BUREAU OF 

PRISONS

Management of New 

Prison Activations 

Can Be Improved

Report to Congressional Requesters

August 2014

GAO-14-709

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-709, a report to 

congressional requesters

August 2014

BUREAU OF PRISONS

Management of New Prison Activations Can Be 

Improved

Why GAO Did This Study

The federal inmate population has 

increased over the last two decades,

and as of July 2014, BOP was 

responsible for the custody and care of 

more than 216,000 inmates. To handle 

the projected growth of between 2,500 

and 3,000 or more inmates per year 

from 2015 through 2020, BOP has

spent about $1.3 billion constructing

five new institutions and acquiring one 

in Thomson, Illinois. BOP is activating 

these institutions by staffing and

equipping them and populating them 

with inmates. 

GAO was requested to review BOP’s 

activation process of newly constructed

and acquired institutions. GAO 

reviewed, among other things, (1) the 

extent to which BOP is activating 

institutions within estimated timeframes 

and has an activation policy or

schedules that meet best practices, 

and (2) why DOJ purchased Thomson 

and how the purchase affected system 

wide costs. GAO reviewed BOP 

budget documents from fiscal years 

2008 to 2015 and assessed schedules 

against GAO’s Schedule Assessment 

Guide. GAO conducted site visits to 

the six institutions, interviewed BOP 

officials, and reviewed staffing data

from fiscal years 2010 through 2013.

What GAO Recommends

GAO recommends that DOJ use its 

annual budget justification to 

communicate to Congress factors 

that might delay prison activation,

and that BOP analyze institutionlevel staffing data and develop and 

implement a comprehensive 

activation policy and a schedule that 

reflects best practices. DOJ 

concurred with all of GAO’s 

recommendations. 

What GAO Found

The Department of Justice’s (DOJ) Federal Bureau of Prisons (BOP) is behind 

schedule activating all six new institutions—the process by which it prepares

them for inmates—and does not have a policy to guide activation or an activation 

schedule that reflects best practices. BOP is behind schedule, in part, because of 

challenges, such as staffing, posed by the locations of the activating institutions. 

According to BOP officials, delays in receiving congressionally directed activation 

funding can exacerbate these challenges (see fig.). None of the six institutions is 

fully activated, or at rated capacity, as they do not house the number of inmates 

they are designed to safely and securely house.

Schedule Slippages for Institutions in the Activation Process

BOP does not effectively communicate to Congress how the locations of new 

institutions may affect activation schedules. BOP officials said that when directed 

by Congress to investigate a location, they consider this as direction to focus on

construction at that site. DOJ and BOP could more effectively manage activation 

timelines and costs by using the BOP annual budget justification to communicate 

to Congress the factors associated with certain locations that can delay 

activations, such as challenges hiring staff and placing inmates in institutions.

Also, BOP officials said they review staffing data system-wide, but they have not 

prioritized an analysis of such data at the institution level. Analyzing staffing data 

on institutions in the activation process could help BOP assess its progress in 

staffing and tailoring effective mitigating strategies. Finally, BOP lacks a 

comprehensive activation policy to guide activations, as well as an activation 

schedule that reflects best practices, and it has largely relied on staff’s past 

experience to complete ongoing activations. Developing and implementing a 

comprehensive policy and a schedule that reflects best practices, could better 

position BOP to meet its estimated timeframes and activation costs.

DOJ purchased Thomson to help reduce crowding among inmates requiring high 

levels of security. Once it is fully populated, it will reduce BOP-wide crowding by 

16 percent at the high-security level. Thomson will cost about $160 million 

annually to operate once fully activated, adding to BOP’s system-wide costs.

BOP officials said Thomson will provide benefits, such as high-security bed 

space, which outweigh the costs associated with the institution.

View GAO-14-709. For more information, 

contact Dave Maurer at (202) 512-9627 or 

maurerd@gao.gov.
Page i GAO-14-709 Bureau of Prisons

Letter 1

Background 6

BOP Is behind Schedule Fully Activating New Institutions, and 

Does Not Have an Activation Policy or Schedules That Meet 

Best Practices 12

BOP Obligated Funds from Two Accounts to Maintain Partially 

Activated Institutions 24

The Six Institutions Being Activated Will Reduce Crowding 

System-wide when They Reach Rated Capacity 27

DOJ Purchased Thomson to Reduce High-Security Crowding, but 

It Will Increase Costs 29

Conclusions 35

Recommendations for Executive Action 35

Agency Comments and Our Evaluation 36

Appendix I Description of Schedule Slippages due to Delays in Receiving 

Congressionally Directed Activation Funding 40

Appendix II Analysis of BOP’s Human Resources Data 43

Appendix III Analysis of BOP’s Products against Best Practices 47

Appendix IV Comments from the Department of Justice 56

Appendix V GAO Contact and Staff Acknowledgments 59

Tables

Table 1: Extent to Which the Federal Bureau of Prisons’ (BOP) 

Schedules Met Best Practices 20

Contents
Page ii GAO-14-709 Bureau of Prisons

Table 2: Federal Bureau of Prisons’ (BOP) Congressionally 

Directed Activation Funding and Actual Obligations from 

Its Salaries and Expenses (S&E) Account for Partially 

Activated Institutions from Fiscal Year 2010 through 

March 2014 25

Table 3: Anticipated Federal Bureau of Prisons’ (BOP) Beforeand-After Crowding Rates, Assuming Institutions Reach 

Rated Capacity in Fiscal Year 2016 and Associated 

Obligations Data 28

Table 4: Staff On Board at Partially Activated Federal Bureau of 

Prisons’ (BOP) Institutions from Fiscal Years 2010 

through 2013 44

Table 5: Staff Hired at Partially Activated Federal Bureau of 

Prisons’ (BOP) Institutions from Fiscal Years 2010 

through July 2014 45

Table 6: Staff Separations for Partially Activated Federal Bureau 

of Prisons’ (BOP) Institutions from Fiscal Years 2010 

through July 2014 46

Table 7: Summary Assessment of the Federal Bureau of Prisons’ 

(BOP) Schedule Estimates for Six Institutions Compared

against Best Practices 48

Table 8: Extent to Which Federal Bureau of Prisons’ (BOP) 

Schedules Were Comprehensive 50

Table 9: Extent to Which Federal Bureau of Prisons’ (BOP) 

Schedules Were Controlled 52

Table 10: Extent to Which Federal Bureau of Prisons’ (BOP) 

Schedules Were Well Constructed 53

Table 11: Extent to Which Federal Bureau of Prisons’ (BOP) 

Schedules Were Credible 54

Figures

Figure 1: Life Cycle of Federal Bureau of Prisons’ (BOP) 

Institutions 9

Figure 2: Map of Federal Bureau of Prisons’ (BOP) Institutions in 

the Activation Process 11

Figure 3: Schedule Slippages for Federal Bureau of Prisons’ 

(BOP) Institutions in the Activation Process 13
Page iii GAO-14-709 Bureau of Prisons

Abbreviations

ADX Administrative Maximum 

B&F Buildings and Facilities

DOJ Department of Justice

EHRI Enterprise Human Resources Integration

BOP Federal Bureau of Prisons

FCI Federal Correctional Institution

M&R Modernization and Repair

OPM Office of Personnel Management

S&E Salaries and Expenses

USP U.S. Penitentiary

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Page 1 GAO-14-709 Bureau of Prisons

441 G St. N.W.

Washington, DC 20548

August 22, 2014

Congressional Requesters

The Department of Justice’s (DOJ) Federal Bureau of Prisons (BOP) 

requested about $6.9 billion in fiscal year 2014 to provide for the custody 

and care of an inmate population that has increased from about 24,000 in 

fiscal year 1980 to over 216,000 in July 2014. According to DOJ, as of 

July 2014, BOP-operated institutions are about 31 percent overcrowded, 

which occurs when institutions house more inmates than they are 

designed to hold. Moreover, according to BOP’s most recent long-range 

capacity plan included in DOJ’s annual congressional budget justification 

for BOP, the bureau projects annual inmate growth of between 2,500 and 

3,000 or more from fiscal years 2015 through 2020.1 BOP is not 

responsible for controlling the flow of inmates into the federal prison 

system, as convicted felons are placed directly into BOP’s custody and 

care, but BOP is responsible for confining these inmates safely and 

securely. As we reported in September 2012, this responsibility can be 

challenging with a growing inmate population.2

BOP considers reducing crowding rates system-wide to be a strategic 

goal and has spent over $1.3 billion on the construction and acquisition of 

six new federal institutions to help alleviate crowding across the prison 

system. Specifically, BOP constructed five federal prisons: (1) Federal 

Correctional Institution (FCI) Aliceville in Alabama, (2) FCI Berlin in New 

Hampshire, (3) FCI Hazelton in West Virginia, (4) FCI Mendota in 

In particular, we found that 

crowding has negatively affected inmates housed in BOP institutions, 

institutional staff, and the infrastructure of BOP facilities, and has 

contributed to inmate misconduct, which affects staff and inmate security 

and safety. In recognition of the difficulties crowding causes, DOJ’s 

Inspector General included detention and incarceration among DOJ’s top 

10 management and performance challenges department-wide for 2013, 

and noted that the department has identified crowding as a material 

weakness every year since 2006.

 1

For the purposes of our report, we refer to DOJ’s annual congressional budget 

justifications for BOP as BOP’s budget justifications.

2

GAO, Bureau of Prisons: Growing Inmate Crowding Negatively Affects Inmates, Staff, 

and Infrastructure, GAO-12-743 (Washington, D.C.: Sept. 12, 2012).
Page 2 GAO-14-709 Bureau of Prisons

California, and (5) U.S. Penitentiary (USP) Yazoo City in Mississippi.3 In 

addition, BOP acquired the Thomson Correctional Center, now referred to 

as Administrative USP Thomson, from the state of Illinois in October 2012 

to address crowding for inmates requiring high levels of security.4 BOP is 

currently working to activate these institutions—a process by which BOP 

staffs and equips institutions, and populates them with inmates—and has 

received or is waiting for congressionally directed funding to activate all 

six of these new institutions.5

In light of crowding conditions and BOP’s recent construction of new 

institutions and the acquisition of the Thomson Correctional Center, you 

asked us to review BOP’s activation process. Specifically, this report 

addresses the following questions:

In addition to BOP, DOJ is also working to 

address the growth in the prison population, and in 2013, launched its 

Smart on Crime Initiative, which includes several efforts to modernize the 

criminal justice system, including reprioritizing federal law enforcement 

prosecutions to focus on the most serious cases. Additionally, over the 

past 2 years, Members of Congress have introduced at least five bills to 

date that seek to modify federal sentencing requirements in order to 

reduce the length of incarceration of inmates convicted of nonviolent 

drug-related offenses.

1. To what extent has BOP activated the six institutions within estimated 

time frames, and to what extent does BOP have an activation policy 

or schedules that meet best practices?

2. How has BOP covered the costs of maintaining the six institutions?

 3

BOP has several types of institutions, including FCIs that generally house inmates who 

need less security than those housed in USPs, which generally house inmates requiring 

higher security.

4

According to BOP officials, Administrative USP Thomson may hold both high-security and 

maximum-security inmates, but BOP is still in the process of determining the specific 

types of inmates that the institution will house.

5

Generally, either the annual appropriation act or the conference report accompanying 

BOP’s annual appropriation act directs BOP to use Salaries and Expenses (S&E)

appropriations for activation activities at particular institutions. Conference report language 

that is incorporated by reference into an appropriations act becomes part of the public law. 

