BUREAU OF 

PRISONS

Better Planning and 

Evaluation Could Help 

Ensure Effective Use 

of Retention 

Incentives

Report to the Chairman, Committee on 

the Judiciary, U.S. Senate

December 2017

GAO-18-147

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-147, a report to the 

Chairman, Committee on the Judiciary, U.S. 

Senate 

December 2017

BUREAU OF PRISONS

Better Planning and Evaluation Could Help Ensure

Effective Use of Retention Incentives

What GAO Found

From fiscal years 2012 to 2016, the Department of Justice’s (DOJ) Federal 

Bureau of Prisons’ (BOP) total retention incentive expenditures generally 

increased from $10.7 to $14.0 million and the number of employees receiving

retention incentives increased from 2,024 to 2,460. During those five years, BOP 

spent more than 97 percent of its total retention incentive expenditures on

employees at four BOP institutions in California and for medical professionals 

nationwide. Further, total retention incentive expenditures for medical 

professionals increased by an average of 21 percent per year (see figure).

According to BOP officials, BOP uses retention incentives, for example, to 

supplement BOP’s medical professionals’ salaries which are generally lower 

than private sector salaries.

Bureau of Prisons’ (BOP) Retention Incentive Expenditures by Groups of Occupations, Fiscal 

Years 2012- 2016

BOP has a variety of internal controls in place throughout the retention incentive 

process that help ensure retention incentive applications and approvals meet 

requirements. For example, each application goes through multiple levels of 

review to verify its accuracy and completeness. 

BOP takes steps to determine workforce needs and how to fill those needs, but 

has not strategically planned for and evaluated its use of retention incentives. 

According to BOP, planning for human capital needs is conducted at institutions 

during quarterly meetings, but discussions about these incentives respond to 

short-term staffing situations rather than proactively addressing future staffing 

needs. Including human capital goals and strategies in BOP’s human capital plan 

would create a roadmap so the agency could move from being reactive to its

current workforce needs to being strategic in trying to achieve its long-term 

workforce goals. Additionally BOP has not evaluated the effectiveness of its use 

of retention incentives in retaining staff. As a result, BOP does not know whether 

retention incentives have contributed to employees’ retention in relation to other 

incentives used by BOP. Consistent with key principles for strategic human 

capital planning, planning for and evaluating the use of retention incentives could

help BOP better determine if these incentives are an efficient and effective 

means by which to retain staff. 

View GAO-18-147. For more information, 

contact Diana Maurer at (202) 512-9627 or 

maurerd@gao.gov.

Why GAO Did This Study

BOP is the largest employer within 

DOJ and is responsible for the care 

and custody of an inmate population of 

about 186,000. BOP has faced 

challenges retaining staff at 

correctional facilities, although it has 

used retention incentives, along with 

other human capital flexibilities. GAO 

was asked to review BOP’s use of 

retention incentives. 

This report addresses: (1) how BOP 

used its authority to pay retention 

incentives; (2) internal controls BOP 

has in place for the use of retention 

incentives; and (3) the extent to which 

BOP plans for and evaluates the use of 

retention incentives. GAO obtained 

employee-level retention incentive 

expenditure data from DOJ’s Justice 

Management Division for fiscal years 

2012 through 2016. GAO also 

reviewed agency documentation, such 

as policy statements and 40 randomly

selected retention incentive application 

packet case files from fiscal years 

2014 through 2016. GAO also 

interviewed officials from BOP’s

Central Office and four correctional 

facilities that use retention incentives,

selected to reflect variation in the 

number and types of employees 

receiving retention incentives, BOP 

regions, and BOP institution security 

levels. 

What GAO Recommends

GAO recommends that BOP (1) 

include human capital goals and how 

retention incentives will be used to 

achieve these goals in its human 

capital plan; and (2) evaluate the use 

of retention incentives. BOP concurred 

with GAO’s recommendations.
Page i GAO-18-147 BOP Retention Incentives

Letter 1

Background 4

BOP Increased Its Use of Retention Incentives and Used Them 

Primarily to Retain Staff in California and for Medical 

Professionals Nationwide 9

BOP Has a Variety of Internal Controls in Place throughout the 

Retention Incentive Process 17

BOP Conducts Limited Planning and Evaluation of the 

Effectiveness of Retention Incentives 22

Conclusions 26

Recommendations for Executive Action 26

Agency Comments 26

Appendix I Objectives, Scope, and Methodology 28

Appendix II Bureau of Prisons’ Use of Retention Incentives by Occupations in 

Fiscal Year 2016 32

Appendix III GAO Contact and Staff Acknowledgments 42

Tables

Table 1: Bureau of Prisons’ (BOP) Retention Incentive 

Expenditures and Number of Employees Who Received 

Retention Incentives, Fiscal Years (FY) 2012 through 

2016 9

Table 2: Bureau of Prisons’ (BOP) Use of Retention Incentives by 

Occupations, Fiscal Year 2016 32

Figures

Figure 1: Number of Years Bureau of Prisons’ (BOP) Employees 

Received Retention Incentives, Fiscal Years 2012 

through 2016 10

Figure 2: Percentage Share of Total Retention Incentive 

Expenditures for Bureau of Prisons’ (BOP) Four 

California Institutions and Medical Professionals, Fiscal 

Year 2016 11

Contents
Page ii GAO-18-147 BOP Retention Incentives

Figure 3: Bureau of Prisons’ (BOP) Retention Incentive 

Expenditures and Number of Employees who Received 

Retention Incentives across Institutions, Fiscal Years 

2012 through 2016 13

Figure 4: Bureau of Prisons’ (BOP) Retention Incentive 

Expenditures by Groups of Occupations, Fiscal Years 

2012 through 2016 16

Abbreviations

3R Recruitment, Relocation, and Retention 

BOP Federal Bureau of Prisons

CPU Consolidated Processing Unit

DOJ Department of Justice

FBI Federal Bureau of Investigation

FCC Federal Correctional Complex

FCI Federal Correctional Institution

GS General Schedule

HHS Department of Health and Human Services

HRMD Human Resource Management Division

JMD Justice Management Division

OIG Office of the Inspector General

OMB Office of Management and Budget

OPM Office of Personnel Management

PHS Public Health Service

PRD Program Review Division

SERS Staffing and Employee Relations Section

USP United States Penitentiary

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

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Page 1 GAO-18-147 BOP Retention Incentives

441 G St. N.W.

Washington, DC 20548

December 7, 2017

The Honorable Charles E. Grassley

Chairman

Committee on the Judiciary

United States Senate

The Federal Bureau of Prisons (BOP) is the largest employer within the 

Department of Justice (DOJ). Its staff are responsible for managing the 

care and custody of an inmate population of about 186,000, but BOP has 

faced challenges retaining staff at some of its correctional facilities. With a 

fiscal year 2017 budget of more than $7 billion—a quarter of DOJ’s 

budget—and about 40,000 employees, BOP uses retention incentives, 

along with other human capital flexibilities, to help retain its staff.1

Over the last decade, we, along with the Office of Personnel Management 

(OPM), DOJ, and DOJ’s Office of the Inspector General (OIG), have 

reported on the challenges BOP encounters when trying to retain or hire 

staff critical to the care of prisoners, such as medical professionals. 

These reviews showed, in part, that BOP faced challenges in retaining 

employees at federal institutions primarily because the private sector 

offered higher pay and more desirable work conditions, which was 

especially attractive to BOP personnel who were assigned to remote 

locations.2 These reviews found that, as a result of these challenges,

BOP had agency-wide staffing shortages, including mission-critical skills 

gaps that could have a significant impact on BOP’s mission. For example, 

as of June 2017, only 82 percent of BOP’s authorized medical positions 

were filled.

 1

Retention incentives are a type of compensation-based human capital flexibility intended 

to help federal agencies address human capital challenges and to build and maintain a 

high-performing workforce with essential skills and competencies. Retention incentives 

are one of the “3R” incentives, along with recruitment and relocation incentives. According 

to the Office of Personnel Management (OPM), the intent of 3R incentives is to provide 

agencies with discretionary authority to help recruit, retain, and relocate employees in 

difficult staffing situations. 

2

OPM, Recruitment, Relocation, and Retention Incentives Calendar Year 2007: Report to 

the Congress (September 2008); Justice Management Division, DOJ, BOP Staffing Study

(Washington, D.C.: August 2010); GAO, Bureau of Prisons: Management of New Prison 

Activations Can Be Improved, GAO-14-709 (Washington, D.C.: August 22, 2014); DOJ 

OIG, Review of the Federal Bureau of Prisons’ Medical Staffing Challenges, Evaluations 

and Inspections Division 16-02 (March 2016) and GAO, High-Risk Series: An Update,

GAO-15-290 (Washington, D.C.: February 2015).

