Office of the Inspector General
U.S. Department of Justice
OVERSIGHT

INTEGRITY

GUIDANCE

Review of the Federal Bureau of
Prisons’ Management of Its Female
Inmate Population

Evaluation and Inspections Division 18-05

September 2018

Executive Summary
Review of the Federal Bureau of Prisons’ Management of Its Female Inmate
Population

Introduction

and better ensure compliance with female inmatefocused policies and protocols.

As of September 2016, the Federal Bureau of Prisons
(BOP) incarcerated 10,567 sentenced female inmates,
representing 7 percent of the total BOP sentenced
inmate population of 146,084. Though female inmates
compose a small percentage of the nationwide
incarcerated population, correctional officials have
recognized that in some areas female and male inmates
have different needs and BOP has adopted genderresponsive programs and policies that account for these
needs. As a continuation of prior U.S. Department of
Justice Office of the Inspector General (OIG) reviews
examining BOP’s management of certain subpopulations
of inmates, including aging inmates and inmates with
mental illness in restrictive housing, OIG initiated this
review of BOP’s management of female inmates,
specifically BOP’s efforts and capacity to ensure that
BOP-wide policies, programs, and decisions adequately
address the distinctive needs of women. Our decision
to initiate this review was also informed by members of
Congress and public interest groups recently raising
concerns about what they consider to be deficiencies in
BOP’s current management of female inmates.

Further, while BOP established a Central Office branch
that serves as BOP’s source of expertise on the
management of female inmates in BOP custody, this
branch may not have adequate staffing to fully fulfill its
mission. Female inmates are just one of six special
populations about which the Women and Special
Populations Branch is responsible for providing national
direction and subject matter expertise and for ensuring
that the needs of each of these populations are met at
BOP institutions. For example, this branch designs and
delivers training to institution staff and ensures that
programming run by other BOP divisions is responsive
to the needs of each subpopulation. Given the branch’s
wide range of responsibilities, its four staff members
may not be sufficient to accomplish its mission and to
ensure that BOP adequately addresses the distinctive
needs of women in its custody.
Additionally, BOP requires all staff in its female institutions
to take training on the management of female inmates, as
well as training in trauma-informed correctional care for the
management of inmates who have experienced trauma.
However, BOP does not require the same training for its
Executive Staff and, as a result, National Executive Staff
officials may develop policy and make decisions that affect
female inmates without awareness of their needs.

Results in Brief
We concluded that BOP has not been strategic in its
management of female inmates. We determined that
BOP needs to take additional steps at the Central Office
level to ensure that female inmate needs are met at the
institution level. Our review identified instances in
which BOP’s programming and policy has not fully
considered the needs of female inmates, which has
made it difficult for inmates to access certain key
programs and supplies. Further, while BOP is adhering
to federal regulations and BOP policies requiring that
only female Correctional Officers conduct strip searches
of female inmates, BOP’s method for ensuring
compliance with these requirements assigns staff
inefficiently. Finally, we found that BOP’s conversion of
Federal Correctional Institution (FCI) Danbury to house
male inmates negatively affected certain female
inmates who had been housed there.

BOP’s Programming and Policy May Not Fully Consider
the Needs of Female Inmates
We identified three areas in which BOP’s programming
and policy decisions did not fully consider the needs of
female inmates: trauma treatment programming,
pregnancy programming, and feminine hygiene.
BOP relies on research that shows that physical and
emotional trauma affects as many as 90 percent of the
female inmate population. Research also recommends
that female inmates undergo trauma treatment early
during incarceration to enhance their ability to benefit
from all institutional programming. However, we found
that BOP may not be able to provide its trauma
treatment program to all eligible female inmates until
late in their incarceration, or ever, because it has
assigned only one staff member at each institution to
offer this program. The lack of sufficient staff is most
noticeable at larger female institutions, where inmates
face delays in completing each of the program’s two
prerequisites, as well as the program’s treatment
phases.

BOP’s Approach to Managing Female Inmates Has Not
Been Strategic, Resulting in Weaknesses in Its Ability to
Meet Their Specific Needs
We found that during the period of our review BOP
could not ensure that its institutions adhered to policies
pertaining to female inmates because BOP had only
recently taken steps to formalize a process for verifying
compliance. As of April 2018, BOP was drafting
planning documents that it believes will enhance its
ability to perform internal oversight of these policies

In addition to female inmates being unable to use BOP
trauma treatment programs, we estimate that only
37 percent of sentenced pregnant inmates participated

i

Executive Summary
Review of the Federal Bureau of Prisons’ Management of Its Female Inmate
Population

male institution as part of a larger plan to increase bed
space for low security female and male inmates
throughout BOP institutions. Although concerns were
raised that the conversion would cause female inmates
to be incarcerated farther from home, we found that,
while 19 percent of U.S. citizen inmates were
transferred farther from their homes, the overwhelming
majority were transferred closer to their homes.

in BOP’s pregnancy programs between fiscal year (FY)
2012 and FY 2016. Further, we confirmed that these
programs had additional capacity to include more
pregnant inmates during this period. We believe that
participation is low because BOP inmates and staff lack
awareness of these programs. We also determined that
BOP staff may apply eligibility criteria more restrictively
than intended by BOP headquarters officials and that
BOP lacks data to assess inmate interest and
participation in its pregnancy programs.

The conversion resulted in 366 low security sentenced
female inmates serving a portion of their sentences in
Metropolitan Detention Center (MDC) Brooklyn, a
detention center intended for short-term confinement.
The National Association of Women Judges found that
the conditions of confinement at MDC Brooklyn
amounted to a violation of the American Bar Association
Standards on Treatment of Prisoners, as well as the
United Nations Standard Minimum Rules for the
Treatment of Prisoners. When we visited MDC
Brooklyn, we found that BOP offered female inmates no
access to outdoor space, less natural light, and fewer
programming opportunities than what would otherwise
be available to female inmates at BOP facilities designed
to house sentenced inmates in long-term confinement.
In addition, a separate OIG criminal investigation
determined that, during the time that sentenced female
inmates were assigned to MDC Brooklyn, multiple
custody staff sexually assaulted female inmates,
resulting in the convictions of two Lieutenants and a
Correctional Officer.

In visits to several BOP institutions housing female
inmates, we found that the distribution methods for
feminine hygiene products provided to inmates varied
by institution and did not always ensure that inmates
had access to a sufficient quantity of products to meet
their needs. BOP issued new guidance in August 2017
to standardize the range of products available free of
charge. However, BOP still lacks a method to ensure
sufficient access because the guidance did not address
how products should be distributed to inmates.
BOP’s Lack of Gender-specific Posts Results in
Inefficiencies at Female Institutions
We found that BOP’s practice of assigning Correctional
Officers to posts solely by seniority has resulted in male
Correctional Officers being assigned to posts at which
staff must regularly conduct searches of female
inmates. Because the Prison Rape Elimination Act of
2003 and BOP policy prohibit cross-gender searches of
female inmates, female Correctional Officers must leave
other assigned posts to conduct these searches, leading
to an inefficient use of Correctional Officer resources.
Both female and male institution staff suggested that a
small number of posts in female institutions, particularly
some of the posts in the Special Housing Unit (SHU)—a
unit used to separate inmates from the general
population for protective or disciplinary purposes—and
the visiting room, be reserved for female staff to ensure
that they can conduct inmate searches without
disrupting other operations. We agree that BOP should
implement this or another approach to ensure the
availability of female staff at locations in female
institutions where inmate searches are common.

In December 2016, after reversing its decision not to
house female inmates at FCI Danbury, BOP opened a
new low security institution for female inmates at
FCI Danbury. However, because FCI Danbury was
constructed without a SHU, we found that managing
female inmates who needed to be placed in a SHU
disrupted institution operations because BOP had to
transfer these inmates to Federal Detention Center
Philadelphia for SHU placement.

Recommendations
In this report, we make 10 recommendations to
improve BOP’s management of its female inmate
population. These recommendations include training
executive leaders on issues important to managing
female inmates, enhancing the capacity of BOP’s
trauma treatment program, communicating information
about pregnancy programs, and clarifying guidance on
the distribution of feminine hygiene products.

BOP’s Decision to Convert Federal Correctional
Institution Danbury to a Male Institution Negatively
Affected Female Inmates Transferred to Metropolitan
Detention Center Brooklyn
As a case study, we also examined BOP’s 2013 decision
to convert FCI Danbury from a female institution to a

ii

TABLE OF CONTENTS
INTRODUCTION ............................................................................................ 1
Background ........................................................................................ 1
RESULTS OF THE REVIEW ............................................................................ 11
BOP’s Approach to Managing Female Inmates Has Not Been Strategic,
Resulting in Weaknesses in Its Ability to Meet Their Specific Needs ........... 11
BOP’s Programming and Policy May Not Fully Consider the Needs of
Female Inmates ................................................................................ 18
BOP’s Lack of Gender-specific Posts Results in Inefficiencies at Female
Institutions ....................................................................................... 32
BOP’s Decision to Convert Federal Correctional Institution Danbury to a
Male Institution Negatively Affected Female Inmates Transferred to
Metropolitan Detention Center Brooklyn ................................................ 35
CONCLUSION AND RECOMMENDATIONS ........................................................ 43
Conclusion ........................................................................................ 43
Recommendations ............................................................................. 43
APPENDIX 1: METHODOLOGY OF THE OIG REVIEW ........................................ 45
Standards ......................................................................................... 45
Purpose and Scope ............................................................................ 45
Methodology ..................................................................................... 45
APPENDIX 2: MAP OF BOP INSTITUTIONS FOR SENTENCED FEMALE INMATES ... 48
APPENDIX 3: BOP’S RESPONSE TO THE DRAFT REPORT .................................. 49
APPENDIX 4: OIG ANALYSIS OF BOP’S RESPONSE.......................................... 52

iii

INTRODUCTION
Background
According to the U.S. Department of Justice’s (Department, DOJ) Bureau of
Justice Statistics, state and federal prisons had jurisdiction over more than
1.5 million inmates at the end of 2015. Of these inmates, approximately 111,500,
or 7 percent, were female.1 The percentage of female inmates in the Federal
Bureau of Prisons’ (BOP) custody as of September 2016 was also 7 percent
(10,567) of BOP’s total population of 146,084 sentenced inmates.2 While female
inmates compose a small percentage of the nationwide inmate population, BOP
recognized that in some areas female and male inmates have different needs.
Accordingly, BOP developed gender-responsive programs and policies to account for
female inmates’ distinctive needs.
As a continuation of several prior Office of the Inspector General (OIG)
reviews examining BOP’s management of certain subpopulations of inmates,
including aging inmates and inmates with mental illness in restrictive housing, OIG
initiated this review of BOP’s management of female inmates.3 Our decision to
initiate this review was also informed by members of Congress and public interest
groups recently raising concerns about what they considered to be deficiencies in
BOP’s current management of female inmates.4
In this report, we assess BOP’s efforts and capacity to ensure that BOP-wide
policies, programs, and decisions address the unique needs of female inmates.
Specifically, we assess female inmates’ access to BOP’s trauma treatment and
pregnancy programs, which are significant for female inmates and their families
and can play important roles in successful reentry into society. Additionally, we
discuss BOP’s gender-responsive policies and evaluate how they affect the
1

DOJ Bureau of Justice Statistics, Prisoners in 2015 (December 2016).

2 For this review, we examined sentenced inmates incarcerated in BOP-managed institutions
only. We excluded approximately 22,000 male inmates who were incarcerated in contract institutions,
approximately 12,000 female and male inmates who were in halfway houses, and approximately
12,000 female and male pretrial detainees in the custody of the U.S. Marshals Service. BOP does not
incarcerate female inmates in contract institutions.
3 DOJ OIG, The Impact of an Aging Inmate Population on the Federal Bureau of Prisons,
Evaluation and Inspections Report 15-05 (May 2015), and DOJ OIG, Review of the Federal Bureau of
Prisons’ Use of Restrictive Housing for Inmates with Mental Illness, Evaluation and Inspections
Report 17-05 (July 2017).

In July 2017, four U.S. Senators introduced legislation designed to increase familial
visitation and female inmates’ access to feminine hygiene products. See Dignity for Incarcerated
Women Act of 2017, 115th Congress, 1st sess., S. 1524. The Arthur Liman Public Interest Program at
Yale Law School also wrote about the management of female inmates affected by BOP’s decision to
convert Federal Correctional Institution (FCI) Danbury from a female to male institution in Dislocation
and Relocation: Women in the Federal Prison System and Repurposing FCI Danbury for Men
(September 2014). This issue was also discussed in “Female Inmates from Danbury Still in Limbo,
Lacking Key Services,” Slate Magazine, September 3, 2014, and “Female Inmate Transfers to
Resume; Senators Say Relocation Disrupts Women’s Lives, Vow to Fight Bureau of Prisons’ Decisions;
Danbury Federal Correctional Institution,” Hartford Courant, October 5, 2013.
4

1

conditions of confinement for female inmates. We pay particular attention to
policies relevant to inmate access to feminine hygiene products and physical
searches of female inmates. Lastly, we examine as a case study how BOP’s
decision to convert its low security institution in Danbury, Connecticut, from a
female institution to a male institution affected female inmates.
Characteristics of BOP’s Female Inmate Population
As shown in Table 1, the overall population of sentenced female inmates
decreased between fiscal years (FY) 2012 and 2016. The ratio of female inmates to
male inmates has remained constant during this period and is approximately equal
to the nationwide ratio, as mentioned previously.
Table 1
Female and Male Sentenced Inmate Population
FYs 2012–2016
Fiscal Year

Female
Inmates

Male
Inmates

Number of
Inmates
Percentage of
BOP Population
Number of
Inmates
Percentage of
BOP Population

Total BOP Population

2012

2013

2014

2015

2016

11,737

12,154

11,868

11,214

10,567

7%

7%

7%

7%

7%

152,803

152,676

149,663

143,655

135,517

93%

93%

93%

93%

93%

164,540

164,830

161,531

154,869

146,084

Source: BOP SENTRY

BOP data shows that between FYs 2012 and 2016 the majority of both female
and male inmates were incarcerated for drug offenses; but male inmates were much
more likely to have been convicted of weapons, sex, or other violent crime offenses
than were female inmates. Further, research shows that female inmates
incarcerated for drug crimes were often accessories to the broader criminal activity of
a male partner, rather than being the instigator of a crime.5 Female inmates also
tend to have shorter sentences than male inmates. For example, as of September

Darrell Steffensmeier and Emilie Allan, “GENDER AND CRIME: Toward a Gendered Theory
of Female Offending,” Annual Review of Sociology 22 (1996): 459–487. BOP cited this particular
point as part of its own research, which found that gender is a powerful predictor of risk for serious
violence and other serious misconduct while incarcerated. Miles D. Harer and Neal P. Langan, “Gender
Differences in Predictors of Violence: Assessing the Predictive Validity of a Risk Classification System,”
Crime and Delinquency 47 (2001): 513–536. Because of this internal BOP research, BOP determines
security levels for female and male inmates separately and, as a result, classifies nearly all female
inmates as minimum or low security.
5

2

2016, the median total sentence length for female inmates in BOP custody was
5 years, whereas the median total sentence length for male inmates was 10 years.
BOP has four security classification levels for inmates: high, medium, low,
and minimum. Nearly all sentenced female inmates are classified as low or
minimum security. BOP does not classify female inmates as medium security but
does classify a small number as high security.6 BOP institutions are also assigned
security levels, and BOP generally assigns inmates to institutions that correspond
with their security level.7
Twenty-nine BOP locations throughout the United States house one or more
female institutions.8 BOP manages female inmates in 20 institutions designed for
the long-term incarceration of sentenced inmates.9 We describe these below:


Minimum security institutions, also known as Federal Prison Camps (FPC),
have dormitory-style housing and limited or no perimeter fencing. As of
December 2017, BOP managed 13 of these institutions for female inmates.



