Office of the Inspector General 

United States Department of Justice

ANALYSIS OF THE RESPONSE BY THE 

FEDERAL BUREAU OF PRISONS TO 

RECOMMENDATIONS IN THE OIG’S 

APRIL 2004 REPORT ON THE SELECTION OF 

MUSLIM RELIGIOUS SERVICES PROVIDERS

July 2004 
Office of the Inspector General (OIG) Analysis of Response by the 

Federal Bureau of Prisons to Recommendations in the OIG’s April 2004 

Report on the Selection of Muslim Religious Services Providers

I. Introduction 

The Office of the Inspector General (OIG) has analyzed the Federal Bureau of 

Prisons’ (BOP) response to the recommendations contained in the OIG’s report 

entitled, “A Review of the Bureau of Prisons’ Selection of Muslim Religious 

Services Providers” (Report). The OIG Report, issued on May 5, 2004, 

examined the recruitment, selection, screening, and supervision of individuals 

who provide Islamic religious services to federal inmates. In our report, we 

made 16 recommendations to help the BOP improve its process for selecting, 

screening, and supervising Muslim religious services providers. 

On June 7, 2004, the BOP submitted its response to the OIG’s 

recommendations. In this analysis, the OIG evaluates the BOP’s response to 

each of the recommendations. In general, we believe the BOP is taking 

important steps to implement most of the OIG’s recommendations. 

In the analysis below, we reproduce the text of the OIG recommendations, 

followed by the text of the corresponding BOP responses, and then the OIG’s 

analysis of each of these responses.*

 We are also attaching to this report the 

BOP’s response. 

Consistent with our normal practice, when specific action has been taken on a 

recommendation to fully address the issues raised by the recommendation, we 

consider the recommendation to be “closed.” Where the BOP has indicated a 

plan or an intention to implement measures in the future to address the 

recommendation, we consider the recommendation to be “resolved.” Where we 

believe insufficient action has been taken to address the recommendation, we 

consider the recommendation to be “unresolved.” 

Recommendation 1 

Status: Resolved 

OIG Recommendation 

The BOP should screen all religious services providers’ doctrinal beliefs. 

Currently the BOP does not screen religious services providers’ religious and 

doctrinal beliefs. Instead, it relies on the candidates’ endorsements to certify 

 

* At the BOP’s request, we have “redacted” or blacked out several words or passages in the

BOP’s response and in our analysis of that response that the BOP believes relate to sensitive

security issues that should not be made public. 
that they will minister to inmates of all faiths and provide appropriate religious 

services in a prison setting. However, it is essential to the security of the BOP 

that candidates who have extreme views and who pose a security threat not be 

allowed into the prisons. 

We recommend the BOP take steps to examine all chaplains’, religious 

contractors’, and religious volunteers’ doctrinal beliefs to screen out anyone 

who poses a threat to security. For example, the BOP could ask chaplains, 

contractors, and Level 2 volunteers doctrinal questions in their interviews and 

require them to submit a statement of faith with their applications. We 

recommend that the BOP OGC examine this issue to determine what screening 

procedures are legally permissible. The BOP’s screening of candidates’ 

religious and doctrinal beliefs should be for security purposes only, not to 

assess the purity of candidates’ views or serve as an approval or endorsement 

of their religious beliefs. The BOP also should develop a list of criteria to use 

when screening individuals. At the least, this list should include: 1) 

endorsement of violence, 2) support of terrorism or other anti-U.S. activities, 

and 3) discrimination against other inmates or exclusion of other inmates from 

religious services, whether based on race, religion, or other discriminatory 

factors. In addition, the BOP should consider requesting that OPM’s 

background investigations examine chaplains’ past statements and conduct in 

religious communities. 

BOP Response

The Bureau agrees with this recommendation. The BOP’s Office of General 

Counsel (OGC) will examine the recommended screening procedures for 

chaplains, contractors, and Level 2 volunteers to determine whether it is legally 

permissible to screen the doctrinal beliefs of religious service providers. Upon 

completion of the review, OGC will advise and counsel Chaplaincy Services, 

Human Resource Management, and the Volunteer and Management Branch 

regarding permissible screening procedures on chaplains, contractors, and 

volunteers. 