Letter
Page 2 GAO-18-147 BOP Retention Incentives

According to BOP officials and OPM, BOP uses retention incentives to 

better attract, hire, and retain top talent to work at remote locations and in 

undesirable working conditions and to help address staffing challenges at 

some institutions. You asked us to review BOP’s use of retention 

incentives. For this report, we provide information regarding (1) how BOP 

has used its authority to pay retention incentives; (2) what internal 

controls BOP has in place for the use of retention incentives; and (3) the 

extent to which BOP plans for and evaluates the use of retention 

incentives.

To determine how BOP used its authority to pay retention incentives, we 

obtained employee-level retention incentive expenditure data from DOJ’s 

Justice Management Division (JMD) for fiscal years 2012 through 2016.3

We analyzed data from this period in order to capture the most recent 

trends in BOP’s retention incentive expenditures and report on the most 

current data available. We aggregated and analyzed the employee-level 

data by institution, occupation, and employee grade level. We reviewed 

BOP, DOJ, and OPM manuals to identify the system codes used to track 

retention incentives expenditures related to specific institutions and BOP 

regions and to identify the names for each occupational series code in the 

datasets. We also obtained aggregated retention incentive expenditure 

data from U.S. Department of Health and Human Services’ (HHS) Public 

Health Service (PHS) on the total amount of funds BOP reimbursed 

PHS.4 These funds were used to reimburse for retention incentives 

awarded to PHS staff who were assigned to BOP for fiscal years 2012 

through 2016. Additionally, we interviewed BOP Human Resource 

Management headquarters officials to obtain information on the primary 

purposes for BOP’s use of retention incentives and their views on 

identified retention incentive expenditures trends. We also interviewed 

PHS officials to better understand how BOP and PHS manage costs, 

including retention incentive expenditures, for PHS staff assigned to BOP. 

To assess the reliability of both BOP employee-level data and PHS 

aggregated data, we examined the data and related controls, and we 

 3

The Justice Management Division serves as the focal point for performance and financial 

information for all Department of Justice components and employees, including BOP.

4

BOP partners with HHS PHS to acquire medical staff to provide medical care for BOP’s 

inmate population. BOP reimburses PHS for the costs of compensation and benefits—

including retention incentive payments, if applicable—for PHS staff assigned to BOP. PHS 

has final approval authority for retention incentives paid to PHS staff assigned to BOP 

facilities. 
Page 3 GAO-18-147 BOP Retention Incentives

interviewed relevant BOP and PHS officials. We determined these data 

are sufficiently reliable for the purposes of this report.

To describe the internal controls that BOP has in place related to 

retention incentives, we reviewed documentation regarding BOP 

requirements and guidance for the use of retention incentives. We also 

interviewed officials from BOP’s Central Office who are responsible for 

the administration, management, and oversight of BOP’s human capital 

management systems, including retention incentives. Additionally, we 

interviewed the warden and human capital officers at 4 of the 122 BOP 

institutions to obtain illustrative examples regarding the internal controls in 

place at these institutions for ensuring the proper disbursement of 

retention incentives. Specifically, we interviewed BOP officials at Federal 

Correctional Complex Pollock in Pollock, LA; Federal Correctional 

Complex Butner in Butner, NC; United States Penitentiary Atwater in 

Atwater, CA and Federal Correctional Institution Phoenix, in Phoenix, AZ. 

These institutions were selected to ensure variation in the number and 

types of employees receiving retention incentives, BOP region, and 

security-level. Although the information we obtained from the interviews 

with officials at these four institutions cannot be generalized to other BOP 

institutions, these interviews provided important insights and perspectives 

about the use of retention incentives at BOP institutions. We also 

reviewed a non-generalizable random sample of 40 retention incentive 

application packet case files for fiscal years 2014 through 2016 to provide 

examples of the internal control activities that BOP institutions have in 

place to monitor the application, approval, and funds disbursement 

processes of BOP’s retention incentive program.

To determine the extent to which BOP plans for and evaluates the use of 

retention incentives, we interviewed BOP officials regarding their 

experiences with retention incentives, how they use retention incentives 

to strategically manage their workforce needs, how the agency evaluates 

the effectiveness of retention incentives, and how retention incentives 

contribute to BOP’s broader human capital goals. We then compared 

BOP efforts to our prior work on strategic human capital planning, 

specifically in terms of planning for and evaluating the use of human 
Page 4 GAO-18-147 BOP Retention Incentives

capital flexibilities.5 Additionally, we interviewed the warden and human 

capital officers at the four BOP institutions mentioned above to obtain 

illustrative examples of how workforce planning occurs at these 

institutions. We also reviewed the DOJ OIG’s relevant work and our prior 

reports to better understand the challenges that BOP faces in retaining 

medical professionals and other staff.

We conducted this performance audit from August 2016 through 

December 2017 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

BOP is responsible for incarcerating all federal offenders sentenced to 

prison. To carry out its mission, BOP, under the oversight of DOJ’s JMD, 

manages the human resource operations of its institutions, including the 

use of retention incentives. BOP administers, monitors, and oversees 

retention incentives through its Central Office, regional offices, and 

institutions.6

Central Office. The Central Office serves as BOP’s headquarters and 

provides oversight of BOP operations and program areas. Within the 

Central Office is BOP’s Human Resource Management Division (HRMD) 

which is responsible for developing, implementing and administering 

human resource policies and programs, including the use of retention 

 5

GAO, FBI Counterterrorism: Vacancies Have Declined, but FBI Has Not Assessed the 

Long-Term Sustainability of Its Strategy for Addressing Vacancies, GAO-12-533 

(Washington, D.C.: Apr. 16, 2012); GAO, High-Risk Series: An Update, GAO-11-278 

(Washington, D.C.: February 2011); GAO, Human Capital: Key Principles for Effective 

Strategic Workforce Planning, GAO-04-39 (Washington, D.C.: Dec. 11, 2003); GAO, 

Human Capital: Effective Use of Flexibilities Can Assist Agencies in Managing Their 

Workforces, GAO-03-02 (Washington, D.C.: Dec. 6, 2002); GAO, A Model of Strategic 

Human Capital Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002).

6

BOP’s 122 institutions are operated at 5 different security levels: minimum, low, medium, 

high, or administrative. Facilities with different security levels that are in close proximity to 

each other are known as prison complexes.

Background

Justice Management Division (JMD)

JMD provides the Federal Bureau of Prisons 

senior management with guidance as it 

relates to Department of Justice (DOJ) policy 

for all matters pertaining to organization, 

management, and administration, including 

the use of human capital flexibilities such as 

retention incentives. 

Source: DOJ. | GAO-18-147

BOP’s Organization and 

Workforce
Page 5 GAO-18-147 BOP Retention Incentives

incentives that meet OPM and DOJ requirements.7 In addition, the 

Central Office’s Program Review Division (PRD) is responsible for 

assessing BOP programs, including human resources, to ensure that they 

are managed and operated effectively.

Regional offices. BOP has six regional offices that cover the MidAtlantic, North Central, Northeast, South Central, Southeast, and Western 

regions of the United States. These offices, each led by a regional 

director, oversee the operations of the 122 federal institutions within their 

respective geographic regions of the country. According to BOP officials, 

regional office staff also provide local level oversight of institutions’

human capital programs, such as retention incentives, among other 

things.

Institutions. BOP institutions are managed by a warden and other 

officials, including an executive assistant and associate warden who 

generally provide overall direction and, in part, administer the institution’s 

human capital policies, including policies on retention incentives. 

Correctional services staff represent the largest segment of each 

institution’s workforce and are responsible for the correctional treatment, 

custody, and supervision of inmates. Non-correctional services staff 

include, among others, those employees assigned to non-correctional 

services management, facility operations, and the health services unit.8

Workers in health services and psychology services are responsible for 

providing inmates with medical, dental, and mental health services and 

include, for example, dentists, pharmacists, physicians, nurses, 

psychologists, and drug treatment specialists.

The Federal Employees Pay Comparability Act of 1990 first authorized 

OPM to allow federal agencies to give incentives, including retention 

incentives, to employees.9 The Federal Workforce Flexibility Act of 2004 

provided federal agencies increased flexibilities regarding these 

 7

HRMD’s responsibilities include coordinating BOP’s personnel matters, incentive awards, 

retirement, and performance evaluations, among others. 