However, BOP generally follows directives contained in the conference report language 

even if not incorporated into the appropriations act. For the purpose of this report, we refer 

to the conference report language as “congressional direction” and the related funding as 

“congressionally directed activation funding.”
Page 3 GAO-14-709 Bureau of Prisons

3. How will the addition of each institution likely affect system-wide 

crowding rates?

4. Why did DOJ purchase the Thomson Correctional Center, and how, if 

at all, will it affect costs?

To determine whether BOP has activated the six institutions within 

estimated time frames, we reviewed documents that accompany BOP’s 

annual congressional budget justifications, called budget exhibits, from 

fiscal years 2008 through 2014 that include timelines for when BOP 

expects to activate new institutions.6 We also analyzed data from the 

Office of Personnel Management’s (OPM) human resources database, 

Enterprise Human Resources Integration (EHRI) Statistical Data Mart, for 

fiscal years 2010 through 2013 to determine the extent to which staffing 

challenges identified by institutions in the activation process affected 

BOP’s ability to meet estimated time frames related to activation.7

Further, we reviewed legislation enacted from relevant fiscal years, 

specifically fiscal years 1999 through 2006, and associated reports to 

identify the process through which specific institution locations are 

identified, as well as BOP’s assessments of proposed locations for new 

institutions. Additionally, we evaluated the extent to which BOP’s 

schedule documents used for completing activation for each institution 

complied with and reflected best practices outlined in GAO’s Schedule 

Assessment Guide.

8

 6

BOP was unable to provide full budget justifications prior to fiscal year 2008.

We also interviewed agency officials on the 

challenges, if any, institutions face related to activation and the actions 

BOP has taken to mitigate the effects of those challenges.

7

OPM’s EHRI is a collection of human resources, payroll, and training data that facilitates 

management of personnel in the federal government. We used EHRI data to report hires 

and separations through the end of each relevant fiscal year. To report the most current 

data on hires and separations in fiscal year 2014—from October, 2013 through July, 

2014—we relied on BOP to provide this information from its personnel database. We 

determined that BOP’s staffing data are comparable to our analysis of OPM’s EHRI data 

and are reliable for the purposes of our report.

8

GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules, 

GAO-12-120G (Washington, D.C.: May 2012). Our Schedule Assessment Guide provides 

guidance to agencies on developing and maintaining reliable, high-quality schedules to 

manage programs and projects, such as construction or activation projects. We developed 

this guide through a compilation of best practices that federal cost-estimating 

organizations and industry use.
Page 4 GAO-14-709 Bureau of Prisons

To determine how BOP has covered the costs of maintaining the six 

institutions while waiting for congressional direction on activation funding, 

we reviewed BOP’s annual congressional budget justifications from fiscal 

years 2008 through 2015. We also reviewed BOP’s annual spend plans, 

which DOJ or its components develop after receiving an appropriation, for 

fiscal years 2010 through 2014 to identify congressionally directed 

activation funding. Further, we analyzed data on actual obligations BOP 

made from fiscal years 2010, or the first year BOP made activationrelated obligations for those six institutions, through March 2014 to fund 

and activate the six institutions to determine the total cost of new 

institution activations. We also reviewed program statements, which are 

BOP’s formal policies and procedures, related to using appropriated 

funds for building projects.

To determine how each new institution will likely affect system-wide 

crowding rates, we evaluated BOP’s long-range capacity plan that 

accompanied BOP’s fiscal year 2015 congressional budget justification. 

That plan includes BOP’s estimates of the future inmate population and 

crowding rates through fiscal year 2020, and assumes that all six 

institutions in our review will be fully populated, or fully activated, by fiscal 

year 2016. We then used data in that plan to calculate estimated 

crowding rates—assuming the new institutions were not fully activated by 

fiscal year 2016 (e.g., did not provide any beds)—by subtracting the 

number of beds the six institutions would otherwise have added to overall 

capacity in that fiscal year. Our analysis compared crowding rates with 

and without the addition of new beds provided by the six institutions and 

examined the effect of that additional capacity across (1) all BOP 

institutions, (2) respective security levels of each institution, and (3) 

gender.

To assess why DOJ purchased the Thomson Correctional Center in 

2012, we reviewed BOP’s congressional budget justifications and 

accompanying budget exhibits that specifically requested funds for 

Thomson from fiscal years 2011 through 2015; state of Illinois documents 

on selling the Thomson Correctional Center to the federal government 

that were produced in 2010; and relevant acquisition documents, such as 

an environmental assessment and appraisals of the institution. We also 

reviewed relevant statutes to understand the department’s legal authority 

to acquire the Thomson Correctional Center. To determine how, if at all, 

the purchase of Thomson affected costs, we reviewed BOP’s 
Page 5 GAO-14-709 Bureau of Prisons

Modernization and Repair Unfunded Priorities list from 2012, which was 

the list available when DOJ purchased Thomson.9

To address all of the objectives in our review, we conducted site visits to 

all six institutions, and interviewed institution and regional office staff 

about the challenges, if any, they face during activation.

We also analyzed BOP 

budget documentation to determine how much BOP will spend to operate 

the institution once it is fully activated.

10 We also 

interviewed BOP officials to discuss crowding, cost and schedule 

estimates, and any potential cost implications of the Thomson purchase. 

To assess the reliability of data related to BOP’s staffing, obligations, and 

the inmate population, we reviewed documentation related to BOP’s 

staffing database; annual congressional budget requests; and the Sentry 

database, which contains inmate population data.11

We conducted this performance audit from November 2013 to August 

2014 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 

We interviewed 

human resources officials from BOP’s Central Office to discuss what data 

BOP provides to OPM to verify our data analysis and tested the data for 

missing data, outliers, and obvious errors to ensure that the data are

reliable. We also conducted interviews with knowledgeable agency 

officials about related internal controls of databases. We determined that 

the data used as a basis for these findings are reliable for the purposes of 

our report.

 9

BOP uses funds for modernization and repair activities to cover the costs of items on this 

list. BOP designates modernization and repair funds, which are aimed at rehabilitating, 

modernizing, and renovating buildings and associated systems, as well as repairing or 

replacing utilities or other critical infrastructure at BOP institutions. Because DOJ acquired, 

rather than constructed, the Thomson Correctional Center, we analyzed the extent to 

which purchasing the Thomson Correctional Center affected other BOP costs.

10BOP has six regional offices, each led by a regional director, covering the North Central, 

Northeast, South Central, Mid-Atlantic, Southeast, and Western regions of the United 

States. BOP’s regional offices and its Central Office, which has its headquarters in 

Washington, D.C., provide administrative oversight and support to prisons, among other 

things. We interviewed officials from the regional offices that have oversight of the prisons 

undergoing activation in our review, which include all but the South Central region.

11BOP’s Sentry database is an information system containing, among other things, 

information related to the care, classification, subsistence, protection, discipline, and 

programs of federal inmates.
Page 6 GAO-14-709 Bureau of Prisons

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.

To carry out its responsibility for the custody and care of federal 

offenders, BOP currently houses inmates across six geographic regions 

in 120 long-term federal institutions.12

Male long-term institutions include four security-level designations––

minimum, low, medium, and high––and female long-term institutions 

include three security designations––minimum, low, and high. The 

security-level designation of a facility depends on the level of security and 

staff supervision that the facility is able to provide, such as the presence 

of security towers; perimeter barriers; the type of inmate housing, 

including dormitory, cubicle, or cell-type housing; and inmate-to-staff ratio. 

Additionally, BOP designates some of its institutions as administrative 

institutions, which specifically serve inmates awaiting trial, or those with 

intensive medical or mental health conditions, regardless of the level of 

supervision these inmates require. As of June 2014, BOP owned and 

operated seven stand-alone minimum-security institutions, 30 lowsecurity institutions, 47 medium-security institutions, 16 high-security 

institutions, 1 administrative maximum (ADX) institution that houses 

inmates requiring the highest levels of security, and 19 administrative 

institutions. Many of these facilities are colocated on BOP-operated 

complexes that also contain minimum-security camps, which are 

The Central Office and regional 

offices provide administrative oversight and support to institutions, among 

other things. The management officials located at each institution, 

including wardens and associate wardens, provide overall direction and 

implement policies.

 12In addition to these long-term federal institutions, BOP also houses inmates in privately 

managed facilities and home detention. According to BOP officials, privately managed 

contract facilities are low security and primarily house non-U.S. citizens convicted of 

crimes while in this country legally or illegally. Home detention describes all circumstances 

under which an inmate is serving a portion of his or her sentence while residing in his or 

her home. BOP also houses inmates in 200 residential reentry centers, and BOP officials 

stated that they use an additional 49 residential reentry centers through intergovernmental 

agreements for work release purposes.

Background

Federal Prison System
Page 7 GAO-14-709 Bureau of Prisons

nonsecure facilities that generally house nonviolent, low-risk offenders 

that are not included in this count. For example, USP Yazoo City is 

located on the Yazoo City Complex, which also includes a mediumsecurity FCI, a low-security FCI, and a minimum-security camp.

BOP calculates the number of inmates a given institution is built to safely 

and securely house and defines this as its rated capacity. BOP 

establishes a rated capacity for each of the institutions that it owns and 

operates. In determining rated capacity, BOP considers occupancy and 

space requirements. According to BOP, rated capacity is the basis for 

measuring crowding and is essential to both managing the inmate 

population and BOP’s annual congressional budget justifications for 

resources.

After an inmate receives his or her sentence, BOP initially designates that 

person to a particular institution based on (1) the level of security and 

supervision the inmate requires; (2) the level of security and staff 

supervision the institution is able to provide; (3) the inmate’s program 

needs, such as residential drug treatment or intensive medical care; (4) 

where the inmate resides at the time of sentencing; (5) the level of 

crowding in an institution; and (6) any additional security measures to 

ensure the protection of victims, witnesses, and the public.13

BOP communicates its schedule estimates related to activating new 

institutions to Congress through the annual budget process. BOP 

receives appropriated funds through two accounts—Buildings and 

Facilities (B&F) and Salaries and Expenses (S&E)—which BOP has 

divided into subaccounts, called decision units. The B&F account funds 

the construction of new institutions and the maintenance of existing 

institutions. Specifically, the B&F account has two subaccounts: (1) new 

construction and (2) modernization and repair. The B&F account includes 

no-year appropriations, which are available until expended. BOP’s B&F 

account’s modernization and repair subaccount funds are used to 

rehabilitate, modernize, and renovate buildings and associated systems, 

as well as repair or replace utilities or other critical infrastructure at BOP 

institutions. BOP’s B&F budget justification includes accompanying 

 13BOP, Inmate Security Designation and Custody Classification, Program Statement 

P5100.08 (Washington, D.C.: Sept. 12, 2006).

BOP’s Schedule Estimates
Page 8 GAO-14-709 Bureau of Prisons

budget exhibits, which, among other things, provide estimated timelines 

for when new institutions will provide rated capacity. Broadly, the S&E 

account covers costs for staffing; inmate medical care, food, and 

programming; and utilities at existing institutions. Specifically, the S&E 

account has four subaccounts: (1) inmate care and programs, (2) 

institution security and administration, (3) contract confinement, and (4) 

management and administration. Generally, the S&E account includes 1-

year appropriations, which are available for obligation only in the fiscal 

year for which they were appropriated.