Low security institutions, also known as Federal Correctional Institutions
(FCI) or Federal Satellite Lows, have perimeter fencing and either dormitorystyle or cell-style housing. As of December 2017, BOP managed six of these
institutions for female inmates.



Federal Medical Centers (FMC) are used to treat sentenced inmates of all security
levels who have serious or chronic medical problems. As of December 2017,
BOP managed one medical center, FMC Carswell, for female inmates. This
institution also housed the small number of BOP’s high security female inmates.

In addition to these 20 institutions, BOP houses female inmates in 12 detention
centers, which generally are designed for the short-term incarceration of pretrial

Two officials in BOP’s Designation and Sentence Computation Center, the BOP office
responsible for determining where inmates should be housed, told us that nearly all female inmates
can be managed in minimum security or low security settings because they are less prone to
behaviors such as violence and escape attempts. The small number of female inmates who cannot be
managed in these settings are designated as high security and housed in BOP’s sole high security
female unit at FMC Carswell.
6

7 Throughout this report, we will use the term “female institutions” to refer to all of BOP’s
institutions designed to house sentenced female inmates, regardless of security level.
8 During our fieldwork, BOP housed female inmates in 28 locations throughout the United
States. BOP added a 29th location in late 2017 by converting a minimum security institution in Pekin,
Illinois, which had formerly housed male inmates, into a female institution. Because Pekin did not
house female inmates during the time we conducted the analyses used in our report, these analyses
do not include data or information from Pekin.

Eight of these female institutions are a part of larger facilities that also contain at least one
other female institution. Such facilities include a low security institution and a minimum security
institution in Aliceville, Alabama; a low security institution and a minimum security institution in
Dublin, California; a low security institution and a minimum security institution in Danbury,
Connecticut; and a minimum security institution and a female inmate medical facility in Fort Worth,
Texas. As a result, BOP’s 20 female institutions are in 16 locations throughout the country.
9

3

detainees, as well as a transfer center that houses inmates in transit to other BOP
facilities. Unlike institutions designed for long-term incarceration, detention centers
and the transfer center house both female and male inmates.
Figure 1 shows the number of sentenced female inmates assigned to each of
the three types of institutions described above. A map showing the locations of BOP’s
female institutions designed for long-term incarceration can be found in Appendix 2.
Figure 1
Number of Sentenced Female Inmates, by Institution Type
September 2016

Medical Center,
1,082 Female
Inmates (10%)

Low Security,
4,584 Female Inmates
(44%)

Detention Centers and
Transfer Center,
538 Female Inmates
(5%)

Minimum Security,
4,363 Female Inmates
(41%)

Source: BOP SENTRY

BOP Policy on the Management of Female Inmates
In August 1997, BOP developed a formal policy, known as a program
statement, on the Management of Female Offenders. While this program statement
recognized that BOP programs and services should meet the different physical,
social, and psychological needs of female offenders, the Women and Special
Populations Branch Administrator told us that this policy was not substantive and was
difficult to enforce. In an effort to strengthen existing policy, BOP issued a new
4

Female Offender Manual in November 2016.10 The new manual expanded on the
prior policy by incorporating gender-responsive language on how BOP should classify
and designate female inmates; discipline female inmates; provide gender-responsive
programming; and address birth control, pregnancy, child placement, and abortion.
The Female Offender Manual also identifies the Women and Special
Populations Branch, within BOP’s Reentry Services Division, as BOP’s source of
expertise on classification, management, and intervention programs and practices
for females in BOP custody.11 Further, the Female Offender Manual delegates a
wide range of responsibilities to the Women and Special Populations Branch. For
female inmates specifically, these responsibilities include advising BOP management
and institution staff on issues affecting female inmates, developing staff training on
these issues, and ensuring that programs managed by other BOP branches are
gender responsive.12 As of November 2017, the Women and Special Populations
Branch comprised one Branch Administrator and three staff members.13
Gender-responsive Approaches to Corrections
The BOP defines gender-responsive approaches to corrections as those that
are based on an understanding of the ways female inmates are different from male
inmates and that specifically aim to address those differences. In particular, BOP
has established gender-specific policies pertaining to access to female and
reproductive health services, to the provision of feminine hygiene products, and to
the implementation of regulatory requirements that ensure female inmates are
physically searched only by female BOP employees.14

10

BOP Program Statement 5200.02, Female Offender Manual, November 23, 2016.

11 BOP’s Reentry Services Division aims to prepare inmates for reentry by focusing on
programming and community transition. The Reentry Services Division is composed of six branches:
(1) National Reentry Affairs, (2) Education Services, (3) Chaplaincy Services, (4) Residential Reentry
Management, (5) Women and Special Populations, and (6) Psychology Services.
12 BOP also delegates to the Women and Special Populations Branch the responsibility of
ensuring that BOP policy and practices are inclusive of the needs of other special populations. BOP
identifies special populations to include female inmates, juvenile inmates, transgender inmates,
inmates with disabilities, inmates who are parents, and inmates who are veterans. The Women and
Special Populations Branch Administrator told us that she considers “special populations” to be any
group of inmates that is not part of the male majority.
13 In response to a working draft of this report, BOP stated that all four staff in the Women and
Special Populations Branch, including the Branch Administrator, focus on program or training work.
14 Federal regulations and BOP policies mandate that strip searches be conducted by a staff
member who is the same gender as the inmate being searched. See 28 C.F.R. § 552.11(c) and BOP
Program Statement 5521.06, Searches of Housing Units, Inmates, and Inmate Work Areas, June 4,
2015, 4. See also 28 C.F.R. § 115.15(a). Additionally, federal regulations and BOP policies mandate
that only female staff can pat search female inmates. See 28 C.F.R. § 115.15(b); BOP Program
Statement 5521.06, 3; and BOP Program Statement 5324.12, Sexually Abusive Behavior Prevention
and Intervention Program, June 4, 2015, 17.

5

Trauma-informed Correctional Care
An important but less obvious difference between female and male inmates
has to do with past traumatic experiences. While many studies support the
conclusion that female inmates experience very high rates of trauma before
incarceration, BOP used one particular study as a basis for emphasizing the need to
account for past trauma in its management of female inmates. This study found that
as many as 90 percent of women in prison have experienced trauma and that the
most common type of traumatic experience for female inmates is repeated sexual
violence, followed by intimate partner violence.15 Male inmates are less likely to
have been a direct victim of violence, but they more commonly have experienced or
witnessed a singular traumatic event such as a shooting.16
Research also shows that the effects of trauma manifest themselves
differently for female and male inmates. For example, female inmates who
experience trauma can develop chronic depression, eating disorders, or difficulty
managing emotions, while trauma in male inmates is more likely to manifest itself
externally, resulting in emotional outbursts or violence.17 Although female inmates
are more likely to internalize their trauma, a Resolve Coordinator we interviewed
told us that female inmates are generally more willing to discuss their trauma than
are male inmates.
To address the effects of past trauma on inmates, BOP implemented a
“trauma-informed correctional care approach.” The BOP Psychology Services
Branch describes trauma-informed care as a comprehensive approach to
corrections in which all policies recognize, and actions of staff reflect, the concept
that trauma is a “real and prevalent occurrence, and that any opportunity to avoid
re-traumatizing an inmate is an opportunity for healing.” The Psychology Services
Branch stated that there is not a strict method for applying trauma-informed
correctional care approaches, but it identifies important principles for traumainformed staff to consider. These principles include:


ensuring physical, psychological, and emotional safety for inmates and staff;



ensuring that, when practicable, staff interventions highlight strengths that
can be used as a foundation for improvement, as opposed to focusing only on
problems;



ensuring that information and training about trauma are available to inmates
and staff; and

Niki A. Miller and Lisa M. Najavits, “Creating Trauma Informed Correctional Care: A
Balance of Goals and Environment,” European Journal of Psychotraumatology (2012): 2. BOP asserts
that the 90 percent statistic is likely a low estimate because traumatic experiences are often
underreported by victims.
15

16

Miller and Najavits, “Creating Trauma Informed Correctional Care,” 4.

17

Miller and Najavits, “Creating Trauma Informed Correctional Care,” 3.

6



using communication methods that deescalate conflict and avoid triggering
memories of past traumatic experience. (See the text box.)

Gender-responsive Programs
Potential Effects of Past Trauma on
Female Inmates

Below, we highlight three genderresponsive programs because of their
importance to female inmates and their
families. These programs are
administered by branches within the
Reentry Services Division.

Awareness of how female inmates
are affected by trauma is important in all
aspects of BOP operations. For example,
an inmate having her teeth cleaned is
lying on her back, with someone leaning
over her and something in her mouth
that she cannot remove. These
sensations can trigger flashbacks for
victims of sexual abuse. It is therefore
important for all BOP staff who work with
female inmates to be aware of the
potential for such reactions and how to
respond to them.

Resolve Program

The Resolve program, managed by
BOP’s Psychology Services Branch and
offered at 14 of BOP’s 15 female
institutions, is a national treatment
program for female inmates with a history
Source: Interview with DOJ Civil Rights
of trauma-related mental illnesses.18
Division official
According to the Psychology Services
Branch, the objective of the Resolve
program is to promote positive behavioral changes that decrease the incidence of
trauma-related psychological disorders and improve inmates’ level of functioning.19
Psychology Services staff emphasized the importance of this program because of
the high number of female inmates with a history of trauma or victimization prior to
incarceration. All inmates undergo an intake interview with a Psychologist at the
beginning of their BOP incarceration.20 If a female inmate describes a history of
trauma during this intake interview, the Psychologist will recommend that she sign
up for the Resolve program’s introductory workshop. Participation in the Resolve
program is voluntary.
All elements of the Resolve program, outlined in Table 2 below, are managed
by a Resolve Coordinator, who is a Psychologist. One Resolve Coordinator is
assigned to each of the 14 female institutions that offer the program.21 According
to BOP’s program statement on Psychology Treatment Programs, inmates with a
history of trauma or victimization initiate the Resolve program by taking the
18 FCI Phoenix did not offer the Resolve program during the scope of our review because it
had not been allocated a Resolve Coordinator position. Resolve is not offered at the 12 detention
centers or the Federal Transfer Center because those institutions are exempt from most BOP
programming requirements. As of September 2016, only 5 percent of the sentenced female inmate
population was in a detention center or the Federal Transfer Center.

BOP employs psychology, psychiatry, and mental health staff to offer services, beyond the
scope of the Resolve program, to inmates who require mental health treatment.
19

20

In this report, we use the term Psychologist to refer to a doctoral-level Psychologist.

BOP operates multiple female institutions at 4 of the 14 locations where it offers the
Resolve program to female inmates. BOP also offers the Resolve program, with a modified malespecific curriculum, to male inmates at two institutions.
21

7

introductory workshop during the first 12 months of incarceration. BOP policy
states that the Resolve program takes approximately 40 weeks to complete, but it
also notes that scheduling conflicts may extend the length of the program.
Table 2
Structure of the Resolve Program for Female Inmates
Segment of Program

Name

Description

Prerequisites
Introductory
Workshop

Trauma in Life

Educational workshop that provides female
inmates with psychological information on
trauma and its potential impact in their lives

Screening

Psychological Testing

Psychological eligibility assessment to
diagnose the related traumaa

Seeking Safety

Therapy group that emphasizes the
acquisition of basic skills, with a focus on
coping and interpersonal skills

Cognitive Processing
Therapy

Therapy group for inmates with a diagnosis
of post-traumatic stress disorder, major
depression, or substance abuse

Dialectical Behavioral
Therapy

Therapy group for treatment of inmates
with borderline personality disorder

Maintenance Group

Skills group for maintaining treatment gains
for inmates whose symptoms, if present, no
longer interfere with daily functioning

Active Treatmentb
Phase I

Phase II

Post Treatment
Maintenance

In response to a working draft of this report, BOP stated that it completes psychological
eligibility assessments to provide diagnostic clarity and accuracy prior to a formal diagnosis.
a

In response to a working draft of this report, BOP stated that the group sessions used during
the Active Treatment phases of the Resolve program are psychotherapy groups.
b

Note: The Psychologist who performs the screening determines which version of the Phase II
therapy is most appropriate for each inmate, depending on her specific diagnosis.
Source: BOP

Female Integrated Treatment Program
In the fall of 2017, the Psychology Services Branch, in coordination with the
Women and Special Populations Branch, piloted the Female Integrated Treatment
(FIT) program at BOP’s low security female institution in Danbury, Connecticut.22
According to BOP, the FIT program offers evidence-based treatment for trauma,
substance abuse, and mental health in a comprehensive, holistic program. The
program begins with a 4-month educational curriculum that includes a Trauma in
Life workshop as well as basic drug and mental health education. After completing
The FIT program is available only for inmates in Danbury’s low security female institution.
Inmates in Danbury’s minimum security female institution take the Resolve program instead.
22

8

the introductory portion of the program, each inmate participates in a treatment
curriculum tailored to her individual trauma, substance abuse, or mental health
needs. Inmates in FIT requiring trauma treatment take the Resolve curriculum
described in Table 2 above. All female inmates designated to the low security
female institution in Danbury participate in the FIT program.23
Mothers and Infants Nurturing Together Program
The Mothers and Infants Nurturing Together (MINT) program, managed by
BOP’s Residential Reentry Management Branch, is a community-based residential
program in which pregnant inmates prepare for delivery and bond with their infant
after giving birth.24 According to BOP’s Female Offender Manual, pregnant inmates in
BOP custody are eligible to serve a portion of their sentence at a MINT program site if
they are pregnant upon incarceration with an expected delivery date prior to release,
have less than 5 years remaining on their sentence, are eligible for halfway house
placement, and assume financial responsibility for their child’s care.25 Female inmates
are generally eligible to transfer to a MINT program site during the last 2 months of
pregnancy. After birth, the Female Offender Manual requires BOP to allow
participating inmates at least 3 additional months to bond with their infant, although
the manual recommends 6 months. Once an inmate completes the MINT program,
BOP returns the inmate to a BOP institution for the remainder of her sentence.
Residential Parenting Program
According to the Female Offender Manual, BOP’s female inmates, no matter
their location, may also participate in the Washington State Department of
Corrections’ Residential Parenting Program. In contrast to the MINT program,
Residential Parenting Program participants and their infants reside in the minimum
security unit of the Washington Corrections Center for Women in Gig Harbor,
Washington, for up to 30 months after birth.26 Female inmates who participate in
In response to a working draft of this report, the Administrator of the Women and Special
Populations Branch elaborated on the terminology of this model, stating that “the entire facility
operates as a ‘modified therapeutic community.’”
23

24 During the scope of this review (FYs 2012–2016), MINT program sites were located in San
Francisco, California; Tallahassee, Florida; Phoenix, Arizona; Fort Worth, Texas; Springfield, Illinois;
Hartford, Connecticut; and Hillsboro, West Virginia. As of December 2017, the sites in San Francisco
and Hartford no longer accepted MINT inmates because they were unable to comply with some of the
contract requirements for hosting the MINT program.
25 The Female Offender Manual further states that inmates with more than 5 years remaining
on their sentences, or who become pregnant while on furlough, or who plan to place their infants up
for adoption are not eligible for the MINT program.

BOP provides prenatal care and covers the financial costs associated with delivery for all
pregnant inmates, regardless of whether they participate in this program.
26 The eligibility requirements for the Residential Parenting Program are established by the
Washington State Department of Corrections and are stricter than those for BOP’s MINT program. For
example, only minimum security inmates are eligible to participate in the Residential Parenting
Program, whereas both minimum and low security inmates are eligible to participate in the MINT
program. We discuss the eligibility requirements for the Residential Parenting Program in greater
detail in a text box later in this report.