Additionally, the BOP has developed further screening criteria to be used 

during the application process for chaplains, volunteers, and contractors. The 

screening criteria will be used to ascertain the applicant’s position with respect 

to: 

• endorsement of violence, 

• support of terrorism, 

• advocating the overthrow of the U.S. Government, or 

• any discrimination based upon race, color, religion, sex, or national 

origin (Title VII, Civil Rights Act of 1964) 

2 
The Bureau will explore, and petition the Office of Personnel Management 

(OPM) to expand background investigation questioning of chaplains through 

use of the OPM SF86 form. Through use of this form the foreign activities, 

associations, and loyalties of each chaplain candidate may be identified. This 

investigation form is used exclusively for positions with a need for a higher 

national security clearance classification. Currently, Bureau chaplains do not 

require this level of clearance. The target date for completion of this petition is 

September 30, 2004. 

OIG Analysis

We believe the BOP’s response is a significant step toward fully implementing 

this recommendation. 

We agree with the BOP’s decision to have its Office of General Counsel (OGC) 

review and advise what screening procedures are legally permissible for 

chaplains, contractors, and Level 2 volunteers. To close this part of the 

recommendation, please provide us by October 1, 2004, the OGC’s legal 

determination and the additional screening procedures the BOP will implement 

as a result of the OGC’s conclusions. 

We also agree with the BOP’s development of further screening criteria to 

ascertain applicants’ positions with respect to endorsing violence; supporting 

terrorism; advocating the overthrow of the U.S. government; or discriminating 

based on race, color, religion, sex, or national origin. However, it is unclear 

from the BOP’s response what the new screening criteria will be or how it will 

be applied during the selection process. To close this part of the 

recommendation, please provide by October 1, 2004, the precise criteria that 

will be used and an explanation of how it will be used during the selection 

process. 

Finally, we agree with the BOP’s decision to petition the Office of Personnel 

Management (OPM) to expand background investigation questioning of 

chaplains through use of OPM form SF86 to better discern their foreign 

activities, associations, and loyalties. This action also addresses some of the 

concerns underlying Recommendation 4. However, we encourage the BOP also 

to petition OPM, as part of the background investigation, to examine chaplains’ 

past statements and conduct in religious communities. To close this part of 

the recommendation, we request the BOP carefully consider this suggestion, 

and provide us its response by October 1, 2004.

3 
Recommendation 2 

Status: Unresolved 

OIG Recommendation 

The BOP should require all chaplain, religious contractor, and religious 

Level 2 volunteer applicants to be interviewed by at least one individual 

knowledgeable of the applicant’s religion. This individual could be a BOP 

chaplain, BOP official, or member of an interfaith chaplain advisory board 

created by the BOP for the purpose of interviewing chaplain candidates. 

However, if the BOP creates an interfaith chaplain advisory board, members of 

the board must be screened sufficiently to ensure they do not hold views 

contrary to BOP policy, including advocating violence, supporting terrorism, or 

discriminating against people of certain races or religions. 

BOP Response

The Bureau agrees with this recommendation. All chaplains will be interviewed 

by a subject matter expert (SME) knowledgeable of the applicant’s religious 

beliefs and practices. A BOP chaplain from each faith will be selected and 

assigned collateral duties as an SME. In addition to their regular duties, these 

individuals will be utilized to recruit, screen, and interview prospective religious 

service providers, develop training, and act as the Bureau’s resource on all 

religious practices related to their specific faith. 

New religious service providers will be interviewed by the institution chaplain 

who will elicit information to assess whether or not the service provider is likely 

to preach or provide instruction contrary to BOP policy; will advocate violence; 

support terrorism; or discriminate against others because of their race or 

religion. Interview responses that elicit questionable information will be 

forwarded to the religion-specific SME and the local JTTF for review and 

further vetting. Bureau staff in consultation with the warden will make the 

final determination, in accordance with the FAR, based upon recommendations 

of the chaplain and/or the SME. The target date for implementation of this 

process is October 1, 2004. 

 

OIG Analysis 

We believe the BOP’s response is a positive step towards implementing this 

recommendation, but it only partially addresses the concerns underlying our 

recommendation. 