BOP receives congressionally directed funding for activation—the overall 

process by which BOP staffs and equips institutions and then populates 

them with inmates—through its S&E account.14

When these steps are completed, the institution begins receiving inmates, 

and when this occurs, for the purposes of this report, we consider that 

institution to be partially activated. Once the institution houses inmates at 

BOP officials stated that, 

generally, BOP does not start the activation process until it has received 

congressionally directed activation funding. Upon receipt of 

congressionally directed activation funds, BOP begins completing what, 

for the purposes of this report, we consider “preactivation” steps, which 

include completing renovations; hiring staff, such as wardens and 

executive staff to manage the institution; and ordering supplies and 

equipment. Preactivation also includes meeting with community 

members, recruiting and training new staff, and furnishing the new 

institution.

 14The annual appropriations act or the conference report accompanying BOP’s annual 

appropriations act may direct BOP to use S&E appropriations for activation activities at 

particular institutions. For example, the Consolidated and Further Continuing 

Appropriations Act, 2013, Pub. L. No. 113-6, 127 Stat. 198, 249, stated “[t]hat of the 

amount provided [for Salaries and Expenses] . . . not less than $99,496,000 shall be for 

activation of newly constructed prisons in Berlin, New Hampshire, Aliceville, Alabama, 

Yazoo City, Mississippi, and Hazelton, West Virginia, as requested in the Department’s 

fiscal year 2013 budget.” As another example, the conference report, H.R. Con. Rep. No. 

111-366, at 671 (2009), accompanying the Consolidated Appropriations Act, 2010, Pub. L. 

No. 111-117, 123 Stat. 3034 (2009), directed that “[o]f the total amount provided,[for 

Salaries and Expenses] . . . not less than $22,000,000 shall be used for the activation of 

FCI Mendota.” Conference report language that is incorporated by reference into the 

appropriations act becomes part of the public law. However, according to BOP officials, 

BOP generally follows directives contained in conference report language even if not 

incorporated into the appropriations act.

Description of the 

Activation Process
Page 9 GAO-14-709 Bureau of Prisons

its rated capacity, or the number of inmates BOP determines the 

institution can safely and securely house, we consider that institution to 

be fully activated. All of the institutions in our review are currently in the 

preactivation or partial activation phases of the activation process 

because they do not yet house the number of inmates they were 

designed to hold. See figure 1 for a description of the life cycle of those 

institutions.

Figure 1: Life Cycle of Federal Bureau of Prisons’ (BOP) Institutions

BOP’s Design and Construction Branch is responsible for, among other 

things, overseeing the construction of new institutions, and when 

construction of an institution is almost complete, it transfers responsibility 

to the regional office or the local institution, thereby formally transitioning 

from construction to the beginning of the activation process. Once this 

responsibility has been transferred, regional or local officials work with the 

construction contractor to ensure that all items covered by the 

construction contractor’s warranty, such as cooling and heating systems, 

are working properly prior to the warranty’s expiration. They also work to 

conduct some alterations, installations, and repairs, such as placing

additional razor wire and upgrading security features, that must be 
Page 10 GAO-14-709 Bureau of Prisons

completed before the institution can securely house inmates. BOP made 

similar repairs to four of the six institutions in our review.

When the institution is ready to accept inmates, BOP issues an 

“Activation Memo” that specifies the criteria that inmates must meet in 

order to be housed in the new institution. Such criteria are based on the 

security level of the institution and the medical and mental health care 

services the institution was designed to provide. The criteria also 

generally include inmate characteristics that will allow for smooth 

transitions as the institution prepares for activation. For example, the 

Activation Memo may state that inmates should have histories of good 

conduct, no prior gang affiliation, and be generally healthy. Institutions 

that have inmates that meet those criteria can request that those inmates 

be transferred to the activating institution by submitting a formal request 

to the Designation and Sentence Computation Center, which officially 

approves the transfer. The Designation and Sentence Computation 

Center is also responsible for classifying inmate security levels and 

designating those inmates to specific institutions.

From fiscal years 2005 through 2007, the President’s annual budget 

request included a moratorium on new institution construction in an effort 

to have BOP take greater advantage of public and private sector bed 

space, which operate under contract with BOP, to meet the need for 

greater capacity. As a result of that moratorium, BOP officials reported 

that they were reluctant to proceed with the construction of several 

institutions, as we previously reported.15

 15GAO, Prison Construction: Clear Communication on the Accuracy of Cost Estimates and 

Project Changes Is Needed,

BOP has six federal institutions 

across the country currently in different phases of the activation process, 

as we discuss later in this report. See figure 2 for a description of each of 

those institutions.

GAO-08-634 (Washington, D.C.: May 29, 2008). In that 

report, we recommended that the Attorney General of the United States instruct the 

Director of BOP to clearly communicate in DOJ’s annual congressional budget submission 

(1) the extent to which project costs may vary from initial estimates and (2) changes that 

may affect the functionality of projects. BOP agreed with and implemented our 

recommendation.

Background on Institutions 

in the Activation Process
Page 11 GAO-14-709 Bureau of Prisons

Figure 2: Map of Federal Bureau of Prisons’ (BOP) Institutions in the Activation Process
Page 12 GAO-14-709 Bureau of Prisons

BOP is behind schedule in fully activating, or reaching rated capacity for,

all six institutions in the activation process. This is due, in part, to 

challenges posed by the locations of the activating institutions. However, 

although the institutions’ locations posed challenges related to staffing, 

BOP is not effectively monitoring staffing challenges at individual 

institutions to ensure that they are staffed and, in turn, fully activated, 

within estimated time frames. Further, BOP does not have a policy in 

place to guide the activation process, or an associated schedule that 

meets best practices, which limits BOP’s ability to accurately assess 

activation progress and ensure that the new institutions effectively reduce 

crowding as intended.

All six institutions in the activation process have had schedule slippages 

due to challenges caused by their locations and delays in receiving 

congressionally directed activation funding. According to BOP officials, 

delays in receiving congressionally directed activation funding are outside 

BOP’s control and can exacerbate existing challenges with staffing or 

populating an institution with inmates. This type of delay generally occurs 

because of aspects of the appropriations process, including continuing 

resolutions, that have resulted in BOP receiving its final funding level and 

associated congressional direction late in the fiscal year.16 In addition, in 

some fiscal years, BOP does not receive congressionally directed 

activation funding for specific institutions.17 Generally, either the annual 

appropriations act or the conference report accompanying BOP’s annual 

appropriations act directs BOP to use S&E appropriations for activation 

activities at particular institutions.18

 16Continuing resolutions provide funding when action on regular appropriation bills is not 

completed before the beginning of the fiscal year. GAO, A Glossary of Terms Used in the 

Federal Budget Process, 

BOP generally follows directives 

contained in the conference report language even if not incorporated into 

the appropriations act and therefore, in practice, does not activate 

institutions without congressional direction. Figure 3 illustrates the fiscal 

year in which BOP initially expected each institution to be fully activated, 

GAO-05-734SP (Washington, D.C.: September 2005).

17For the purpose of this report, we refer to the conference report language as 

“congressional direction” and the related funding as “congressionally directed activation 

funding.”

18Broadly, the S&E account covers costs for staffing; inmate medical care, food, and 

programming; and utilities at existing institutions.

BOP Is behind 

Schedule Fully 

Activating New 

Institutions, and Does 

Not Have an 

Activation Policy or 

Schedules That Meet 

Best Practices

BOP Is behind Schedule, 

In Part, because of 

Challenges Posed by 

Institutions’ Locations
Page 13 GAO-14-709 Bureau of Prisons

the subsequent revisions to that estimate, and the reasons for delay. 

Appendix I provides additional details on how delays in congressionally 

directed activation funding have resulted in schedule slippages for each 

of the institutions in the activation process.

Figure 3: Schedule Slippages for Federal Bureau of Prisons’ (BOP) Institutions in the Activation Process

Note: Activation is the overall process by which BOP staffs and equips institutions and then populates 

them with inmates. Once the institution houses inmates at its rated capacity, or the number of 

inmates BOP determines the institution can safely and securely house, we consider that institution to 

be fully activated. BOP officials stated that, generally, BOP does not start the activation process until 

it has received congressionally directed activation funding. Generally, either the annual appropriation 

act or the conference report accompanying BOP’s annual appropriation act directs BOP to use 

Salaries and Expenses (S&E) appropriations for activation activities at particular institutions. 

Conference report language that is incorporated by reference into an appropriations act becomes part 

of the public law. However, BOP generally follows directives contained in the conference report 

language even if not incorporated into the appropriations act. For the purpose of this report, we refer 

to the conference report language as “congressional direction” and the related funding as 

“congressionally directed activation funding.”

On our site visits to these institutions, we found that the locations of these 

institutions posed challenges related to staffing institutions and populating 

them with inmates within schedule estimates. For example, officials from 

FCI Aliceville stated that the institution’s location made it challenging to 

hire staff up to authorized staffing levels during activation because of the 
Page 14 GAO-14-709 Bureau of Prisons

low locality pay in Alabama compared with pay in other states.19

According to officials, it has been difficult to find local applicants who 

could pass BOP’s preemployment background check because 

prospective hires often had disqualifying levels of debt, even though they 

met the qualifications based on skill.20

Moreover, we found on our site visits that the locations of some of these 

institutions also posed challenges related to populating them with 

inmates. In particular, these institutions generally accept inmates who are 

healthy, because the institutions are not located close to hospitals that 

can provide care for inmates with chronic or serious conditions requiring 

frequent visits, such as those with liver disease.

Similarly, officials from the 

Southeastern Regional Office stated that staffing two of the institutions 

within its region—FCI Aliceville and USP Yazoo City—has been 

challenging because of their rural locations. Further, officials from USP 

Yazoo City told us that it was particularly challenging to hire medical staff 

because of the institution’s location and low pay in that area.

21 For example, officials 

from FCI Berlin told us that they had difficulty populating the institution 

with inmates because it could provide care only for generally healthy 

inmates, given its distance from major hospitals.22

 19BOP determines the number of staff a new institution is authorized to hire based on 

funding levels and security levels of the new institution. Each activating institution is 

authorized to hire up to a certain number of staff, from within BOP or from outside the 

agency, including applicants from the local community. Hiring is generally funded through 

congressionally directed activation funding.

In fact, FCI Berlin is 

more than 2 hours away from the closest large hospital that can provide 

care for inmates with serious health conditions. As a result, according to 

officials from FCI Berlin, they originally planned to transfer to FCI Berlin 

only those inmates who are in overall stable health—those with a Care 

Level 1 designation—as doing so would minimize the need to regularly 

20BOP’s preemployment check assesses applicants’ financial and criminal histories to 

ensure that they are not vulnerable to corruption within the institution. 

21BOP determines the level of medical care for a new institution based on the types of 

medical care services available in the local area. BOP-operated institutions generally 

provide a range of outpatient services related to primary health care and transport inmates 

with medical emergencies to the nearest hospital.

22FCI Berlin was not designed to provide acute or intensive medical care services at the 

institution.
Page 15 GAO-14-709 Bureau of Prisons

transport inmates to faraway hospitals for necessary medical care.23

Although the specific locations of these new institutions can delay 

activation, BOP does not communicate to Congress the effect that 

location can have on BOP’s ability to fully activate the institutions and to 

do so within estimated time frames. Our analysis of legislation enacted 

from fiscal years 1999 through 2006 and associated reports shows that 

conference reports directed BOP to investigate specific locations to 

determine whether institutions could be built there and to identify land 

where the institutions would eventually be built. In some cases, such as 

for FCI Berlin, the conference report accompanying DOJ’s annual 

appropriations act for fiscal year 2002 directed BOP to begin partial site 

selection and planning for an institution to be located in Berlin, New 

Hampshire.

