.

The Correctional Intelligence Initiative

The CII is led by the BOP detailee to the NJTTF. The purpose of
the CII is to prevent potential acts of terrorism by inmates in the
United States. The CII has four subprojects: 1) general intelligence,
The scope of this review is limited to the selection of Muslim religious services
providers, and does not include an examination of the entire CII program and its
“recruiting in custody subproject.”
29

30 Shortly after congressional inquiries regarding concerns about Islamic
endorsing organizations, the BOP detailee began to gather information from the FBI on
a few of the endorsing organizations he knew were of concern to Congress. He
conducted several test searches of these groups for the purpose of determining what
information the FBI had on them and whether this information indicated the BOP
should not use them to endorse chaplain candidates. He also had informal
conversations with analysts in the FBI’s Counterterrorism Division regarding their
knowledge about Wahhabism, Salafism, the ISNA, and the GSISS. According to the
detailee, his research was “non-directed” and executed “just on my own.”

27

2) recruiting in custody, 3) development of inmate sources on terrorism
matters, and 4) inmates calling persons of concern.
The CII’s recruiting in custody subproject focuses specifically on
detecting and deterring the radicalization or recruitment of inmates by
extremist organizations or individuals who come into the prisons to
provide services directly to the inmates. This includes all services,
religious or otherwise, and all people, including staff, contractors, and
volunteers.
According to the SDAD of the BOP’s Correctional Programs
Division, all contractors and volunteers were managed and screened by
local prisons until April 2003. Until that time, their security screening
did not include any checks with the FBI beyond fingerprint and NCIC
checks. However, in April 2003, BOP Headquarters began working with
the NJTTF to conduct further security checks on BOP contractors and
volunteers. The BOP created a database of the names of all its
contractors and volunteers and submitted the names to the FBI’s Name
Check Unit for a security threat assessment.
Through this and other projects under the recruiting in custody
subproject, the FBI has identified some BOP contractors or volunteers “of
interest” who it suspects could be recruiting or radicalizing inmates.31
According to the BOP detailee to the NJTTF, “of interest” means that
there is an indication that the person is connected, directly or indirectly,
to individuals or a group of concern to the FBI’s Counterterrorism
Division. He said that while the FBI may suspect these individuals to be
a security threat, the information is not always conclusive and may
require further investigation or research.
The SDAD of the Correctional Programs Division said that the BOP
analyzes the information obtained by the FBI on the contractors and
volunteers identified as “of interest” to determine whether to recommend
that they be dismissed. He said that a contractor or volunteer will be
dismissed based on any credible evidence that the person has potential
ties to any terrorist-affiliated organizations or individuals; advocates
racism or violence; or has made anti-U.S. statements or supports such
statements. He also said that the BOP maintains a database of its
decisions on these cases to assist in making decisions on future cases.
He further stated that the BOP plans to screen new contractors’ and
Level 2 volunteers’ names through the FBI before hiring them.

According to the FBI, none of the BOP’s chaplains, Muslim or otherwise, is “of
interest.” In addition, the BOP never has dismissed a Muslim chaplain for
inappropriate work-related conduct or teachings.
31

28

Ultimately, the BOP’s success in identifying and dismissing staff,
contractors, and volunteers who are radicalizing and recruiting inmates
for terrorist acts depends in part on the FBI developing and documenting
sufficient, accurate, and credible information to support a decision to
dismiss an individual. This further underscores the importance for
improving the FBI-BOP information flow process.
3.

The Joint Intelligence Coordinating
Council (JICC)

On February 24, 2004, the Attorney General announced the
initiation of the Joint Intelligence Coordinating Council (JICC). The JICC
will include personnel from key DOJ agencies, including the FBI, Drug
Enforcement Administration, and the BOP. According to a press release
from the Attorney General’s office, the purpose of the JICC is to improve
counterterrorism intelligence collection, analysis, and information
sharing within the DOJ. While the creation of the JICC may improve
information sharing between the FBI and the BOP on issues of inmate
radicalization, the JICC is not yet operational and the actual effect of the
JICC on the FBI-BOP information flow is not clear.
IV.

ENDORSING ORGANIZATIONS
A.

Role of Endorsers for Staff, Contractors, and Volunteers

The BOP uses local and national endorsements to help determine
that chaplain, contractor, and volunteer applicants are qualified and able
to provide appropriate religious services in a prison setting. The roles for
local and national endorsers differ in many respects.
Contractors and volunteers require only local endorsements that
are supposed to attest to a person’s good standing in the organization.
These endorsements authorize the person to work in the local BOP
facility on behalf of the organization. According to the Chief of the
Chaplaincy Services Branch, the endorsement serves to verify the
legitimacy and qualifications of the contractor or volunteer. However, the
BOP does not contact the endorser to discuss the candidate or the basis
for the endorsement, or maintain any kind of relationship with local
endorsing organizations.
National endorsements are required for chaplain candidates.
National endorsements are supposed to signify that the chaplain
candidates are mature in their religion; can provide religious services in a
pluralistic environment; represent the national organization in the
provision of religious services; and have no legal, moral, or ecclesiastical
barrier to serving as chaplains. According to the Chief of the Chaplaincy

29

Services Branch, the national endorsement also is supposed to attest
that the candidate has mainstream religious beliefs and is qualified and
capable to teach in BOP institutions.
The BOP requires chaplain candidates to obtain a national
endorsement from an organization like the ISNA rather than a local
endorsement because they provide services for many different kinds of
inmates at facilities across the nation. In contrast, the BOP requires
contractors and volunteers to obtain only a local endorsement because
they work at a single, local facility with inmates of their faith group.
The Chief of the Chaplaincy Services Branch stated that before
1995 the BOP required Muslim chaplains to provide only a local
endorsement, just like volunteers and contractors. However, because it
was difficult for chaplains to maintain relationships with local
organizations when they were assigned to prisons in other states, the
BOP decided to move to a national endorsement requirement for chaplain
candidates. To maintain the relationships between the endorsing
organizations and the chaplains, the BOP encourages national endorsers
to visit chaplains in their facilities and authorizes chaplains to take
administrative leave to attend endorsers’ annual conferences or spiritual
retreats.
The Chief of the Chaplaincy Services Branch said that the national
endorsement is intended to hold chaplains accountable, keep them
rooted in their faith, and help them maintain contacts with their faith
communities. The endorsement is an affirmation that the candidate will
be performing a valid ministry consistent with the faith group’s beliefs
and has presented evidence of having the education, experience, and
skills necessary to perform that ministry in a correctional setting.
The Chief of the Chaplaincy Services Branch acknowledged,
however, that national endorsing organizations likely would not know
candidates as well as a local endorsing organization would. But she said
that it is safer and more effective to require national endorsements for
chaplain candidates than local endorsements. She asserted that radical
local organizations could go undetected much easier than national
organizations. She also said that national endorsers have more
experience working with chaplains and have more resources to assist
them in their work. Furthermore, she said the BOP builds relationships
with the national endorsers because it can more easily work with a
consistent group of people over time. Through these relationships, she
said, the BOP is able to obtain greater support for its chaplains and
further ensure that the organizations are mainstream, understand the
BOP’s mission, and share the BOP’s values. For example, the BOP has
asked endorsers to report any language or conduct that indicates a staff

30

member, contractor, or volunteer is promoting a message that is contrary
to the BOP’s policies.
B.