Our review concluded that if a candidate for a religious services position was 

not interviewed by an individual knowledgeable of the candidate’s religion, then 

the interviewers may not be able to adequately assess the candidate’s 

responses and whether the candidate likely would provide instruction contrary 

4 
to BOP policy, advocate violence, support terrorism, or discriminate against 

others because of their race or religion. 

The BOP indicates that all chaplain candidates will be interviewed by a subject 

matter expert (SME) of the candidate’s religion. This addresses our concerns 

regarding the interviews of Muslim chaplain candidates. However, the BOP 

proposes that an applicant for other religious services positions will be 

interviewed initially by the institution chaplain, who may or may not be a 

chaplain of the applicant’s religion. If the institution chaplain believes the 

candidate’s responses are questionable, he or she will forward the responses to 

the BOP’s SME for that candidate’s religion and to the Federal Bureau of 

Investigation’s (FBI) local Joint Terrorism Task Force (JTTF) for further review 

and vetting. 

While we agree with the BOP’s plan to designate SMEs for religious services 

providers’ religions, we believe that the SMEs, or other individuals 

knowledgeable of the applicants’ religions, should be involved from the outset 

in the interview and screening process of candidates for religious services 

positions. Otherwise, it is less likely that an institution chaplain will be able to 

assess from candidates’ responses whether they hold views contrary to BOP 

policy, and thus unlikely that the institution chaplain will forward the 

candidates’ responses to the SME for further review. For example, a candidate 

who advocates violence for religious reasons likely will not answer affirmatively 

the direct question, “Do you advocate violence for religious reasons?” 

Therefore, we believe the BOP will have to discern candidates’ true beliefs from 

nuances in their responses. We believe these nuances can best be identified 

and assessed by an SME or other individual knowledgeable of the applicant’s 

religion. 

To close this recommendation, we request the BOP consider involving SMEs in 

the initial interviews of contractors and Level 2 volunteers, and explain how the 

SMEs for each faith group will complete their additional responsibilities while 

maintaining their primary job duties. The BOP should provide its response by 

October 1, 2004. 

Recommendation 3 

Status: Closed 

OIG Recommendation 

The BOP should require panel interviews for all religious contractors and 

Level 2 volunteers. Because of the extensive contact contractors and 

volunteers have with inmates, we recommend the BOP require contractor and 

Level 2 volunteer applicants to be interviewed thoroughly by a panel consisting 

of a chaplain, a security officer, and a human resources official from the BOP 

institution where the applicants will work. The BOP likely will be able to 

5 
screen contractors and volunteers more adequately if they are given more 

thorough interviews such as the panel interviews given to chaplain candidates. 

BOP Response

The Bureau does not agree with this recommendation. There are close to 

10,000 level 2 religious volunteers and contractors, an average of 

approximately 100 per institution. We do not have the resources necessary to 

conduct panel interviews for the volume of volunteers and contractors who 

provide religious services/programs in BOP institutions. We believe that the 

increased scrutiny provided by the revised application materials, coupled with 

the assistance of SMEs and review by the local JTTF will help to address the 

same issues that could be derived from panel interviews. 

OIG Analysis

Although the BOP has concluded that its current resources do not permit it to 

conduct panel interviews for all religious contractors and Level 2 volunteers, we 

agree that the steps it has taken in response to other recommendations will 

help to address the concerns underlying this recommendation. 

Recommendation 4 

Status: Resolved 

OIG Recommendation 

The BOP should implement further security screening requirements for 

religious services providers. The BOP should ask chaplains and religious 

contractors whether they have ever received funds from foreign governments. 

The BOP should ask contractors and Level 2 volunteers to report the 

professional, civic, and religious organizations in which they hold membership. 

In addition, the BOP should verify chaplains’ foreign travel to determine 

whether they have spent a significant amount of time in a country that does 

not have diplomatic relations or treaties with the United States. 

BOP Response

The Bureau agrees with this recommendation. The Religious Services Branch 

has revised the internal security documents for volunteers and contractors 

(Attachments 1 and 2) to include information on the following: 

• professional affiliations; 

• civic affiliations; 

• religious affiliations; 

• foreign travel during the past five years; and 

• funding from foreign governments 

6 
Responses provided by the prospective religious service providers will be one of 

the factors used to determine whether or not to award the contract or admit 

the volunteer. Unfamiliar religious affiliates will be forwarded to the local JTTF 

for review and recommendation. Bureau staff in consultation with the warden 

will make the final determination, in accordance with the FAR, based upon 

recommendations of the local JTTF. The target date for implementation of this 

process is October 1, 2004. 