8

BOP also employs other staff, such as human resource specialists, which provide 

support and technical assistance in all areas of human resources; safety and compliance 

specialists; accountants, attorneys, secretaries, electricians, food services, and 

maintenance mechanics to help, for example, administer BOP programs and support 

operational readiness.

9

Pub. L. No. 101-509, § 208, 104 Stat. 1389, 1458-1460.

Federal Laws and 

Regulations Related to 

Retention Incentives
Page 6 GAO-18-147 BOP Retention Incentives

incentives.10 For example, individual retention incentives that were 

capped at 25 percent of an employee’s basic pay rate could be increased 

up to 50 percent in cases of critical agency need with OPM’s approval. 

Generally, under OPM regulations, an agency is authorized to pay a 

retention incentive to employees. This happens when the agency 

determines that the unusually high or unique qualifications of the 

employee or a special need of the agency for the employee’s services 

makes it essential to retain the employee and that the employee would be 

likely to leave federal service in the absence of an incentive.11 In addition, 

OPM requires agencies to develop plans for using retention incentives 

outlining, in part, the required documentation for justifying the retention 

incentive and any criteria for determining the amount of incentive and the 

length of the service period.12 Generally, agencies must require that 

employees sign a written service agreement that outlines the terms of the 

service such as the employee’s agreement to remain a certain length of 

time with the agency.13 Additionally, according to OPM regulations, to 

qualify for a retention incentive, each employee must have a performance 

rating of at least “fully successful” or an agency’s equivalent performance 

rating.14

 10Pub. L. No. 108-411, § 101, 118 Stat. 2305, 2305-2311.

115 C.F.R. §§ 575.301, 575.306. 

125 C.F.R. § 575.307.

13The term “service agreement” means a written agreement between an agency and an 

employee outlining the terms of the retention incentive. Under 5 C.F.R. § 575.310, before 

paying a retention incentive, an agency must require an employee, including each 

employee covered by a group retention incentive authorization and any employee who 

may receive a higher retention incentive as a result of an OPM-approved waiver, to sign a 

written service agreement to complete a specified period of employment with the agency 

with certain exceptions. A written service agreement is not required if the agency pays the 

retention incentive in biweekly installments, and sets each biweekly installment payment 

at the full retention incentive percentage rate established for the employee under 5 C.F.R. 

§ 575.309(a).

145 C.F.R. § 575.305(d).
Page 7 GAO-18-147 BOP Retention Incentives

BOP funds the majority of its retention incentives through its Salaries and 

Expenses appropriation account which represented almost 93 percent of 

BOP’s budget in FY 2016.15 According to BOP officials, BOP’s Central 

Office allocates funding from the Salaries and Expenses account to the 

regional offices. These regional offices then determine how to allocate 

their budget among various salary and expense activities, including 

retention incentives. HRMD delegates retention incentive determinations 

to each institution. In accordance with OPM requirements and BOP’s 

October 2016 Program Statement on Compensation, the wardens make 

retention incentive requests based on documented evidence that the 

employee possesses unusually high or unique qualifications or meets a 

special need of the agency and has a performance rating of at least 

“successful or its equivalent.”16 These incentives are calculated as a 

percentage of the employee’s basic pay and are disbursed in installments 

to the employee each pay period.

In addition to retention incentives, BOP has authority to provide other 

compensation-based human capital flexibilities to employees, in certain 

circumstances.17 The following summarizes some of the compensationbased human capital flexibilities that BOP uses in addition to retention 

incentives, to retain and recruit staff:

• Recruitment and relocation incentives. BOP pays recruitment 

incentives to new hires and relocation incentives to current employees 

 

15In addition to the Salaries and Expenses account, BOP may also use its Buildings and 

Facilities appropriation account and Trust Fund account—a self-sustaining account that is 

funded through sales of goods and services to inmates—to fund small portions of its 

retention incentive payments. (In fiscal year 2016, payments from the Trust Fund account 

represented about 1 percent of BOP’s retention incentive payments; no retention incentive 

payments were made from the Buildings and Facilities account in fiscal year 2016.) In 

fiscal year 2016, BOP was appropriated $6,948,500,000 to its Salaries and Expenses 

account for the Federal Prison System and $530,000,000 to the Buildings and Facilities 

account, with $444,000,000 of that available only for costs related to the construction of 

new facilities. Consolidated Appropriations Act, 2016, Pub. L. No. 114-113, 129 Stat. 

2242, 2302-2303.

16BOP program statements serve as the formal policies guiding agency operations across 

the entire federal prison system, setting the foundation for how all institutions should 

operate.

17There are also a number of non-compensation-based flexibilities BOP may provide its 

employees such as work arrangements and work-life flexibilities, which include telework, 

health and wellness programs, subsidized transportation, and subsidized education and 

training, among others.

BOP’s Retention Incentive 

Program

Other CompensationBased Human Capital 

Flexibilities
Page 8 GAO-18-147 BOP Retention Incentives

who elect to move to a different geographic area, when a position is 

likely to be difficult to fill in the absence of an incentive.

• Student loan repayments. Using this authority, BOP may repay 

federally-insured student loans to attract job candidates or retain

current employees.

• Special salary rates. With OPM approval, BOP may establish higher 

rates of pay for an occupation or group of occupations nationwide or 

in a local area when it finds the government’s recruitment or retention 

efforts are, or would likely become, significantly handicapped without 

those higher rates.

• Physicians and dental comparability allowances. Comparability 

allowances may be paid to certain eligible physicians or dental 

professionals who enter into service agreements. These allowances 

are paid only to categories of physicians and dentists for which the 

agency is experiencing recruitment and retention problems and are 

fixed at the minimum amounts necessary to deal with such problems.
Page 9 GAO-18-147 BOP Retention Incentives

BOP retention incentive expenditures generally increased from $10.7 

million in fiscal year 2012 to $14.0 million in fiscal year 2016.18

Additionally, as illustrated in table 1, the number of employees who 

received retention incentives increased each year from 2,024 employees 

in fiscal year 2012 to 2,460 employees in fiscal year 2016.

Table 1: Bureau of Prisons’ (BOP) Retention Incentive Expenditures and Number of Employees Who Received Retention 

Incentives, Fiscal Years (FY) 2012 through 2016

FY 2012 FY 2013 FY 2014 FY 2015 FY 2016

Total retention incentive expenditures $10,657,463 $10,515,986 $11,583,960 $12,589,780 $14,035,226 

Number of employees receiving retention 

incentives 2,024 2,133 2,258 2,375 2,460

Source: GAO analysis of BOP retention incentive data. | GAO-18-147

 18Total expenditures do not include retention incentive expenditures for PHS medical staff 

assigned to BOP. HHS has final approval authority regarding whether to pay a retention 

incentive to PHS staff assigned to BOP, and BOP reimburses PHS for the cost of 

compensation and benefits, including retention incentives, for these staff. According to 

PHS, BOP reimbursed PHS $804,260 in retention incentives for 25 of the assigned PHS 

staff in fiscal year 2012 and $886,837 in retention incentives for 31 of the assigned PHS 

staff in fiscal year 2016.

BOP Increased Its 

Use of Retention 

Incentives and Used 

Them Primarily to 

Retain Staff in 

California and for 

Medical Professionals 

Nationwide

BOP’s Total Retention 

Incentive Expenditures 

and the Number of 

Employees Receiving 

Retention Incentives 

Generally Increased from 

Fiscal Year 2012 through 

Fiscal Year 2016
Page 10 GAO-18-147 BOP Retention Incentives

In general, BOP employees who received retention incentives received 

the incentive for more than one year. For example, from fiscal year 2012 

through fiscal year 2016, a total of 3,382 BOP employees received 

retention incentive payments. Of those, 82 percent (2,766 of 3,382) 

received retention incentive payments for at least 2 years and 39 percent 

received retention incentives all 5 years, as shown in figure 1.

Figure 1: Number of Years Bureau of Prisons’ (BOP) Employees Received Retention 

Incentives, Fiscal Years 2012 through 2016

Note: A total of 3,382 BOP employees received retention incentives from fiscal year 2012 through 

2016.
Page 11 GAO-18-147 BOP Retention Incentives

From fiscal years 2012 through 2016, BOP spent more than 97 percent of 

its total retention incentive expenditures on employees at four California 

institutions and for medical professionals nationwide. BOP’s total 

retention incentive expenditures for the four California institutions and 

medical professionals nationwide in fiscal year 2016 are provided in figure 

2.

Figure 2: Percentage Share of Total Retention Incentive Expenditures for Bureau of 

Prisons’ (BOP) Four California Institutions and Medical Professionals, Fiscal Year 

2016

Notes: The four California Institutions are U.S. Penitentiary Atwater, Federal Correctional Institution 

(FCI) Herlong, FCI Mendota and Federal Correctional Complex Victorville.