Qualification to be an Endorser

The Chief of the Chaplaincy Services Branch said that the religious
legitimacy of the endorsement provided by a particular organization or
mosque is based on its reputation. She said if the BOP had any
suspicion that an organization or mosque was radical, the BOP would
not rely on its endorsements. Before October 2003, the BOP relied on
information known to the general public or reported in newspapers to
know whether a mosque or organization was radical. She said that the
BOP evaluated the integrity of a mosque or organization based on the
conduct of the staff members, contractors, and volunteers it had
previously endorsed.
Prior to this review, if the BOP had no reason to be concerned
about a local organization, the organization’s endorsement of a
contractor or volunteer applicant was accepted without any further
qualification requirements or security screening procedures. Security
screening steps taken since initiation of our review are discussed below
in section IV (E), “The FBI’s Assessment of Endorsing Organizations.”
Before a national group is allowed to endorse chaplain applicants,
it must complete the paperwork required by the BOP to verify the
organization’s religious legitimacy. Such organizations must provide the
BOP a statement of their beliefs and practices, proof of their tax-exempt
status (501(c)(3)), an endorsement for their candidate, and a completed
application form.32 The form asks endorsers how they select candidates,
what criteria they use to determine whether candidates are qualified as
professional ministers, and how the candidates receive the official
endorsement of the organization. Since December 2003, the BOP also
has started requiring national endorsing organizations to submit an
additional form certifying that their organization does not promote
separatism, terrorism, or violence.
Currently, the ISNA is the only national organization that has
submitted all paperwork required by the BOP to be a national endorser
for Muslim chaplains. However, the BOP recently stopped accepting
ISNA-endorsed Muslim candidates, effectively ceasing the hiring of

The Chief of the Chaplaincy Services Branch told the OIG that the BOP does
not use 501(c)(3) information for purposes other than to establish that the endorsing
group is recognized by the Internal Revenue Service as a religious organization.
32

31

Muslim chaplains.33 The BOP’s decision to stop accepting ISNA-endorsed
chaplains is discussed further below under IV (D), “ISNA and GSISS
Endorsements of BOP Religious Services Providers.”
The BOP has encouraged other Islamic organizations to apply to be
endorsers for Muslim chaplains, including the Islamic Supreme Council
of America (a moderate Sufi organization). However, the BOP normally
does not seek endorsers for chaplains. Instead, chaplain candidates
identify which organization will provide their endorsement and if the
organization has not completed the paperwork required by the BOP to be
a national endorser, the BOP will send it an endorser application packet.
We found no evidence indicating that the BOP excludes non-Wahhabist
organizations from endorsing Muslim chaplain candidates. According to
the Chief of the Chaplaincy Services Branch, Muslim chaplain candidates
recently identified two moderate Muslim organizations as endorsers, but
neither of them has completed the requisite paperwork.
The Chief of the Chaplaincy Services Branch asserted that there
are special problems posed by requiring Muslim chaplain candidates to
obtain a national endorsement: 1) the non-hierarchical structure of
Islam does not lend itself naturally to the existence of national Islamic
organizations; 2) very few Islamic national organizations have been
established in the United States; 3) many of these organizations have
fallen into disrepute; and 4) the BOP is not presently accepting
endorsements from the ISNA and other Muslim endorsing organizations.
She added that despite her reluctance to rely on local endorsements for
chaplains, she would consider permitting local endorsements for Muslim
chaplains if the candidate cannot identify a national organization that
will complete the paperwork required by the BOP to be an official BOP
endorser.
C.

Background of the ISNA and the GSISS

Founded in 1981 and located in Plainfield, Indiana, the ISNA is the
oldest national Islamic organization in the United States. According to
the ISNA’s website, the ISNA is an association of Muslim organizations
and individuals that provides a common platform for uniting Islamic
communities nationwide; presenting Islam; developing educational,
social, and outreach programs; and fostering good relations with other
religious communities and civic organizations. The ISNA’s stated mission
is to be an exemplary and unifying Islamic organization in North America

The BOP has stopped accepting endorsements from all Islamic organizations
until it receives information on those organizations from the FBI and determines
whether to continue using those organizations as endorsers.
33

32

that contributes to the betterment of the Muslim community and society
at large.
The ISNA is operated by an executive council of nine officers,
including the president, two vice presidents, a former president, and five
regional representatives. The president, two vice presidents, and former
president also serve on the ISNA’s Board of Directors. The ISNA’s Board
of Directors is composed of 22 individuals, including leaders of various
Islamic organizations, ISNA chapter presidents, and members at large.
The Chief of the Chaplaincy Services Branch said that she has
worked with the ISNA since the 1980s when the BOP hired its first
Muslim chaplains. She stated that originally the federal government
sought the ISNA’s assistance with locating qualified, trustworthy Muslim
chaplains; the ISNA did not approach the federal government to perform
this role.
The Chief of the Chaplaincy Services Branch asserted that the
ISNA is a moderate, mainstream, non-Wahhabist, Islamic organization
that encompasses Muslims from several Islamic sects. She said that the
ISNA’s president participated in inter-faith prayer services following the
September 11 terrorist attacks. She said that the ISNA is funded by its
member mosques and does not receive Saudi funding. She recounted a
time when the BOP approached the ISNA with concerns about a
particular Muslim contractor, and the ISNA informed the BOP that the
individual was not teaching Islam appropriately and that he did not
represent the organization’s views.
The GSISS was founded in 1985 by a group of Islamic scholars.
Due to the death of a significant contributor to the program, the GSISS
did not begin enrolling students until 1996. The GSISS, located in
Leesburg, Virginia, was the first Muslim-governed, campus-based
institution of Islamic graduate studies in the United States. As of March
2004, 11 students were enrolled at the GSISS and 13 professors made up
the GSISS’s faculty. The president of the GSISS is Taha Jabir Alalwani.
The GSISS offers two degrees, the Masters of Arts in Islamic Studies and
the Masters of Religious Practice, which is a 90-credit hour professional
degree that trains Muslim chaplains. One of the GSISS’s stated
objectives is to serve as a bridge between cultures by offering a classical
Islamic education framed within the North American experience.
The GSISS is one of the few Islamic graduate programs in the
United States available to BOP Muslim chaplain applicants to obtain
their requisite academic credentials. However, only one of the ten
current BOP Muslim chaplains has attended the GSISS.

33

The Chief of the Chaplaincy Services Branch said she has
maintained a relationship with the GSISS since 1996. In her opinion,
the GSISS is a mainstream, Islamic organization that has not
demonstrated any tendency toward extremism. Following the
September 11 attacks, the president of the GSISS issued a fatwa, or
official Islamic legal opinion, supporting American Muslims who serve in
the United States military, combat terrorism, and bring terrorists to
justice.
The BOP has an ongoing relationship with both the ISNA and the
GSISS. For example, in June 2002 the Chief of the Chaplaincy Services
Branch delivered a commencement address at the GSISS’s graduation
ceremony. She also attended the ISNA national conference in the
summer of 2003 and spoke on one of its panels. In October 2003, the
ISNA Director came to Washington, D.C., and met with the Chief of the
Chaplaincy Services Branch and the SDAD of the Correctional Programs
Division to discuss the goals and mission of the ISNA.
Following the September 11 terrorist attacks, both the ISNA and
the GSISS were scrutinized for their possible connections to terrorist
groups. For example, according to an affidavit in support of an
application for a search warrant that was publicly released by the
U.S. Attorney’s Office for the Eastern District of Virginia, the GSISS and
some of its affiliated entities have been under federal investigation by the
Department since December 2001 for providing material support to
terrorists, laundering money, and evading taxes. As of March 15, 2004,
the GSISS was still under investigation for supporting terrorism.
In addition, several ISNA board members have been accused of
supporting or having ties to terrorism. One member, Siraj Wahhaj, was
named by U.S. Attorney Mary Jo White as one of the “unindicted persons
who may be alleged as co-conspirators” in the 1993 World Trade Center
bombing. Wahhaj also has been accused of urging his followers to
overturn the U.S. system of government and set up an Islamic
dictatorship. Another ISNA board member, Bassam Osman, is Chairman
of the North American Islamic Trust (NAIT), which allegedly owns the
Islamic Academy of Florida (IAF) and many other Islamic organizations.
In a federal indictment handed down in February 2003, the IAF was
accused of raising funds and providing support for the terrorist
organization Palestinian Islamic Jihad.
The ten BOP Muslim chaplains said that Muslims established the
ISNA to accommodate the American custom of having large, unified,
religious organizations to represent a faith group. They said that their
experience indicates that the ISNA is a moderate group and it was
surprising that the ISNA was suspected of being radical and having ties
34