OIG Analysis 

The OIG agrees with the steps the BOP has taken in response to this 

recommendation. The revised internal security documents for religious 

services volunteers and contractors will provide the BOP information about the 

applicants’ foreign travel in the last five years; funding from foreign 

governments; and professional, civic, and religious affiliations. In addition, the 

BOP will work with local JTTFs to review the applicants’ information. We 

believe these steps will assist the BOP in further screening applicants for 

religious services positions. The BOP indicated in its response that this 

enhanced screening process for contractors and volunteers will be implemented 

by October 1, 2004. To close this recommendation, please provide us an 

update on the status of implementation by October 1, 2004. 

While the BOP’s response addresses our recommendation regarding further 

security screening of contractors and volunteers, it does not address whether 

chaplains will be required to report whether they ever have received funds from 

foreign governments or whether the BOP will verify their foreign travel. It is 

unclear whether these issues will be addressed during chaplains’ background 

investigations (if the OPM agrees with the BOP’s request to use background 

investigations to discern chaplains’ foreign activities, associations, and 

loyalties – Recommendation 1). To close this part of the recommendation, we 

request the BOP inform us by October 1, 2004, how it plans to determine 

whether chaplain candidates ever have received funds from foreign 

governments, and how it plans to verify chaplain candidates’ foreign travel. 

Recommendation 5 

Status: Resolved 

OIG Recommendation 

The BOP should encourage chaplains to seek information about contractor 

and volunteer applicants from their local communities. We recommend 

that the BOP encourage chaplains at institutions hiring contractors and 

volunteers to seek information from their local communities about individuals 

applying to be religious services contractors or volunteers. 

7 
BOP Response

The Bureau agrees with this recommendation. Institution chaplains/program 

managers will request a letter of reference from one professional or civic 

organization, and one religious organization listed on the contractor/volunteer 

security document. The names of the referring organizations will be forwarded 

to the local JTTF for review and comment. Bureau staff in consultation with 

the warden will make the final determination, in accordance with the FAR, 

based on the information provided by the local JTTF. References will be 

updated every five years. The target date for implementation of this process is 

October 1, 2004. 

 

OIG Analysis 

Our concern underlying Recommendation 5 was that chaplains at individual 

institutions could learn information about contractor and volunteer candidates 

from their local communities that would not be apparent from the candidates’ 

applications or letters of endorsement. We believe the BOP has addressed this 

concern by requesting letters of reference from one professional or civic 

organization, and one religious organization listed by volunteers and 

contractors on the revised internal security documents. 

We further agree with the BOP’s decision to have the local JTTF review and 

comment on the organizations that provide references. This will provide the 

BOP with further information that could assist it in screening candidates for 

security purposes. 

It is not clear from the BOP’s response, however, whether the religious 

organization that provides a letter of reference must be different from the local 

organization that provides an endorsement of the candidate. We believe the 

BOP should obtain letters of reference from two organizations in addition to the 

endorsement from the local endorsing organization. 

To close this recommendation, please clarify whether the BOP is requiring a 

letter of reference from a religious organization in addition to the endorsement 

from the endorsing organization. In addition, please provide us an update on 

the status of implementation of this recommendation by October 1, 2004. 

Recommendation 6 

Status: Resolved 

OIG Recommendation 

The BOP should take steps to improve and increase the information flow 

between the BOP and the FBI. Our review indicated that the information flow 

between the FBI and the BOP regarding the radicalization and recruitment of 
inmates needs improvement. While the recent creation of the Joint Intelligence 

Coordinating Council (JICC) might help improve FBI-BOP information sharing 

on inmate radicalization issues, we believe that additional steps need to be 

taken to further improve information flow. We recommend that the BOP not 

rely exclusively on the BOP detailee to the NJTTF or the creation of the JICC for 

this information flow, but consider assigning a liaison to the FBI, like other 

agencies do, to improve the exchange of information about the radicalization 

and recruitment of inmates. In addition, we recommend that BOP officials 

meet periodically with FBI officials regarding joint efforts to prevent the 

radicalization of inmates. 