Medical professionals are dentists, dental assistants and hygienists, diagnostic radiological 

technologists, health aid and technicians, medical doctors (including psychiatrists), medical 

technologists, nurses, pharmacists and their technicians, physician assistants, practical nurses, and 

psychologists.

BOP Used Retention 

Incentives Primarily at 

Four California Institutions 

and for Medical 

Professionals Nationwide
Page 12 GAO-18-147 BOP Retention Incentives

Four California Institutions. The California institutions—United States 

Penitentiary (USP) Atwater, Federal Correctional Institution (FCI) 

Herlong, FCI Mendota, and Federal Correctional Complex (FCC) 

Victorville—constituted the largest portion of BOP’s total retention 

incentive expenditures, and the level of their expenditures remained 

relatively steady from fiscal year 2012 through 2016. BOP provides group 

retention incentives for staff at the General Schedule (GS) grades level 

12 and below and those in the Federal Wage System at three 

institutions—USP Atwater, FCI Herlong, and FCC Victorville.19 BOP also 

provides individual retention incentives to its employees at GS grades 

level 12 and below and in the Federal Wage System at FCI Mendota. As 

shown in figure 3, our analysis of BOP data found that from fiscal years 

2012 through 2016, these four California institutions had the largest 

percentage of retention incentive expenditures across institutions as well 

as the largest percentage of employees who received retention 

incentives.

 19Generally, according to OPM guidelines established in 5 C.F.R. § 575.305(b), an agency 

may pay a retention incentive to a group or category of employees when the agency 

determines that the unusually high or unique qualifications of the group or category of 

employees or a special need of the agency for the employees’ services makes it essential 

to retain the employees in that group or category and there is a high risk that a significant 

number of the employees in the group would be likely to leave the federal service in the 

absence of a retention incentive.
Page 13 GAO-18-147 BOP Retention Incentives

Figure 3: Bureau of Prisons’ (BOP) Retention Incentive Expenditures and Number of Employees who Received Retention 

Incentives across Institutions, Fiscal Years 2012 through 2016

Note: The four California Institutions are U.S. Penitentiary Atwater, Federal Correctional Institution 

(FCI) Herlong, FCI Mendota, and Federal Correctional Complex Victorville.

Additionally, the four California institutions’ retention incentive 

expenditures remained relatively steady—around $8.1 to $8.2 million 

during the 5-year period—even though the overall number of employees 

who received the incentives generally increased. BOP officials told us that 

these California institutions’ retention incentive expenditures remained 

relatively steady in spite of an overall increase in the number of 

employees receiving incentives, in part, because in fiscal year 2013 BOP 

reduced the retention incentive rate—the percentage of an employee’s 
Page 14 GAO-18-147 BOP Retention Incentives

basic pay that determines the employee’s retention incentive— by 3 

percent at the four California institutions.20

BOP officials reported using retention incentives primarily at these four 

institutions to supplement correctional officers’ salaries and compensate 

for the gap between BOP’s and other institutions’ salaries. Specifically, 

officials told us that these four California institutions were consistently 

understaffed as a result of their lower salaries in comparison to salaries 

offered at California state and local prisons and at other BOP institutions 

in California metropolitan areas. The Department of Labor’s Bureau of 

Labor Statistics reports that the average salary for correctional officers in 

California in 2016 was $70,020.21 For the same year, the annual average 

salary for BOP correctional officers at these four institutions was $50,859. 

To bring these four California institutions’ salaries in line with those 

offered by state, local, and other BOP institutions in California 

metropolitan areas, BOP officials told us that they first use recruitment 

incentives to attract and hire staff and then provide retention incentives to 

employees with a performance rating of at least “successful.”22

Medical Professionals. From fiscal years 2012 through 2016, BOP 

retention incentive expenditures for medical professionals increased by 

an average of approximately 21 percent per year. Our analysis showed 

that most recently—for fiscal years 2015 and 2016—BOP retention 

incentive expenditures for medical professionals accounted for the largest 

portion of BOP’s total retention incentive expenditures across the various 

occupation groups and was primarily responsible for the overall increase 

 20In 2011, OPM and the Office of Management and Budget (OMB) guidance asked 

agencies to ensure that spending on recruitment, relocation, and retention incentive 

awards did not exceed calendar year 2010 levels. In 2013, BOP reduced its retention 

incentive rate at USP Atwater, FCI Herlong, FCI Mendota, and FCC Victorville to comply 

with this guidance and remain within its 2010 spending levels. OPM and OMB, Guidance 

on Awards for Fiscal Years 2011 and 2012, (Washington D.C.: June 2011), CPM 2011-10.

21The Department of Labor’s Bureau of Labor Statistics estimates are calculated with data 

collected from employers in all industry sectors, including state government, local 

government, the federal government and others, such as psychiatric and substance abuse 

hospitals.

22According to BOP policy, all employees who receive a recruitment incentive are required 

to sign a service agreement that outlines the terms of the service such as the employee’s 

agreement to remain a certain length of time with the agency. BOP retention incentive 

policy states that employees who are under a recruitment incentive service agreement 

cannot receive a retention incentive during the time specified by the recruitment incentive 

service agreement. 
Page 15 GAO-18-147 BOP Retention Incentives

in BOP’s total retention incentive expenditures from fiscal year 2012 

through fiscal year 2016.23 For example, in fiscal year 2016, BOP spent 

approximately 42 percent of total retention incentives expenditures for 

medical professionals ($5.8 million), 27 percent on correctional officers 

($3.8 million), and the remaining 31 percent on employees in other 

occupations. In total, BOP retention incentive expenditures for medical 

professionals increased from approximately $2.7 million in fiscal year 

2012 to $5.8 million in fiscal year 2016, as shown in figure 4. The 

increase accounted for 92 percent of BOP’s total increase in retention 

incentive expenditures during the five-year period. In comparison, BOP’s 

retention incentive expenditures for correctional officers and all other 

occupations remained relatively steady from fiscal year 2012 through 

fiscal year 2016, increasing by an average of approximately 1 percent per 

year.

 23Nurses, physicians, dentists, and physician assistants comprise the majority of retention 

incentive expenditures for medical professionals. For a list of retention incentive 

expenditures and number of employees by occupation and grade level for fiscal year 

2016, see appendix II. 
Page 16 GAO-18-147 BOP Retention Incentives

Figure 4: Bureau of Prisons’ (BOP) Retention Incentive Expenditures by Groups of 

Occupations, Fiscal Years 2012 through 2016

According to our analysis, the increase in retention incentive expenditures 

for medical professionals during the five years is partially explained by the 

increase in the number of institutions providing retention incentives to 

medical professionals. Specifically, from fiscal years 2012 through 2016, 

the number of institutions providing retention incentives to medical 

professionals increased from 53 institutions with 341 employees in 

medical occupations receiving retention incentives to 84 institutions 

providing retention incentives to a total of 646 employees in medical 

occupations.

According to BOP officials, BOP primarily uses retention incentives for 

medical professionals in an effort to retain these employees by 

supplementing BOP salaries which are generally lower than salaries 

offered to medical professionals in the private sector. Officials told us that 

BOP has designated medical professional positions as hard-to-fill and, 

therefore, BOP retaining these professionals in a correctional setting 
Page 17 GAO-18-147 BOP Retention Incentives

requires the use of a variety of incentives, including retention incentives, 

in order to increase pay.24

BOP has a number of internal controls in place to ensure that retention 

incentive applications meet BOP and other requirements. BOP officials 

told us that these controls are part of a multilayered application and 

review process that begins at the institution and culminates at BOP’s 

Central Office. Our review of a random sample of 40 application packet 

case files for retention incentives awarded from fiscal year 2014 through 

fiscal year 2016 found that they all generally incorporated the internal 

controls described by officials. The key controls in this process include:

Application review at the institution and regional levels. 

According to BOP officials, the retention incentive application 

process begins with an institution’s human resources office, 

whose staff complete a retention incentive application on behalf of 

an employee. The institution’s human resources office verifies that 

the information in the application justifies a retention incentive and 

that funds are available to pay the incentive. Although it is not 

required, BOP officials said that they use a retention incentive 

application checklist to help institutions ensure that retention 

incentive applications are complete. The institution’s human 

resources office then submits the completed application packet, 

which includes supporting documentation, to the warden for 

review. Next, the application packet is forwarded to the respective 

BOP regional director who also reviews it for accuracy and 

completeness. The regional director then adds an approval 

 24BOP officials said they determine that positions are “hard-to-fill” by the vacancy rate and 

the length of time they remain vacant. From fiscal years 2012 through 2016, BOP 

increased the number of employees in medical occupations who received retention 

incentives from 341 to 646.