to terrorist organizations. They expressed concern that if the ISNA has
fallen into disrepute, then Muslims have to start all over and build
another national Islamic organization. However, they were concerned
that other Islamic organizations would suffer the same fate that the ISNA
has, mostly because, they said, the hospitable, familial nature of Islam
means that radical Muslims can easily become part of such
organizations, unbeknownst to the organizations, and mainstream
Muslims can innocently become affiliated with the wrong people or
groups. The ten chaplains also said they believed the GSISS was a
mainstream organization and that the GSISS trained Muslims from
various Islamic sects.
D.

ISNA and GSISS Endorsements of BOP Religious Services
Providers

The ISNA’s and the GSISS’s relationship to the BOP came under
scrutiny after a February 2003 Wall Street Journal article reported that a
BOP Muslim contractor defended the September 11 terrorist attacks and
supported terrorism in statements he made at an event outside a prison.
The contractor, Warith Deen Umar, attended the GSISS but was not
endorsed by the GSISS or the ISNA. He is the founder and president of
the National Association of Muslim Chaplains and served as the chief
Muslim chaplain of the New York State prison system, where he was
employed for about 25 years. After he retired from the New York State
prison system in 2000, he became a Muslim contractor at the FCI in
Otisville, New York.
In February 2003, the Wall Street Journal quoted Umar as stating
at a public event, “Even Muslims who say they are against terrorism
secretly admired and applaud [the September 11 hijackers].” The article
also reported that Umar believed black inmates who converted to Islam
in prison were logical recruits for committing future terrorist attacks
against the United States. Around the same time, Umar’s contract was
terminated “for the convenience of the government,” according to a letter
the BOP sent Umar. One of the BOP Muslim chaplains told us that he
knew Umar in a professional setting several years before Umar joined the
BOP, and if asked he would have informed the BOP that Umar did not
hold mainstream Islam values had he known at the time of Umar’s
application that the BOP was considering hiring him as a contractor.
This incident drew attention to the BOP’s process for selecting
Muslim religious services providers. Shortly after the Wall Street Journal
article was published, Senator Schumer wrote a letter to the OIG
expressing concern that the BOP was relying solely on the ISNA and the
GSISS to endorse its Muslim chaplains. His letter precipitated this
review.
35

The ISNA has provided endorsements for the BOP from 1987 to
2001, but the GSISS never has. Three of the BOP’s ten Muslim
chaplains were endorsed by the ISNA. The remaining seven were
endorsed by other organizations. Before 1995, the BOP required Muslim
chaplains to provide only a local endorsement, just like volunteers and
contractors. As a result, six of the chaplains were endorsed by local
organizations such as the Fox Valley Islamic Society, the Islamic Society
of New Jersey, and the Islamic Society of Greater Charlotte. The seventh
chaplain, hired in 1998, was endorsed by a national organization, the
American Muslim Council (AMC). Because the AMC has not complied
with the BOP’s more recent requirements for official recognition as a
national endorser, it is not currently allowed to endorse Muslim
chaplains. In addition, approximately five Muslim volunteers and
contractors have been endorsed by the ISNA. However, volunteers and
contractors generally receive endorsements from local organizations, not
a national group such as the ISNA.
The BOP has not hired a Muslim chaplain since 2001. The Chief of
the Chaplaincy Services Branch stated that around the summer of 2003
the BOP stopped accepting ISNA-endorsed chaplain candidates. She said
that the BOP would not accept ISNA-endorsed candidates until the FBI
determined that the organization was not radical and does not have ties
to terrorism.34 Since the ISNA currently is the only Islamic national
organization that has submitted all paperwork required by the BOP to
endorse chaplains, and chaplain candidates must receive an
endorsement from a national organization that has submitted the
requisite paperwork, the BOP’s non-acceptance of ISNA-endorsed
candidates effectively has resulted in a freeze on hiring Muslim
chaplains. According to the Chief of the Chaplaincy Services Branch, for
example, one qualified Muslim chaplain has submitted his application to
the BOP, but because he was endorsed by the ISNA the BOP will not hire
him at this time.
This freeze on hiring Muslim chaplains implicates prison security
and presents counterterrorism concerns. Without a sufficient number of
Muslim chaplains on staff, inmates are, according to the Chief of the
Chaplaincy Services Branch and the ten BOP Muslim chaplains, much
more likely to lead their own religious services, distort Islam, advocate
Prison Islam, and espouse extremist beliefs.

By contrast, the FBI told us that it would not provide the BOP an assessment
of whether an endorsing organization is radical. Instead, it said it would share the
information it has on the organization so that the BOP can draw its own conclusions
about whether to use the organization as an endorser.
34

36

E.

The FBI’s Assessment of Endorsing Organizations

The FBI potentially could provide the BOP with information that
would help the BOP determine whether there is a reason to be suspicious
about an endorsing organization. However, the BOP did not screen
Islamic organizations through the FBI prior to the time this review began.
In addition, as described above, our review found that FBI information
about organizations’ radicalism or connections to terrorism has not been
shared effectively with the BOP. As a result, the BOP did not have
information from the FBI on the ISNA or the GSISS when public concerns
surfaced about those organizations’ alleged terrorism connections. For
example, when we interviewed the SDAD of the Correctional Programs
Division in July 2003, four months after the BOP received Senator
Schumer’s letter expressing concern about the ISNA and the GSISS, he
informed us that the BOP never had requested or seen any intelligence
from the FBI on the ISNA or the GSISS.
In October 2003, after the OIG began conducting this review, the
BOP formally requested information and a threat assessment from the
FBI on all 82 Muslim national and local endorsing organizations used by
the BOP, including the ISNA.35 The GSISS was not included in this
request because it has not endorsed any chaplains, contractors, or
volunteers for the BOP. According to the SDAD of the Correctional
Programs Division and the BOP detailee to the NJTTF, the purpose of the
request was to assist the NJTTF and the BOP in determining if
derogatory information indicated an Islamic organization should not be
used as an endorsing organization for Muslim chaplains, contractors, or
volunteers. Prior to this request, the BOP had not asked for information
from the FBI on whether the ISNA or other endorsing organizations posed
a security threat to the BOP.
In mid-December 2003, the FBI finished screening the 82 Muslim
endorsing organizations. The FBI determined that some of the
organizations were “of interest,” although most of them were not.36
According to the BOP detailee to the NJTTF, “of interest” means that
there is an indication that the organization is connected, directly or
indirectly, to individuals or a group of concern to the FBI’s
Counterterrorism Division. He said that while the FBI may suspect these
organizations to be a security threat, the information is not always
conclusive and may require further investigation or research.

35

The endorsing organizations of other faith groups have not been examined.