However, there were not enough Care Level 1 inmates who also met the 

other criteria FCI Berlin specified, such as inmate security level, so the 

institution expanded its health care designation to also accept stable Care 

Level 2 inmates, who need more medical care than Care Level 1 inmates. 

BOP officials acknowledged that distance from major hospitals is a 

primary factor in determining the care level for institutions, such as FCI 

Berlin.

24 In contrast, for USP Yazoo City, the conference report 

accompanying DOJ’s annual appropriations act for fiscal year 2000 

directed BOP to study the feasibility of constructing an institution in Yazoo 

City, Mississippi.25

 23BOP classifies inmates into four categories of medical care needs, ranging from Care 

Level 1, which includes generally healthy inmates, to Care Level 4, which includes 

inmates with the most serious medical conditions. According to BOP officials, an inmate’s 

medical care level can change over time because he or she can develop chronic care 

conditions during imprisonment.

In response to congressional direction to investigate a 

given location, BOP conducts environmental assessments or 

24The conference report, H.R. Conf. Rep. No. 107-278, at 83 (2001), accompanying the 

Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies 

Appropriations Act, 2002, Pub. L. No. 107-77, 115 Stat. 748 (Nov. 28, 2001), stated that 

“[t]he conference agreement provides that of the $650,047,000 provided for increases as 

outlined below, $5,000,000 shall be for partial site and planning of the USP Northeast/MidAtlantic facility, to be located in Berlin, New Hampshire.”

25The conference report, H.R. Con. Rep. No. 106-1005, at 220 (2000), accompanying the 

District of Columbia Appropriations Act, 2001, Pub. L. No. 106-553, 114 Stat. 2762 (Dec. 

21, 2000), stated that “[t]he conference agreement adopts the Senate report language 

directing BOP to continue to assess the feasibility of construction of a high-security facility 

in Yazoo City, MS, as described in the Senate report.”
Page 16 GAO-14-709 Bureau of Prisons

environmental impact statements.26

According to BOP officials, when BOP is congressionally directed to 

investigate a particular location, BOP generally considers this as a 

direction to focus its efforts on constructing an institution in that specific 

location. However, officials from both BOP’s Central Office and activating 

institutions acknowledged that the locations of these newly constructed 

institutions make activation more difficult. Standards for Internal Control in 

the Federal Government states that management should ensure that 

there are adequate means of communicating with, and obtaining 

information from, external stakeholders, such as Congress, that may have 

a significant impact on the agency achieving its goals.

In contrast, BOP’s annual 

congressional budget justification is used to convey BOP’s funding and 

housing needs, and these justifications would allow DOJ and BOP 

officials the opportunity to convey to Congress any potential challenges 

BOP may be facing or anticipating with respect to selecting certain sites 

for new institutions.

27 Since delayed 

activations limit BOP’s ability to reduce crowding as BOP intended, DOJ 

and BOP would be better positioned for future activations and could more 

effectively manage activation costs and timelines by using BOP’s annual 

congressional budget justification to communicate to Congress the factors 

that might delay future activations, such as challenges hiring staff and 

placing inmates, associated with the locations of new institutions. In turn, 

congressional decision makers could be better positioned to take such 

factors into account when directing BOP where to build new institutions.

 26Environmental assessments describe how an institution would affect the physical 

environment, such as air quality, and the socioeconomics of the local area, such as the 

unemployment rate. Environmental impact statements are more detailed than 

environmental assessments.

27GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1999). Further, we recommended in December 2013 that BOP 

could better ensure that it meets congressional stakeholders’ needs by consulting with 

congressional decision makers to determine if it would be helpful to include additional

funding details in its annual budget justification. GAO, Bureau of Prisons: Opportunities 

Exist to Enhance the Transparency of Annual Budget Justifications, GAO-14-121 

(Washington, D.C.: Dec. 6, 2013). DOJ agreed with our recommendation.
Page 17 GAO-14-709 Bureau of Prisons

BOP’s Central Office reviews aggregated data of staffing system-wide, 

but it does not monitor or analyze staffing data by individual institutions, 

such as those located on a complex, or track how long it takes individual 

activating institutions to hire staff. When we analyzed OPM’s EHRI data 

on BOP staffing, we found that none of the institutions in the activation 

process has a full complement of staff.28 Although the following 

institutions are partially activated, FCI Aliceville is 63 percent staffed, FCI 

Berlin is 67 percent staffed, and FCI Mendota is 73 percent staffed.29

Standards for Internal Control in the Federal Government calls for 

agencies to identify, capture, and distribute operational data to determine 

whether an agency is meeting its goals and effectively using resources.

Since these institutions are not fully staffed, they cannot be fully activated 

until they have a full complement of staff to effectively manage additional 

inmates.

30

According to BOP officials, they could analyze available data by institution 

by reallocating staff to conduct such an analysis. However, BOP has not 

made such monitoring a priority because, as BOP officials told us, 

wardens of institutions are ultimately responsible for ensuring that 

institutions are properly staffed. In addition, our analysis demonstrates 

that each institution has experienced recruiting and retention challenges. 

For example, although two of the three partially activated institutions have 

experienced increases in the number of staff it hires each fiscal year, 

Because BOP’s Central Office does not review staffing data at the 

institution level, BOP’s human resources officials from the Central Office 

could not tell us whether all of the specific institutions in our review, 

specifically those located on complexes, faced obstacles recruiting and 

retaining staff. Likewise, BOP officials were not positioned to discuss the 

impact of potential staffing challenges on activation. Such staffing 

challenges could affect how quickly BOP can reduce crowding across the 

system—one of BOP’s key strategic goals.

 28OPM’s EHRI database is the primary government-wide source for information on federal 

employees. EHRI contains information on personnel actions and other data for most 

federal civilian employees. These data are as of September 30, 2013.

29OPM’s EHRI data are reported by complex, rather than by institution. As a result, we 

were unable to use these data to accurately determine the extent to which FCI Hazelton 

and USP Yazoo City were staffed since they are both located on complexes.

30GAO/AIMD-00-21.3.1.

BOP Does Not Analyze 

Staffing Data at the 

Institution Level to Mitigate 

Staffing Challenges
Page 18 GAO-14-709 Bureau of Prisons

where institutions hired staff at higher rates in each consecutive year, 

authorized positions remained unfilled. In addition, for example, not all of 

the employees FCI Mendota hired from fiscal years 2010 through 2013 

remained on board to work at the institution. Additionally, our analysis of 

OPM data indicates that each institution undergoing activation has had 

staff sever employment with BOP or transfer to other institutions, 

compounding existing staffing issues. For instance, each year more staff 

have separated from employment at FCI Mendota than in the prior year, 

for a total of 40 employees—about 21 percent of its total hires—from 

fiscal years 2010 through 2013.31

BOP currently provides some relocation benefits and salaries above the 

minimum rate to any institution struggling to hire sufficient staff, including 

those undergoing activation.

Additionally, according to data provided 

by BOP from its personnel database for fiscal year 2014—through July—

an additional 11 employees separated from FCI Mendota. See appendix 

II for our analysis of BOP’s human resources data.

32 However, these incentives have not 

effectively addressed the challenges that activating institutions face hiring 

staff. Specifically, BOP officials said that BOP has the authority to offer 

incentives in order to recruit and retain qualified staff for positions that are 

difficult to fill, either because they are specialty positions, such as medical 

personnel, or because they are located at institutions in remote 

locations.33 According to BOP data, BOP offered incentives a total of 150 

times for a combined total of about $1.1 million as a means of recruiting 

potential new hires to the institutions in our review, and 147 of those 

incentives were ultimately accepted by new hires.34

 31During this time frame, there were likely also existing BOP staff that transferred in and 

out of that institution.

Although BOP 

Central Office officials stated that these incentives were used frequently, 

the staffing challenges continue to delay activation. Without analyzing 

staffing data, such as recruiting and retention data, at individual activating 

institutions, BOP is not positioned to assess its progress toward reaching 

32OPM defines the minimum rate as the minimum wage an employee may be paid based 

on the employee’s scheduled rate of pay.

33BOP cited three legal authorities allowing it to use incentives for attracting candidates in 

hard-to-fill positions: 5 C.F.R. § 575.106 (recruitment incentives), 5 C.F.R. § 575.206 

(relocation incentives), and 5 C.F.R. § 575.306 (retention incentives).

34According to BOP, more than 1 incentive could be offered to a potential applicant.
Page 19 GAO-14-709 Bureau of Prisons

authorized staffing levels or to develop effective, tailored strategies to 

mitigate those challenges.

BOP institutions in the activation process rely on the expertise of staff and 

two templates that the Central Office developed to guide the activation 

process: (1) the activation handbook, which identifies roles and 

responsibilities for BOP officials during the activation process, and (2) the 

staffing timeline, which provides a general sequence of hiring events that 

BOP staff are to follow prior to the institution receiving inmates. Activating 

institutions complete these templates, and may modify the documents at 

their discretion; thus, they differ in style, scope, and substance depending 

on the institution completing them. However, the two templates do not 

constitute a documented, bureau-wide policy related to activation, nor do 

they include an activation schedule that incorporates best practices, such 

as accounting for factors that might delay activation, including delays in 

receiving congressionally directed activation funding or challenges with 

staffing institutions.

Activating institutions in our review did not have a detailed policy or 

schedule to guide the activation process. Instead, they relied heavily on 

relationships with individuals who had experience with activations. For 

example, officials at half of the institutions told us that they relied on the 

experience of officials who had previously been involved with activations 

to help guide the process. Further, on our site visit to USP Yazoo City, 

officials told us that the primary challenge related to financial 

management during the activation process was ensuring that the 

managers of each of the departments in the institution, such as business 

administration or human resources, knew what was required for 

activation. The business administrator sought out assistance from the 

regional office and visited another institution that was activated prior to 

USP Yazoo City to review records and itemized lists of what officials had 

determined they needed for that activation. Further, BOP relied on the 

experience of a now-retired official serving as the Activation Coordinator 

for the institutions in our review. BOP relied on that official to initiate the 

activation process by ordering necessary supplies and equipment. 

Officials we interviewed from the regional offices noted that without the 

Activation Coordinator’s guidance, they would not have known what 

supplies and equipment were needed for activation. Standards for 

Internal Control in the Federal Government states that policies and 

procedures are needed to enforce management’s directives, and that 

BOP Does Not Have a 

Policy to Guide Activation 

or a Schedule That Meets 

Best Practices

No Documented Activation 

Policy
Page 20 GAO-14-709 Bureau of Prisons

significant events need to be documented in policies and procedures.35

According to our analysis of the details included in each institution’s 

version of the activation handbook template and the staffing timeline 

template, we determined that BOP’s schedules do not meet all 10 best 

practices required for a schedule to be reliable. Specifically, we assessed 

each of the six institutions’ versions of the activation handbook and 

staffing timeline templates against four characteristics of a reliable 

schedule associated with the 10 best practices.