BOP Has a Variety of 

Internal Controls in 

Place throughout the 

Retention Incentive 

Process

BOP’s Internal Controls 

Are Intended to Ensure 

That Retention Incentive 

Applications and 

Approvals Meet 

Requirements
Page 18 GAO-18-147 BOP Retention Incentives

statement and forwards the packet to the Central Office for final 

review and approval. Of the 40 randomly selected application 

packet case files that we reviewed, 36 included a retention 

incentive checklist used by the institutions and all contained 

information to justify the retention incentive as well as a statement 

of the regional director’s approval.

Central Office’s final application approval. BOP policy requires 

that all retention incentive applications undergo two levels of 

review in BOP’s Central Office: first by the Human Resource 

Management Division’s (HRMD) Staffing and Employee Relations 

Section (SERS) and next by HRMD’s Personnel Director, for final 

review and approval. According to BOP officials, during the review 

process there is ongoing communication between the various 

entities to ensure that applications are complete and accurate; for 

example, if SERS finds an error in the application or requests 

additional information, SERS returns the application to the 

regional or institutional level for correction and re-review. All of the 

40 BOP application packet case files that we reviewed included 

approvals by HRMD’s Personnel Director or an authorized official, 

as required by BOP policy.

Annual review and re-certification to continue retention 

incentives. According to BOP policy, on an annual basis, 

institutions’ human resources offices are required to review 

employees’ retention incentives to determine whether the 

incentive is still warranted. Payment of a retention incentive may 

be recertified and continued as long as the conditions giving rise 

to the original determination to pay the incentive still exist and 

funds are available. For each retention incentive, an institution’s 

human resources office must determine whether to continue,

adjust, or terminate the incentive within one year of the initial or 

most recent approval. If the human resources office decides to 

continue the retention incentive, the institution’s warden must 

again submit a retention incentive application. Applications to 

continue the retention incentive proceed through the same review 

and approval process as initial applications. Of the 40 application 
Page 19 GAO-18-147 BOP Retention Incentives

files that we reviewed, 29 were continuations and 8 were initial 

requests for a retention incentive.25

According to BOP officials, after the initial approval of a retention 

incentive, an institution’s human resources office has primary 

responsibility for the monitoring of retention incentive payments. 

According to officials, institutions use a variety of internal controls to 

monitor the expiration, continuation, or termination of retention incentives, 

for example:

Monitoring expiration dates. BOP officials stated that 

institutions’ human resources offices monitor retention incentives 

in order to identify incentives that are approaching their expiration 

date and need to be terminated or renewed. For example, 

according to BOP officials from USP Atwater, FCC Butner and FCI 

Phoenix, staff from their institutions’ human resources offices may 

generate a retention incentive activity report and cross reference 

this report with their locally generated tracking sheets. This 

process helps identify retention incentives approaching their 

expiration dates so that the human resources offices can submit a 

request for continuation before the incentive expires.

Using automated reminders to prompt file review. BOP 

officials stated that institutions use automated reminders to alert 

human resources staff to check the records of retention incentive 

recipients for human resources-related events such as promotions 

or relocations that could affect the continuation of a retention 

incentive.

Following a checklist of steps for relocation processes. BOP 

officials told us that in April 2016 they instituted a checklist that 

outlines steps that an institution’s human resources staff must 

take when employees relocate to a different institution. Based on 

our review of this checklist, one step on the sheet prompts human 

resources staff to review the employee’s retention incentive.

According to BOP policy, when an employee receiving a retention 

incentive transfers to another location, the human resources office 

 25Three of the application files did not indicate whether the retention incentive was a 

continuation or an initial request. According to BOP officials, the missing information may 

have been an oversight by the institutions that processed the applications. 

BOP Institutions Use 

Internal Controls to Help 

Monitor the Expiration, 

Continuation, or 

Termination of Retention 

Incentives
Page 20 GAO-18-147 BOP Retention Incentives

where the employee was receiving the retention incentive is 

responsible for submitting a request to terminate the incentive. 

The termination must be effective the last day of the pay period 

that the employee occupies the position.26

Submitting forgiveness waivers. BOP officials told us that 

institutions submit forgiveness waivers if a request to continue a 

retention incentive is not submitted and approved prior to the 

retention incentive expiring. BOP officials said that a forgiveness 

waiver is considered an acknowledgement of an administrative 

error and is a late submission of a retention incentive renewal that 

was still warranted. The waiver is not a request to forgive an 

overpayment since the employee was still considered to be 

eligible for the retention incentive. Of the 40 retention incentive 

applications that we reviewed, 5 applications included forgiveness 

waivers to excuse the tardiness of the filing and request 

continuations of the retention incentive.

According to BOP officials, BOP conducts periodic audits and reviews of 

its human capital activities and related internal controls, to ensure that 

retention incentives are being used appropriately. The following offices 

conduct various audits and reviews involving BOP’s retention incentives:

BOP’s Program Review Division (PRD) audits regional and 

institutional human resources functions. PRD audits BOP’s 

regional and institutional human resources offices to ensure that 

they are in compliance with BOP policies and procedures. 

According to BOP officials, as part of the audit process, PRD 

audits retention incentives to ensure that they have the proper 

approvals and are justified. PRD audits each institution’s human 

resources office at least every three years. During these audits, 

PRD generates retention incentive activity reports (the same 

reports that institutions run when monitoring for expiration dates), 

to check the accuracy of retention incentive programs under 

 26Requests to terminate retention incentives are submitted to the Consolidated Processing 

Unit (CPU). The CPU is responsible for processing BOP payroll and personnel 

transactions, including terminating retention incentives; setting pay; maintaining electronic 

Official Personnel Files and performance and payroll files. The CPU is also BOP’s primary 

liaison with DOJ and the National Finance Center on matters related to payroll processing 

and time and attendance.

BOP and DOJ Conduct 

Periodic Reviews of 

Retention Incentive 

Controls
Page 21 GAO-18-147 BOP Retention Incentives

review. Following each audit, PRD issues a final report with 

findings to the institution and to the staff operating the program 

area under audit. Institutions respond to the report with corrective 

actions that the institution will take to address the findings. When 

the institution has resolved all corrective actions from the audit, 

the audit is closed. Additionally, each quarter, PRD provides 

HRMD with a report that summarizes its quarterly audit findings. 

According to BOP officials, HRMD uses these reports to identify 

any agency-wide trends that need to be addressed.

Our review of BOP data showed that between fiscal years 2012 

and 2016, PRD conducted nearly 200 audits. For example, in the 

fourth quarter of fiscal year 2016, PRD audited five institutions’

and regional offices’ human resource management functions. 

During these audits, PRD identified nine deficiencies, one of which 

pertained to retention incentives. Specifically, it found that one 

audited institution did not terminate an employee’s retention 

incentive after the employee had relocated to another institution. 

To correct the deficiency, the institution cancelled the retention 

incentive which discontinued future disbursements. According to 

BOP officials, a bill was generated to recoup the overpayment 

from the employee.

BOP institutions conduct annual operation reviews of internal 

functions, such as human resources. BOP officials told us that 

each institution conducts annual operational reviews of various 

internal functions, such as human resources. According to BOP’s 

Program Review Guidelines for Human Resource Servicing 

Offices, during these reviews, institutions are required to review 

supporting documentation for staff currently receiving an incentive 

to determine if the incentives are still warranted. If the initial 

request for the retention incentive was made over the preceding 

12 months, institutions are also required to ensure that it was 

approved. According to BOP officials, the results of these reviews 

are reported to PRD through the Central Office.

DOJ’s Justice Management Division (JMD) audits BOP’s 

human resources programs. According to BOP officials, JMD 

conducts audits of component-level human resources programs to 

determine whether BOP’s systems are compliant with DOJ policy 

and aligned with DOJ’s Human Capital Strategic Plan. JMD’s most 

recent audit of BOP’s human resources programs that included a 

review of BOP’s retention incentives occurred in September 2010 
Page 22 GAO-18-147 BOP Retention Incentives

at BOP’s Human Resource Service Center in Grand Prairie, 

Texas. JMD found that in some cases BOP granted retention 

incentives prior to the signing of service agreements. JMD also 

found that BOP lacked documentation to authorize a group 

retention incentive for employees at its Victorville, California 

institution. BOP’s written response to the findings stated that JMD 

incorrectly applied the service agreement requirement, as service 

agreements were not warranted in the specific case that it 

identified.27 Additionally, BOP stated that the documents JMD 

identified as missing from the case files in question were kept in 

separate files and not required to be part of the retention incentive 

application. JMD agreed with BOP’s responses and in January 

2013, JMD closed out the audit’s findings noting that these 

responses satisfied all required corrective actions.