9

this program receive credit toward their federal sentence for any time served at the
Gig Harbor facility. BOP Social Workers are responsible for providing pregnant
inmates with information about the two pregnancy programs.
Scope of the OIG Review
BOP has implemented gender-responsive policies and programs that affect
the conditions of confinement for female inmates. OIG initiated this review to
examine BOP’s management of its female inmate population between FYs 2012 and
2016. We focused our analysis on how the Women and Special Populations Branch
and other relevant BOP branches implement gender-responsive trauma-treatment
and pregnancy programs. Additionally, we examined how BOP has implemented
policies relevant to inmate access to feminine hygiene products and physical
searches of female inmates. We also examined how BOP’s decision to convert its
low security institution in Danbury, Connecticut, from a female institution to a male
institution affected female inmates transferred from Danbury. We held in-person,
telephone, and video teleconference interviews with BOP officials responsible for or
involved in the management of federal female inmates, as well as with state
correctional officials to learn how non-federal correctional agencies manage their
female inmates.

10

RESULTS OF THE REVIEW
BOP’s Approach to Managing Female Inmates Has Not Been Strategic,
Resulting in Weaknesses in Its Ability to Meet Their Specific Needs
We found that over time BOP has made efforts to improve its management of
female inmates. However, we identified several additional steps BOP should take to
ensure female inmate needs are addressed appropriately. First, BOP has only
recently taken steps to formalize a process for verifying staff compliance with
policies related to the management of female inmates. Second, we found that
while BOP established a Central Office branch with responsibilities that include
providing national direction and subject matter expertise on the treatment,
management, and programming of female inmates, the branch may not have
adequate staffing to fulfill its mission. Finally, while BOP requires all personnel
working in female institutions to take training on current best practices in the
management of female inmates, it does not require its National Executive Staff to
take any training related to female inmates. As a result, National Executive Staff
may develop policy or make decisions without awareness of female inmates’ needs.
As we will discuss later in this report, we also identified similar limitations in certain
BOP programs and policies of significance to female inmates. For BOP to be fully
effective at appropriately managing female inmates, we believe that it must take a
holistic approach at the Central Office level to identify and address issues affecting
this population.
BOP Has Not Fully Implemented Internal Controls to Ensure Institutions Follow
Policies Related to the Management of Female Inmates
The Female Offender Manual is BOP’s primary policy on the management of
female inmates. The Assistant Director of the Reentry Services Division told us that
it is important for institutions housing female inmates to be in compliance with the
Female Offender Manual.27 While BOP has recently taken its first initial steps to
verify compliance with the manual, it has not yet fully implemented these efforts.
Specifically, BOP is still in the interim stage of establishing a program review to
evaluate the implementation of its Female Offender Manual.28
In 1997, BOP created its first policy on the management of female inmates.29
This four-page policy only briefly described BOP’s role in identifying the appropriate
programs and services to meet the different physical, social, and psychological
needs of female inmates; but it never explained what those needs were and it
27 Subsequent to our interview, the Assistant Director of the Reentry Services Division was
named the Acting BOP Director.
28 BOP develops program reviews to assess an institution’s internal controls, programs, and
operations in a topic area. Most program reviews summarize the overall findings with a rating of
Superior, Good, Acceptable, Deficient, or At Risk.
29

BOP Program Statement 5200.01, Management of Female Offenders, August 4, 1997.

11

lacked specific guidance that would help institutions identify and address those
needs. Further, BOP did not conduct program reviews to verify compliance with
this policy.
To address the deficiencies in its initial policy concerning female inmates,
BOP issued its Female Offender Manual in November 2016.30 This manual is much
more comprehensive than the 1997 policy in the topics covered, and it offers more
guidance about how BOP should handle a range of policy and management issues
pertaining to female inmates. For example, it describes how BOP should classify
and designate female inmates; discipline female inmates; provide genderresponsive programming; and address birth control, pregnancy, child placement,
and abortion.31 While the new manual is more comprehensive, we found that BOP
has not yet finalized a mechanism to ensure that institutions housing female
inmates comply with it.
During interviews, three managers in the Reentry Services Division
emphasized the importance of establishing a program review to ensure institutions
are managing female inmates consistently with the Female Offender Manual. For
example, the Senior Deputy Assistant Director of the division described the
establishment of a program review as critical for ensuring that BOP’s female
institutions are held accountable for how they manage female inmates. He and the
Women and Special Populations Branch Administrator described the program review
as the most important factor in ensuring compliance with the Female Offender
Manual and said that the absence of a program review has weakened the branch’s
ability to ensure that institutions are implementing BOP’s primary policy on the
management of female inmates.
Program reviews are also important because BOP policy requires reviewed
institutions to implement corrective action plans, monitored by the BOP Central
Office, to correct any deficiencies identified during the course of the review. In
response to a working draft of this report, the Senior Deputy Assistant Director of
the Program Review Division described these follow-up requirements as critical
aspects of all program reviews to ensure accountability.
We found that BOP had not begun to implement any review mechanism to
evaluate institutions’ compliance with the Female Offender Manual until November
2017, a year after its release, and, as of June 2018, BOP has not fully implemented
these efforts.32 According to a Senior Deputy Assistant Director of BOP’s Program

30

BOP Program Statement 5200.02, Female Offender Manual, November 23, 2016.

31

BOP Program Statement 5200.02.

In response to a working draft of this report, BOP stated that it began the process to
establish this review mechanism in March 2017 by scheduling a management assessment, which
initiates BOP’s formal process for designing program reviews. BOP further stated that the management
assessment was scheduled within the timeframe required by policy based on the release date of the
Female Offender Manual.
32

12

Review Division, BOP created an interim program review in November 2017 with
the intention of establishing a permanent program review in the near future.33
We reviewed BOP’s interim program review plan and found that BOP
conducted it entirely remotely, rather than on site at the institutions. We also
learned that under the interim plan BOP did not intend to issue an institution a
formal compliance rating at the close of the review. After BOP conducted its first
remote program review, a Senior Deputy Assistant Director of BOP’s Program
Review Division told us that BOP intended to change its program review
methodology to conduct future program reviews on site and provide the institution
a rating on compliance with the Female Offender Manual.
We are encouraged that BOP plans to implement a rated, on-site program
review. Although the Program Review Division’s Assistant Director and Senior
Deputy Assistant Director told us that on-site reviews may stretch limited
resources, an on-site program review would allow BOP to assess compliance with
the Female Offender Manual in part through direct observation, which BOP’s
Management Control and Program Review Manual describes as “the most
dependable type of evidence, and…essential in determining the adequacy of internal
controls.”34 Additionally, we believe that some of the criteria in BOP’s interim
program review guidelines and other guidance are particularly suited to direct
observation.35 For example, the interim program review guidelines for the Female
Offender Manual require Program Review Division staff to assess whether
institutions offer gender-responsive programs to inmates and whether institutions
widely advertise those programs “in visible areas in the institution,” such as bulletin
boards, electronic message boards, and resource centers to assist in raising inmate
awareness of the availability of those programs. In addition, BOP’s August 2017
guidance on the accessibility and availability of feminine hygiene products, which
we discuss in more detail later in our report, also lends itself to direct observation.
We believe that a physical visit to the institution being reviewed would allow the
Program Review Division staff to confirm that institutions are complying with BOP
We focus on November 2017 in this report because that was the date that BOP’s Central Office
notified the Wardens of the female institutions that a program review to evaluate institutions’
compliance with the Female Offender Manual had been designed, and that the reviews would begin.
The Program Review Division conducted its first program review of the Female Offender
Manual in December 2017, using the interim program review plan, and provided results to the
reviewed institution in January 2018.
33

BOP Program Statement 1210.23, Management Control and Program Review Manual,
August 21, 2002, Chapter 2, p. 8. This policy establishes BOP’s standards for conducting program
reviews.
34

35 Officials in the Program Review Division told us that they could not create program review
guidelines for all sections of the Female Offender Manual because some portions were too broadly
written. The Women and Special Populations Branch Administrator said that some sections of the
Female Offender Manual were written this way as a result of negotiations with the union before the
policy was implemented. The Assistant Director of the Program Review Division said that a more
detailed Female Offender Manual would allow for more robust oversight of how female institutions
implement the policy.

13

policy on the management of female inmates and to better identify any deficiencies
that should be monitored through a corrective action plan.
BOP’s Management Control and Program Review Manual generally requires
that program reviews provide a rating that summarizes the review’s findings and
reflects the reviewer’s overall judgment as to how well the institution accomplishes
the program area’s mission and objectives. Currently, all program reviews are
rated except for the Prison Rape Elimination Act of 2003 (PREA) program review.36
The Senior Deputy Assistant Director for the Reentry Services Division said that it is
important for the Female Offender Manual program review to be rated to ensure
that the female institutions take the findings from the review seriously.
We agree that ratings would promote accountability, and we believe that
ratings for the Female Offender Manual will make it easier for the Program Review
Division to identify trends in an institution’s results, potentially allowing BOP to
identify deficiencies and systemic issues across BOP institutions over time.37 The
Senior Deputy Assistant Director for the Reentry Services Division said that it is
important to rate female institutions on their management of female inmates so
that the significance of meeting these standards does not get diluted across
multiple reviews that cover items related to female inmates as well as items related
to all inmates. He also said that a rated program review of the Female Offender
Manual will make it easier for the Reentry Services Division to spot problems
multiple institutions have in managing female inmates and identify areas where
broader action is needed.
At the time of our review, BOP was in the early stages of implementing a
system of formal oversight and enforcement for the Female Offender Manual. This
accountability mechanism will provide BOP with a key tool for determining whether
institutions are complying with policy governing the management of female
inmates.
The Women and Special Populations Branch’s Staffing May Not Be Sufficient to Fully
Accomplish its Mission
BOP created the Women and Special Populations Branch in the Reentry
Services Division of BOP’s Central Office to address the needs of special

36 A Senior Deputy Assistant Director of BOP’s Program Review Division said that the PREA
program review does not receive a rating because the goal of the PREA program review is to help
institutions prepare for the formal PREA audits conducted by outside auditors.
37 We asked BOP whether program review ratings were taken into account during Wardens’
annual performance evaluations. BOP’s Management Control and Program Review Manual (Program
Statement 1210.23) states that a program review rating is a measure of a program’s performance,
not directly related to a program manager’s performance. BOP’s Human Resource Management
Division further reported that a program review rating was taken into account only if it directly related
to a specific performance measure described in a Warden’s performance work plan.

14

populations, including female inmates.38 However, we found that the number of
staff members BOP allocated to this branch may not be enough to carry out all of
the responsibilities it has given to the branch. In February 2014, the branch had
only 1 staff position (of the Reentry Services Division’s 247 positions). As of
November 2017, the branch had four full-time employees, making up 2 percent of
the Reentry Services Division’s staffing.39 The four staff members are responsible
for six separate inmate special populations that, when combined, make up a large
share of BOP’s total inmate population.40 While there is bound to be some overlap
in the inmates that are a part of these populations, each population has distinct
needs.
The Women and Special Populations Branch’s responsibilities require it to
coordinate regularly nationwide and across all BOP divisions at the Central Office
and regional levels, at all female institutions, and with external organizations. The
branch is required to perform a broad range of responsibilities for each special
population, potentially independently of one another. For example, the following
duties, among many others, demonstrate the broad scope of duties for this branch:


developing, implementing, and maintaining national programs for female
inmates, inmates with disabilities, children of incarcerated parents, and other
special populations, which require extensive knowledge of mental health,
case management, custody/discipline, vocational/workforce, education, life
skills, release preparation, and community placement;



representing BOP in the day-to-day dealings with outside agencies and with
other BOP branches and institutions regarding female inmates or inmates
from special populations; and



serving as the BOP National Executive Staff’s primary resource concerning
female inmate and special population issues. The Women and Special
Populations Branch also provides information and advice to other Branch
Chiefs and management, including the BOP Director, regarding the needs of
female or special population inmates and programs for these inmates.41

As of April 2018, BOP had identified six special populations. We list these in the
Introduction.
38

The Women and Special Populations Branch Administrator is included in this staffing level.
In response to a working draft of this report, BOP stated that all four staff in the Women and Special
Populations Branch, including the Branch Administrator, focus on program or training work.
39

40 Female inmates account for approximately 7 percent of the inmate population, as we state
in the Introduction. We could not determine the number of inmates with disabilities from the BOP
data we analyzed; but, in response to a working draft of this report, BOP estimated that inmates with
disabilities account for approximately one-third of the inmate population.

The items we highlight here represent just a fraction of the Women and Special Populations
Branch’s responsibilities. The Administrator’s position description includes seven pages of
responsibilities.
41

15

To accomplish these duties, the branch must collaborate with Health Services staff,
Psychology Services staff, Education Services staff, and staff located in any other
area of BOP, as necessary, to address the needs of female inmates. The Senior
Deputy Assistant Director of the Reentry Services Division said that it is challenging
for the branch to ensure institutions are complying with policy when the branch has
only four staff, all of whom are located at Central Office. He noted that BOP might
need to consider a variety of staffing arrangements, including placing staff at
regional offices or individual institutions, as the branch continues to develop
additional policies that each need to be implemented for different special
populations.
The Women and Special Populations Branch Administrator told us that the
branch’s range of responsibilities and current level of staffing left it unable to
provide training on current best practices for managing female inmates. She told
us that she would like the branch to conduct more in-person, interactive trainings
on the management of female inmates for staff at female institutions. In 2017, the
branch conducted one such training at an institution; several Psychologists who
attended told us that it was very useful because it enhanced staff members’
understanding of trauma, how trauma impacts female inmates, and how to more
effectively communicate with female inmates. A Social Worker at another female
institution had not received in-person training but told us that given the mental
health effects of abuse and the high rate of trauma in the female inmate
population, Correctional Officers would benefit from increased training on effectively
managing the needs of inmates with mental illness.42
As we described above, the Women and Special Populations Branch is
responsible for overseeing BOP’s management of multiple special populations,
which includes coordinating across BOP’s many divisions at the Central Office, as
well as with individual institutions. Given these multiple responsibilities, we believe
that BOP should evaluate the breadth of the branch’s mission and ensure that the
branch has sufficient staff to accomplish that mission.
BOP Does Not Require Its National-Level Executives to Take Training on Managing
Female Offenders
We found that while BOP has implemented mandatory training on the
management of female inmates for staff who work in female institutions, BOP has
not required its National Executive Staff to take this or other training pertaining to
female inmates.43 As a result, the officials who make decisions affecting the
OIG’s review of BOP’s management of inmates with mental illness in restrictive housing
recommended additional mental health training for staff monitoring the behavior of inmates in
restrictive housing. DOJ OIG, Review of the Federal Bureau of Prisons’ Use of Restrictive Housing for
Inmates with Mental Illness, Evaluation and Inspections Report 17-05 (July 2017), 66.
42

43 BOP’s National Executive Staff consists of the BOP Director, Deputy Director, 6 Regional
Directors, and 10 Assistant Directors in BOP’s Central Office. The trauma-informed correctional care

(Cont’d)

16

conditions of confinement for female inmates may not be fully aware of the unique
needs of female inmates. According to BOP’s primary training video on the
management of female inmates, these unique needs include the prevalence of
trauma in the female inmate population and how trauma affects female inmates’
behavior; communication strategies that BOP recommends staff use when working
with female inmates to avoid triggering memories of previously experienced
trauma; BOP policies that impact female inmates differently, such as the inmate
search policy; female inmate healthcare needs; relationships, especially
relationships with their minor children; and educational and release needs. We will
discuss actions BOP has taken to address some of these needs in later sections of
this report.
BOP has made training on the management of female inmates mandatory
only for staff who work in female institutions and directly with female inmates.
When staff begin working at a female institution for the first time, they are required
to take two trainings that were prepared by the Women and Special Populations
Branch: a 1.5-hour video on the management of female inmates, accompanied by
discussions moderated by an on-site trainer, and a 24-minute video on traumainformed correctional care.44 Both of these trainings have been updated since 2016
to reflect BOP’s current practices in the management of the female inmate
population. A Correctional Officer who watched the trauma-informed correctional
care video described the training as very powerful and said it made her more
empathetic toward female inmates because it helped her understand how past
traumas influence how female inmates express frustration and react to staff.
However, BOP National Executive Staff exposure to this training is ad hoc.
One National Executive Staff member with decision-making authority over female
inmates said that he had not received training on the management of female
inmates because he had never worked at an institution that housed female
inmates.45 Another member of the BOP National Executive Staff told us that he had
training on the management of female inmates in the 1990s because at that time
he worked at an institution that housed female inmates. The Senior Deputy
Assistant Director of the Reentry Services Division said that he believes it is

training video was incorporated into BOP’s annual refresher training curriculum one time, in FY 2016,
and all staff employed by BOP that year, including National Executive Staff, saw the video. BOP has
an ongoing requirement that all staff assigned to a female institution for the first time take the
trauma-informed correctional care training. However, because BOP does not also require this training
at the time of promotion to BOP’s National Executive Staff, it is possible for an individual to be
promoted to an executive position without ever having taken the training. BOP reported to us that its
National Executive Staff are required only to complete and maintain certification in a series of
standard government manager and supervisory trainings.
44 Three April 2018 program reviews of the Female Offender Manual conducted by BOP found
that three different female institutions were failing to provide all institution staff with these trainings
as required by BOP policy.
45 During the course of this review, we interviewed three members of the BOP National Executive
Staff who oversee aspects of BOP operations directly related to the management of female inmates.