BOP Response

The Bureau agrees with this recommendation. An additional staff member will 

be assigned as liaison with the FBI. Additionally, periodic meetings have 

already been initiated with the FBI to discuss efforts to prevent the recruitment 

and radicalization of Bureau inmates. The target date for selection of the 

additional liaison is October 1, 2004. 

OIG Analysis 

The BOP plans on assigning an additional staff member to serve as liaison to 

the FBI to improve and increase the information flow between the BOP and the 

FBI. In addition, the BOP has initiated periodic meetings with the FBI to 

discuss efforts to prevent the recruitment and radicalization of inmates. To

close this recommendation, please provide us by October 1, 2004, an update 

on the BOP’s efforts to select the additional FBI liaison, a detailed description 

of the liaison’s responsibilities, and how the liaison’s work will improve 

information sharing. In addition, please inform us by October 1 what meetings 

have occurred between BOP and FBI officials regarding joint efforts to prevent 

the radicalization of inmates. 

Recommendation 7 

Status: Resolved 

OIG Recommendation 

The BOP should more effectively use the expertise of its current Muslim 

chaplains to screen, recruit, and supervise Muslim religious services 

providers. The BOP should utilize its Muslim chaplains more effectively by 

having them review the applications, references, and endorsements of potential 

Muslim chaplains, contractors, and volunteers. We also recommend the BOP 

consider having at least one Muslim chaplain serve on the interview panel for 

Muslim chaplain candidates. 

9 
BOP Response

The Bureau agrees with this recommendation. The Religious Services Branch 

will announce, fill, and fund travel for a collateral duty Islamic SME position. 

Duties will include recruitment, screening, and interviewing prospective Islamic 

religious service providers, development of staff training modules, and other 

duties as assigned. The target date for implementation of this process is 

October 1, 2004. 

 

OIG Analysis 

The BOP plans to select an Islamic SME who will be involved in recruiting, 

screening, and interviewing applicants for Muslim religious services provider 

positions. We believe this process will address some of the concerns 

underlying our recommendation. 

However, we are concerned that assigning collateral Islamic SME duties to a 

single chaplain could foreclose consultations with and participation by the 

other chaplains. For example, in our review we found that one Muslim 

chaplain knew BOP contractor Warith Deen Umar in a professional setting 

several years before Umar joined the BOP, and the chaplain could have 

informed the BOP that Umar did not hold mainstream Islam values had he 

known at the time of Umar’s application that the BOP was considering hiring 

him as a contractor. We believe that the BOP can benefit significantly from 

the collective knowledge and experience of its current Muslim chaplains. We 

also believe that the BOP’s procedures for the recruitment, screening, and 

supervision of Muslim religious services personnel should draw on the 

expertise of more than one of its chaplains. 

To close this recommendation, please provide us by October 1, 2004, an 

update on the status of the use of an Islamic SME in recruiting, screening, and 

interviewing Muslim religious services providers, and whether the 

responsibilities of the SME will include consultation with other BOP Muslim 

chaplains. 

Recommendation 8 

Status: Unresolved 

OIG Recommendation 

The BOP should develop a strategy specifically targeted towards recruiting 

Muslim religious services providers. Currently the BOP does not have 

enough Muslim chaplains, contractors, and volunteers compared to the size of 

its Muslim inmate population. As a result, inmates are leading religious 

services, which presents prison security and national security concerns. 

Recruiting qualified Muslim religious services providers could reduce inmate-
led services, Prison Islam, and radicalization. We recommend that the BOP 

develop a strategy specifically for recruiting Muslim chaplains, contractors, and 

volunteers. For this strategy, the BOP should consider having BOP personnel 

reach out more to Muslim communities or enabling Muslim chaplains to spend 

part of their work hours recruiting. 

BOP Response

The Bureau agrees with this recommendation. The BOP includes in its specific 

recruitment strategy for Islamic religious providers, the advertisement of 

openings in various respected Islamic organizations, referrals by BOP Muslim 

chaplains, and the application of age waivers to employ qualified Islamic 

chaplains who exceed the statutory age requirements. The BOP also accepts 

graduate level equivalencies to the Master of Divinity professional degree, 

maintains cordial ties with Islamic academicians, and has developed a strategy 

for allowing the appointment of Islamic chaplains without benefit of a national 

endorsing body. (See the response to Recommendation 9 below.) We request 

this recommendation be closed. 