While BOP takes a number of steps to determine current workforce needs 

and how to fill those needs, BOP does not strategically plan for how 

retention incentives can be used to meet long-term human capital goals. 

BOP officials stated that planning for human capital needs is conducted at 

institutions during quarterly workforce utilization meetings or manpower 

salary meetings. During these meetings, executive staff at the institution 

discuss the current state of the institution’s workforce. According to the 

BOP officials, while considering attrition, hiring, and turnover rates, the 

executive staff decide strategies they will employ to attract and retain 

employees for their current needs.

 27According to BOP, per OPM regulations, a written service agreement was not required 

because the agency 1) paid retention incentives in biweekly installments and 2) set each 

biweekly installment at the full retention incentive percentage rate established for the 

employee under 5 C.F.R. § 575.309(a).

BOP Conducts 

Limited Planning and 

Evaluation of the 

Effectiveness of 

Retention Incentives

BOP’s Planning for the 

Use of Retention 

Incentives is Limited
Page 23 GAO-18-147 BOP Retention Incentives

While officials we spoke with at four institutions have discussed retention 

incentives at their workforce utilization meetings, details about the content 

of these discussions ranged. According to these officials and our review 

of meeting minutes from the four institutions, discussions about retention 

incentives respond to each institution’s short-term staffing situation rather 

than address future staffing needs based on an overall strategic human 

capital plan. For example:

• USP Atwater officials told us that they review the current turnover 

rate, budget, projected vacancies, and use of retention incentives at 

annual budget development meetings. Meeting minutes reflected the 

following on retention incentives: “retention [incentives]... [are] still 

necessary to retain staff and hard-to-fill positions.”

• FCC Butner is a medical facility that offers retention incentives to all 

medical officers (all types of doctors) and nurses (practitioners, 

registered, etc.) at the institution. According to Butner officials, during 

workforce utilization meetings, Butner officials discuss recruitment and 

staffing trends for the institution and plans for how to address any 

staffing challenges. Meeting minutes we reviewed did not indicate 

specific discussions about the use of retention incentives.

• FCC Pollock executive staff discuss current institutional salary 

expenditures and projections and the status of vacant positions at 

workforce utilization meetings. While meeting minutes we reviewed 

indicated discussions about projected expenditures for incentive 

awards, the minutes did not differentiate between retention incentive 

awards, and other incentive awards such as recruitment or relocation 

incentive awards.

• FCI Phoenix officials stated that in their workforce utilization 

meetings, executive staff discuss salary projections and vacancy 

statuses. Meeting minutes we reviewed did not indicate specific 

discussions about the use of retention incentives.

BOP decisions about retention incentives are currently not tied to any 

strategic human capital plan for how to use human capital flexibilities—

such as retention incentives—to address their ongoing challenge of 

retaining staff in hard-to-fill positions. According to officials, retention 

incentives are awarded on an as-needed basis, determined by an 

institution’s warden, if funds are available.

According to key principles for effective strategic human capital planning, 

such planning is an important component of an agency’s effort to develop 

long-term strategies for acquiring, developing, and retaining staff needed 
Page 24 GAO-18-147 BOP Retention Incentives

for an agency to achieve its goals.28 Specifically, senior leaders should be 

involved in developing, communicating, and implementing strategic 

human capital plans. Within an agency’s strategic human capital plan, the 

human capital policies, practices, and programs—for example, an 

agency’s retention incentive program—should clearly link to the human 

capital and program goals of the organization. By not having a strategic 

human capital plan that clearly establishes strategies that will be used to 

achieve specific human capital goals, BOP cannot ensure that its 

institutions are strategically managing their workforces in a manner that 

meets the agency’s human capital needs.

In August 2017, BOP officials told us that they began drafting a strategic 

human capital operating plan that will include strategic objectives, action 

plans, performance objectives and measures, and evaluation/reporting 

requirements. Officials stated that the plan will also include planning 

regarding the use of human capital flexibilities, such as retention 

incentives. BOP officials told us that they anticipate that the strategic 

human capital operating plan will be a supplement to their workforce 

utilization meetings and that an agency-wide plan will provide a set of 

strategies for all institutions to consider. However, BOP could not provide 

documentation of the project beginning or whether it would include a 

strategic approach specific to retention incentives. Including retention 

incentives in BOP’s strategic human capital operating plan would create a 

roadmap for the agency and the institutions to use to move from being 

reactive in their current workforce needs—for example, awarding 

retention incentives on an ad hoc basis when funds are available—to 

being strategic in how retention incentives are used and to ensure that 

these and other flexibilities help the agency achieve its long-term 

workforce goals.

From fiscal year 2012 through fiscal year 2016, BOP spent more than $59 

million on retention incentives but has not established any measures to 

evaluate their effectiveness. According to officials, BOP has not evaluated 

the effectiveness of its use of retention incentives because BOP officials 

consider a retention incentive successful if an employee does not leave 

the agency. However, BOP also uses other human capital flexibilities 

along with retention incentives to help retain staff. For example, BOP 

uses physician and dental comparability allowances—additional pay to a 

 28GAO-04-39.

BOP Does Not Evaluate 

the Effectiveness of 

Retention Incentives
Page 25 GAO-18-147 BOP Retention Incentives

physician or dentist who enters into an agreement for a specified period 

of service—to help retain these medical personnel. According to officials, 

it would otherwise be difficult to compete with private sector salaries 

without the use of all available incentives. However, BOP has not studied 

whether or how retention incentives have contributed to employees’

retention in relation to other incentives such as physician and dental 

comparability allowances.

According to our work on strategic human capital management and 

OPM’s guidance, it is crucial for organizations to evaluate the success of 

their human capital strategies, such as the use of retention incentives.29

In measuring the performance of these strategies and their contribution to 

key programmatic results, agencies can make adjustments, if 

necessary.30 For example, agencies can use evaluation results to make 

targeted investments in certain human capital strategies—such as the 

use of retention incentives—creating a cycle of strategic workforce 

management, where evaluation informs planning, planning dictates 

strategies, and strategies are evaluated for effectiveness.31 While BOP 

uses retention incentives to address critical skills gaps—such as with 

medical professionals—evaluating the effectiveness of retention 

incentives would help BOP determine whether and how retention 

incentives, as well as other human capital flexibilities, contribute to an 

employee’s continued employment at BOP or if adjustments to BOP 

retention strategies must be made for improved results.

BOP officials agreed that evaluating the effectiveness of retention 

incentives would help them be more strategic about their human capital 

needs and spending on incentives. By including and implementing such 

an evaluation in its upcoming strategic human capital operating plan, 

BOP could better determine if it is making maximum use of its funds to 

retain the necessary qualified personnel or if changes must be made to 

most effectively retain its staff.

 29GAO-11-278; GAO-04-39; and Office of Personnel Management, Human Capital 

Framework.

30According to our work on program evaluation, successful evaluations should articulate 

key elements to help ensure overall usefulness, reliability, objectivity, and timeliness of the 

results. These elements include specific actions, such as developing measurable 

objectives and criteria to measure performance, identifying sufficient data sources and 

methodology, determining and allocating sufficient resources to conduct the evaluation, 

and establishing time frames for completing the evaluation phases. GAO-12-533.

31GAO-02-373SP, GAO-03-02, and GAO-04-39.
Page 26 GAO-18-147 BOP Retention Incentives

As the largest employer within DOJ with some staff working in remote 

locations and undesirable conditions, BOP relies on a number of available 

flexibilities, including retention incentives, to help retain its employees. 

However, BOP currently lacks a strategic approach for using and 

evaluating retention incentives to address human capital goals. Given 

BOP’s ongoing staffing challenges, for example, retaining staff in hard-tofill medical positions, developing a plan that includes a thoughtful 

blueprint for using retention incentives could help BOP better anticipate 

and address staffing needs. Moreover, evaluating its use of retention 

incentives could help BOP determine whether these incentives are 

effective or whether adjustments are needed to better retain its 

employees. By using evaluation results to inform planning, and planning 

to inform how retention incentives are used, BOP would be better 

positioned to achieve its long-term human capital goals and address its 

critical staffing needs.