17

important for Regional Directors to take this training because they oversee such
institutions in their respective regions. He further recommended that the BOP
Director take any training associated with a program statement he signs.46
Although the Assistant Director of the Reentry Services Division told us that he
does not believe that requiring National Executive Staff to take training on the
management of female inmates is important, he also acknowledged that, if left to
its own devices, BOP is not gender responsive. We are concerned that, without
such training, members of the National Executive Staff who are in a position to
make decisions that affect the female inmate population may not be fully aware of
female inmates’ unique needs.
Individuals inside and outside BOP described training as an effective method
for helping staff recognize the unique needs of female inmates, as well as an
effective tool to convey support from agency leadership. A DOJ Civil Rights Division
official who works closely with BOP on issues related to female inmates emphasized
the importance of support from top BOP officials in ensuring that the incarceration
of women is gender responsive in all areas. The Women and Special Populations
Branch Administrator added that it is important for BOP leadership to be exposed to
female inmate-specific issues so they understand the importance of those issues
when making decisions. A Deputy Commissioner from the Alabama Department of
Corrections told us that providing multidisciplinary training in gender-responsive
corrections was “probably one of the most impactful” things the Department of
Corrections has done to make its culture more understanding of female inmates.
The Deputy Commissioner said that the training created significant buy-in from
staff across all levels about understanding the unique needs of female inmates and
recognizing the differences between female and male inmates.
Accordingly, we believe that BOP should ensure that all staff, including the
National Executive Staff, who work with or have management decision authority
over female inmates receive the current mandatory training on the unique needs of
female inmates.
BOP’s Programming and Policy May Not Fully Consider the Needs of Female
Inmates
We identified concerns with the way BOP implements two programs for
female inmates, as well as a concern with how BOP’s implementation of its inmate
grooming policy affects female inmates. First, BOP has not staffed its trauma
treatment program for female inmates at a level that ensures that all female
inmates who are eligible for the program can participate in it before they are
released. Second, a lack of staff awareness and a lack of data may limit access to
BOP’s residential programs for pregnant inmates. Third, the distribution methods
for feminine hygiene products did not always ensure that inmates had sufficient
access to the quantity of products they needed.

We note that the six Regional Directors plus the BOP Director account for more than a third
of the BOP officials who make up the National Executive Staff.
46

18

BOP’s Trauma Treatment Program Is Inadequately Staffed Compared to the Level of
Need
Based on research we previously referred to in the Introduction of this
report, BOP’s training materials acknowledge that the prevalence of trauma in the
female inmate population is high—approximately 90 percent. Some of the inmates
we interviewed described a range of traumatic experiences they had faced prior to
incarceration, including homelessness, sexual abuse, and domestic violence. To
treat the psychological and interpersonal difficulties that can result from traumatic
life experiences, BOP offers the Resolve trauma therapy program at 14 of its
15 female institutions. One Resolve Coordinator said that the goal of the program
is to help inmates improve their ability to function on a daily basis through
treatment that reduces psychological symptoms, improves behavior, and decreases
an inmate’s need for medication. A BOP Mental Health Treatment Coordinator told
us that, ideally, an inmate should take the Resolve program during the first
12 months of her sentence because the program can help the inmate adjust to
being in an institution and prepare for other psychological programming, such as
residential drug treatment. BOP Psychologists inform female inmates about the
Resolve program at the start of incarceration and encourage all female inmates with
a history of trauma to sign up for the introductory workshop. Participation in the
Resolve program is voluntary.
Several of the inmates we interviewed who had taken Resolve told us that
the program helped them come to terms with their past and prepare for life after
prison. One inmate praised the Resolve program for helping her recover from
severe domestic violence, saying, “I’m trying to better myself while in prison. I
don’t want to walk in here and walk out the same way.” She also praised the
Resolve Coordinator for helping her understand her marriage and how to heal from
the abuse she suffered.
Although BOP considers Resolve to be an especially important program for
female inmates, we found that due to current staffing BOP may not be able to
ensure that all inmates who are eligible for the program can participate in it before
their release from BOP custody. We learned that, regardless of the size of the
institution’s female inmate population, BOP allocates one position, known as a
Resolve Coordinator, to administer and facilitate the Resolve program, its two
prerequisites, and other tasks that are part of the program.47 As we explain below
in our discussion of the ramifications of BOP’s current staffing model for Resolve,
we estimate that the 40-week Resolve program can accommodate only 336 female
inmates nationwide at a time, and 24 per institution at a time, representing roughly
3 percent of BOP’s sentenced female inmate population.48

During the time of our review, BOP was piloting the Resolve program for male inmates at
two institutions. At all other institutions, the Resolve program was available only to female inmates,
even if the institution as a whole housed both female and male inmates.
47

As of the end of FY 2016, there were 10,567 sentenced female inmates in the BOP’s female
institutions.
48

19

As a result of this limited staffing, inmates at larger institutions are often
delayed from beginning each separate step of the program. This presents a
challenge for BOP because female inmates generally have shorter sentences than
male inmates. We also identified an unfilled need for trauma programming among
non-English speaking inmates because BOP offers Resolve only in English. Finally,
we found that Resolve’s staffing level is significantly lower than several other BOP
psychological treatment programs.
To determine an inmate’s eligibility for the Resolve program, BOP policy
requires that she complete two prerequisites: the Trauma in Life seminar and
psychological screening tests (see Table 2 above). A Resolve Coordinator explained
that the psychological screening tests determine whether an inmate meets certain
traumatic stress criteria and is therefore eligible for the Resolve treatment. Typical
diagnoses indicating eligibility include post-traumatic stress disorder, anxiety, or
depression but may also include conditions such as schizophrenia if the condition is
triggered or worsened by the traumatic experience. We found that inadequate
staffing creates delays for inmates in completing the prerequisites, which may
result in eligible inmates not being able to complete the treatment phases until later
in their sentence, and possibly not at all. BOP cannot easily determine how many
female inmates complete the Resolve program because, while BOP tracks
completion of individual segments of the Resolve program, it does not track
completion of the program as a whole.
For example, the Trauma in Life seminar, the first prerequisite for
determining eligibility in the Resolve program, is an 8-hour course and is typically
taught in four 2-hour sessions over 4 weeks. Trauma in Life is intended to provide
female inmates with information on trauma and its potential impact on their lives,
as well as to identify inmates who need trauma treatment and to motivate them to
participate in the Resolve program. As shown in Table 3 below, we found that
waiting lists for Trauma in Life seminars can be lengthy, particularly in BOP’s seven
large, all-female institutions. We found this troubling because, as of September
2016, 70 percent of BOP’s sentenced female population was in one of the seven allfemale institutions.

20

Table 3
Trauma in Life Waiting Lists at All-female and Mixed-gender
BOP Institutions, August 2017
Type of
Institution
All femaleb
Mixed genderc

Average
Female
Population

Average Number of Female
Inmates on a Trauma in Life
Waiting List

OIG Estimate of Months
Needed to Teach Trauma
in Life to All Inmates on an
Average Waiting Lista

1,103

172

8

318

47

3

BOP institutions told us that Trauma in Life courses can accommodate a maximum of
24 inmates at a time. Therefore, our analysis assumes that each Trauma in Life seminar can
accommodate 24 inmates.
a

The seven all-female institutions were Federal Prison Camp (FPC) Alderson, Federal Correctional
Institution (FCI) Aliceville, FPC Bryan, Federal Medical Center Carswell, FCI Dublin, FCI
Tallahassee, and FCI Waseca.
b

The eight mixed-gender institutions were FPC Coleman, Federal Satellite Low and FPC Danbury,
FPC Greenville, Secure Female Facility Hazelton, FPC Lexington, FPC Marianna, FPC Phoenix, and
FPC Victorville. At these institutions, BOP housed female and male inmates in buildings separated
by fences and enforced strict operational rules to keep female and male inmates apart at all times.

c

Notes: The BOP’s detention centers and Federal Transfer Center Oklahoma City all housed female
inmates, but we excluded them from this analysis because they did not offer the Resolve program.
We used August 2017 population data for this analysis to more accurately reflect the female
population at the time we collected the waiting lists.
Sources: BOP data on Resolve program waiting lists; institution population data on BOP’s website
as of August 30, 2017; and OIG analysis

We found that 6 of BOP’s 15 female institutions had Trauma in Life waiting
lists of 150 inmates or more. We concluded that inmates at the end of a waiting
list of 150 could wait at least 6 months before they could take the first step toward
determining whether they were even eligible for the Resolve program.49 However,
this may understate the amount of time that individual inmates must wait to enroll
in the program because BOP organizes its program waiting lists by release date, not
the date an inmate is added to the waiting list. A Social Worker told us that, as a
result, female inmates with longer sentences may spend years rather than months
on a program waiting list, including the Trauma in Life waiting list.50
After inmates complete Trauma in Life, they must undergo a psychological
assessment to determine whether they have a psychological diagnosis related to a
traumatic life event. Such a diagnosis is a requirement for inmates to begin
Resolve’s treatment phases. Making such a diagnosis requires the Resolve
49 One institution reported to us that its Trauma in Life waiting list was 311 inmates. At this
institution, we estimate the wait for the Trauma in Life course could be as long as a year.
50 BOP policy states that inmates should enroll in the Trauma in Life seminar during the first
12 months of incarceration. An inmate was always placed on the Trauma in Life seminar’s waiting list
based on her release date, even if she did not sign up for the Trauma in Life seminar until after her
first 12 months of incarceration. BOP policy does not establish a timeframe for completing the rest of
the Resolve program.

21

Coordinator to perform a screening assessment that includes several psychological
tests and a review of the inmate’s file. One Resolve Coordinator said that the
process of interviewing an inmate, performing the psychological tests, and
reviewing the inmate’s file takes several hours for each inmate. Another Resolve
Coordinator at a large female institution said that the amount of psychological
testing required for Resolve is a lot of work for a single staff member, especially
given all of a Resolve Coordinator’s responsibilities.
During our fieldwork, 5 of BOP’s female institutions reported that 45 or more
inmates were awaiting a screening assessment to determine whether they were
eligible for Resolve. At 1 of these institutions, 180 inmates, representing
18 percent of the institution’s population, were on the waiting list for screening.51
The second-longest waiting list for screening assessments, 82 inmates, represented
5 percent of that institution’s population.
After inmates complete Trauma in Life and receive a psychological
assessment that results in a diagnosis related to a traumatic event, they are eligible
to begin the Resolve program. However, according to BOP Psychologists, the single
Resolve Coordinator running the program can manage a caseload of only
24 inmates at a time in the treatment phases. The caseload of inmates in the
treatment phases does not include inmates who are taking the Trauma in Life
seminar, are undergoing the psychological screening assessment, or have
completed the treatment phases and are in the maintenance group. With a current
staffing level of one Resolve Coordinator per institution, eligible inmates will not
necessarily begin a Resolve program right after completing the two prerequisites.
Additionally, we found that the existing waiting lists for Resolve programming
may underrepresent the actual level of need because Resolve is offered only in
English and, therefore, waiting lists generally include only inmates who speak fluent
English. BOP Psychologists at multiple institutions expressed concern that BOP is
not able to provide sufficient trauma treatment for non-English speaking female
inmates, specifically Spanish-speaking female inmates. While the fact that Resolve
is taught only in English could be an impediment for any non-English speaking
inmate, institution staff told us that Spanish is by far the most common non-English
language spoken by inmates. A Warden and a Chief Psychologist from two female
institutions told us that their greatest unmet programming need was for Spanish
Resolve. According to the Chief Psychologist, “There’s horrific history, but we just
can’t get to them.”
Psychological staff at multiple female institutions expressed concern that
having only one position dedicated to administering all aspects of Resolve at each
institution, regardless of the size of the institution, was inadequate. We note that
this is particularly problematic for the three female institutions that have both a low
security institution and a minimum security camp because security considerations

BOP’s Chief of Mental Health Services attributed the backlog to the fact that the Resolve
Coordinator position at this institution was vacant, noting that BOP has found it challenging to keep
the Resolve Coordinator position filled at this rural institution.
51

22

require the low and minimum security inmates to be separated. The Resolve
Coordinator from one of these institutions said that if she offered treatment to both
low and minimum security inmates at the same time, she must do so in separate
treatment groups. Another Resolve Coordinator worried that, as a result of low
staffing levels, “you have people going home without the treatment, although we
identified that they needed it.”
The Chief of Mental Health Services described this staffing model as “not
ideal” and noted that it worked better at camps, which typically have populations of
around 300 female inmates, than at larger institutions. She further explained that
BOP had not added staff to the Resolve program as of the time of our review
because it had to balance competing priorities for psychological resources and had
chosen in recent years to prioritize the treatment of serious mental illness.52
Finally, the Chief of Mental Health Services said that, because Resolve is run by a
single coordinator in each institution, any time that position is vacant the program
goes dormant until a replacement is hired. A September 2016 BOP statistical
report summarizing staffing levels and inmate participation in psychology treatment
programs showed that 5 of the 14 Resolve Coordinator positions in female
institutions were vacant at that time. As a result, the Resolve program was not
available to the female inmates at these institutions until the positions were filled.
We found that Resolve’s staffing model allotted fewer staff than several of
BOP’s other psychology treatment programs, including the Residential Drug Abuse
Program (RDAP), the Brave program, and the Challenge program.53 BOP policy
requires the RDAP, Brave, and Challenge programs each to be staffed by a Program
Coordinator and multiple Treatment Specialists, allowing these programs to treat
more inmates concurrently than Resolve can, as shown in Table 4 below, because
each Treatment Specialist maintains a caseload of inmates. Meanwhile, Resolve is
the only psychological treatment program with a capacity not established in policy,
although BOP’s Chief of Mental Health Services told us that the general expectation
is that each Resolve Coordinator will treat 24 inmates at a time. The Chief
Psychologist at a large female institution said that BOP does a great job treating
substance abuse through RDAP because it allocates sufficient resources and staffing
to RDAP; but it does not do the same for trauma treatment through Resolve.