According to BOP documents and officials, BOP does not plan to 

construct, and subsequently activate, new institutions for the foreseeable 

future. In addition, officials contend that BOP has vast institutional 

knowledge to guide the activation process, rendering a formal written 

policy unnecessary. Nevertheless, BOP will likely face difficulty during 

future activations since about 32 percent of BOP staff will be retirement 

eligible within 5 fiscal years—a proportion that is similar to the retirement 

rate for the federal workforce as a whole. Such staffing attrition 

underscores the need to have documented policies in place to ensure 

that future staff can conduct and complete activations effectively and 

within cost and schedule commitments.

36

Table 1: Extent to Which the Federal Bureau of Prisons’ (BOP) Schedules Met Best 

Practices

As table 1 shows, 

collectively, the six BOP institutions minimally met two and did not meet 

two of these four characteristics.

Characteristic Characteristic description Assessment 

Comprehensive A schedule should reflect all activities. Minimally met

Controlled A schedule should be continuously updated using 

logic, durations, and actual progress to realistically 

forecast dates for program activities.

Minimally met

Well constructed A schedule should be planned so that critical project 

dates can be met.

Not met 

Credible A schedule should include data on risks and 

opportunities for the project, and a level of 

confidence in meeting a project’s completion date 

based on those data.

Not met

Source: GAO analysis of BOP schedule documentation. I GAO-14-709

 35GAO/AIMD-00-21.3.1.

36GAO-12-120G.

Activation Schedule Does Not 

Meet Best Practices
Page 21 GAO-14-709 Bureau of Prisons

The activation handbook template and general staffing timeline template 

that BOP’s Central Office provides are positive steps toward a schedule 

that could be used to guide future institution activations because they 

provide some level of detail regarding the activities required for activation. 

However, as illustrated in table 1, collectively, institutions’ versions of the 

activation handbook and the staffing timeline templates minimally met the 

criteria for being comprehensive or controlled and did not meet the criteria 

for being well constructed or credible, which are aspects of reliable 

schedules.

Comprehensive. We reviewed the activation handbook and staffing 

timeline templates that each of the six institutions completed and found 

that they minimally met the requirements for a comprehensive schedule. 

The activation handbook template contains some elements key to having 

a comprehensive schedule, such as listing necessary tasks, organized by 

responsible departments or contractors. However, the activation 

handbook template provides the tasks, or activities, in the list in a general 

way, but none of the six institutions tailored the tasks to meet their 

specific requirements, limiting the bureau’s ability to oversee all activation 

activities. Similarly, the activation handbook template does not fully 

include details on all of the necessary resources to do the work 

associated with each activity and does not identify the specific personnel 

within the department responsible for each activity. Finally, none of the six 

institutions included any reference to project duration in its respective 

activation handbook. Without information about the estimated length of 

time required to complete each activity, management cannot accurately 

identify the staffing resources required to complete it, assess the progress 

of the activation process, or establish realistic dates for institution 

activation. With respect to the general staffing timeline template that 

BOP’s Central Office provides, this document roughly identifies when 

particular staff resources are needed based on the anticipated activation 

date. However, the general staffing timeline template is based on the 

anticipated activation date rather than based on the activities each of the 

staff would be doing—and none of the six institutions made modifications 

to elaborate on these activities. Because of these deficiencies, the 

information contained in each of the six institutions’ activation handbooks 

and staffing timelines does not assist management in forecasting whether 

activities will be completed as scheduled or as budgeted. Further, these 

documents do not allow insight into the allocation of resources, increasing 

the likelihood that the activation process will not be completed as 

anticipated and limiting BOP’s ability to ensure accountability for the total 

scope of work.
Page 22 GAO-14-709 Bureau of Prisons

Controlled. The activation handbook and staffing timeline templates that 

each of the six institutions modified minimally met the requirements for a 

controlled schedule. Two of the activating institutions provided versions of 

BOP’s activation handbook and staffing timeline templates that contained 

some indication that information on key dates and activities was updated 

at some point in time by the activating institutions. However, the activation 

handbook and staffing timeline templates modified by each institution did 

not indicate whether they had been updated at regular intervals, or that 

they reflected the actual status of the respective activations. Further, 

none of the activating institutions’ activation handbooks or staffing 

timelines included the status of key milestone dates, such as whether 

specific activities had been completed, or when the activation should be 

completed. In addition, none of the activating institutions used the 

activation handbook and staffing timelines to describe the critical risks 

that the institution faced in meeting its goals for activation or 

contingencies if those risks were realized, such as challenges with 

staffing. Without regularly updating the schedule based on the current 

status of the activation at each respective institution, BOP is limited in its 

ability to monitor activation progress or make decisions on how to mitigate 

risk or allocate resources for activating institutions.

Well Constructed. The activation handbook and staffing timeline 

templates that each of the six institutions modified did not meet the 

requirements for a well-constructed schedule, because the activation 

handbook and staffing timeline documents did not provide specific 

information regarding start and finish dates, durations, or sequencing of 

activation-related activities. As a result, BOP does not have insight about 

the interdependencies between activities or the way in which early delays 

in some activities could affect activities later on as well as the overall 

activation completion date. Additionally, without identifying linkages 

between activities, BOP does not know the critical path of the activation 

process—that is, which activities can and cannot be delayed if the overall 

schedule is to be met. This prevents the agency from providing Congress 

with reliable timeline estimates or anticipated activation dates.

Credible. The activation handbook and staffing timeline templates that 

each of the six institutions modified did not meet the requirements for a 

credible schedule. A credible schedule is horizontally integrated, where 

products and outcomes are linked with other associated sequenced 

activities, which helps verify that activities are arranged in the right order 

to achieve aggregated products or outcomes. A credible schedule is also 

vertically integrated to ensure that the start and completion dates for 

activities are aligned with such dates on subsidiary schedules supporting 
Page 23 GAO-14-709 Bureau of Prisons

tasks and subtasks. With respect to the best practice of vertically and 

horizontally aligning activities, two institutions adapted BOP’s activation 

handbook template to insert targeted due dates for selected activities, but 

neither identified subset activities or linked overall activities in any specific 

order to achieve full horizontal or vertical integration. Without such 

integration, BOP is not positioned to ensure that subactivities are on track 

for an overall activity’s completion.

The activation handbook and staffing timeline templates that BOP 

developed and that are modified by activating institutions are positive 

steps toward a baseline schedule that could be used to guide future 

institution activations, because they provide some level of detail regarding 

the activities required for activation. However, the activation handbook 

and staffing timeline templates contain only limited information consistent 

with best practices and therefore cannot be used by management to 

reliably measure, monitor, or report on performance. Appendix III contains 

our detailed assessment for each characteristic and the reasons BOP 

minimally met or did not meet the best practices.

BOP officials stated that each institution undergoing activation generally 

follows the same process and is guided by experienced officials at both 

the Central Office and the regional offices, which, in the past, included the 

experience of an Activation Coordinator. In particular, according to BOP 

officials, activation of new institutions follows standardized processes that 

allow BOP to generally predict accurate timelines for activation. However, 

as discussed above, each of the activating institutions is behind schedule, 

which indicates that the schedules used during activation may not 

adequately ensure that activation occurs within schedule estimates. BOP 

officials acknowledged that scheduling delays can occur, and when they 

do, it is usually because of delays in congressionally directed funding or 

difficulty with hiring. BOP officials stated that, generally, BOP does not 

start the activation process until it has received congressionally directed 

activation funding, and because of this, according to DOJ officials, 

activation schedules are inherently affected by the availability and timing 

of the agency’s final funding level for a fiscal year. Because BOP officials 

consider that the activation clock does not start until it receives such 

funding, they do not consider it an activation process delay on their part if 

a delay in receiving such funding causes an institution to be activated 

later than was originally planned. However, our analysis showed that the 

activation handbook and staffing timeline documents used as schedules 

by the six institutions did not contain contingencies related to external 

factors, such as receiving congressionally directed activation funding. A 

comprehensive policy with a schedule that is well constructed and 
Page 24 GAO-14-709 Bureau of Prisons

credible, for example, could be used to reflect how delays in receiving 

congressionally directed activation funding might affect activating 

institutions within schedule estimates and improve the quality of 

information that BOP provides to Congress regarding the status of the 

activation process.

Because the activation handbook does not fully reflect a standardized list 

of all of the activities required for activation, management cannot ensure 

that the total scope of work is accounted for by the handbook. 

Consequently, BOP is limited in its ability to minimize the potential for 

delays in the activation process. Developing and implementing a 

comprehensive activation policy that incorporates the knowledge of staff 

with experience activating institutions could help equip BOP staff with the 

expertise and resources needed to efficiently activate new institutions. 

Additionally, having a schedule that incorporates the four characteristics 

of scheduling best practices could better position BOP staff to activate 

institutions in accordance with realistic schedule commitments and to 

navigate potential obstacles that may arise, thereby saving the bureau 

time and resources.

From fiscal year 2010 through March 2014, BOP obligated about $25 

million from its S&E account to maintain partially activated institutions 

while it waited for congressionally directed activation funding through the 

S&E account. The amount of congressionally directed activation funding 

included in BOP’s annual spend plans reflects the amount the bureau 

planned to spend activating each of the individual institutions in our 

review from fiscal year 2010 through March 2014.37

 37After an agency or component receives an appropriation, agencies develop plans for 

how they will spend that funding. We reviewed BOP’s spend plans from fiscal years 2010 

through 2014—the fiscal years for which BOP received congressionally directed funding 

for activation.

However, we found 

that BOP obligated more than its planned amount for two of the three

partially activated institutions (see table 2).

BOP Obligated Funds 

from Two Accounts to 

Maintain Partially 

Activated Institutions
Page 25 GAO-14-709 Bureau of Prisons

Table 2: Federal Bureau of Prisons’ (BOP) Congressionally Directed Activation 

Funding and Actual Obligations from Its Salaries and Expenses (S&E) Account for 

Partially Activated Institutions from Fiscal Year 2010 through March 2014

Institution

Total congressionally 

directed activation 

funding from BOP’s 

S&E account 

Total actual 

obligations from 

BOP’s S&E account

Amount obligated 

from BOP’s S&E 

account while waiting 

for activation funding a

FCI Aliceville

b

$51,457,000 $47,391,800 0

FCI Berlin 50,195,000 57,713,200 7,518,200

FCI Mendota 49,400,000 67,077,300 17,677,300

Total $151,052,000 $172,182,300 $25,195,500

Source: GAO analysis of BOP data. I GAO-14-709

Note: We included institutions in this analysis only for which BOP is no longer obligating activation 

funds. According to BOP officials, it has not finished obligating funding for activities related to the 

activation of Federal Correctional Institution (FCI) Hazelton, U.S. Penitentiary (USP) Yazoo City, or 

Administrative USP Thomson. Accordingly, the extent to which BOP will spend what it planned on 

activating those institutions is not yet clear.

a

These obligations represent the cumulative obligations made from fiscal year 2010 through March 

2014.

b

BOP receives congressionally directed activation funding through its S&E account. When such 

congressionally directed activation funding has been delayed, BOP has obligated funding from the 

S&E account, which is generally used to fund the operation of all BOP institutions, to maintain 

partially activated institutions. For FCI Berlin and FCI Mendota, this amount represents the difference 

between the amount BOP planned to spend and what it actually obligated. Because BOP obligated 

less than it planned for FCI Aliceville, BOP did not obligate any funds from its S&E account while 

waiting for congressionally directed activation funding for that institution.