The classified addendum to this report provides more information about
organizations and individuals that were determined to be “of interest.”
36

37

The FBI indicated that several of the other organizations of interest
required further research by the FBI because there was not enough
information to determine whether they have ties to terrorist groups, are
radical, or should continue to be used by the BOP. According to the BOP
detailee to the NJTTF, if the FBI’s information about an organization is
derogatory, the FBI will further examine all Muslim chaplains,
contractors, and volunteers who have connections with that group.
According to the Unit Chief of the FBI’s Counterterrorism Division
Domestic Sunni Analytical Unit, as of April 13, 2004, detailed
information from the FBI’s review still had not been provided to the BOP.
He said that the Counterterrorism Division was awaiting legal clearance
to release the information contained in the review. According to the
initial request issued to the FBI field divisions, when this information
was provided to the BOP, it would be only advisory in nature and would
not constitute a formal recommendation from the FBI. Rather, once the
BOP receives the information, it would use the information to make its
own judgments about the organizations after consulting with the FBI.
The BOP also said it will determine whether it should discontinue
receiving endorsements from any of the organizations. According to
senior BOP officials, if the FBI does not have any concerns or significant
derogatory information about an organization, the BOP will consider the
organization’s application to be an endorsing organization. If the FBI has
an investigation of or compelling derogatory information about an
organization, the BOP will not continue to accept applicants who are
endorsed by that organization until it is cleared by the FBI.
The SDAD of the BOP’s Correctional Programs Division was unable
to define what the BOP would consider to be “significant” or “compelling”
derogatory information. He said the BOP has to make this determination
on a case-by-case basis, and it cannot begin making such determinations
until it received information from the FBI. He also said that if the FBI’s
information is inconclusive or ambiguous, the BOP would examine each
organization on a case-by-case basis to determine whether to continue
accepting endorsements from that organization. If the BOP decided to
continue accepting endorsements from such an organization, it would
subject the organization and its endorsed applicants to increased levels
of security monitoring until the FBI reaches a conclusion about it.
According to the SDAD of the Correctional Programs Division, if a
future Muslim chaplain, contractor, or volunteer applicant is endorsed by
an organization that has not yet been vetted through the FBI, the BOP
plans to have the FBI process the organization’s name through FBI
databases before it allows the chaplain, contractor, or volunteer
applicant to have access to inmates.

38

V.

SUPERVISION OF RELIGIOUS SERVICES ACTIVITIES AND
PROVIDERS

Supervision within BOP facilities is a further check to ensure that
chaplains, contractors, or volunteers espousing radical beliefs are not
permitted to influence the inmate population. An effective supervision
program also can indicate whether the BOP’s personnel selection process
is successfully screening out individuals who pose a security risk in the
prison environment. In addition, rigorous inmate supervision also can
detect, deter, and prevent terrorist recruitment and radicalization.
A.

Overview

Religious activities in BOP facilities are supposed to occur under
the supervision of chaplaincy staff and typically occur in dedicated space
referred to as “the chapel.” The chapels we observed during this review
typically included one or two areas for worship services, offices for
chaplaincy staff, a library, and several classrooms. These spaces were
enclosed and generally were not amenable to supervision (visual and
auditory) by one person of more than two rooms at a time. In some
facilities, the Psychological Services Department shared space with the
chaplaincy.
The chapel is one of the few areas in BOP facilities where large
numbers of inmates are permitted to meet as a group and to converse.
Services typically occur on Friday through Sunday. Classes are common
in the evenings during the week and last one to two hours each. At the
facilities we visited, from two to six religious activities were scheduled
concurrently each weekday evening. To accommodate the demand for
evening activities, BOP chaplains must work evening hours twice a week.
As with other religious groups, Muslim groups usually gather in
the chapel two times each week: once for a worship service and once for
a study lesson. The BOP staff members we interviewed all believed that
the presence of an Islamic radical in this environment would pose a
threat to institutional security and that supervision practices needed to
be adequate to detect such persons.
The BOP does not have specific policies that address oversight of
religious activities. The BOP P.S. concerning “Religious Beliefs and
Practices” provides simply that “[a]ll institution chaplains are employed
to . . . supervise institution religious activities.” See BOP P.S. 5360.08.
Although responsibilities of some BOP employees who interact with
chaplaincy staff members are described in the P.S. (e.g., food service
staff, employees who make work assignments), the obligations of
correctional officers in support of chaplains are not identified. As
39

described below, the lack of policy guidance allows for significant
variations in the way that religious activities are supervised at BOP
facilities.
B.

BOP Supervision and Intelligence Gathering Methods

The BOP employs a number of methods to oversee religious
activities, including staff observation, electronic monitoring, and physical
inspections. As described to us during our fieldwork, the primary
responsibility for observing and supervising worship services and
religious classes in the chapel rests with the staff chaplains.
According to BOP officials at Headquarters and in the field, the
supervision of contractors, volunteers, and inmates who lead services
and classes in the chapel is intermittent.37 BOP staff members are not
required to be in the same room continuously with religious service
providers and, instead, observe them only periodically. The frequency of
staff observations varied at the facilities we visited. At one institution,
the supervisory chaplain stated that his staff must perform a “walk
around” every hour, while another chaplain stated that this task must be
performed every 30 minutes to an hour. At another facility, the
supervisory chaplain said that chaplains must check on religious
services providers every 15 minutes but was unsure if this requirement
was embodied in a written policy.
During our fieldwork, we observed significant differences in the
level of supervision that correctional officers provided to religious services
and meetings – differences that could not be explained by institution
security level. At one prison, the captain of the correctional officers
explained that the chaplains are responsible for monitoring activities in
the chapel and that the only time he would send an officer to assist with
supervision is when one of the chaplains is absent. A captain at a
different institution explained that the correctional officers visit the
chapel “sometimes,” but most often they rely on the chaplains to provide
supervision. A lieutenant at a third facility explained that “any good
lieutenant working any shift will not rely on chaplains to watch all the
inmates” and that it is important for the custodial staff to make a
presence in the chapel because it acts as a deterrent to misconduct. One
Muslim chaplain also told us that, based on his experiences, the level of
supervision over chapel activities varies by institution.
Moreover, it was apparent to us that at certain facilities the
supervising correctional officers and the associate warden who oversees
chaplaincy services were not familiar with chapel activities. For example,
37

This does not include Level 1 volunteers who must be escorted at all times.

40

at one institution the captain of the correctional officers told us that
Islamic services are conducted entirely in English and both the captain
and associate warden stated categorically that inmates were not allowed
to lead services. When we observed the chapel, however, an inmate was
leading a service in one of the classrooms and Arabic was spoken
periodically throughout the Muslim worship service.
Several BOP staff members stated that the effectiveness of
supervision by correctional officers could be enhanced with additional
training. One associate warden said that he was not confident that
correctional officers could detect radical religious messages (“not a whole
lot of folks are in tune with that kind of stuff”), and a captain explained
that if his staff had more training on Islam they would be better able to
detect inappropriate messages.
In addition to direct staff observation, the BOP relies upon cameras
to monitor activities in some chapel service areas and classrooms. At the
four facilities we visited, a camera was present in the worship areas at
two facilities, and in two classrooms at another facility. One associate
warden told us that the use of cameras had significantly reduced inmate
fighting and strongly deterred inmates from inappropriate conduct. One
Muslim chaplain told us that there should be more cameras in the
chapel, and a supervisory chaplain stated that cameras should be placed
in the classrooms.
While the BOP has video cameras in some worship areas and
chapel classrooms, however, it does not rely upon audio monitoring for
routine supervision of religious services in its facilities. Audio monitoring
is not currently employed in any BOP chapels to evaluate the messages
that religious services providers deliver to inmates. Some correctional
officers said that the ability to listen in on worship services and
classroom instruction would benefit security and would be a deterrent to
the expression of radical messages.
Physical inspections also are a component of security procedures
in the chapel. One lieutenant explained that the chapel is routinely
checked for contraband, and inmates are pat-searched as they enter and
exit the chapel for services and classes. Reading materials that are
delivered to the chapel library also are screened by the chaplaincy staff.
Several of the institutions we visited, however, did not have an inventory
of the books currently available to the inmates, and none of the library
collections had been re-screened since the September 11 terrorist
attacks. We were told by one Muslim chaplain that not all religious
materials that come into BOP institutions are being screened by the
BOP’s chaplains. We found that inmates are allowed to order books,
which are delivered to them directly from the institution mailroom unless
41