 

OIG Analysis

As evidence of having a strategy specifically targeted towards recruiting Muslim 

religious services providers, the BOP states that it advertises vacancies with 

Islamic organizations, receives referrals from BOP Muslim chaplains, waives 

age requirements for qualified Muslim chaplain candidates, and accepts 

graduate level equivalencies to the Master of Divinity professional degree 

required for chaplain candidates. However, the BOP engaged in each of these 

practices before our review. Moreover, these practices are not specific to 

Muslim religious services providers, but are used by the BOP to recruit 

chaplains of all faiths. 

Our review found that despite these recruiting tactics, the BOP was unable to 

recruit enough Muslim chaplains, contractors, and volunteers to serve its 

Muslim inmate population. Our concern underlying this recommendation was 

that the BOP should make special efforts to recruit Muslim religious services 

providers in order to reduce its current deficit of Muslim chaplains. The 

recruiting tactics the BOP lists in its response to date have been unsuccessful 

at reducing the BOP’s lack of sufficient Muslim religious services providers. 

To close this recommendation, we request that by October 1, 2004, the BOP 

implement additional strategies to specifically recruit Muslim religious services 

providers. For example, the BOP should consider having BOP personnel, in 

addition to the Chief of the Chaplaincy Services Branch, reach out more 

frequently to Muslim communities. The BOP also should consider enabling all 

Muslim chaplains, not just the SME, to spend part of their work hours 

recruiting Muslim religious services providers. 

11 
Recommendation 9 

Status: Resolved 

OIG Recommendation 

The BOP should consider implementing alternative endorsement 

requirements for Muslim chaplains. Presently the BOP is experiencing a 

hiring freeze on Muslim chaplains because it will not accept endorsements 

from any Islamic organizations until it receives information on those 

organizations from the FBI. In addition, no other national organization besides 

the ISNA is authorized to endorse Muslim chaplains. Moreover, the BOP will 

not hire chaplains who have endorsements from national organizations about 

which the FBI has derogatory information. We recommend the BOP consider 

developing alternative endorsing requirements for Muslim chaplains, such as 

permitting endorsements from local or regional organizations in specific 

situations. 

BOP Response

The Bureau agrees with this recommendation. The Bureau has exempted 

Islamic candidates from the required national endorsement. In lieu of the 

endorsement, staff now request a letter of reference from a local religious 

organization with which the Islamic candidate is affiliated. The letter of 

reference and vetting form are in addition to the personal and professional 

letters of reference currently required by policy. The local religious 

organization providing a professional reference will be screened through the 

local JTTF. The target date for implementation of the screening process is 

October 1, 2004. 

OIG Analysis

We believe the BOP’s response addresses the concerns underlying our 

recommendation. By exempting Muslim chaplains from producing national 

endorsements, the BOP opens opportunities for more Muslims to apply for 

chaplain vacancies. Furthermore, by screening local Muslim endorsing 

organizations through the local JTTF, the BOP can better determine whether 

the organization poses a security concern or is connected to terrorism. 

To close this recommendation, please provide us by October 1, 2004, an 

update on implementation of the alternative endorsement process for Muslim 

chaplain candidates. 

12 
Recommendation 10 

Status: Unresolved 

OIG Recommendation 

The BOP should evaluate the feasibility of having correctional officers 

provide intermittent supervision to all chapels to supplement the 

supervision provided by chaplaincy staff. As a further means to enhance 

supervision of religious services, the BOP should evaluate the cost, 

legality, and feasibility of audio and video monitoring to include all 

worship areas and chapel classrooms. With few exceptions, individuals who 

lead religious services in BOP facilities are subject to only limited supervision. 

As a result, once contractors and volunteers gain access to BOP facilities, 

ample opportunity exists for them to deliver inappropriate messages without 

direct supervision from BOP staff members. Our fieldwork identified significant 

differences in the level of support provided to chaplains by correctional officers. 

We also observed that video coverage of BOP chapels varies by institution, and 

that audio monitoring is not employed. We believe that the BOP should 

evaluate options to make chapel supervision more thorough and consistent 

Bureau-wide. 