Based on concerns about insufficient mental health staff, OIG’s review of BOP’s
management of inmates with mental illness in restrictive housing recommended that BOP prioritize
and incentivize hiring mental health staff at institutions that have inmates with mental illness in longterm restrictive housing. DOJ OIG, Use of Restrictive Housing, 65.
52

53 The Brave program is an institutional adjustment program for male inmates who are
medium security, age 32 or younger, serving their first BOP sentence, and beginning a sentence of at
least 5 years. The Challenge program is for male inmates who are high security and have either a
history of substance abuse or a severe mental health diagnosis.

BOP’s program statement for Psychology Treatment Programs describes four additional
programs for mental health treatment. We excluded these programs from our analysis because they
are for inmates whose mental health diagnoses require intensive treatment services.

23

Table 4
Psychology Treatment Program Average Participation Levels and
Onboard Staffing Levels, September 2016
Program

Average Inmate
Participants per
Institution at a Time

Average Program Staff
per Institution

Resolve

1

24

RDAP

6

118

Brave

5.5

75

4

65

Challenge

Notes: We excluded three institutions from our analysis of Resolve program
participation because the Resolve Coordinator positions at those institutions were
vacant.
The staffing levels of RDAP, Brave, and Challenge varied slightly, usually ranging
between four and six staff per program location. Additionally, some BOP institutions
operated multiple RDAPs at a single institution.
Source: OIG analysis of BOP data on psychology treatment programs

RDAP, Brave, and Challenge
differ from Resolve also because they
Female Integrated Treatment
are residential programs, meaning that
all inmates in the program also live
BOP has taken a promising first step in its
efforts to enhance the capacity of its trauma
together in a single housing unit
treatment programming at one female institution.
separate from the institution’s general
The Female Integrated Treatment (FIT) program
population. BOP residential programs
being piloted at the low security female
are more intensive than non-residential
institution in Danbury, Connecticut, has positions
programs, requiring more programming
for a FIT Program Coordinator, two Psychologists,
54
and four Treatment Specialists. BOP anticipated
hours to complete.
Residential
that, when fully staffed, FIT would be able to
programs have more staff to account
provide treatment to up to 96 women at a time.
for these differences. While we
The capacity of the low security female institution
recognize that residential programs are
in Danbury is 192 inmates, meaning that, unlike
Resolve, the FIT program will be able to
frequently of a greater intensity than
accommodate a relatively high proportion of
non-residential programs such as
Danbury’s low security female population.
Resolve, we believe that BOP’s current
Sources: OIG interviews of BOP staff and BOP
approach to staffing Resolve does not
documents describing the FIT program
take into account the importance of
female inmates completing this
program as close as possible to the
beginning of their incarceration. For a description of a new trauma treatment
program that BOP was piloting during the time of our review, see the text box.

54 Typical residential programs require inmates to participate in group sessions for 3–4 hours
per day. Resolve consists of group sessions that meet for approximately 1–2 hours per week.

24

A 2003 National Institute of Corrections report stated that “among women,
the most common pathways to crime are based on survival (of abuse and poverty)
and substance abuse.”55 The Women and Special Populations Branch Administrator
described sexual assault in particular as the pipeline to prison for many female
inmates. BOP recognizes that trauma treatment programs are an important tool to
disrupt this pathway. A 2012 study on trauma-informed correctional care reported
that histories of sexual abuse could interfere with female inmates’ ability to benefit
from other institution programs; the study stated that addressing trauma should be
a priority for female inmates.56 Also, these programs have been in high demand
among female inmates, as evidenced by waiting lists for the Trauma in Life seminar
that extend for 6 months or more. However, we found that BOP’s staffing level for
these program is inadequate to meet the demand. As a result, BOP cannot ensure
that all eligible female inmates receive trauma treatment before their release.
BOP’s Pregnancy Programs May Be Underutilized
To further address the unique needs of female inmates, BOP offers two
programs for its pregnant inmates. The first is the BOP-sponsored Mothers and
Infants Nurturing Together (MINT) program, which allows female inmates to serve
a portion of their sentence living in a halfway house with their infants after birth.
According to BOP, the MINT program was designed to teach parenting skills and
facilitate mother-child bonding so that inmates will be more likely to provide a
stable home environment upon release from BOP custody. The second program,
which has similar goals to the MINT program, is the Washington State Department
of Corrections’ Residential Parenting Program. BOP maintains an agreement with
the Washington State Department of Corrections that allows BOP female inmates
and their infants to participate in the program, which is housed inside a Washington
state minimum security female institution.
The Female Offender Manual requires BOP Social Workers to meet with
pregnant inmates to provide information regarding the MINT program and the
Residential Parenting Program. The Social Worker must document this meeting in
the inmate’s electronic medical record and notify the Women and Special
Populations Branch Administrator, Regional Social Worker, and institution Clinical
Director of any inmate wishing to participate in either pregnancy program.57 The
BOP National Institute of Corrections, Gender-Responsive Strategies: Research, Practice
and Guiding Principles for Women Offenders (June 2003), 52–54. The report discussed female
inmates in both federal and state prison systems.
55

The National Institute of Corrections provides training, technical assistance, information
services, and policy and program development assistance to federal, state, and local correctional
agencies.
56 Niki A. Miller and Lisa M. Najavits, “Creating Trauma Informed Correctional Care: A
Balance of Goals and Environment,” European Journal of Psychotraumatology (2012): 3.
57 Not every female institution employs a Social Worker. When an institution does not have a
Social Worker, the Women and Special Populations Branch Administrator told us that the Regional
Social Worker is responsible for meeting with a pregnant inmate.

25

MINT program is open to inmates who do not plan to place their infant up for
adoption, are pregnant upon incarceration with an expected delivery date prior to
release, have less than 5 years remaining on their sentence and are eligible for
halfway house placement, and can assume financial responsibility for the child’s
care.58 During the scope of this review (FYs 2012–2016), MINT program sites were
located across the country in multiple regions.59
If a pregnant inmate is interested in either program, the inmate’s Unit Team
is responsible for preparing a referral packet and forwarding the packet to the
Residential Reentry Management Branch within the Reentry Services Division for a
final decision about the inmate’s eligibility and placement. After completing the
MINT program, inmates who have time remaining to serve on their sentence
transfer their infant to another legal guardian and return to a BOP institution or are
transferred to a halfway house or home confinement.
One MINT Coordinator told us that she believes that MINT is valuable to
inmates because it helps them bond with their infants and can increase the
likelihood that those inmates will assume parental responsibilities when they are
released, therefore motivating them to avoid future criminal behavior. Participants
in the MINT program told us that the residential placement during and after
pregnancy has helped them learn important parenting skills and develop a bond
with their infants.
Despite the benefits that the MINT program can provide to pregnant inmates,
we found that the program may be underutilized. Between FYs 2012 and 2016,
there were 951 pregnant inmates in BOP’s custody, 558 of whom were in
institutions designed to house sentenced inmates. Of these 558 sentenced
pregnant inmates, we estimate that only 204 (37 percent) participated in MINT or
the Residential Parenting Program.60
We believe that the low levels of participation likely can be attributed to four
causes. First, we found that pregnant inmates may not always be told about
available pregnancy programs. Social Workers are responsible for informing
inmates about these programs, but Social Worker positions are often vacant. In
fact, we found that 5 of the 15 female institutions had Social Worker vacancies in
September 2017. Additionally, underscoring the importance of program reviews,
BOP’s first review of its policies on the management of female inmates in December
2017 concluded that Social Workers at one institution were not meeting with
pregnant inmates to discuss pregnancy programming, as required. Although we

58 The Residential Parenting Program has a separate set of eligibility criteria, established by
the Washington State Department of Corrections. We discuss these criteria in a text box below.
59 As of December 2017, the sites in San Francisco, California, and Hartford, Connecticut, no
longer accepted MINT inmates. BOP ended the MINT program at these locations because the sites
were unable to comply with some of the contract requirements for hosting MINT programs.
60 For this review, we evaluated participation for those inmates who were in institutions
designed to house sentenced inmates only. Additionally, BOP Program Statement 7310.04,
Community Corrections Center Utilization and Transfer Procedure, December 16, 1998, states that
pretrial detainees are not eligible for halfway house placement.

26

also found that some institution staff did not fully understand the eligibility criteria
for the pregnancy programs, the Health Services Administrator of one female
institution said that staff there inform pregnant inmates of either MINT or the
Residential Parenting Program only if the staff believes that the inmate meets the
eligibility criteria for those programs, to avoid disappointing inmates who are not
eligible.
In addition to a lack of program awareness among inmates, we also found
that BOP institution staff were generally unaware of the Washington State
Department of Corrections’ Residential Parenting Program, for which some BOP
pregnant inmates were eligible. We believe that this general lack of awareness has,
in part, contributed to low BOP inmate participation in the Residential Parenting
Program. Specifically, only five inmates entered the program between FYs 2012
and 2016, most recently in FY 2013. This was the case despite the fact that
Washington State Department of Corrections officials told us that the program had
excess capacity. We describe the Residential Parenting Program, and its eligibility
criteria, in the text box.

Residential Parenting Program
During the course of our review, we learned that BOP inmates may participate in the
Washington State Department of Corrections’ Residential Parenting Program. Unlike the MINT
program, which provides a shorter period of mother-infant bonding time in a halfway house
setting, the Residential Parenting Program offers 30 months of mother-infant bonding time in
the minimum security unit of the Washington Corrections Center for Women in Gig Harbor,
Washington. If an inmate is interested in the program after learning about it from a BOP Social
Worker, the inmate’s Unit Team submits a referral packet to BOP’s Residential Reentry
Management Branch for review and placement.
The eligibility requirements for the Residential Parenting Program are stricter than those for
the MINT program. For example, only minimum security inmates are eligible to participate in
the Residential Parenting Program, whereas both minimum and low security inmates can be
eligible to participate in the MINT program. To be eligible for the Residential Parenting Program,
inmates must meet certain disciplinary and work evaluation criteria and must have no history of
violence, sex offenses, or child abuse. Inmates must also be eligible for release or home
confinement within 30 months of their expected delivery date.
Sources: Washington State Department of Corrections officials, BOP officials, and BOP policies

Third, we found that BOP institution staff may be applying policy more
restrictively than intended by Central Office policymakers. BOP policy states only
that inmates must be eligible for halfway house placement to participate in the
MINT program and does not explicitly bar inmates from participation based on
security level; however, we learned that some BOP institution officials may apply a
more restrictive eligibility standard. For example, a Warden of a female institution
told us that only minimum security inmates qualify for MINT, because, she
believed, that low security inmates had not proven they were ready for halfway
house style housing. However, the former Chief of BOP’s Designation and Sentence
Computation Center, which has responsibility for determining where inmates should
be housed, told us that security level designation alone should not prevent an
interested inmate from participating in MINT. BOP’s policy on halfway house
27

eligibility calls for case-by-case consideration of each interested MINT participant
and her likelihood to pose a threat, rather than a blanket disqualification based on
her security level.61
Fourth, we found that BOP does not collect data that would allow it to identify
barriers to participation and monitor pregnant inmates’ awareness of, interest in,
and enrollment in the MINT program or the Residential Parenting Program. The
Women and Special Populations Branch Administrator told us that collecting
sufficient data on pregnant inmates historically has been a challenge for BOP. It
was not until 2016 that BOP added a code to its inmate tracking system to indicate
that an inmate is pregnant. Additionally, four of the interim remote program
reviews that BOP conducted on Female Offender Manual compliance between
December 2017 and May 2018 found inconsistencies in tracking pregnant inmates.
During the time of our review, BOP did not track data that would allow it to ensure
that pregnant inmates were informed about pregnancy programs, as required by
the Female Offender Manual. Additionally, BOP did not collect data that would allow
it to determine the specific eligibility criteria that preclude program participation,
such as whether a pregnant inmate faced financial barriers to supporting her baby
during mother-infant bonding time or planned to pursue adoption, either of which
would render the inmate ineligible for participation in MINT.
Lastly, BOP did not track the length of time a pregnant inmate spent at a
MINT program site. Tracking duration of stay could help BOP better determine the
ideal amount of time an inmate should spend at a MINT program site to achieve the
program’s goals. During the time of our review, policy allowed institution staff to
exercise discretion as to how long an inmate may stay at a MINT program site;
inmates must be allotted 3 months after birth, but the policy recommended that
inmates be allowed to participate for 6 months after giving birth.62 Multiple MINT
Coordinators told us that many inmates stay at the MINT program site for only
3 months after birth.
We learned from MINT capacity data and interviews with BOP and
Washington State Department of Corrections officials that both the MINT program
and the Residential Parenting Program can accept additional eligible BOP inmates.
Therefore, we determined that low levels of inmate participation in pregnancy
programs were not caused by limited program capacity. Instead, we found that low
participation was likely due to BOP staff members’ failure to fully communicate
program opportunities and eligibility criteria to staff and pregnant inmates and to
collect relevant data to assess pregnant inmates’ interest and participation in the
MINT program and the Residential Parenting Program. As a result, we believe that
pregnancy program participation will remain low until BOP addresses these issues.

61

BOP Program Statements 7310.04 and 5200.02.

62 MINT Coordinators believe that when inmates participate in MINT for at least 6 months
after birth, they are more likely to achieve the program’s goals of learning parenting skills and
bonding with their infants. One region’s MINT program site allows any inmate who enrolls there to
participate for 12 months.

28

BOP Recently Implemented New Guidance on Access to Feminine Hygiene Products,
but This Guidance Is Silent on How These Products Should be Distributed
In addition to managing female inmates’ needs related to pregnancy, BOP
must also appropriately manage female inmates’ distinct needs related to feminine
hygiene. During our fieldwork, we found that the distribution methods for feminine
hygiene products and the type of products provided to inmates free of charge
varied by institution and did not always ensure that inmates had access to a
quantity of products sufficient to meet their needs. Even though BOP issued an
Operations Memorandum on the Provision of Feminine Hygiene Products
(Operations Memorandum) expanding the availability of products, which appears to
have made some important improvements, we note that the policy lacked
specificity in how institutions should distribute the products.63 Because our
fieldwork ended around the same time as this policy was issued, we could not
confirm that it has addressed our concern that some institutions were not making
these products sufficiently accessible.
All BOP institutions that house female inmates provide some feminine
hygiene products to inmates free of charge, as required by the BOP grooming
policy, which states, “for women, products for female hygiene needs shall be
available.”64 However, we found that distribution practices varied across
institutions. All of the institutions we visited provided sanitary pads free of charge,
and a few also provided tampons. Female inmates could also purchase at their own
expense both pads and tampons at the commissary.
We found that the method of distribution generally varied by the type of
institution. For example, minimum security institutions stored feminine hygiene
products in central locations such as bathrooms or a container that was accessible
to all inmates at all times. In contrast, at several low security institutions, BOP
correctional staff issued each inmate a predetermined number of feminine hygiene
products per month, usually 25 to 30, regardless of individual need. One BOP staff
member we interviewed told us that the number of feminine hygiene products
distributed was determined largely by dividing the number received from the
warehouse by the number of inmates. One inmate we interviewed from an
institution that issued a preset number of hygiene products said that the amount
she received from the institution each month was not enough to meet her
menstrual needs. At one institution we visited, officials told us that feminine
hygiene products were centrally distributed because the inmates had been misusing

BOP Operations Memorandum 001-2017, Provision of Feminine Hygiene Products,
August 1, 2017.
63

BOP Program Statement 5230.05, Grooming, November 4, 1996, is BOP’s policy on
standards of grooming for all inmates in BOP custody. The policy describes standards of grooming
regarding bathing, clothing, and hygiene for all inmates. In addition, the policy states that BOP
institutions are to provide feminine hygiene products free of charge to all female inmates.
64

29

them for purposes such as cleaning their cells.65 Inmates told us that the
centralized distribution was problematic because hygiene products were no longer
accessible in the housing units and the amount inmates received was limited.
We also found that, if inmates needed more feminine hygiene products than
were issued, their ability to receive additional products varied. At institutions
where access was tightly controlled, inmates who needed additional feminine
hygiene products had to request them from a counselor. One inmate we
interviewed told us that she had requested additional sanitary pads from a
counselor and the counselor told her that the amount she received should be
enough. In other institutions, inmates must go to health services to request
additional products and, in some instances, going to health services also required
permission from correctional staff.66 Inmates at these institutions indicated that
they interpreted this as a quota system because they could not necessarily obtain
additional hygiene products beyond the number issued, even if they asked for
them; or if they asked, they might be questioned about why they needed more.
We believe that any distribution method that tightly controls access to feminine
hygiene products and requires inmates to request more from staff, with no
guarantee that their requests will be granted, places an excessive burden on
inmates and does not meet BOP’s grooming policy requiring that such products
“shall be available” to female inmates.
Advocacy groups also have stated that access to and affordability of feminine
hygiene products has been a concern for incarcerated women. Feminine hygiene
products are costly relative to the salary inmates earn in prison. Additionally, advocacy
groups have raised concerns that limited access to feminine hygiene products creates
anxiety and is dehumanizing for incarcerated women. Several U.S. Senators
introduced legislation on this topic in 2017, as we discuss in the text box below.
We found that some state correctional systems made feminine hygiene
products more readily available for their inmates. Some states made the products
freely available in several locations throughout the institution, including search
areas, housing units, programming areas, and bathrooms, rather than distributing a
preset number to each inmate per month. One state official we interviewed told us
that at one time there were issues with inmates hoarding feminine hygiene
products. He explained that the hoarding stopped once the inmates believed they
would have regular access to the products for their menstrual needs. Other state
officials told us that if inmates were misusing feminine hygiene products for other

No BOP staff member told us that feminine hygiene products were misused in a manner
that presented a security concern. When we asked the Women and Special Populations Branch
Administrator whether making them accessible could be a security concern, she said that they could
not be.
65

66 We note that not all of the reasons for which a female inmate might need additional
feminine hygiene products are indicative of a medical problem. For example, a female inmate whose
menstrual period began as frequently as every 21 days would be considered medically normal.
However, if she received feminine hygiene products every 28 days she would not have enough.