the mailroom screener first routes the material to the chaplains for
review.
The BOP collects intelligence and security information from a
variety of sources, including staff, inmate informants, and other law
enforcement agencies. Nearly every BOP staff member we interviewed
believed that if a Muslim radical infiltrated a BOP facility and began
expressing his views, an inmate would report the conduct. According to
one lieutenant, “inmates are knocking down our doors to tell us things.”
Another lieutenant told us that he had inmate informants in virtually
every known group of inmates in the institution. Intelligence on inmates
also is generated by the BOP’s Sacramento Intelligence Unit, which
distributes a weekly bulletin to BOP facilities. Captains at several of the
BOP institutions we visited further said that their emergency
preparedness coordinators had contacts with the local JTTF. A captain
at one facility stated that he believed that a member of his intelligence
staff should be a member of the JTTF because information sharing is a
paramount concern.
C.

Inmate-Led Services

Some staff members we interviewed stated that they were troubled
by the practice of allowing inmates to lead religious services. According
to one chaplain, “inmates look for things to control and the chapel is a
good place to do that.” One associate warden told us that allowing an
inmate to lead a service would “put the inmate on a pedestal,” elevating
the inmate’s stature, which could lead to security problems. At one
facility where inmates were leading the Muslim services, the chaplain
could not describe how the inmates were selected for their position,
whether by vote of the inmates, self-appointment, or otherwise.
VI.

OIG ANALYSIS

Based on our review, we concluded that the BOP’s selection
process needs improvement to further protect the BOP from hiring
religious services providers who could pose security threats. We found
that the BOP made some improvements after we initiated this review, but
we believe additional changes are necessary to address deficiencies in the
BOP’s selection and supervision of religious service providers.
With regard to chaplains, the BOP requires Muslim chaplain
candidates to obtain graduate school accreditation in Islam, have two
years of full-time pastoral experience, provide three personal references,
supply recommendations from previous employers, receive an
endorsement from an Islamic national organization, have a
pre-employment screening interview and a panel interview, and undergo
42

a criminal history check, drug screening urinalysis, and background
investigation. These requirements appear to have identified appropriate
chaplain candidates. According to the Chief of the Chaplaincy Services
Branch, none of the BOP’s Muslim chaplains has been of concern to the
FBI or caused problems for the BOP.
With regard to contractors, the BOP requires applicants to provide
documentation of their religious and ministerial role within the Islamic
community, obtain an endorsement from a local Islamic organization,
provide contact information for their employers for the past five years, be
interviewed by the institution’s program manager, and undergo a
criminal history check and drug screening urinalysis. Volunteers are
required to obtain an endorsement from a local Islamic organization,
provide verifiable religious credentials, undergo a criminal history check,
and be interviewed by the institution’s program manager if they are
Level 2 volunteers. Unlike the Muslim chaplains, a few of the BOP’s
Muslim contractors or volunteers, such as Warith Deen Umar, have been
of concern to the FBI or been dismissed from the BOP for inappropriate
behavior such as making extremist statements and appearing to give
preferential treatment to inmates.
With regard to endorsing organizations, before the OIG initiated
this review, the BOP required national endorsers to provide a statement
of their beliefs and practices, proof of their tax-exempt status, an
endorsement for their candidate, and a completed application form that
asked endorsers how they select candidates, what criteria they use to
determine which candidates are qualified as professional ministers, and
how the candidate will receive the official endorsement of the
organization. However, the BOP did not check with the FBI for
information on these organizations.
After the OIG initiated this review in March 2003, the BOP began
requiring national endorsing organizations to submit an additional form
certifying that their organizations do not promote separatism, terrorism,
or violence. In addition, in April 2003 the BOP began to seek assistance
from the FBI with screening out potentially extremist contractors and
volunteers. In October 2003, the BOP began to seek assistance from the
FBI with screening out endorsing organizations that may be attempting
to infiltrate the BOP to radicalize or recruit inmates for terrorist acts.
According to the SDAD of the Correctional Programs Division, the BOP
intends to continue screening new national and local Muslim endorsing
organizations through the FBI, as well as the names of all new
contractors and Level 2 volunteers, regardless of faith. The BOP also
plans to wait until it receives the FBI’s results from these screenings
before it grants applicants access to BOP institutions.

43

In addition, the BOP and FBI have taken steps to improve their
information sharing. For example, the BOP has made formal requests to
the FBI for information and assessments on contractors, volunteers, and
endorsing organizations, and a senior official from the BOP met in
December 2003 with a senior official from the FBI to discuss concerns
about the BOP’s selection of Muslim chaplains, contractors, and
volunteers.
While the BOP has taken several steps towards improving its
selection process, we believe additional changes are necessary to address
deficiencies in the BOP’s selection and supervision of religious service
providers.
For example, the BOP still does not screen doctrinal beliefs of
chaplains, contractors, or volunteers. BOP officials expressed some
concern to the OIG that such screening would not be legally permissible.
According to the BOP’s General Counsel, the BOP Office of General
Counsel (OGC) has not thoroughly analyzed this legal issue, but it
believes screening chaplain, contractor, or volunteer applicants on the
basis of their beliefs rather than their actions or statements may violate
Title VII of the Civil Rights Act of 1964 or the First Amendment.
We believe, based on our review of the case law, that the BOP
legally may screen all chaplain candidates by asking them questions
about their beliefs. The responses to these questions can provide
important information for the BOP to determine whether the candidates
pose a security threat. Pursuant to the Religious Freedom Restoration
Act (RFRA), the BOP may “substantially burden” a person’s exercise of
religion if the BOP’s actions are the “least restrictive means” of furthering
a “compelling state interest.”38 Many courts have determined that a
correctional institution’s maintenance of security, safety, and orderliness
qualifies as a “compelling interest.”39 Moreover, prison officials are
entitled to take action based on potential threats to institution security or
Religious Freedom Restoration Act, 42 U.S.C. § 2000bb (2000). The RFRA
standard for burdening an individual’s free exercise of religion in a prison context is
more stringent than the constitutional standard. Under the U.S. Constitution, the BOP
may impinge on a person’s exercise of religion if the BOP’s actions are “reasonably
related to legitimate penological interests.” See O’Lone v. Estate of Shabazz, 482 U.S.
342, 349 (1987). Therefore, if the BOP’s screening of applicants’ religious beliefs meets
the RFRA standard, it would likely meet the constitutional standard as well.
38

39 See Hines v. South Carolina Dep’t of Corrections, 148 F.3d 353, 358 (4th Cir.
1998); Mack v. O’Leary, 80 F.3d 1175, 1180 (7th Cir.), cert. granted, judgment vacated
on other grounds, 522 U.S. 801 (1997); Winburn v. Bologna, 979 F. Supp. 531, 535
(W.D. Mich. 1997); Woods v. Evatt, 876 F. Supp. 756, 769 (D.S.C. 1995). Cf. Bell v.
Wolfish, 441 U.S. 520, 546-547 (1979); Kikumura v. Hurley, 242 F.3d 950, 962 (10th
Cir. 2001).