 

BOP Response

The Bureau agrees with this recommendation. Religious Services policy has 

been changed to include a section on supervision of inmates (Attachment 3). 

This section describes the levels of staff or electronic supervision required for: 

• inmate-led groups: ████████ ███████████; 

• programs led by Level I volunteers: ████████ ███████████; 

• programs led by Level II volunteers and contractors: ████████████

███████████; 

• special programs, e.g., choir presentations, seminars: ████████

███████████

We request this recommendation be closed. 

OIG Analysis 

The BOP has taken steps to make chapel supervision more thorough and 

consistent BOP-wide by amending BOP Program Statement (P.S.) 5360 to 

include a section specifying how inmates are to be supervised. We believe 

these amendments address in part the concerns underlying our 

recommendation. 

However, the BOP’s response does not mention what steps will be taken to 

ensure that correctional officers, not chaplains or other staff, are consistently 

13 
involved in the supervision of Chaplaincy Service activities. As described in 

our report and recommendations, our review identified significant differences 

in the level of support provided to Chaplaincy Services by correctional officers. 

In addition, the BOP has not addressed whether it intends to evaluate the 

feasibility of introducing audio monitoring and additional video monitoring in 

facility worship areas and chapel classrooms. 

The amended P.S. 5360 is pending final approval and clearance before it 

becomes official. To close this recommendation, please provide us by 

October 1, 2004, an update on implementation of the amended P.S. 5360, ███

███ ███ ███████ ██ ██████ ████ ███████████ ████████ ███

████████████ ████████ ██ ███ ███████████ ██ ██████████ ██

██████████ ████████, ███ ███████ ███ ███ ███████ ██

████████ ███ ███████████ ██ ███████████ █████ ██████████

███ ██████████ █████ ██████████ ██ ███████ █████ ███ ██████

██████████. 

Recommendation 11 

Status: Resolved 

OIG Recommendation 

The BOP should limit and more closely supervise inmate-led religious 

services. Inmates are radicalized primarily by other inmates. We do not 

believe that it is appropriate for inmates to assume leadership positions in BOP 

facilities, including the position of surrogate chaplain. We recommend that the 

BOP take steps to reduce inmate-led religious services. For example, in 

facilities where inmates presently are leading Juma services, the BOP should 

evaluate the alternative of providing Internet video feeds to chapel areas for 

Juma prayer by a BOP Muslim chaplain. The BOP also should consider 

requiring inmate-led services to be monitored by staff constantly rather than 

intermittently. 

BOP Response

The Bureau agrees with this recommendation. The level of supervision of 

inmate religious groups in secure facilities will follow guidelines for religious 

programs involving worship, study, or meetings. ███ ██████████

█████████ ████████ ████ ███████ ████████ █████

███████████. BOP Islamic chaplains will provide Jumah resource materials. 

Video/audio media will be authorized by the SME’s for study programming. 

Internet video feeds to chapel areas for religious services are not feasible at this 

time. The use of such feeds would not fulfill the religious obligation for Islamic 

Jumah prayer services. The target date for full implementation of this process 

is October 1, 2004. 

14 
OIG Analysis 

We believe the BOP’s response addresses our recommendation. To close this 

recommendation, please provide us by October 1, 2004, an update on the 

status of implementation of these new processes, and an explanation for why 

the use of video feeds is not feasible at this time. 

Recommendation 12 

Status: Resolved 

OIG Recommendation 

The BOP should provide its staff with training on Islam. Supervisory 

correctional officers and BOP managers advised us that many correctional 

officers are not familiar with Islam, and that this lack of knowledge may limit 

their ability to recognize radical Islamist messages that are inappropriate in 

BOP facilities. At a minimum, we believe that the BOP should provide basic 

training to its staff members who supervise Muslim religious services so that 

they will be familiar with accepted prayer and service rituals, understand 

Islamic terminology, and recognize messages that violate BOP security policy. 

 

BOP Response

The Bureau agrees with this recommendation. All BOP captains will receive 

the recommended training in August 2004. During this training they will be 

provided with training materials for local use. 

All institution staff will receive training during Annual Refresher Training in 

2005, on the accommodation of Islamic beliefs and practices and appropriate 

uses of Arabic in the correctional environment. During this training, all staff 

will receive a ready reference glossary of common Islamic terminology used in 

religious practice. The target date for completion of the staff training is 

April 30, 2005. 