Specifically, BOP obligated about $7.5 million and $17.7 million more 

than it planned to activate FCI Berlin and FCI Mendota, respectively, for a 

collective total of about $25.2 million more than it estimated in its spend 

plan. Additionally, we found that BOP’s obligations for activating those 

three institutions are similar to what BOP has spent in the past when 

activating new institutions. Specifically, when adjusting for inflation, BOP 

spent, on average, about $41,100 per bed for those institutions, and 

spent, on average, about $40,600 per bed on the 21 institutions activated 

from 1994 through 2000.38

 38We adjusted for inflation all obligations made for partially activated institutions and 

divided those by the total number of beds that these institutions and their respective 

camps provide for each fiscal year from 2010 through 2014. Without adjusting for inflation, 

BOP spent, on average, about $39,600 per bed on partially activated institutions in our 

review, and, on average, $29,200 per bed on the 21 institutions constructed from 1994 

through 2000.
Page 26 GAO-14-709 Bureau of Prisons

To finance the additional $25 million of activation-related activities, BOP 

officials told us they used S&E funds that are generally used to fund the 

operation of all BOP institutions. Specifically, BOP officials told us that 

BOP spends between $1 million and $4 million each year to maintain a 

newly constructed or acquired institution while waiting for the 

congressionally directed activation funding needed to complete the 

activation process. This additional spending supports, among other 

things, salaries of a core group of staff and the cost of utilities to maintain 

institutions and keep them secure prior to receiving congressionally 

directed activation funding. According to BOP officials, when BOP is 

waiting for congressionally directed activation funding for a given 

institution, BOP hires a facility manager to ensure that the building is 

operating appropriately and covers costs associated with utilities, such as 

electricity and water. For example, to maintain Administrative USP 

Thomson while waiting for congressionally directed activation funding, 

BOP obligated $1.3 million in fiscal year 2013, and, as of March 2014, 

BOP has obligated about $440,700. Those costs included relocation 

expenses, uniforms, and training for the maintenance staff; utilities; and 

mechanical services for the institution, among other things. In addition, 

BOP officials told us that BOP spent about $150,000 over 2 fiscal years to 

fund a state of Illinois employee to maintain the institution while waiting 

for BOP staff to be hired. Further, BOP spent about $10 million in utility 

and personnel costs to maintain FCI Berlin for an additional 2 fiscal years 

while BOP waited for congressionally directed activation funding to begin 

activation. According to BOP officials, that additional funding covered the 

salary expenses for 16 employees that the agency hired to maintain the 

institution. BOP officials told us they had planned on paying for these 

salaries with its requested activation funding, but because the activation 

funding was delayed, BOP used other available funds from its S&E 

account to keep the staff in place.

In addition to maintaining empty institutions while waiting for 

congressionally directed activation funding, BOP has also obligated funds 

from its B&F account to provide a range of modifications to new 

institutions after construction is complete. According to BOP data, BOP 

spent a total of about $1.2 million on alterations, installations, and repairs 

at four of the six institutions in our review, with costs per institution 

ranging from about $130,000 to $458,000. For example, FCI Berlin spent 

$150,000 repairing roofs that could not handle the heavy amounts of 

snowfall and constructing overhangs at exterior doorways to provide 
Page 27 GAO-14-709 Bureau of Prisons

protection from the weather.39 BOP officials told us that additional costs 

are generally related to maintaining empty institutions because of a lag in 

receiving activation funds. As discussed earlier in this report, 

communicating the potential challenges that certain locations may pose 

for activation could help BOP minimize the amount of renovation or staff 

relocation expenses it ultimately spends while awaiting congressionally 

directed activation funding.

BOP plans to activate and fully populate all six institutions with inmates by 

fiscal year 2016, which would add 7,852 beds to BOP’s overall capacity.40

 39Officials explained that the construction contractor contended that the building’s flat roof, 

which is part of BOP’s standard design, was not appropriate for the heavy snowfall in 

northern New Hampshire and took steps to limit its liability for weather-related warranty 

repairs. BOP’s Design and Construction Branch staff explained that they routinely review 

and modify designs as necessary, but told us the construction contractor determines how 

the roof of an institution will be built, and the material of the roof determines whether or not 

the roofs are pitched or flat.

If BOP achieves this goal, these institutions will reduce the overall 

crowding rate from almost 42 percent to 34 percent. According to our 

estimates using BOP’s projections of the future inmate population, we 

found that crowding reductions will vary for inmates depending on their 

gender and security level. To determine how these institutions will affect 

system-wide crowding, we compared crowding rates with and without the 

addition of new beds that BOP anticipates the six institutions will provide 

by fiscal year 2016. On the basis of that comparison, we estimate that 

BOP will have spent almost $200 million per percentage point decrease in 

the overall crowding rate—or about $1.6 billion since fiscal year 2003—on

constructing, acquiring, and activating the institutions in our review. For 

specific details on these institutions’ impact on crowding, see table 3.

40This number includes the additional beds provided by the individual institutions in our 

review only. This number does not include the beds provided by each institution’s 

respective minimum-security camp, because camps were outside the scope of our review.

The Six Institutions 

Being Activated Will 

Reduce Crowding 

System-wide when 

They Reach Rated 

Capacity
Page 28 GAO-14-709 Bureau of Prisons

Table 3: Anticipated Federal Bureau of Prisons’ (BOP) Before-and-After Crowding Rates, Assuming Institutions Reach Rated 

Capacity in Fiscal Year 2016 and Associated Obligations Data

Crowding rate in fiscal 

year 2016 if 

institutions in our 

review do not house 

any inmates (before)a

Crowding rate in 

fiscal year 2016 if 

institutions in our 

review are fully 

populated (after)

Anticipated 

percentage point 

reduction in 

crowding

Total obligations 

made to construct and 

activate institutions in 

our review

Obligations made 

per percentage 

point decrease in 

crowding rate b

Overall 42% 34% -8% $1,582,575,403 $204,231,529

By gender

Overall male 41 34 -7 1,309,691,973 175,247,023

Overall female 45 24 -21 272,883,430 12,761,393

Security level

Medium male 55 42 -13 918,947,210 72,087,213 

High male 57 31 -26 390,744,763 14,945,386 

Low female 84 28 -56 272,883,430 4,890,524 

Source: GAO analysis of BOP data. I GAO-14-709

a

The estimated crowding rates are based on BOP’s estimates of the future inmate population in fiscal 

year 2016. Fiscal year 2016 is the year when BOP anticipates that each of the institutions in our 

review will be fully activated.

b

We totaled BOP data on obligations BOP made to construct or acquire and activate Federal 

Correctional Institution (FCI) Aliceville, FCI Berlin, FCI Hazelton, FCI Mendota, U.S. Penitentiary 

(USP) Yazoo City, and Administrative USP Thomson. To calculate the obligations made by security 

level, we totaled obligations for institutions with corresponding gender and security levels.

Crowding by gender. The new institutions housing male inmates will add 

a total of 6,316 beds to total capacity once they are fully activated. The 

addition of these beds will reduce crowding among male institutions by 

about 7 percentage points, lowering the rate from about 41 percent to 

about 34 percent, assuming that the institutions will reach rated capacity 

by fiscal year 2016 as BOP intends. Similarly, the only new institution to 

add beds for female institutions, FCI Aliceville, will add a total of 1,536 

beds to total capacity for institutions housing female inmates. The 

addition of these beds will reduce crowding among female institutions by 

about 21 percentage points, falling from about 45 percent to about 24 

percent.

Crowding by security level. The new institutions housing mediumsecurity inmates will add a total of 3,456 beds, while the new institutions 

housing high-security inmates will add a total of 2,860 beds, once they 

are fully activated. Additionally, the new institution housing low-security 

female inmates will add 1,536 inmates. The addition of medium-security 

beds at FCI Berlin, FCI Hazelton, and FCI Mendota will reduce crowding 

at that security level by about 13 percentage points, lowering the 
Page 29 GAO-14-709 Bureau of Prisons

crowding rate from about 55 percent to about 42 percent, assuming that 

the new institutions will reach rated capacity by fiscal year 2016 as BOP 

intends. Similarly, the addition of high-security beds at Administrative 

USP Thomson and USP Yazoo City will reduce crowding at that security 

level by about 26 percent, lowering the crowding rate from about 57 

percent to 31 percent. Finally, once fully activated, FCI Aliceville will 

reduce crowding among low-security female institutions by about 56 

percentage points, or a decrease from about 84 percent to about 28 

percent. Because FCI Aliceville will add 1,536 beds to an overall capacity 

of 5,048 beds among medium-security institutions housing female 

inmates, these new beds will have a large effect on crowding at that 

security level.

DOJ purchased the Thomson Correctional Center in an effort to reduce 

high-security crowding, and if the institution reaches rated capacity by 

fiscal year 2016, we estimate that the institution will reduce high-security 

crowding by about 16 percentage points. However, purchasing Thomson 

resulted in unplanned costs at the time of the purchase and will increase 

costs in the future.

DOJ stated in its budget requests that acquiring the Thomson 

Correctional Center in Illinois would address high-security crowding and 

support BOP’s mission, as well as DOJ’s strategic goal to ensure the fair 

and efficient administration of justice. The state of Illinois constructed the 

institution in 2001 to address inmate crowding in state-operated 

institutions, but never populated the high-security portion of the institution 

with inmates because of the institution’s high operating costs, among 

other things. In December 2009, the President issued a memorandum to 

the Attorney General and Secretary of Defense directing DOJ and the 

Department of Defense to purchase and use the Thomson Correctional 

Center.41

 41The President, Memorandum of December 15, 2009—Directing Certain Actions with 

Respect to Acquisition and Use of Thomson Correctional Center to Facilitate Closure of 

Detention Facilities in Guantanamo Naval Base, Federal Register Vol. 74, No. 241 

(Washington, D.C.: Dec. 15, 2009).

The memorandum stated that the acquisition of the institution 

would facilitate the closure of detention facilities at Guantanamo Bay 

DOJ Purchased 

Thomson to Reduce 

High-Security 

Crowding, but It Will 

Increase Costs

DOJ Purchased Thomson 

to Provide High-Security 

Bed Space and Used

Several Accounts to 

Finance the Purchase
Page 30 GAO-14-709 Bureau of Prisons

Naval Base and reduce BOP’s shortage of high-security, maximumcustody bed space. However, legislation limited or prohibited the use of

federal funds to transfer Guantanamo Bay detainees into the United 

States,42

DOJ requested funding from Congress to purchase and activate the 

Thomson Correctional Center in its annual budget requests for fiscal 

years 2011 and 2012. Congress did not provide funding for either 

request. While DOJ continued to wait for specific funding for the 

acquisition of the Thomson Correctional Center, DOJ and the state of 

Illinois assessed the purchase of the institution. During this time, DOJ 

obtained two appraisals indicating an average value of $165 million, and 

the state of Illinois conducted three appraisals. On the basis of the 

average value from the two appraisals conducted on behalf of the federal 

government, DOJ and the state of Illinois agreed on a price of $165 

million (the compensation for the taking of the property by the federal 

government as described below).

and DOJ officials stated that the department was committed to 

fully adhering to those prohibitions. DOJ pursued the purchase of the 

institution to provide beds for high-security inmates who, according to 

DOJ officials, were not previously detained at Guantanamo Bay.