44

the anticipation of security problems,40 and are accorded deference in
creating regulations and policies directed at the maintenance of prison
safety and security.41 Therefore, we believe that the law allows the BOP,
for security purposes, to ascertain from chaplain, contractor, and
volunteer applicants information to determine whether their religious
beliefs include: 1) endorsement of violence, 2) support of terrorism or
other anti-U.S. activities, or 3) discrimination against other inmates or
exclusion of other inmates from their services, whether based on race,
religion, or other discriminatory factors.
Thus, we believe, based upon our initial review, that screening
religious services applicants’ beliefs is legally permissible. We encourage
the BOP’s OGC, in conjunction with DOJ attorneys, to carefully evaluate
this legal issue. It is critical for the security of federal prisons that the
BOP determine whether religious services providers support violence;
terrorism; anti-U.S. activities; or discrimination or exclusion of other
inmates, whether based on race, religion, or other discriminatory factors,
before they are allowed access to inmates.
In addition to not screening religious services providers’ doctrinal
beliefs, the BOP does not request assistance from the BOP Muslim
chaplains in recruiting or screening chaplains, contractors, and
volunteers. However, we believe that the Muslim chaplains are a
valuable resource within the BOP for preventing inmate radicalization
and can assist with the recruitment and selection of Muslims who have
mainstream Islamic beliefs. No other group of BOP employees has as
much expertise and experience with Islam as the chaplains. The Muslim
chaplains stated that they would be able to discern whether a Muslim
chaplain, contractor, or volunteer candidate was an Islamic extremist in
part by knowing who his teachers were and what mosques he has
attended. However, the BOP currently does not request this kind of
information from applicants or discuss it with the chaplains to determine
whether there is a problem with the candidates’ views. The chaplains
suggested that the BOP could have them review Muslim candidates’
application forms, references, and endorsement letters. They said that
based on this information, they could flag any concerns with the
applicants and suggest questions that BOP interviewers could ask them.

40 Whitley v. Albers, 475 U.S. 312, 323 (1986); Hewitt v. Helms, 459 U.S. 460,
474 (1983); Jones v. North Carolina Prisoners’ Labor Union, Inc., 433 U.S. 119, 132133 n.9 (1977); Procunier v. Martinez, 416 U.S. 396, 405 (1974); Butler-Bey v. Frey,
811 F.2d 449, 451 (8th Cir. 1987).

O’Lone, 482 U.S. at 353; Bell, 441 U.S. at 547; Hamilton v. Schriro, 74 F.3d
1545, 1556 (8th Cir. 1996).
41

45

Moreover, the BOP does not encourage its chaplains to seek
information from their local communities on individuals who have
applied to be religious contractors and volunteers in their institutions.
To the extent chaplains are able to obtain this type of information on
religious contractor and volunteer applicants, regardless of faith, it would
assist the BOP in identifying and screening out individuals with
extremist views.
The BOP also has not developed a recruitment strategy specifically
focused on identifying and hiring qualified Muslim chaplains and
contractors, and recruiting Muslim volunteers. While there are many
factors affecting the BOP’s ability to successfully recruit Muslim religious
services providers, one of the main reasons the BOP is experiencing a
critical shortage of Muslim chaplains and a deficiency of Muslim
contractors and volunteers is that it does not have an official program or
strategy specifically focused on recruiting Muslim religious services
providers. The BOP needs to develop such a strategy and increase the
number of Muslim religious services providers in its institutions in order
to accommodate sufficiently the religious needs of Muslim inmates and
further protect institutions from Prison Islam and inmates’ radicalization
efforts. The lack of Muslim religious services providers in the BOP gives
inmates more opportunities to radicalize other inmates by leading
religious services.
Moreover, the BOP has not developed alternative endorsement
policies for Muslim chaplains now that it is not accepting ISNA-endorsed
candidates. This has resulted in a hiring freeze on Muslim chaplains,
which contributes to the BOP’s critical shortage of Muslim chaplains.
While the Chief of the Chaplaincy Services Branch said she would
consider accepting endorsements from local organizations for Muslim
chaplains, the BOP has not developed a policy prescribing when local
endorsements will be accepted in lieu of national endorsements. Hiring
more Muslim chaplains to meet the religious needs of Muslim inmates is
essential to deterring radicalization and Prison Islam.
The BOP also does not require Muslim chaplains, contractors, or
Level 2 volunteers to be interviewed by anyone knowledgeable about
Islam. Interviewers who are unfamiliar with Islam and radical beliefs
within Islam are unlikely to be able to discern whether a Muslim
candidate poses a security threat.
In addition, the BOP does not require an in-depth panel interview
for contractors and volunteers. The Chief of the Chaplaincy Services
Branch asserted that because of the extensive contact contractors and
volunteers have with inmates, she supports requiring contractor and
Level 2 volunteer applicants to be interviewed more thoroughly by a

46

panel consisting of a chaplain, a security officer, and a human resources
official from the BOP institution where the applicants will work.42
Moreover, the BOP’s Muslim chaplains suggested that Muslim contractor
applicants be asked questions that would explore how they would handle
hypothetical correctional scenarios and discuss their motivation for
working in the prisons. We believe the BOP will be able to screen
contractors and volunteers more adequately if they are given more
thorough interviews such as the panel interviews given to chaplain
candidates.
The BOP does not ask whether chaplains, contractors, or
volunteers have received funds from foreign governments. In addition, it
does not verify chaplains’ foreign travel or ask contractors or volunteers
to report the professional, civic, and religious organizations in which they
hold membership. This information could help the BOP better determine
whether applicants have extremist beliefs or pose a security threat to
institutions.
As of April 13, 2004, the FBI still had not shared with the BOP the
information it has on Muslim endorsing organizations. We were told that
the FBI is awaiting legal clearance to release to the BOP the classified
and sensitive information it has gathered on the organizations. As a
result, the BOP has not yet been able to make assessments of its
endorsing organizations or decide whether to continue using them.
The BOP and the FBI continue to exchange almost all information
regarding the radicalization of inmates through the BOP detailee to the
NJTTF. We found that this process is flawed because the BOP has not
received critical information from the FBI about endorsing organizations’
possible connections to terrorism. The BOP detailee has many NJTTF
responsibilities and may not be able to serve effectively as the sole
conduit for the FBI-BOP information-flow.43 Other agencies such as the
Secret Service and the Immigration and Customs Enforcement assign
permanent liaisons to the FBI, in addition to their detailees on the
NJTTF, to assist in exchanging information.
With regard to BOP supervision practices, our examination
revealed that the BOP relies on various methods to oversee its religious
42 In comments to a draft of this report, the Chief of the Chaplaincy Services
Branch clarified that she does not believe it is necessary to conduct panel interviews of
religious services contractors and volunteers who average four to eight hours in a BOP
institution per month and have very limited contact with inmates.