OIG Analysis

We believe the BOP’s response addresses our recommendation. To close this 

recommendation, please provide us by October 1, 2004, the training materials 

given to all BOP captains at the August 2004 training, and an update on the 

training the BOP plans to provide all staff at the Annual Refresher Training in 

2005. 

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Recommendation 13 

Status: Resolved 

OIG Recommendation 

To improve supervision practices in facilities that do not have a Muslim 

chaplain, the BOP should encourage staff members from those facilities to 

consult with the BOP Muslim chaplains to address potential or actual 

radicalization problems. Our review found that the BOP is not fully using the 

expertise of its staff Muslim chaplains. These individuals have knowledge and 

abilities that can and should be used to assist the BOP to address radical 

influences. 

BOP Response

The Bureau agrees with this recommendation. An Islamic chaplain will be 

identified and trained as a SME for Islamic issues. All Bureau chaplains will 

be notified and encouraged to utilize the expertise available through the SME. 

The target date for selection of the Islamic SME is October 1, 2004. 

OIG Analysis

We believe the BOP’s response addresses our recommendation. To close this 

recommendation, please provide us by October 1, 2004, an update on the 

status of the selection of the Islamic SME. 

Recommendation 14 

Status: Resolved 

OIG Recommendation 

The BOP should include in contractors’ SOWs the themes and topics on 

which they should focus. The BOP should provide contractors guidance on 

what they are to teach during religious services by including topics and themes 

to be discussed with inmates in contractors’ SOWs. The SOWs also should 

include specific things contractors are not allowed to say as part of their 

messages, such as statements that support violence, denigrate the United 

States, or disparage other inmates or other faith groups. 

BOP Response

The Bureau agrees with this recommendation. Bureau chaplains will submit 

general topics or themes to be included in contractors’ SOWs to the respective 

SME. The SMEs will make the final recommendation for topics to be included 

and/or excluded in the SOWs. At a minimum, future SOWs will specifically 

indicate that statements that support violence, advocate the violent overthrow 

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of the government of the United States, or disparage other inmates or other 

faith groups are not allowed. The target date for initiation of this process is 

October 1, 2004. 

OIG Analysis

We believe the BOP’s response addresses our recommendation. To close this 

recommendation, please provide us by October 1, 2004, an update on 

implementation of the process for including SMEs in the development of 

contractors’ SOWs. 

Recommendation 15 

Status: Resolved 

OIG Recommendation 

The BOP should conduct an inventory of chapel books and videos and rescreen them to confirm that they are permissible under BOP security 

policies. The BOP should consider maintaining a central registry of 

acceptable material to prevent duplication of effort when reviewing these 

materials. Of the institutions we visited, several did not have an inventory of 

the books currently available to the inmates, and none of the collections had 

been re-screened since the September 11 terrorist attacks. 

BOP Response

The Bureau agrees with this recommendation. Staff will complete an inventory 

of current print and audio-video materials and review the materials for 

endorsement of violence, support for domestic or foreign terrorism, or any 

discrimination based upon race, color, religion, gender or national origin. The 

Religious Services Branch will provide an automated list of materials 

appropriate for circulation in a correctional environment. Chaplains will be 

advised to use the automated list for future library acquisitions. The target 

date for completion of the inventory and central registry is June 1, 2005. 

OIG Analysis

We believe the BOP’s response addresses our recommendation. To close this 

recommendation, please provide us by October 1, 2004, an update on the 

screening of print and audio-video materials and the creation of the inventory 

and central registry. 

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Recommendation 16 

Status: Resolved 

OIG Recommendation 

BOP facilities should maintain a liaison with their local JTTF. BOP 

facilities should be fully integrated into local counterterrorism initiatives. Our 

review revealed that not all BOP facilities are working closely with their local 

JTTF. 

BOP Response

The Bureau agrees with this recommendation. Each institution will be 

reminded of the requirement to develop liaison efforts with their local JTTF and 

will be required to certify in writing this has been accomplished. The target 

date for submission of the certification documentation is October 1, 2004. 

 

OIG Analysis

We believe the BOP’s response addresses our recommendation. To close this 

recommendation, please provide us by October 1, 2004, an update on 

institutions’ submissions of the certification documentation. 

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