43

Congress did not provide specific funding to finance the purchase of the 

Thomson Correctional Center. Therefore, in July 2012, DOJ notified the 

Senate and House Committees on Appropriations of its intention to 

allocate $165 million in existing funding to purchase the institution.44

 42See Supplemental Appropriations Act, 2009, Pub. L. No. 111-32, 123 Stat. 1859 (June 

24, 2009). Congress continued to pass legislation limiting or prohibiting the use of federal 

funds to transfer Guantanamo Bay detainees to U.S. facilities. See, e.g., National Defense 

Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, 123 Stat. 2190 (Oct. 28, 

2009); Consolidated Appropriations Act, 2010, Pub. L. No. 111-117, 123 Stat. 3034 (Dec. 

16, 2009); Ike Skelton National Defense Authorization Act for Fiscal Year 2011, Pub. L. 

No. 111-383, 123 Stat. 4137 (Jan. 7, 2011); and National Defense Authorization Act for 

Fiscal Year 2012, Pub. L. No. 112-81, 125 Stat. 1298 (Dec. 31, 2011).

DOJ 

43Additionally, BOP estimates that it will cost $25 million to renovate Administrative USP 

Thomson for a total acquisition and renovation cost of $190 million. Further, in its fiscal 

year 2014 spend plan, BOP included $43.7 million to begin activation of USP Thomson.

44DOJ provided a notification letter to the appropriations committees in response to 

requirements of the Consolidated and Further Continuing Appropriations Act, 2012, as it 

related to the reprogramming and transferring of appropriated funds in BOP’s annual 

appropriation, as well as 28 U.S.C. § 524(c)(8)(E), as it related to the transferring of funds 

from the Assets Forfeiture Fund Super Surplus.
Page 31 GAO-14-709 Bureau of Prisons

and BOP allocated funds from three separate funding sources. 

Specifically, BOP reprogrammed $5 million in its B&F appropriation from 

the modernization and repair subaccount into the B&F new construction 

subaccount,45 and transferred $9 million from BOP’s S&E account to 

BOP’s B&F account.46 In addition, DOJ transferred $151 million from 

DOJ’s Assets Forfeiture Fund Super Surplus to BOP’s B&F account.47

According to DOJ and BOP budget officials, the absence of specific 

funding for purchasing the Thomson Correctional Center, and restrictions 

on transferring and reprogramming applicable to BOP’s annual 

appropriations affected DOJ’s decisions to use these multiple funding 

streams.48

 45Reprogramming is a shifting of funds from one purpose to another within a single 

appropriation.

In September 2012, the Director of BOP filed in the United 

States District Court for the Northern District of Illinois a “declaration of 

taking” to acquire the Thomson Correctional Center and deposited the 

$165 million with the court as compensation. In October 2012, DOJ 

46A transfer is the shifting of funds between appropriations.

47Every year, federal, state, and local law enforcement agencies seize millions of dollars in 

assets that are forfeited through the DOJ Assets Forfeiture Program. Forfeited assets can 

include, but are not limited to, businesses, cash, bank accounts, automobiles, boats, 

airplanes, jewelry, art objects, and real estate. Under the statutory authority of 28 U.S.C. § 

524(c)(8)(E), subject to certain notification procedures, any excess unobligated balance 

remaining in the Assets Forfeiture Fund Super Surplus is available to the Attorney General 

for any federal law enforcement, litigative/prosecutive, and correctional activities, or any 

other authorized purpose of DOJ. Further, any amounts provided could be used under the 

authorities available to the organization receiving the funds.

48Section 205 of the Consolidated and Further Continuing Appropriations Act, 2012, 

provided that “not to exceed 5 percent of any appropriation made available for the current 

fiscal year for the Department of Justice in this Act may be transferred between such 

appropriations, (emphasis added)” which limited the amount BOP could transfer from its 

S&E account. Additionally, the Act provided that “no such appropriation, except as 

otherwise specifically provided, shall be increased by more than 10 percent by any such 

transfers, (emphasis added)” which limited the amount that the B&F account could accept 

from any appropriation made available for fiscal year 2012 for DOJ in the Act. Pub. L. No. 

112-55, § 205, 125 Stat. 552, 619. Section 205 of the Act provided that any transfer 

conducted pursuant to the section was to be treated as a reprogramming of funds under 

section 505 of the Act. Under section 505 of the Act, none of the funds provided under the 

Act would be available for obligation or expenditure through certain types of 

reprogramming of funds unless the House and Senate Committees on Appropriations 

were notified 15 days in advance of such reprogramming of funds. Pub. L. No. 112-55, § 

505, 125 Stat. 552, 630-31.
Page 32 GAO-14-709 Bureau of Prisons

acquired the Thomson Correctional Center from the state of Illinois and 

subsequently renamed the institution Administrative USP Thomson.49

Once it reaches rated capacity, according to our analysis of inmate 

population data, Administrative USP Thomson will help address crowding 

at the high-security level by about 16 percent for male inmates, which is 

similar to the decrease in crowding rates that DOJ asserted in the 

business cases submitted to Congress as part of the annual budget 

process. The expenses associated with the initial purchase price shifted 

funds away from BOP repairs and program services, and the continued 

expenses of operating and maintaining the institution will incur future 

costs. BOP officials acknowledged that the purchase of Administrative 

USP Thomson posed costs at the time of the purchase and will pose 

costs in the future, but said that the benefits that Administrative USP 

Thomson provides—particularly high-security bed space—far outweigh 

the costs associated with the institution. The activation of any new 

institution, including Administrative USP Thomson, will increase BOP’s 

operational costs. Further, according to DOJ officials, the purchase of 

Administrative USP Thomson provided bed space at a lower cost than 

constructing a new institution.

The $14 million DOJ used from BOP’s S&E and B&F accounts toward the 

purchase of Administrative USP Thomson came from accounts that BOP 

uses for the operation and maintenance of the federal prison system. 

Specifically, BOP uses funds from the B&F account’s modernization and 

repair subaccount to address outstanding, unfunded modernization and 

repair items system-wide, otherwise known as BOP’s maintenance and 

repair backlog. BOP maintains a list of these backlogged items that are in 

excess of $300,000, such as replacing roofs and boilers, that it considers 

important in order to rehabilitate, modernize, and otherwise repair 

physical structures and systems needed to maintain safety and security at 

its institutions and avoid costlier repairs in the future. BOP’s list from 2012 

totaled approximately $346 million and included 150 items, the most 

 49DOJ acquired the Thomson Correctional Center through eminent domain, a process by 

which the federal government can obtain property from other entities. Pursuant to 40 

U.S.C. § 3113, “[a]n officer of the Federal Government authorized to acquire real estate 

for the erection of a public building or for other public uses may acquire the real estate for 

the Government by condemnation, under judicial process, when the officer believes it is 

necessary or advantageous to the Government to do so.”

Purchasing Thomson Will 

Address Crowding at the 

High-Security Level, but 

Will Result in Increased 

Operational Costs
Page 33 GAO-14-709 Bureau of Prisons

expensive of which was about $16 million. Since Thomson is a 13-yearold facility and will incur repair costs as it ages, it may add new items to 

BOP’s existing list of unfunded maintenance and repair priorities. BOP’s 

S&E account funds staffing, inmate medical care, food, utilities, and 

services at various BOP institutions, such as inmate educational or 

vocational programs, among other things. In addition, during the nearly 2 

years BOP has owned Administrative USP Thomson, it has spent 

approximately $1.8 million from the S&E account to maintain the empty 

facility while waiting for activation funding.

BOP estimates that once Administrative USP Thomson is fully activated,

it will cost $160 million each year to operate it as a high-security 

institution that primarily houses special management unit (SMU) 

inmates.50 Of that amount, $45 million is expected to cover food, medical, 

clothing, laundry, utilities, programming, and other related operating 

expenses, and $115 million is expected to cover staff salary and benefit 

costs. This $160 million estimated total annual operating cost is higher 

than that for all but two other BOP institutions, Federal Correctional 

Complex (FCC) Butner and FCC Coleman, based on fiscal year 2013 

operational cost data.51 In BOP’s fiscal year 2014 congressional budget 

request, BOP estimated the need for 1,158 correctional positions at 

Administrative USP Thomson, 749 of which will be positions for 

correctional officers.52

 50SMU inmates are housed in a type of segregated housing unit used to separate inmates 

from the general population for different purposes—such as disciplinary reasons, gangrelated activity, or assaulting staff. SMU inmates are part of a four-level program where 

they progress from more restrictive to less constrictive conditions.

SMUs require more staff than institutions with 

lower security levels because more staff are needed to provide constant 

inmate supervision. BOP officials told us that Administrative USP 

Thomson will require a large number of staff to operate because BOP 

plans to move some of the most dangerous SMU inmates housed 

elsewhere into Administrative USP Thomson.

51FCC Butner is a large complex consisting of four separate institutions and a camp, and 

its staff provide medical services to inmates requiring an advanced level of care. FCC 

Coleman is also a large complex consisting of four separate institutions (two at the highsecurity level) and a camp, and it has the largest number of inmates of any BOP facility.

52BOP officials told us that the remaining correctional positions will be for staff necessary 

for operating the institution.
Page 34 GAO-14-709 Bureau of Prisons

Administrative USP Thomson has a rated capacity of 2,100 beds—1,900 

high-security SMU beds and 200 minimum-security beds at the onsite 

camp—and, according to BOP officials, the potential to use some of its 

high-security rated capacity to house up to 400 ADX inmates. 

Additionally, BOP officials told us that they estimate the institution 

eventually will be overcrowded by about 30 percent, given current and 

projected inmate population levels system-wide. Accordingly, they 

estimate that Administrative USP Thomson will ultimately house between 

2,600 and 3,000 inmates. While this level of crowding would be lower 

than the current rate of 52 percent at BOP’s other high-security 

institutions, the daily cost per inmate at Administrative USP Thomson will 

still exceed the daily cost per inmate for SMU bed space at USP 

Lewisburg, which is the only other institution whose USP entirely houses 

SMU inmates.53 Specifically, we estimate that BOP will spend between 

$146.12 and $168.60 each day per inmate housed at Administrative USP 

Thomson and its camp. In comparison, we estimate that BOP spends 

about $100.46 daily per inmate for all inmates at USP Lewisburg (i.e., the 

SMU and camp inmates). This cost rises to $123.33 daily for only those 

inmates in its SMU.54

BOP included funding to activate Administrative USP Thomson in its 

fiscal year 2014 spend plan and anticipates that it will be fully activated by 

fiscal year 2016. As of July 2014, BOP had not determined how many 

inmates the institution will house, including how many ADX beds will be 

necessary. As we found in 2013, BOP has had empty ADX beds in 

Florence since fiscal year 2008. We also found that, according to BOP 

officials, the ADX population has declined overall because, among other 

things, BOP has placed inmates in SMUs instead of in the ADX 

institution.55

 53USP Lewisburg also has a minimum security camp onsite.

Given that BOP expects to begin activation at Administrative 

USP Thomson this fiscal year, and is behind its target date for completing 

54We divided BOP’s estimate by the number of inmates it estimates that the institution will 

house—2,600 inmates in one case and 3,000 inmates in another case— to provide the 

range in annual costs per inmate. We then divided the annual costs by 365 days in the 

calendar year to arrive at daily cost per inmate. BOP’s daily cost per inmate varies 

depending on the number of inmates housed at the institution. BOP previously provided 

daily inmate costs for the SMU institution, USP Lewisburg, which we adjusted for inflation.