30

purposes, they would address the issue with
the individual inmates rather than changing
the distribution method for all inmates.
We believe that the Operations
Memorandum that BOP distributed to all
institutions in 2017 is a positive step in that
it required all institutions to provide sanitary
pads, tampons, and panty liners free of
charge to inmates. Even though the
Operations Memorandum did not explicitly
address how products should be dispersed,
BOP’s Women and Special Populations Branch
Administrator told us that the intent of the
Operations Memorandum was to ensure that
these products were freely available and that
institutions should not be dispersing a preset
amount of hygiene products to female
inmates. She added that during the
quarterly conference calls with Wardens of
female institutions, she instructed them that
placing quotas on or issuing a preset amount
of feminine hygiene products was prohibited.

2017 Legislation on Providing
Feminine Hygiene Products for
Inmates
In July 2017, four U.S. Senators
introduced the “Dignity for
Incarcerated Women Act of 2017.”
Among other provisions, the bill, if
passed, would permanently prohibit
federal prisons from charging female
inmates for essential healthcare
items, including sanitary napkins and
tampons. The proposed legislation
received widespread attention, and
some states were reviewing their
policies on sanitary napkins and
tampons to make them more
accessible for women.
In May 2018, the House
Judiciary Committee passed the
“FIRST STEP Act,” a bill intended to
improve the federal prison system
through the implementation of
corrections policy reforms. This bill
included language that would require
BOP to make sanitary napkins and
tampons available for free, in a
quantity that is appropriate to the
healthcare needs of each inmate.

We could not validate that our
concerns about inmates having insufficient
Sources: U.S. Congress website,
access to products were addressed because
media articles
the Operations Memorandum was issued at
67
Further, BOP’s
the end of our fieldwork.
interim program reviews of the Female
Offender Manual, implemented in November 2017, also assessed only whether an
institution provided the products required in the Operations Memorandum, but did
not assess the accessibility of the products to inmates.68 Although the new
guidance is in place and BOP has taken some steps to bring institutions into
compliance, we are concerned that BOP still lacks a method to ensure sufficient

67 The Assistant Director of the Reentry Services Division told us that even after the new
guidance was issued he became aware that six institutions had not implemented it as promptly as
expected. He told us that the Regional Directors, who directly supervise the Wardens of each
institution, had to intervene to bring those institutions into compliance.

Program Review G5200I.01, Interim Remote Guideline Steps, November 2017, evaluated
how well an institution was providing vital services to female offenders. The review included an
assessment of the following: Classification, Staff Training, Inmate Programs, Pregnancy/Child
Placement, Pregnancy/Programming, High Security Administrative Units, Trust Fund/Commissary, and
Feminine Hygiene Products.
68

31

access. As noted previously, in-person program reviews may provide a way to
ensure institutions have implemented the Operations Memorandum as intended.
BOP’s Lack of Gender-specific Posts Results in Inefficiencies at Female
Institutions
In addition to programming, pregnancy, and hygiene matters, another issue
we identified in BOP’s management of its female inmate population relates to BOP’s
policy prohibiting cross-gender searches. The Prison Rape Elimination Act of 2003
(PREA) and BOP policy prohibit cross-gender searches of female inmates.69 We
found that BOP did not take this policy into account when assigning posts for its
Correctional Officers. BOP assigned Correctional Officers to posts solely based on
seniority, which resulted in male Correctional Officers being assigned to posts at
which staff regularly conducted searches of female inmates. This means that
female Correctional Officers had to leave other assigned posts to conduct these
searches, which we found to be inefficient and disruptive. This problem is more
acute at institutions where the inmate population is entirely female and female
Correctional Officers must perform all inmate searches.
BOP policy requires that staff conduct strip searches of inmates in certain
situations, most commonly when they enter or leave the Special Housing Unit
(SHU) and before and after they have contact with the public, such as when they
receive visitors in the institution’s visiting room, appear in court, or have a medical
appointment outside the institution.70 Therefore, conducting strip searches is
among the inherent duties of the Correctional Officer posts in those locations.
However, BOP cannot currently ensure that there is a female Correctional Officer on
each post where strip searches are required.
The fact that every inmate search at BOP’s female institutions—both strip
searches and pat searches—must be done by female staff can be disruptive to
operations when female inmate searches are needed at a post staffed only by male
In August 2012, the Department issued a final rule adopting national standards to prevent,
detect, and respond to prison rape, as required by PREA. This rule banned male staff from conducting
pat searches of female inmates (known as cross-gender pat searches) beginning in August 2015. See
28 C.F.R. § 115.15(b). BOP updated multiple policies to incorporate the ban after the rule was issued.
See BOP Program Statements 5521.06, Searches of Housing Units, Inmates, and Inmate Work Areas,
June 4, 2015, 3, and 5324.12, Sexually Abusive Behavior Prevention and Intervention Program,
June 4, 2015, 17.
69

The Department chose not to ban cross-gender pat searches of male inmates when
promulgating the PREA regulations because it found that male inmates are less likely than female
inmates to have a history of sexual abuse and are also less likely to experience re-traumatization as a
result of a cross-gender pat search. Further, the Department concluded that in correctional agencies
where the percentage of female correctional staff is substantial, but the percentage of female inmates
is small, banning cross-gender pat searches of male inmates could have a significant adverse impact
on employment opportunities for female staff.
70 Federal regulations and BOP policies mandate that strip searches also be conducted by a
staff member who is the same gender as the inmate being searched. See 28 C.F.R. § 552.11(c) and
BOP Program Statement 5521.06, 4. See also 28 C.F.R. § 115.15(a).

32

staff. Female Correctional Officers we interviewed at female institutions told us
that in these instances they are required to leave their post and go to the post
where the search is needed.71 A female Correctional Officer at an all-female
institution told us that in a recent 3-month period she was called to the SHU an
average of 3 or 4 times each week to search female inmates because all of the
Correctional Officers assigned to the SHU were male. Similarly, another female
Correctional Officer told us that when all of the visiting room posts at her institution
were filled by males she had to juggle the duties of her own post as well as theirs.
At BOP’s mixed-gender institutions, the need for female staff to search
female inmates is more manageable. While female Correctional Officers represent
only a fraction of the staff, female inmates represent only a fraction of the
population. The challenge at mixed-gender institutions is physical distance. BOP
policy requires female institutions, including mixed-gender institutions, to have at
least one female staff member on duty during every shift but does not specify
where the female staff should be posted. Correctional Officers at mixed-gender
institutions told us that, while there was always a female officer on duty, the duty
location could be so far away that the female Correctional Officer would have to
drive to respond to the search request.
In our interviews, BOP staff expressed widespread support for BOP requiring
certain posts, such as in the visiting rooms and SHUs at female institutions, to be
staffed by female Correctional Officers, citing as an impediment to operations the
frequent need to call female staff from other posts to strip search and pat search
female inmates.72 Nearly two-thirds (15 of 23) of both supervisory and nonsupervisory custody staff at female institutions with whom we discussed the topic
were in favor of establishing a small number of gender-specific posts at female
institutions.73 This includes 9 of the 11 female custody staff, who are the most
affected by BOP’s current policies, and 6 of the 12 male custody staff we spoke to.
The Women and Special Populations Branch Administrator echoed these views.

71 BOP’s policy on inmate searches states that except when circumstances are such that delay
would constitute an immediate threat to the inmate, staff, others, property, or institution security, a
female staff member should come to a post to pat search a female inmate rather than invoke an
exemption in the PREA regulations that permits cross-gender pat searches in “exigent circumstances.”
BOP Program Statement 5521.06, 3.

The PREA regulations define “exigent circumstances” as those that require immediate action in
order to combat a threat to the security or institutional order of a facility. Institution staff did not
describe to us any situations where they had to invoke the exemption.
72 These disruptions occur despite the fact that, on average, nearly 40 percent of Correctional
Officers in BOP’s seven female institutions are female.
73 BOP staff specifically recommended that BOP require at least one of the Correctional
Officers assigned to a female visiting room or female SHU be female.

We reviewed the written directives describing the specific duties of these posts, known as post
orders, from four of BOP’s female institutions and found that the post orders anticipated that the
Correctional Officers working the posts would routinely strip search and pat search female inmates.

33

State correctional officials we interviewed told us that their agencies had
recognized this issue and had taken several different approaches to address it.
Officials from two of the five state correctional agencies told us that they had
established gender-specific posts in specific areas of their female institutions, such
as the SHU and the visiting room, to ensure that only female Correctional Officers
search female inmates without interfering with operations.74 Officials from two
additional state correctional agencies told us that their agencies did not have any
gender-specific posts in their female institutions, but that the institutions had
enough female staff to handle all search needs. The fifth agency obviated the need
for gender-specific posts by assigning only female staff to work at its female
institution.
We found differences of opinion about whether the establishment of genderspecific posts is allowable under the Master Agreement that governs BOP labor
practices and working conditions and even whether gender-specific posts are
needed.75 Specifically, BOP’s Assistant Director of the Correctional Programs
Division stated that the terms of the Master Agreement do not expressly allow for
gender-specific posts and that he was not aware of any problems that would
require the establishment of gender-specific posts.76 He also expressed concern
that having such posts could lead to an increase in staff complaints or grievances.
Further, institution custody supervisors told us that they believed seniority was the
only factor they could consider in determining assignments. They explained that
Correctional Officers bid for their preferred posts quarterly in order of seniority and
institution staff create a roster based on “reasonable efforts” to grant the requests.
The Master Agreement defines “reasonable efforts” to mean that “management will
not arbitrarily deny such requests.”77
In contrast, BOP’s General Counsel said that the Master Agreement could
allow female institutions to establish a few gender-specific posts because, in his
view, having enough staff on a post to complete the work efficiently is not arbitrary.
Further, while in his opinion an institution could not establish a blanket rule that all
posts in a particular location could be filled only by staff from one gender,

One of these two correctional agencies said that the agency had not faced challenges from
male staff as a result of establishing gender-specific posts in female institutions, although the official
we interviewed acknowledged that the agency’s lack of a public sector union may also be a reason
why the posts have not been challenged. See Appendix 1 for the methodology of our review,
including the officials we interviewed.
74

The current Master Agreement between BOP and the Council of Prison Locals, the union
that represents BOP’s bargaining unit employees, went into effect in July 2014. Master Agreement
between the Federal Bureau of Prisons and Council of Prison Locals, July 21, 2014–July 20, 2017.
75

The Master Agreement does not discuss gender-specific posts. Instead, BOP’s program
statement on inmate searches prohibits the establishment of gender-specific posts and requires
institutions to evaluate operational needs consistent with the Master Agreement and collective
bargaining obligations. BOP Program Statement 5521.06, 3.
76

77 Master Agreement, Article 18, Section d, para. 2d. This Master Agreement was in effect
during the scope of our review.

34

institutions could require that a certain portion of them be filled by staff from one
gender.78
We note that the Master Agreement went into effect in 2014, but the PREA
regulations and BOP policies that ban cross-gender pat searches of female inmates
did not go into effect until 2015. Given that cross-gender pat searches of female
inmates were banned after the Master Agreement came into effect, BOP may need
to reexamine its blanket ban on gender-specific posts. We recommend that BOP
improve the availability of female staff at locations in female institutions where
inmate searches are common, through the establishment of gender-specific posts
or other methods.
BOP’s Decision to Convert Federal Correctional Institution Danbury to a Male
Institution Negatively Affected Female Inmates Transferred to Metropolitan
Detention Center Brooklyn
Our broader evaluation of BOP’s management of female inmates also
encompassed a more specific review of the circumstances and results of BOP’s
decision to convert Federal Correctional Institution (FCI) Danbury to a male
institution. We believe that the effects of this decision, described below, serve as a
case study that highlights BOP’s ongoing challenges in strategically managing its
female inmate population.
In April 2014, BOP converted FCI Danbury, its low security female institution
in Danbury, Connecticut, to a male institution.79 As a result of the conversion, BOP
eliminated its only low security female institution in its Northeast Region. Members
of Congress and other stakeholders expressed concern that without a comparable
facility in the region BOP would send local inmates to BOP institutions farther from
their homes, making it difficult for families to visit inmates throughout their
incarceration.80 As a result of this concern, and the concern of other criminal
justice stakeholders that following the conversion sentenced female inmates were
housed in inappropriate conditions in Metropolitan Detention Center (MDC)
Brooklyn, we examined how BOP’s decision to convert FCI Danbury affected female
inmates.
First, we found that, although the Danbury conversion resulted in 19 percent
of U.S. citizen female inmates being transferred farther from home, far more were
transferred to facilities closer to home. Second, we found that BOP offered female
The post orders we reviewed indicated that visiting rooms and SHUs were staffed by
multiple Correctional Officers.
78

According to a September 2013 BOP projection, BOP would see a reduction in both the
male and female low security overcrowding rates by opening FCI Aliceville as a low security female
institution and converting FCI Danbury to a low security male institution. Specifically, BOP estimated
that these changes would reduce the low security female overcrowding rate from 48 percent to
23 percent and the low security male overcrowding rate from 38 percent to 36 percent.
79

In August 2013, Senators Christopher Murphy (Connecticut) and Kirsten Gillibrand (New
York) sent a letter to then BOP Director Charles Samuels expressing concern regarding the conversion
of FCI Danbury.
80

35

inmates at MDC Brooklyn no access to outdoor space, less natural light, and fewer
programming opportunities than what would otherwise be available to female
inmates at a BOP facility designed to house sentenced inmates for long periods of
time. Third, although BOP opened a new low security institution for female inmates
from the Northeast in December 2016, during the course of our fieldwork we found
that BOP built the new institution without a SHU for female inmates, which has
created challenges for disciplining female inmates. We discuss each of these
findings below.
Most Female Inmates Transferred from FCI Danbury Moved Closer to Home
In response to congressional concerns that the conversion of FCI Danbury
would cause female inmates to be housed farther from their homes, we analyzed
the distances from home for female inmates transferred from FCI Danbury. We
found that 81 percent of Danbury’s U.S. citizen female inmates were transferred
closer to or remained the same distance from home and 19 percent were
transferred farther from home.
We further describe the outcomes of our analysis below in Table 5, which
shows that of the 1,127 female inmates transferred or released from FCI Danbury,
497 were U.S. citizen female inmates who were transferred to other BOP
institutions. Of those 497, we found that 401 were transferred to a BOP institution
closer to their homes or were reassigned to a minimum security prison camp at FCI
Danbury. Conversely, 96 were transferred to a BOP institution farther from home.
Of those 96, 61 were from BOP’s Northeast Region.81 We did not consider the nonU.S. citizen inmates whom BOP transferred from FCI Danbury in this analysis
because the BOP data we analyzed did not always include a U.S. residence for
these individuals.