The OIG is conducting a separate evaluation that is examining the NJTTF and
expects to issue a report later this year that addresses various aspects of the NJTTF’s
operations, including information sharing and training for NJTTF detailees.
43

47

services providers and inmates, including direct staff supervision and
electronic monitoring, but significant gaps remain. Once an individual is
allowed entry to a BOP institution and therefore has a platform to
instruct inmates or to lead them in worship, ample opportunity exists for
them to deliver inappropriate messages without the direct oversight of
BOP personnel. With few exceptions, contractors, unescorted volunteers,
and inmates who lead services are subject only to intermittent
supervision. Service areas and chapel classrooms frequently lack
cameras, and audio monitoring currently is not employed. Our fieldwork
also identified significant differences in the level of supervision or
observation of them by chaplains or correctional officers, and that BOP
staff did not always understand the frequency with which they were
supposed to observe religious services providers. Supervisory
correctional officers and BOP managers further advised us that many
correctional officers are not familiar with Islam, and that this lack of
knowledge may limit their ability to recognize radical Islamist messages
that are inappropriate in BOP facilities.
BOP staff members were consistent in their views that the most
significant radicalization threat comes from the inmates and not from
chaplains, contractors, and volunteers. Many of the BOP staff we
interviewed also emphasized that allowing inmates to lead services posed
security risks, and in one institution we were told the practice was
prohibited for security reasons.44 Although BOP staff acknowledged the
importance of a rigorous selection process for religious services
providers, they repeatedly told us that they had not encountered
significant problems with chaplains, volunteers, and contractors, and
that if such persons were Islamic radicals they would be identified
quickly because of inmate reporting and other detection methods.45
We believe that the BOP should evaluate the feasibility of having
correctional officers provide intermittent supervision of all religious
activities to supplement the supervision provided by chaplaincy staff. As
a further means to enhance supervision of religious services, the BOP
should evaluate the cost, legality, and feasibility of expanding video or
audio monitoring of all worship areas and chapel classrooms. To better
44 As explained above, however, we observed an inmate leading a service at this
institution.
45 We note that in the case of former BOP contractor Warith Deen Umar,
described above, BOP staff observed Umar repeatedly give sermons that violated BOP
security policies but failed to terminate his contract. Several of his Contractor Progress
Reports explain that he “disparages Judaism and Christianity” and that his “sermons
are sometimes not appropriate; has been spoken to.” Despite this conduct, the same
Reports provide him with “Good” or “Excellent” marks for the “Quality of
Goods/Services” rendered.

48

ensure that correctional officers are familiar with Islam and can
recognize radical Islamist messages that are inappropriate in BOP
facilities, the BOP also should provide training on Islam and
radicalization to its correctional officers.
Another significant problem identified by BOP staff was the
practice of allowing inmates to lead religious services. Many BOP
officials and employees said they do not believe that it is appropriate for
inmates to assume leadership positions in BOP facilities, including the
position of surrogate chaplain. We agree. Too many opportunities for
abuse of this practice exist. We think that the BOP should restrict the
use of inmates to lead religious services. For example, in facilities where
inmates presently are leading services, the BOP should evaluate the
feasibility of providing Internet video feeds to chapel areas for Juma
prayer by a BOP Muslim chaplain.
In addition, the BOP does not require inmate-led religious services
to be monitored constantly by a staff member. Rather, staff must
supervise inmate-led services only intermittently, like services led by
contractors or Level 2 volunteers. As a result, inmates have the
opportunity to deliver radical messages during religious services
undetected by BOP staff. Staff supervision at inmate-led services is
essential to deterring and preventing inmate radicalism.
The BOP does not require contractors to submit to the chaplains
lesson plans or an outline of what they intend to cover during services.
The Chief of the Chaplaincy Services Branch expressed concern that
making contractors submit their lesson plans for approval would deter
people from working for the BOP. However, she said that the SOW for
religious contractors could include the themes and topics on which
contractors are to focus and list the specific things contractors are not
allowed to say as part of their messages (i.e., advocate violence, make
statements against the United States, or make exclusionary statements).
Our discussions with the BOP’s Muslim chaplains revealed that
they are discouraged from assisting non-Muslim chaplains in other
facilities with supervision issues related to the practice of Islam,
including problems concerning radicalization. We believe this is a
serious error and that the BOP could better use the expertise of its
Muslim chaplains. Few other BOP employees have the degree of
knowledge and experience with Islam to advise BOP staff members
adequately on matters related to Islamic radicalization. For example, to
improve supervision practices in facilities that do not have a Muslim
chaplain, the BOP could encourage staff members from those facilities to
consult with the Muslim chaplains at other facilities to address potential
or actual radicalization problems.
49

Our fieldwork also revealed that supervision of chapel libraries is
not as thorough as it should be. None of the chaplains at the facilities
that we visited was able to produce an inventory of the books and videos
available to the inmates, and it did not appear that these materials had
been evaluated after the terrorist attacks of September 11. We
recommend that the BOP undertake an inventory of chapel books and
videos to confirm that they are permissible under BOP security policies.
The BOP also should consider maintaining a central registry of
acceptable material to prevent duplication of effort when reviewing these
materials.
Lastly, we found that not all of the BOP facilities we visited were
working closely with the local JTTF. BOP facilities should be fully
integrated into local counterterrorism initiatives. We recommend that all
BOP facilities maintain at least a liaison with their local JTTF.
VII.

OIG RECOMMENDATIONS

We believe the BOP can and should improve its process for
selecting, screening, and supervising Muslim religious services providers.
We therefore offer a series of recommendations to address the issues we
examined in our review.
A.

Screening of Religious Services Providers

1.

The BOP should screen all religious services providers’
doctrinal beliefs. Currently the BOP does not screen
religious services providers’ religious and doctrinal beliefs.
Instead, it relies on the candidates’ endorsements to certify
that they will minister to inmates of all faiths and provide
appropriate religious services in a prison setting. However, it
is essential to the security of the BOP that candidates who
have extreme views and who pose a security threat not be
allowed into the prisons.
We recommend the BOP take steps to examine all chaplains’,
religious contractors’, and religious volunteers’ doctrinal
beliefs to screen out anyone who poses a threat to security.
For example, the BOP could ask chaplains, contractors, and
Level 2 volunteers doctrinal questions in their interviews and
require them to submit a statement of faith with their
applications. We recommend that the BOP OGC examine
this issue to determine what screening procedures are legally
permissible. The BOP’s screening of candidates’ religious
and doctrinal beliefs should be for security purposes only,
50

not to assess the purity of candidates’ views or serve as an
approval or endorsement of their religious beliefs. The BOP
also should develop a list of criteria to use when screening
individuals. At the least, this list should include:
1) endorsement of violence, 2) support of terrorism or other
anti-U.S. activities, and 3) discrimination against other
inmates or exclusion of other inmates from religious services,
whether based on race, religion, or other discriminatory
factors. In addition, the BOP should consider requesting
that OPM’s background investigations examine chaplains’
past statements and conduct in religious communities.
2.

The BOP should require all chaplain, religious contractor,
and religious Level 2 volunteer applicants to be
interviewed by at least one individual knowledgeable of
the applicant’s religion. This individual could be a BOP
chaplain, BOP official, or member of an interfaith chaplain
advisory board created by the BOP for the purpose of
interviewing chaplain candidates. However, if the BOP
creates an interfaith chaplain advisory board, members of
the board must be screened sufficiently to ensure they do
not hold views contrary to BOP policy, including advocating
violence, supporting terrorism, or discriminating against
people of certain races or religions.

3.

The BOP should require panel interviews for all religious
contractors and Level 2 volunteers. Because of the
extensive contact contractors and volunteers have with
inmates, we recommend the BOP require contractor and
Level 2 volunteer applicants to be interviewed thoroughly by
a panel consisting of a chaplain, a security officer, and a
human resources official from the BOP institution where the
applicants will work. The BOP likely will be able to screen
contractors and volunteers more adequately if they are given
more thorough interviews such as the panel interviews given
to chaplain candidates.

4.

The BOP should implement further security screening
requirements for religious services providers. The BOP
should ask chaplains and religious contractors whether they
have ever received funds from foreign governments. The BOP
should ask contractors and Level 2 volunteers to report the
professional, civic, and religious organizations in which they
hold membership. In addition, the BOP should verify
chaplains’ foreign travel to determine whether they have

51

spent a significant amount of time in a country that does not
have diplomatic relations or treaties with the United States.
5.