We are making two recommendations to BOP:

1. The Director of BOP should include in the forthcoming strategic 

human capital operating plan, 1) human capital goals and 2) 

strategies on how human capital flexibilities—including retention 

incentives—will be used to meet these goals. (Recommendation 1)

2. The Director of BOP should evaluate the effectiveness of BOP’s use 

of retention incentives to help determine whether the incentives have 

helped BOP achieve its human capital goals or if adjustments in 

retention incentives are needed. (Recommendation 2)

We requested comments on a draft of this report from DOJ. In an email 

received November 15, 2017, the DOJ liaison stated that DOJ concurred 

with our recommendations. The Department did not provide official written 

comments to include in our report, but did provide written technical 

comments, which we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the Attorney 

General and the Director of BOP. In addition, the report is available at no 

charge on the GAO website at http://www.gao.gov. 

Conclusions

Recommendations for 

Executive Action

Agency Comments
Page 27 GAO-18-147 BOP Retention Incentives

If you or your staff have any questions about this report, please contact 

me at (202) 512-9627 or maurerd@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in Appendix III.

Sincerely yours,

Diana Maurer

Director, Homeland Security and Justice Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-18-147 BOP Retention Incentives

This report examines (1) how BOP has used its authority to pay retention 

incentives; (2) what internal controls are in place for the use of retention 

incentives; and (3) the extent to which BOP plans for and evaluates the 

use of retention incentives.

To determine how BOP has used its authority to pay retention incentives, 

we reviewed BOP’s July 2012 report on its use of recruitment, relocation, 

and retention (3R) incentives. We then obtained underlying retention 

incentive expenditure data from DOJ’s Justice Management Division 

because it serves as the focal point for performance and financial 

information for all Department of Justice components and employees, 

including BOP. In particular, we obtained employee-level retention 

incentive payroll data for fiscal years 2012 through 2016. We selected this 

time period because it includes the most recent five complete fiscal years 

for which data were available and because we believe five years is 

sufficient time to identify trends in BOP’s retention incentive expenditures. 

We analyzed and aggregated the employee-level data by institution, 

occupation, and employee grade level. To identify trends, we compared 

per fiscal year expenditures across the various categories of occupations 

and locations across the five years. Additionally, we categorized 

institutions by BOP region, institutions that use group retention incentives, 

and institutions that use individual retention incentives. We also 

categorized occupations as medical professionals, correctional officers, 

and all other occupations and compared aggregate retention incentive 

expenditures for the different groups. Using information from BOP’s 

website and testimonial evidence from BOP officials on its health care 

system, for the purposes of this report, we defined medical professionals 

as BOP employees in occupations that provide medical, dental, and 

mental health care services and who do not solely provide these services 

in an administrative function. For the purposes of our analyses, medical 

professionals are dentists, dental assistants and hygienists, diagnostic 

radiological technologists, health aid and technicians, medical doctors 

(including psychiatrists), medical technologists, nurses, pharmacists, 

pharmacy technicians, physician assistants, and practical nurses and 

psychologists. To assess the employee-level retention incentive payroll 

data’s reliability, we obtained and analyzed documentation on systems’

capabilities and data control, interviewed data users and managers 

responsible for maintaining data, conducted checks for completeness and 

logical consistency, and compared the employee-level data to aggregated 

institution-level retention incentive expenditure data from BOP’s Financial 

Management Information System. We found the employee-level data to 

be sufficiently reliable for the purpose of this report.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-18-147 BOP Retention Incentives

Additionally for this objective, we reviewed documents such as the DOJ’s 

Financial Management Information System Sub-Object Classification 

Code Guide1 and the Office of Personnel Management (OPM) Handbook 

of Occupational Groups and Families2 to respectively identify the system 

codes used to track retention incentives expenditures and to identify the 

names for each occupational series code in the datasets. We also 

interviewed BOP Human Resource Management headquarters officials to 

obtain information on the primary purposes for BOP’s use of retention 

incentives and their views on identified retention incentive expenditures 

trends. We also interviewed U.S. Department of Health and Human 

Services’ (HHS) Public Health Service (PHS) officials to better 

understand how BOP and PHS manage costs, including retention 

incentive expenditures, for PHS staff assigned to BOP. BOP partners with 

PHS to acquire medical staff to provide medical care for BOP’s inmate 

population. BOP reimburses PHS for the costs of compensation and 

benefits—including retention incentive payments, if applicable—for PHS 

staff assigned to BOP. PHS has final approval authority for retention 

incentives paid to PHS staff assigned to BOP facilities. Furthermore, we 

obtained aggregated retention incentive expenditure data from PHS on 

the total amount of funds BOP reimbursed PHS for fiscal years 2012 

through 2016. For the reliability of PHS’s data, we reviewed the system’s 

data fields to check that the appropriate fields were used to provide data 

and interviewed data users and managers to discuss how expenditures 

are recorded and maintained. We found the PHS data to be sufficiently 

reliable for the purpose of this report.

To identify and describe the internal controls that BOP has in place 

related to retention incentives, we obtained and analyzed documentation 

regarding BOP requirements and guidance for the use of retention 

incentives. We also interviewed officials from BOP’s Central Office who 

are responsible for the administration, management, and oversight of 

BOP’s human capital management systems, including retention 

incentives. We focused on the management and administrative controls 

used by BOP to review, approve, re-certify, and monitor retention 

 1

Federal agencies use Sub-Object Classification Code Guides to standardize budgetary 

information. Sub-Object Classification codes define the nature of services or articles 

obligated, and include codes for items such as, rent, supplies, contractual services, and 

personnel compensation—including retention incentives.

2

Federal agencies use the OPM Handbook of Occupational Groups and Families to 

classify employees’ positions into occupational group or job family consisting of similar line 

of work and qualification requirements. 
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-18-147 BOP Retention Incentives

incentives. Additionally, we interviewed the warden and human capital 

officers at 4 of the 122 institutions to obtain illustrative examples 

regarding the internal controls in place at these institutions to ensure the 

proper disbursement of retention incentives. We interviewed BOP officials 

at Federal Correctional Complex Pollock in Pollock, LA; Federal 

Correctional Complex Butner in Butner, NC; United States Penitentiary, 

Atwater in Atwater, CA and Federal Correctional Institution Phoenix, in 

Phoenix, AZ. These institutions were selected to ensure variation in the 

number and types of employees receiving retention incentives, BOP 

region, and security-level. Although the information we obtained from the

interviews with officials at these four institutions cannot be generalized to 

other BOP institutions, these interviews provided important insights and 

perspectives about the use of retention incentives at BOP institutions. We 

also reviewed a non-generalizable random sample of 40 retention 

incentive application packet case files to determine the extent to which 

these files contained documentation on the internal control activities in 

place to monitor the application, approval, and funds disbursement 

processes of BOP’s retention incentive program. To identify our sample, 

we used employee-level expenditure data to randomly select 40 

application files from the universe of BOP employees who received 

retention incentives from fiscal years 2014 through 2016.3 Each 

application file was reviewed by two GAO analysts who each assessed 

the extent to which each application contained the appropriate 

justification, approval signatures, and other documentation such as an 

application checklist and whether the application was an initial or 

continuation application.

To determine the extent to which BOP plans for and evaluates the use of 

retention incentives, we interviewed BOP officials regarding their 

experiences with retention incentives, how they use retention incentives 

to strategically manage their workforce needs, how the agency evaluates 

the effectiveness of retention incentives, and how retention incentives 

contribute to BOP’s broader human capital goals. We then compared 

these efforts to our work on strategic human capital planning, specifically 

in terms of planning for and evaluating the use of human capital 

flexibilities. Additionally, we interviewed the warden and human capital 

officers at four BOP institutions mentioned above to obtain illustrative 

 3

BOP maintains hard copies of retention incentive application packet case files for three 

years from the date of approval. We selected files for fiscal years 2014 through 2016 

because these years comprised the three most recent fiscal years for which complete 

hard copy files are available.
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-18-147 BOP Retention Incentives

examples of how workforce planning occurs at these institutions. We also 

reviewed the DOJ’s Office of Inspector General Report 16-02 “Review of 

the Federal Bureau of Prisons’ Medical Staffing Challenges” (March 

2016) and our past work to better understand the challenges that BOP 

faces in retaining medical professionals and other staff.
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 32 GAO-18-147 BOP Retention Incentives

Table 2 provides the Bureau of Prisons’ (BOP) fiscal year 2016 retention 

incentive expenditures by various occupations and groups of occupations, 

such as medical professionals, correctional officers, and other 

occupations. A range of occupations are reflected in the table primarily as 

a result of four California institutions—United States Penitentiary (USP) 

Atwater, Federal Correctional Institution (FCI) Herlong, FCI Mendota, and 

Federal Correctional Complex Victorville—providing retention incentives 

to all employees at General Schedule grades level 12 and below and 

those in the Federal Wage System.