These 61 inmates were transferred to 12 different institutions. BOP told us that it
considered multiple factors when making each transfer decision. These factors include distance from
home, availability of programming, and physical and mental health needs.
81

36

Table 5
Geographic Outcomes of FCI Danbury Female Inmate Transfers
1,127 Inmates Transferred or Released Between August 2013 and March 2014
675 U.S. citizens
445 non-U.S. citizens
7 U.S. citizens with incomplete data for geographical analysisa
675 U.S. Citizens
497 transferred to another BOP institution
45 released from BOP custody
133 transferred to a halfway house prior to release from BOP custody
497 Transferred to Another BOP Institution
373 transferred closer to home
96 transferred farther from home
28 not changed (transferred to Federal Prison Camp Danbury)b
96 Transferred Farther from Home
61 from BOP’s Northeast Regionc
35 from other BOP regions
Of the 1,127 inmates BOP transferred or released from FCI Danbury, 682 were U.S. citizens.
Due to data limitations, we were unable to conduct a distance analysis for seven of these U.S.
citizen female inmates.
a

BOP reduced the security level of these inmates to minimum and assigned them to the
minimum security Federal Prison Camp Danbury, which is adjacent to FCI Danbury.
b

For the purpose of this analysis, we used the 10 states that BOP designated as within its
Northeast Region as our parameter for “Northeast.” These states are Connecticut, Maine,
Massachusetts, New Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, and
Vermont.

c

Sources: BOP Sentry and SAS geolocation library

The Duration and Conditions of Confinement of Inmates Housed at MDC Brooklyn
After members of Congress expressed concern that the conversion of FCI
Danbury would eliminate BOP’s only low security institution for female inmates in
the Northeast, in October 2013 BOP announced that it would open a new low
security institution in Danbury in order to keep low security female inmates from the
Northeast closer to home. While BOP was constructing the new institution, it
decided to house many of the displaced inmates from the Northeast at
MDC Brooklyn, a detention center designed and generally used for short-term
confinement. BOP housed these inmates at MDC Brooklyn between March 2014 and
December 2016, significantly longer than the 18 months it had initially anticipated.
According to the former Chief of the Designation and Sentence Computation
Center, detention facilities such as MDC Brooklyn lack the physical infrastructure
and programming opportunities appropriate for long-term incarceration. However,
BOP officials decided that it would be better to house sentenced inmates at MDC
Brooklyn in order to keep them closer to their families, as opposed to transferring
them to institutions farther away from their homes that were suitable for long-term
37

confinement.82 The former Chief of the Designation and Sentence Computation
Center stated that BOP officials chose the former in part because they estimated
that the inmates would be housed there only on a temporary basis until the new
institution at Danbury was complete.
In October 2013, BOP anticipated that the new institution would open
18 months later, in March 2015. However, the construction did not actually begin
until June 2015, or 20 months later, and the new institution at Danbury did not
open until December 2016, causing 70 of the 366 female inmates to remain at MDC
Brooklyn for longer than 18 months, with the longest stay lasting 34 months.83
Figure 2 provides a more detailed explanation of the period of confinement for
sentenced female inmates at MDC Brooklyn.
Figure 2
Length of Confinement for Sentenced Female Inmates at MDC Brooklyn
180
160
140
Number of Inmates

120
100
80

Non-Northeast

60

Northeast

40
20
0
1-6
months

7-12
months

13-18
months

19-24
months

25-30
months

31-34
months

Length of Confinement
Notes: For the purpose of this analysis, we defined 1 month as 30 days.
This figure includes MDC Brooklyn’s U.S. citizen and non-U.S. citizen sentenced female inmates.
For the purpose of this analysis, we use the 10 states that BOP designated as within its Northeast
Region as our parameter for “Northeast.” These states are Connecticut, Maine, Massachusetts, New
Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, and Vermont.
Source: BOP SENTRY

82 We also note that, given the greater number of male institutions, BOP would be less likely
to have to choose between institutions close to home and institutions suitable for long-term
confinement if it had decided to convert or close one of its male institutions. For example, BOP
operated four low security male institutions in its Northeast Region in 2013 (FCI Allenwood Low, FCI
Elkton, FCI Fort Dix, and FCI Loretto), compared to one for women (FCI Danbury). Had the BOP
decided to convert or close one of these low security male institutions at that time, the other three
institutions would have remained options for low security male inmates from the Northeast.
83 According to BOP, the March 2015 estimate was always subject to change. OIG is currently
completing an audit of the FCI Danbury construction contract.

38

Conditions of Confinement at MDC Brooklyn
Between March 2014 and December 2016, members of the National
Association of Women Judges (NAWJ) visited MDC Brooklyn multiple times and
issued two reports detailing its concerns about the conditions of confinement at the
facility.84 NAWJ reported that BOP housed female inmates at MDC Brooklyn without
access to an outdoor recreation space that had fresh air and exposure to sunlight,
which, NAWJ believed, amounted to a violation of both the American Bar
Association Standards on Treatment of Prisoners and the United Nations Standard
Minimum Rules for the Treatment of Prisoners.85
During our visit to MDC Brooklyn in August 2017, we found that its female
inmates had less access to fresh air and sunlight than what would have been
available to them at FCI Danbury. Unlike female inmates at MDC Brooklyn, who
rarely left the floor of their housing unit, low security inmates at FCI Danbury and
those at most other BOP institutions designed for sentenced inmates have access to
fresh air and sunlight not only during recreation, but throughout the day when they
move from one part of the institution to another. Further, FCI Danbury and other
BOP institutions have open outdoor recreation spaces, whereas the recreation space
at MDC Brooklyn was directly attached to the female inmate housing unit and had
only two caged sides exposed to sunlight.86 Because male inmates in the facility
had a direct sightline into the exposed sides of the women’s recreation cage,
MDC Brooklyn staff added metal sheeting to the exposed sides, which left only
small portions, at the top and bottom, uncovered, further restricting the amount of
natural light.87
Some BOP staff acknowledged that the limited access to sunlight for the
sentenced female inmates was not ideal, and in our report on the Federal Bureau of
84 NAWJ Women in Prison Committee, Visit to BOP’s Metropolitan Detention Center (MDC),
Brooklyn, New York (March 2015) and Second Visit to BOP’s MDC, Brooklyn, New York (June 2016).
85 In particular, NAWJ cited the American Bar Association Standards on Treatment of
Prisoners, Standard 23-3.1(a) 3rd edition, 2011, which states that “a correctional facility should not
deprive prisoners of natural light, of light sufficient to permit reading throughout prisoners’ housing
areas, or of reasonable darkness during the sleeping hours.” Additionally, NAWJ cited a standard
related to access to exercise and sports for inmates, which is outlined in the UN Standard Minimum
Rules for the Treatment of Prisoners, 1977. The standard specifies that “every prisoner who is not
employed in outdoor work shall have at least one hour of suitable exercise in the open air daily if the
weather permits.”

These differences exist because MDC Brooklyn is a high-rise building, with all of its
departments housed in a single building. As a result, inmates rarely leave the floor their unit is on.
FCI Danbury and other institutions designed for sentenced inmates consist of multiple smaller
buildings surrounded by a perimeter fence. Inmates in these types of institutions have access to the
outdoors daily because they must go outside to get from their housing units to the cafeteria, the
medical clinic, classrooms, and other departments.
86

Judges belonging to NAWJ, who visited MDC Brooklyn in March 2015, estimated that there
was an 18-inch opening at the top and a 6-inch opening at the bottom of the exposed walls. We did
not take measurements at the time of our visit in August 2017 because most of the metal sheeting
had been removed in late 2016.
87

39

Prisons’ Use of Restrictive Housing for Inmates with Mental Illness, a BOP
Psychologist explained that access to sunlight is important for an inmate’s mental
and physical well-being.88 Although the level of natural light in the recreation space
was below the level BOP generally considers appropriate for long-term confinement,
a February 2015 American Correctional Association (ACA) accreditation report on
MDC Brooklyn did not identify natural light levels as a concern.89
We also found that female inmates assigned to MDC Brooklyn did not have
the range of programming that is normally available at institutions for sentenced
inmates. According to BOP’s program statement on Education, Training, and
Leisure Time, detention centers are exempt from providing the same education
programs that are offered at other BOP institutions.90 We believe that this
exemption is reasonable when the only mission of a detention center is to provide
short-term housing for pretrial inmates. However, in the case of MDC Brooklyn, the
exemption limited the programming opportunities below the level BOP determined
is appropriate for sentenced inmates.
Additionally, we found that MDC Brooklyn did not offer the Resolve program
(discussed above) because it did not have a Resolve Coordinator on staff. We
found this surprising given the emphasis that BOP places on trauma-informed care.
MDC Brooklyn’s Chief Psychologist told us that it was difficult to conduct those
group psychology programs for which MDC Brooklyn did have sufficient staff
because the population of sentenced inmates was too small to generate the number
of interested inmates required for participation. When discussing the availability of
programming at MDC Brooklyn, the Women and Special Populations Branch
Administrator told us that in retrospect she believes that BOP should have better
recognized the need to provide MDC Brooklyn with additional programming
resources before it transferred sentenced female inmates there.
Although not directly related to the work of this review, a separate OIG
investigation determined that, during the time that sentenced female inmates were
assigned to MDC Brooklyn, multiple custody staff sexually assaulted female
inmates.91 We discuss the findings of this investigation of staff in the text box
below.

88

DOJ OIG, Use of Restrictive Housing, 23.

The accreditation report determined that MDC Brooklyn was compliant with all relevant
light access requirements outlined in ACA’s Standards for Adult Local Detention Facilities. ACA’s
standards for access to light, as relevant to our review, are the same for both detention facilities and
adult correctional institutions. However, ACA’s accreditation report covers the institution as a whole
and does not separately describe the female and male housing units. ACA, Standards for Adult Local
Detention Facilities, 4th edition and 2012 Standards Supplement.
89

BOP Program Statement 5300.21, Education, Training, and Leisure Time Standards,
February 18, 2002.
90

We note that as a result of OIG investigations, six BOP staff members from five additional
female institutions have pled guilty to sexual abuse of a ward since January 2016.
91

40

OIG Investigation of Sexual Assaults at MDC Brooklyn
As a result of a nearly yearlong OIG investigation into allegations of sexual abuse of
female inmates at MDC Brooklyn, the U.S. Attorney’s Office for the Eastern District of New
York filed indictments in May 2017 alleging that Lieutenants Carlos Martinez and Eugenio Perez
and Correctional Officer Armando Moronta engaged in criminal sexual acts with female inmates
between 2013 and 2016.
In January 2018, Martinez was found guilty on 20 counts that covered 4 sexual assaults
between December 2015 and April 2016. The evidence at trial established that Martinez
repeatedly raped a female inmate who spoke limited English and worked as a cleaner inside
the prison. Specifically, Martinez raped his victim while she cleaned the Lieutenants’ office on
the weekends, when that area of the institution is generally empty, and monitored security
video footage of the surrounding area to make sure no one would discover him committing
sexual assault. Martinez also threatened his victim with placement in the SHU and additional
jail time if she told anyone what he had done.
In May 2018, Perez was found guilty on 23 counts that covered sexual abuse of 5 women
between January 2013 and September 2016. The evidence at trial established that Perez lured
each of his victims into isolated situations by arranging for them to clean the Lieutenants’
office at night and then used physical force and intimidation to compel the victims to engage in
various sexual acts with him, including oral sex. Perez used his authority over the inmates to
ensure they did not report the abuse.
In November 2017, Moronta pled guilty to four counts of sexual abuse of a ward.
Specifically, between May and June 2016, Moronta engaged in criminal sexual contact and acts
with three female inmates, including fondling a female inmate and causing inmates to perform
oral sex on him while he was assigned to guard their unit.
Sources: U.S. Attorney’s Office, Eastern District of New York, Press Releases, January 19,
2018; May 14, 2018; and November 8, 2017

While BOP recognizes that detention centers offer sentenced inmates less
suitable recreation space and fewer programming opportunities than would be
available in other institutions, we found that BOP does not have a policy that limits
the amount of time sentenced inmates can be assigned to a detention center. We
recognize that, in the case of FCI Danbury, BOP made a difficult decision either to
transfer some female inmates to institutions that offer the appropriate type of
recreation space and programming opportunities or to transfer female inmates to a
detention center closer to their homes. However, we believe that BOP may
continue to confine sentenced inmates for an extended period of time in conditions
it recognizes as inappropriate unless it establishes a policy that defines how long a
sentenced inmate can be confined in a detention center or ensures that the
conditions of confinement at a detention center more closely approximate those of
a non-detention center when sentenced inmates are housed there.
The Lack of a SHU for Female Inmates at Danbury Has Been Disruptive to Operations
During our fieldwork, we found that changes at FCI Danbury have created a
separate challenge for BOP in enforcing discipline on female inmates. In particular,
we found that BOP built the new low security female institution on the FCI Danbury
campus without a SHU, a unit used to separate inmates from the general
41

population for protective or disciplinary purposes.92 Because BOP does not house
female inmates and male inmates in the same unit, Danbury staff cannot use the
SHU at the all-male institution to house female inmates for whom the SHU is
appropriate. As a result, when Danbury staff determine that a female inmate
should be separated from the general population, they must transport the inmate
more than 150 miles to Federal Detention Center (FDC) Philadelphia.
We found that before construction on the new low security institution was
completed, both the former and current Wardens of FCI Danbury expressed concern
to BOP leadership that the construction plans did not include a SHU. They further
explained that, without secure housing, Danbury staff would be forced to utilize
secure housing in other facilities, which could cause operational problems. Despite
these warnings, the BOP Central Office told OIG that it did not include a SHU in the
construction plans because the new institution would have only a small number of
low security inmates (its capacity is 192) and BOP did not believe this population
necessitated the construction of a SHU.
Danbury staff told us that it is difficult to enforce rules and investigate
misconduct at the institution given this arrangement. During our visit to FCI
Danbury, we found that the operational challenges predicted by the former and
current Wardens have manifested themselves. According to the current Warden,
Danbury staff are less likely to recommend SHU placement for an inmate who
misbehaves because of the challenges of transporting those inmates to FDC
Philadelphia. The Warden also told us that the female inmates understand these
challenges and, on occasion, are emboldened to misbehave.
FCI Danbury’s Lieutenant for Special Investigative Services also told us that
it is difficult to investigate inmate misconduct once the suspected inmates have
been transferred to FDC Philadelphia because the Lieutenant cannot conduct
in-person interviews with Danbury inmates housed at FDC Philadelphia. Instead,
he must rely on a Special Investigative Services investigator at FDC Philadelphia to
conduct the interview. The Lieutenant said that, although he is satisfied with the
quality of his FDC Philadelphia colleagues’ investigative work, he would prefer to
conduct the interviews himself because he is more familiar with the inmates and
the situation he is investigating than his colleagues in other institutions.
The current Warden of FCI Danbury explained that in order to minimize the
burden of transferring female SHU inmates long distances she was looking to
identify a nearby jail that could house Danbury’s female SHU inmates. This solution
has been implemented by at least one other similarly situated institution, which we
visited during our review. However, as of August 2017 the Warden had not yet
identified an appropriate jail.