The BOP should encourage chaplains to seek information
about contractor and volunteer applicants from their
local communities. We recommend that the BOP
encourage chaplains at institutions hiring contractors and
volunteers to seek information from their local communities
about individuals applying to be religious services
contractors or volunteers.

B.

FBI-BOP Information Flow

6.

The BOP should take steps to improve and increase the
information flow between the BOP and the FBI. Our
review indicated that the information flow between the FBI
and the BOP regarding the radicalization and recruitment of
inmates needs improvement. While the recent creation of
the Joint Intelligence Coordinating Council (JICC) might help
improve FBI-BOP information sharing on inmate
radicalization issues, we believe that additional steps need to
be taken to further improve information flow. We
recommend that the BOP not rely exclusively on the BOP
detailee to the NJTTF or the creation of the JICC for this
information flow, but consider assigning a liaison to the FBI,
like other agencies do, to improve the exchange of
information about the radicalization and recruitment of
inmates. In addition, we recommend that BOP officials meet
periodically with FBI officials regarding joint efforts to
prevent the radicalization of inmates.

C.

Reliance on Staff Muslim Chaplains

7.

The BOP should more effectively use the expertise of its
current Muslim chaplains to screen, recruit, and
supervise Muslim religious services providers. The BOP
should utilize its Muslim chaplains more effectively by
having them review the applications, references, and
endorsements of potential Muslim chaplains, contractors,
and volunteers. We also recommend the BOP consider
having at least one Muslim chaplain serve on the interview
panel for Muslim chaplain candidates.

52

D.

Recruiting Muslim Religious Services Providers

8.

The BOP should develop a strategy specifically targeted
towards recruiting Muslim religious services providers.
Currently the BOP does not have enough Muslim chaplains,
contractors, and volunteers compared to the size of its
Muslim inmate population. As a result, inmates are leading
religious services, which presents prison security and
national security concerns. Recruiting qualified Muslim
religious services providers could reduce inmate-led services,
Prison Islam, and radicalization. We recommend that the
BOP develop a strategy specifically for recruiting Muslim
chaplains, contractors, and volunteers. For this strategy, the
BOP should consider having BOP personnel reach out more
to Muslim communities or enabling Muslim chaplains to
spend part of their work hours recruiting.

E.

Endorsements

9.

The BOP should consider implementing alternative
endorsement requirements for Muslim chaplains.
Presently the BOP is experiencing a hiring freeze on Muslim
chaplains because it will not accept endorsements from any
Islamic organizations until it receives information on those
organizations from the FBI. In addition, no other national
organization besides the ISNA is authorized to endorse
Muslim chaplains. Moreover, the BOP will not hire
chaplains who have endorsements from national
organizations about which the FBI has derogatory
information. We recommend the BOP consider developing
alternative endorsing requirements for Muslim chaplains,
such as permitting endorsements from local or regional
organizations in specific situations.

F.
10.

Supervision
The BOP should evaluate the feasibility of having
correctional officers provide intermittent supervision to
all chapels to supplement the supervision provided by
chaplaincy staff. As a further means to enhance
supervision of religious services, the BOP should
evaluate the cost, legality, and feasibility of audio and
video monitoring to include all worship areas and chapel
classrooms. With few exceptions, individuals who lead
religious services in BOP facilities are subject to only limited
supervision. As a result, once contractors and volunteers
53

gain access to BOP facilities, ample opportunity exists for
them to deliver inappropriate messages without direct
supervision from BOP staff members. Our fieldwork
identified significant differences in the level of support
provided to chaplains by correctional officers. We also
observed that video coverage of BOP chapels varies by
institution, and that audio monitoring is not employed. We
believe that the BOP should evaluate options to make chapel
supervision more thorough and consistent Bureau-wide.
11.

The BOP should limit and more closely supervise inmateled religious services. Inmates are radicalized primarily by
other inmates. We do not believe that it is appropriate for
inmates to assume leadership positions in BOP facilities,
including the position of surrogate chaplain. We recommend
that the BOP take steps to reduce inmate-led religious
services. For example, in facilities where inmates presently
are leading Juma services, the BOP should evaluate the
alternative of providing Internet video feeds to chapel areas
for Juma prayer by a BOP Muslim chaplain. The BOP also
should consider requiring inmate-led services to be
monitored by staff constantly rather than intermittently.

12.

The BOP should provide its staff with training on Islam.
Supervisory correctional officers and BOP managers advised
us that many correctional officers are not familiar with
Islam, and that this lack of knowledge may limit their ability
to recognize radical Islamist messages that are inappropriate
in BOP facilities. At a minimum, we believe that the BOP
should provide basic training to its staff members who
supervise Muslim religious services so that they will be
familiar with accepted prayer and service rituals, understand
Islamic terminology, and recognize messages that violate
BOP security policy.

13.

To improve supervision practices in facilities that do not
have a Muslim chaplain, the BOP should encourage staff
members from those facilities to consult with the BOP
Muslim chaplains to address potential or actual
radicalization problems. Our review found that the BOP is
not fully using the expertise of its staff Muslim chaplains.
These individuals have knowledge and abilities that can and
should be used to assist the BOP to address radical
influences.

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14.

The BOP should include in contractors’ SOWs the
themes and topics on which they should focus. The BOP
should provide contractors guidance on what they are to
teach during religious services by including topics and
themes to be discussed with inmates in contractors’ SOWs.
The SOWs also should include specific things contractors
are not allowed to say as part of their messages, such as
statements that support violence, denigrate the United
States, or disparage other inmates or other faith groups.

15.

The BOP should conduct an inventory of chapel books
and videos and re-screen them to confirm that they are
permissible under BOP security policies. The BOP
should consider maintaining a central registry of
acceptable material to prevent duplication of effort
when reviewing these materials. Of the institutions we
visited, several did not have an inventory of the books
currently available to the inmates, and none of the
collections had been re-screened since the September 11
terrorist attacks.

16.

BOP facilities should maintain a liaison with their local
JTTF. BOP facilities should be fully integrated into local
counterterrorism initiatives. Our review revealed that not all
BOP facilities are working closely with their local JTTF.

VIII. CONCLUSION
Religious services providers are in a unique position to influence
the beliefs and conduct of inmates. The presence of extremist chaplains,
contractors, or volunteers in the BOP’s correctional facilities can pose a
threat to institutional security and could implicate national security if
inmates are encouraged to commit terrorist acts against the
United States. For this reason, it is imperative that the BOP has in place
sound screening and supervision practices that will identify persons who
seek to disrupt the order of its institutions or to inflict harm on the
United States through terrorism.
We recognize that the BOP has made significant improvements
since our review was initiated in March 2003 to better screen extremist
religious services providers. However, our review found that while the
BOP has not identified widespread problems with inmate radicalization
and terrorist recruiting, chaplaincy services in the BOP remain
vulnerable to infiltration by religious extremists, and supervision
practices in BOP chapels need strengthening. For example, the BOP
currently does not screen religious services providers’ doctrinal beliefs to
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determine whether the providers pose a security threat. Moreover, once
granted access to an institution, the providers typically have ample
opportunity to deliver messages without supervision from BOP staff. The
BOP also does not effectively use the expertise of its current Muslim
chaplains to screen, recruit, and supervise Muslim religious services
providers. In addition, the BOP has not developed a recruiting strategy
or alternative endorsement requirements to end its shortage of Muslim
chaplains. Furthermore, the FBI and the BOP have not effectively
exchanged information about endorsing organizations’ possible
connections to terrorism. In our view, these and other practices
identified in this report create unnecessary risks to prison and national
security.
This report includes a series of recommendations that address the
deficiencies we identified during our review. We believe that the BOP
needs to carefully evaluate and implement these recommendations to
improve its selection and supervision of religious services providers.

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