Table 2: Bureau of Prisons’ (BOP) Use of Retention Incentives by Occupations, Fiscal Year 2016

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

Medical Professionals

0180

Psychologist

11 1 $568

12 17 $127,774

13 16 $160,477

14 4 $52,851

Total 38 $341,669

0602

Doctors (medical doctors, psychiatrists)

13 1 $1,178

15 112 $1,120,660

Total 113 $1,121,838

0603

Physician Assistant

09 1 $5,040

11 61 $725,793

Total 62 $730,833

0610

Nurse

04 1 $3,144

05 1 $10,690

07 2 $4,233

09 8 $37,771

10 257 $1,512,132

11 59 $688,469

Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in 

Fiscal Year 2016
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 33 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

12 2 $8,261

Total 330 $2,264,701

0620

Practical Nurse

07 14 $67,018

Total 14 $67,018

0640

Health Aid and Technician

05 1 $1,409

06 3 $15,521

09 9 $20,344

Total 13 $37,274

0644

Medical Technologist

09 9 $90,561

11 1 $17,066

Total 10 $107,627

0647

Diagnostic Radiological Technologist

09 1 $9,235

Total 1 $9,235

0660

Pharmacist

11 2 $3,036

12 7 $148,063

Total 9 $151,100

0661

Pharmacy Technician

05 1 $1,637

Total 1 $1,637

0680

Dental Officer

13 37 $737,232

14 11 $210,521

Total 48 $947,752

0681

Dental Assistant

06 1 $7,397

Total 1 $7,397
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 34 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

0682

Dental Hygiene

08 6 $50,556

Total 6 $50,556

Total for Medical Professionals 646 $5,838,638

0007

Correctional Officers

05 9 $23,000

06 110 $313,037

07 363 $1,065,648

08 353 $1,716,377

09 76 $348,350

11 70 $324,357

12 4 $24,237

13 3 $20,826

Total for Correctional Officers 988 $3,835,833

Other Occupations

0006

Correctional Institution Administrative

09 1 $1,941

11 7 $35,380

12 31 $179,812

13 6 $38,317

14 18 $107,260

15 8 $56,223

Total 71 $418,933

0018

Safety and Occupational Health Management 

05 1 $1,408

07 1 $1,785

09 6 $37,906

12 3 $22,996

13 1 $12,570

Total 12 $76,665

0019

Safety Technician

07 1 $1,698

Total 1 $1,698
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 35 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

0028

Environmental Protection Specialist

11 1 $2,092

Total 1 $2,092

0030

Sports Specialist

07 2 $8,824

09 20 $87,982

Total 22 $96,805

0060

Chaplain

12 9 $39,190

13 2 $18,738

Total 11 $57,929

0101

Social Science

05 1 $6,686

07 12 $43,778

09 12 $60,911

11 58 $323,348

12 7 $46,226

13 1 $3,243

Total 91 $484,191

0181

Psychology Aid and Technician

06 1 $6,473

07 2 $9,182

Total 3 $15,655

0188

Recreation Specialist

07 7 $33,074

09 10 $48,966

11 5 $26,420

12 1 $2,847

Total 23 $111,307

0201

Human Resources Management Officer

07 4 $11,197
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 36 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

09 16 $70,054

11 3 $22,659

12 3 $39,123

13 4 $67,046

14 1 $17,367

15 1 $11,210

Total 32 $238,656

0260

Equal Employment Opportunity 

13 1 $2,933

Total 1 $2,933

0301

Miscellaneous Administration and Program

09 12 $64,402

10 6 $27,729

11 2 $4,577

12 4 $21,186

13 1 $3,001

Total 25 $120,896

0303

Miscellaneous Clerk and Assistant

06 2 $7,942

07 9 $26,078

08 33 $158,314

09 5 $39,867

Total 49 $232,200

0304

Information Receptionist

04 2 $4,334

Total 2 $4,334

0318

Secretary

05 6 $22,690

06 30 $111,501

07 6 $21,321

08 6 $26,753

Total 48 $182,264
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 37 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

0501

Financial Administration and Program

09 5 $36,007

11 3 $3,471

12 2 $22,810

13 2 $13,475

14 1 $14,112

Total 13 $89,875

0525

Accounting Technician

06 2 $6,927

07 6 $24,427

Total 8 $31,354

0544

Civilian Pay

05 4 $3,561

Total 4 $3,561

0560

Budget Analysis

09 5 $29,723

14 1 $9,614

15 1 $15,998

Total 7 $55,335

0670

Health System Administration

11 3 $25,073

12 3 $8,059

13 1 $111

Total 7 $33,243

0671

Health System Specialist

11 8 $60,694

Total 8 $60,694

0675

Medical Records Technician

07 7 $21,057

Total 7 $21,057
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 38 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

0802

Engineering Technical

11 5 $36,431

Total 5 $36,431

0856

Electronics Technical

10 1 $2,431

11 11 $70,069

Total 12 $72,499

0905

General Attorney

14 2 $31,709

Total 2 $31,709

0986

Legal Assistance

08 2 $3,778

Total 2 $3,778

1101

General Business and Industry

07 1 $1,839

09 4 $25,857

11 1 $2,578

12 2 $14,179

13 2 $6,867

Total 10 $51,320

1102

Contracting

07 3 $8,761

09 3 $17,417

11 3 $19,300

12 1 $2,443

Total 10 $47,922

1603

Equipment, Facilities and Services Assistance

05 1 $2,468

07 12 $43,661

Total 13 $46,129
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 39 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

1640

Facility Operations Services

12 3 $14,001

13 2 $17,585

Total 5 $31,585

1658

Laundry Operations Services

10 1 $2,409

Total 1 $2,409

1667

Food Services Series

11 3 $28,272

12 5 $31,040

13 2 $17,372

Total 10 $76,684

1701

General Education and Training

09 1 $7,579

11 12 $60,305

Total 13 $67,884

1702

Education and Training Technician

07 8 $22,794

Total 8 $22,794

1710

Education and Vocational Training

05 1 $565

07 1 $540

09 1 $2,808

11 14 $66,408

12 5 $30,753

13 4 $9,416

Total 26 $110,490

1712

Training Instructions

09 2 $14,694

11 13 $82,651

Total 15 $97,345
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 40 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

2210

Informational Technology Management

09 1 $2,207

11 8 $47,110

12 5 $41,202

13 4 $34,105

14 1 $7,594

Total 19 $132,218

2805

Electrician

09 13 $67,774

Total 13 $67,774

3414

Machining

11 1 $2,492

Total 1 $2,492

3703

Welding

08 2 $10,750

Total 2 $10,750

4102

Painting

08 1 $2,072

Total 1 $2,072

4206

Plumbing

08 9 $42,066

Total 9 $42,066

4742

Utility Systems Repairing Operating

08 16 $82,087

Total 16 $82,087

4749

Maintenance Mechanic

08 30 $158,436

14 6 $34,812

Total 36 $193,248

5306

Air Conditioning Equipment Mechanic

09 13 $73,090

Total 13 $73,090

5823

Automotive Mechanic

08 7 $35,627

Total 7 $35,627
Appendix II: Bureau of Prisons’ Use of 

Retention Incentives by Occupations in Fiscal 

Year 2016

Page 41 GAO-18-147 BOP Retention Incentives

Occupations Series Codesa and Names

Grade Level/

Pay band

Number of Employees

Receiving Retention Incentives

Retention

Incentive Expenditures

6907

Materials Handling

03 5 $18,407

04 47 $248,667

05 1 $1,778

Total 53 $268,852

7305

Laundry Machine Operating

04 1 $1,824

Total 1 $1,824

7404

Cooking

08 77 $408,000

Total 77 $408,000

Other Occupations Total 826 $4,360,755

Source: GAO analysis of BOP retention incentive data. | GAO-18-147

a

A subdivision of an occupational group or job family consisting of positions similar as to specialized 

line of work and qualification requirements.
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-18-147 BOP Retention Incentives

Diana Maurer, (202) 512-9627 or maurerd@gao.gov

In addition to the contact named above, Dawn Locke (Assistant Director) 

and Meghan Squires (Analyst-in-Charge) managed the work. Also, David 

Alexander, Renee Caputo, Willie Commons III, Jamarla Edwards, Robert 

Goldenkoff, Chelsa Gurkin, Eric Hauswirth, Janice Latimer, Lerone Reid, 

Rachel Stoiko, and Adam Vogt made significant contributions to this 

report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101074)
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