92 With the opening of the new low security female institution, at the time of our review there
were three institutions on the FCI Danbury campus: (1) FCI Danbury, a low security male institution
that, prior to May 2014, was a low security female institution; (2) Federal Prison Camp Danbury, a
minimum security female institution; and (3) Federal Satellite Low Danbury, the new low security
female institution. We refer to BOP staff who work at any of the three institutions as “Danbury staff.”

42

CONCLUSION AND RECOMMENDATIONS
Conclusion
Overall, we concluded that BOP has not been strategic in its management of
female inmates. At the Central Office level, we found that BOP only recently took
initial steps to implement oversight of the Female Offender Manual. We also found
that BOP may not have allocated sufficient resources to the Women and Special
Populations Branch to fulfill its complete range of responsibilities with regard to
female inmates and that it has not ensured that BOP decision makers understand
how female inmates’ needs differ from those of male inmates. At the institution
level, we identified deficiencies in how BOP staffs its trauma treatment program,
makes staff and inmates aware of its pregnancy programs, distributes feminine
hygiene products, and staffs correctional posts where female inmates are searched.
Finally, we found that BOP’s conversion of FCI Danbury from a female to a male
institution negatively affected female inmates transferred to MDC Brooklyn. For
BOP to be fully effective at appropriately managing female inmates, we believe that
it must take a holistic approach at the Central Office level to identify and address
issues affecting this population.
Recommendations
To ensure that BOP is better positioned to identify and respond to female
inmates’ needs at the Central Office level, provide female inmates with
programming that addresses their unique needs, and consider female inmates’
needs in policy and operational decisions, we recommend that BOP:
1.

Fully implement ongoing plans to create a permanent program review for the
Female Offender Manual that includes in-person visits and an institutionspecific rating.

2.

Determine the appropriate level of staffing that should be allocated to the
Women and Special Populations Branch based on an analysis of its broad
mission and responsibilities.

3.

Ensure that all officials who enter into National Executive Staff positions have
taken appropriate, current training specific to the unique needs of female
inmates and trauma-informed correctional care.

4.

Identify ways to expand the staffing of the Resolve program.

5.

Improve the communication of its pregnancy program availability and
eligibility criteria to relevant staff and pregnant inmates to ensure consistent
understanding across BOP institutions.

6.

Improve data tracking to allow it to more easily identify inmates who are
aware of, interested in, eligible for, or participating in pregnancy programs,
as well as to assess barriers to participation.

43

7.

Clarify guidance on the distribution of feminine hygiene products to ensure
sufficient access to the amount of products inmates need free of charge.

8.

Improve the availability of female staff at locations in female institutions
where inmate searches are common, through the establishment of genderspecific posts or other methods.

9.

Establish policy that determines how long sentenced inmates can be confined
in a detention center, or ensures that the conditions of confinement and
inmate programming at a detention center more closely approximate those
of a non-detention center when sentenced inmates are housed there.

10.

Explore options to procure female Special Housing Unit space closer to
Federal Correctional Institution Danbury.

44

APPENDIX 1
METHODOLOGY OF THE OIG REVIEW
Standards
OIG conducted this review in accordance with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Inspection and
Evaluation (January 2012).
Purpose and Scope
OIG conducted this review to examine BOP’s efforts and capacity to ensure
that BOP-wide policies, programs, and decisions address the unique needs of
female inmates. Our review analyzed BOP inmate population data, as well as BOP
policies and programs from FY 2012 through FY 2016. We also included in our
analysis the revised Female Offender Manual issued by BOP in November 2016, as
well as new staff training materials that BOP launched in FY 2017, during the course
of our fieldwork. We focused our analysis on how BOP’s Women and Special
Populations Branch and other relevant BOP branches implement gender-responsive
trauma treatment and pregnancy programs and examined how BOP has
implemented policies relevant to physical searches of female inmates and inmate
access to feminine hygiene products. Lastly, we examined how BOP’s decision to
convert its low security institution in Danbury, Connecticut, from a female
institution to a male institution affected the female inmates who had been housed
there. Our review focused on federal offenders incarcerated in the 28 BOPmanaged institutions whose populations are all female or mixed gender. We
excluded from our analysis inmates housed in contract halfway houses and contract
state and local institutions. BOP does not house female inmates in private
correctional institutions.
Methodology
Our fieldwork, conducted from July 2016 through September 2017, included
interviews, data collection and analyses, and document reviews. We interviewed
officials from six divisions of BOP’s Central Office. We conducted site visits to 12 of
the 28 institutions where BOP houses female inmates, including 5 institutions
through video teleconference and 7 institutions in person. For each site visit, we
interviewed institution officials and staff. For those institutions that we visited in
person, we also interviewed inmates, toured housing units and programming space,
and observed the physical landscapes. We visited all three types of BOP institutions
for female inmates: minimum security, low security, and administrative. Our site
visits also encompassed female institutions; mixed-gender institutions, including a
detention center; and BOP’s only Federal Medical Center for female inmates.
The seven sites that we visited in person were Federal Correctional
Institution (FCI) Aliceville, Federal Medical Center Carswell, Federal Prison Camp
(FPC) Bryan, FCI Dublin, Secure Female Facility Hazelton, Metropolitan Detention
Center (MDC) Brooklyn, and FCI Danbury. The five sites where we conducted video
teleconferences were FPC Alderson, Federal Correctional Complex (FCC) Victorville,
FCI Marianna, FCC Coleman, and FCI Phoenix.
45

Data Analysis
We analyzed both raw data and data reports provided by BOP, from its
prisoner management system, SENTRY, to assess BOP’s inmate population and
pregnancy program participation. Additionally, to determine whether BOP housed
an inmate closer to or farther from home following the inmate’s transfer from FCI
Danbury, we reviewed SENTRY zip code and transfer location data for the
1,127 inmates transferred from FCI Danbury between August 2013 and March
2014. We performed two SAS calculations to conduct this analysis. First, we
calculated the distance between a transferred inmate’s home zip code and FCI
Danbury’s zip code. Second, we calculated the distance between that inmate’s
home zip code and the zip code of the BOP institution to which that inmate was
transferred.
We did not consider the 445 non-U.S. citizen inmates whom BOP transferred
or released from FCI Danbury in this analysis because most of these inmates did
not have a U.S. residence prior to incarceration. Due to data limitations, we were
also unable to conduct a distance analysis for 7 of the 682 U.S. citizen female
inmates transferred or released from FCI Danbury.
Interviews
We conducted 217 interviews during the course of this review. We
interviewed Central Office officials, including the Assistant Director for the
Correctional Programs Division, the General Counsel, a Senior Deputy Assistant
Director for the Program Review Division, the Assistant Director of the Reentry
Services Division, the Senior Deputy Assistant Director for the Reentry Services
Division, the Women and Special Populations Branch Administrator, the Residential
Reentry Management Branch Administrator, the Education Branch Assistant
Administrator, the former and current Chiefs and a Section Chief of the Designation
and Sentence Computation Center, the Acting Chief of the Construction and
Environmental Assessments Branch, the Chief of Mental Health Services, a Mental
Health Treatment Coordinator, and two Social Science Research Analysts in the
Capacity Planning Branch.
During our site visits, we interviewed 193 staff and inmates, including
10 Wardens, 6 Associate Wardens, 1 Executive Assistant, 1 Captain, 9 Lieutenants,
13 Correctional Officers, 5 Chief Psychologists, 1 Acting Chief Psychologist,
4 Resolve Coordinators, 3 Psychologists, 1 Female Integrated Treatment Program
Coordinator, 1 Chief Social Worker, 5 Social Workers, 6 Health Services
Administrators, 5 Assistant Health Services Administrators, 2 Clinical Directors,
1 Infectious Disease Coordinator, 1 Health Technician, 1 Pharmacy Technician,
10 Supervisors of Education, 2 Assistant Supervisors of Education, 1 Supervisor of
Recreation, 1 Case Management Coordinator, 1 Assistant Case Management
Coordinator, 3 Reentry Services Coordinators, 3 Unit Managers, 14 Case Managers,
14 Counselors, 1 Facilities Manager, 1 Maintenance Supervisor, 1 Supervisory
Contract Specialist, and 61 inmates. Additionally, we interviewed the program
coordinators from four different contract sites that operated BOP’s Mothers and
Infants Nurturing Together residential program as of December 2017.
46

Outside BOP, we interviewed a Section Chief from the DOJ Civil Rights
Division, Special Litigation Section, as well as three judges from the National
Association of Women Judges who were familiar with BOP operations related to
female inmates.
Finally, we interviewed officials from the correctional agencies of four states
(Alabama, Kansas, Washington, and Wisconsin), as well as the U.S. Navy, to
discuss how those agencies meet similar challenges in the management of their
female inmate populations. In the report, we refer to the four states and the Navy
collectively as five state correctional agencies.

47

APPENDIX 2
MAP OF BOP INSTITUTIONS FOR SENTENCED FEMALE INMATES

16

6

12
7

9
1

8

10

15
13
2
4

11 14

3

5

Key to the Map
#

Number of
Female
Institutions
on Site

Name

Security Level(s) of
Female Institution(s)

1

Federal Prison Camp Alderson

1

Minimum

2

Federal Correctional Institution Aliceville

2

Low and Minimum

3

Federal Prison Camp Bryan

1

Minimum

4

Federal Medical Center Carswell

2

Minimum and Administrative

5

Federal Correctional Center Coleman

1

Minimum

6

Federal Correctional Institution Danbury

2

Low and Minimum

7

Federal Correctional Institution Dublin

2

Low and Minimum

8

Federal Correctional Institution Greenville

1

Minimum

9

Federal Correctional Institution Hazelton

1

Low

10

Federal Medical Center Lexington

1

Minimum

11

Federal Correctional Institution Marianna

1

Minimum

12

Federal Correctional Institution Pekin

1

Minimum

13

Federal Correctional Institution Phoenix

1

Minimum

14

Federal Correctional Institution Tallahassee

1

Low

15

Federal Correctional Institution Victorville II

1

Minimum

16

Federal Correctional Institution Waseca

1

Low

48

APPENDIX 3
BOP’S RESPONSE TO THE DRAFT REPORT

49

50

51

APPENDIX 4

OIG ANALYSIS OF BOP’S RESPONSE
OIG provided a draft of this report to BOP for its comment. BOP’s response
is included in Appendix 3 to this report. OIG’s analysis of BOP’s response and the
actions necessary to close the recommendations are discussed below. Please
provide a status update on the 10 recommendations by December 31, 2018.
Recommendation 1: Fully implement ongoing plans to create a permanent
program review for the Female Offender Manual that includes in-person visits and
an institution-specific rating.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would fully implement ongoing plans to create a permanent program review for the
Female Offender Manual that includes in-person visits and an institution-specific
rating.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide a copy of program review guidelines for the
Female Offender Manual that include in-person visits and an institution-specific
rating, as well as a schedule of Female Offender Manual program reviews by
institution for calendar year 2019.
Recommendation 2: Determine the appropriate level of staffing that
should be allocated to the Women and Special Populations Branch based on an
analysis of its broad mission and responsibilities.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would determine the appropriate level of staffing that should be allocated to the
Women and Special Populations Branch based on an analysis of its broad mission
and responsibilities.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide a copy of the analysis BOP performed of the
branch’s mission and responsibilities, including a conclusion about the appropriate
staffing level for the work identified.
Recommendation 3: Ensure that all officials who enter into National
Executive Staff positions have taken appropriate, current training specific to the
unique needs of female inmates and trauma-informed correctional care.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would ensure that all officials who enter into National Executive Staff positions have

52

taken appropriate, current training specific to the unique needs of female inmates
and trauma-informed correctional care.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide an update to the Bureau Mandatory Training
Standards or other relevant policy showing how BOP will ensure that all officials
entering into National Executive Staff positions have taken BOP’s current training
specific to the unique needs of female inmates and trauma-informed correctional
care.
Recommendation 4: Identify ways to expand the staffing of the Resolve
program.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would identify ways to expand the staffing of the Resolve program.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide OIG with a copy of BOP’s analysis of the Resolve
program’s staffing needs and the option BOP selected.
Recommendation 5: Improve the communication of its pregnancy program
availability and eligibility criteria to relevant staff and pregnant inmates to ensure
consistent understanding across BOP institutions.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would improve the communication of its pregnancy program availability and
eligibility criteria to relevant staff and pregnant inmates to ensure consistent
understanding across BOP institutions.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide a copy of any notices, operations memoranda,
program statements, or other written materials used to communicate information
about pregnancy program availability and eligibility criteria to inmates and
institution staff. Please also include a description of how the materials were
disseminated and a list of the institutions and position titles of the addressees who
received them.
Recommendation 6: Improve data tracking to allow it to more easily
identify inmates who are aware of, interested in, eligible for, or participating in
pregnancy programs, as well as to assess barriers to participation.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would improve data tracking to allow it to more easily identify inmates who are

53

aware of, interested in, eligible for, or participating in pregnancy programs, as well
as to assess barriers to participation.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please describe how BOP intends to track pregnant inmates to
more easily identify inmate awareness of, interest in, eligibility for, participation in,
and barriers to participation in BOP’s two pregnancy programs.
Recommendation 7: Clarify guidance on the distribution of feminine
hygiene products to ensure sufficient access to the amount of products inmates
need free of charge.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would clarify guidance on the distribution of feminine hygiene products to ensure
sufficient access to the amount of products inmates need free of charge.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide a copy of BOP policy clarifying that female inmates
should have sufficient access to the amount of feminine hygiene products they need,
free of charge, and a description of how the policy was disseminated, including a list
of the institutions and position titles of the addressees who received it.
Recommendation 8: Improve the availability of female staff at locations in
female institutions where inmate searches are common, through the establishment
of gender-specific posts or other methods.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would improve the availability of female staff at locations in female institutions
where inmate searches are common, through the establishment of gender-specific
posts or other methods.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please describe the method BOP selected to improve the
availability of female staff at locations in female institutions where inmate searches
are common.
Recommendation 9: Establish policy that determines how long sentenced
inmates can be confined in a detention center, or ensures that the conditions of
confinement and inmate programming at a detention center more closely
approximate those of a non-detention center when sentenced inmates are housed
there.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would establish policy that determines how long sentenced inmates can be confined
54

in a detention center, or ensures that the conditions of confinement and inmate
programming at a detention center more closely approximate those of a nondetention center when sentenced inmates are housed there.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please provide a copy of BOP policy that defines the length of
time sentenced inmates can be confined in a detention center or describe how BOP
would ensure that the conditions of confinement and inmate programming at
detention centers more closely approximates those of a non-detention center when
sentenced inmates are housed there.
Recommendation 10: Explore options to procure female Special Housing
Unit space closer to Federal Correctional Institution Danbury.
Status: Resolved.
BOP Response: BOP concurred with the recommendation and stated that it
would explore options to procure female Special Housing Unit space closer to
Federal Correctional Institution Danbury.
OIG Analysis: BOP’s planned actions are responsive to our
recommendation. Please describe the options BOP considered to procure female
Special Housing Unit space closer to Federal Correctional Institution Danbury,
research conducted by BOP to assess each option considered, and the option BOP
selected.

55

The Department of Justice Office of the Inspector General (DOJ OIG) is a
statutorily created independent entity whose mission is to detect and deter
waste, fraud, abuse, and misconduct in the Department of Justice, and to
promote economy and efficiency in the Department’s operations.
To report allegations of waste, fraud, abuse, or misconduct regarding DOJ
programs, employees, contractors, grants, or contracts please visit or call the
DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

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