55GAO, Bureau of Prisons: Improvements Needed in Bureau of Prisons’ Monitoring and 

Evaluation of Impact of Segregated Housing, GAO-13-429 (Washington, D.C.: May 1, 

2013).
Page 35 GAO-14-709 Bureau of Prisons

activation, its uncertainty regarding the number and security level of the 

inmates it plans to house there underscores the challenge of activating 

institutions without a comprehensive policy and without a schedule 

anchored in best practices, as discussed earlier in the report. If BOP had 

a policy in place to guide its activation of new institutions and a schedule 

that could account for different scenarios, it would be better positioned to 

determine more precisely the number and type of inmate it plans to house 

at Administrative USP Thomson and help ensure that the institution is 

activated within schedule estimates. BOP would also be better positioned 

to make adjustments to account for changes in resources, as well as 

variations in cost, while keeping within established time frames.

BOP’s six new institutions will reduce crowding system-wide, but doing so 

has cost more and taken longer than BOP initially estimated because of 

internal and external challenges, many of which, according to BOP 

officials, are outside of BOP’s control. Doing more to guide the aspects of 

the activation process over which BOP does have control could prevent 

similar schedule delays in future activations. In particular, by using the 

BOP annual budget justifications to clearly communicate to Congress the 

factors that might delay activation, like institution locations, DOJ could 

more effectively mitigate activation challenges and better meet the 

bureau’s needs. Further, ensuring that the Central Office is analyzing 

staffing data at individual institutions in the activation process and 

developing effective strategies to mitigate staffing challenges would help 

expedite the activation process. In addition, by developing and 

implementing a comprehensive activation policy that incorporates the 

knowledge of staff with experience activating institutions, as well as the 

four characteristics of scheduling best practices, BOP would be better 

positioned to ensure that future activations are implemented in 

accordance with realistic cost and schedule commitments. While the 

success of new institution activations relies heavily on congressional 

direction regarding activation funding, BOP ultimately is responsible for 

the taxpayer dollars it spends on construction, acquisition, and activation 

of new institutions. Taking action to address challenges that BOP can 

control will help mitigate obstacles in ongoing and future activation of new 

institutions.

To ensure that the challenges that BOP faces activating new institutions 

are clearly conveyed to decision makers, we recommend that, in future 

activations, the Attorney General use DOJ’s annual congressional budget 

justification for BOP to communicate to Congress factors that might delay 

Conclusions

Recommendations for 

Executive Action
Page 36 GAO-14-709 Bureau of Prisons

activations, such as challenges hiring staff and placing inmates 

associated with the locations of new institutions.

To better address obstacles that occur during the activation process and 

to help ensure that institutions are activated within estimated timeframes, 

including those institutions that do not currently have inmates, such as 

Administrative USP Thomson and USP Yazoo City, we recommend that 

the Director of the Bureau of Prisons take the following three actions:

• direct the Central Office to analyze staffing data at individual 

institutions in the activation process to assess their progress toward 

reaching authorized staffing levels and use that assessment to 

develop effective, tailored strategies to mitigate those challenges;

• develop and implement a comprehensive activation policy that 

incorporates the knowledge of staff with experience activating 

institutions; and

• develop and implement an activation schedule that incorporates the 

four characteristics of scheduling best practices.

We provided a draft of this report to DOJ for review and comment. DOJ 

provided written comments, which are reprinted in appendix IV, and 

technical comments, which we incorporated as appropriate. DOJ agreed 

with all four of the recommendations and outlined steps to address them. 

If fully implemented, these actions will address the intent of our 

recommendations.

• With respect to the first recommendation, DOJ agreed to use the 

annual congressional budget justification to communicate with 

Congress any factors that might affect schedules in future activations. 

• Regarding the second recommendation, DOJ agreed that BOP’s 

Central Office will analyze staffing data at individual institutions in the 

activation process to assess progress toward reaching authorized 

staffing levels and use that assessment to develop effective strategies 

to mitigate those challenges. DOJ stated that BOP’s regional offices 

will monitor staffing levels and report to the Central Office quarterly. 

BOP’s Central Office will provide oversight of staffing at activating 

institutions and will work to develop effective strategies, such as using 

recruitment incentives, when hiring challenges occur at those 

institutions. 

Agency Comments 

and Our Evaluation
Page 37 GAO-14-709 Bureau of Prisons

• In response to the third recommendation, DOJ agreed to develop and 

implement a comprehensive activation policy that incorporates the 

knowledge of staff with experience activating institutions. DOJ stated 

that BOP will use knowledgeable staff to develop a new institution 

activation handbook. However, DOJ did not state what information 

would be included in this new institution activation handbook or how it 

would differ from the current activation handbook template. Ultimately, 

BOP should have a consistent policy that staff at institutions can use 

during the activation process to ensure that all future activations follow 

the same process. 

• Finally, for the fourth recommendation, DOJ agreed to develop and 

implement an activation schedule that incorporates the four 

characteristics of scheduling best practices. DOJ stated that a 

template of this schedule will be included in the new institution 

activation handbook and will take into account the best practices 

outlined in GAO’s Schedule Assessment Guide. 

Further, DOJ commented that BOP cannot begin the activation process 

until Congress provides the necessary funding, which occurs over 

multiple years. DOJ stated that it cannot be held to activation estimates 

included in its annual budget requests when it does not receive such 

funding. As we note in the report, each of the institutions in the activation 

process has experienced schedule slippages due to delays in receiving 

congressionally directed activation funding, which is outside of BOP’s 

control, as well as challenges associated with institutions’ locations. We 

also note that institutions have experienced delays even after BOP has 

received multiple years of congressionally directed activation funding, 

which indicates that there is more that BOP could do to ensure that 

institutions are activated within schedule estimates. If BOP had a 

schedule that reflected best practices, it could revise its estimates, when 

warranted, for when activation would be completed. The ability to make 

such schedule revisions would allow BOP to adjust for the risks 

associated with funding delays and more accurately reflect the status of 

activation.

Finally, DOJ commented that Administrative USP Thomson, like every 

newly activated prison, will increase BOP’s future operational costs. DOJ 

also stated that BOP’s primary cost driver is the number of inmates, not 

the number of prisons. We agree that activating any new institution will 

consequently increase BOP’s operational costs, and that this is not 

specific to Administrative USP Thomson. We also agree, and have 

previously reported, that the number of inmates entering the federal 
Page 38 GAO-14-709 Bureau of Prisons

prison system is the primary driver of operational costs, rather than the 

number of institutions that BOP operates.56 However, we believe it is 

important to note that the acquisition or construction any new institution, 

including Administrative USP Thomson, will incur costs to operate and 

maintain in the future.

As agreed with your offices, 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 to the Attorney General of 

the United States, appropriate congressional committees, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO Web site at http://www.gao.gov.

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. Key contributors to this report are listed in 

appendix V.

David C. Maurer

Director, Homeland Security and Justice Issues

 56GAO-14-121.
Page 39 GAO-14-709 Bureau of Prisons

List of Requesters

The Honorable Tom Coburn

Ranking Member 

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Charles Grassley

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Bob Goodlatte

Chairman 

Committee on the Judiciary

House of Representatives

The Honorable F. James Sensenbrenner

Chairman

Subcommittee on Crime, Terrorism, Homeland Security and 

Investigations

Committee on the Judiciary

House of Representatives
Appendix I: Description of Schedule Slippages 

due to Delays in Receiving Congressionally 

Directed Activation Funding

Page 40 GAO-14-709 Bureau of Prisons

Each of the Federal Bureau of Prisons’ (BOP) institutions in the activation 

process has had schedule slippages due to delays in receiving 

congressionally directed activation funding.1

• Federal Correctional Institution (FCI) Mendota. BOP estimated in 

fiscal year 2008 that FCI Mendota would be fully activated by fiscal 

year 2010, but received congressionally directed activation funding in 

fiscal year 2010. As a result, BOP subsequently revised this estimate 

to fully activate FCI Mendota in fiscal year 2011. After BOP received a 

second year of congressionally directed activation funding for FCI 

Mendota in fiscal year 2012, BOP determined the FCI would accept 

its first inmate in February 2012 and accepted the first inmate that 

same month.

Such delays can exacerbate 

existing staffing challenges related to recruitment and retention, as 

discussed in appendix II. None of the six institutions is at rated capacity—

the number of inmates that a given institution can safely and securely 

house.

2

• FCI Berlin. BOP estimated in fiscal year 2008 that FCI Berlin would 

be fully activated by fiscal year 2010. However, BOP subsequently 

revised this estimate to fully activate FCI Berlin in fiscal year 2011 

because it had not received congressionally directed activation 

funding. After BOP received congressionally directed activation 

funding for FCI Berlin in fiscal year 2012, BOP determined that the 

FCI would accept its first inmate in January 2013 and accepted the 

first inmate 1 month later, in February. BOP received congressionally 

directed activation funding for FCI Berlin in fiscal year 2013. As of 

August 2014, FCI Berlin has not reached rated capacity—4 fiscal 

years after BOP’s initial estimate—with 83 percent of its total 1,152 

beds occupied.

As of August 2014, FCI Mendota has not reached rated 

capacity—4 fiscal years after BOP’s initial estimates—with 85 percent 

of its 1,152 beds occupied.

 1

Generally, either the annual appropriation act or the conference report accompanying 

BOP’s annual appropriation act directs BOP to use S&E appropriations for activation 

activities at particular institutions. Conference report language that is incorporated by 

reference into an appropriations act becomes part of the public law. However, BOP 

generally follows directives contained in the conference report language even if not 

incorporated into the appropriations act. For the purpose of this report, we refer to the 

conference report language as “congressional direction” and the related funding as 

“congressionally directed activation funding.”

2

A specific activation date is determined by the activating institution and regional office 

staff primarily based on funding, staffing, and training needs.

Appendix I: Description of Schedule 

Slippages due to Delays in Receiving 

Congressionally Directed Activation Funding 
Appendix I: Description of Schedule Slippages 

due to Delays in Receiving Congressionally 

Directed Activation Funding

Page 41 GAO-14-709 Bureau of Prisons

• FCI Aliceville. BOP estimated in fiscal year 2008 that FCI Aliceville 

would be fully activated by fiscal year 2011. However, BOP 

subsequently revised this estimate to fully activate FCI Aliceville in 

fiscal year 2012 because it did not receive congressionally directed 

activation funding. After BOP received congressionally directed 

activation funding for FCI Aliceville in fiscal year 2012, BOP 

determined that the FCI would accept the first inmate in June 2013 

and accepted the first inmate 1 month later, in July. BOP received 

congressionally directed activation funding for FCI Aliceville in fiscal 

year 2013. As of August 2014, FCI Aliceville has not reached rated 

capacity—3 fiscal years after BOP’s initial estimate—with 77 percent 

of its total 1,536 beds occupied.

• FCI Hazelton. BOP estimated in fiscal year 2008 that FCI Hazelton 

would be fully activated by fiscal year 2012. However, BOP 

subsequently pushed back this estimate twice—once to fully activate 

FCI Hazelton in fiscal year 2013 and again to fully activate the 

institution in fiscal year 2014—because it had not received

congressionally directed activation funding. After BOP received 

congressionally directed activation funding for FCI Hazelton in fiscal 

year 2013, it determined that the FCI would accept its first inmate in 

March 2014. BOP received congressionally directed activation funding 

for FCI Hazelton in fiscal year 2014. However, as of August 2014, the 

institution has not yet reached rated capacity—2 years after BOP’s 

initial estimate—with about 27 percent of its 1,152 beds occupied 

because of a leaking roof that had to be fixed before inmates were 

housed there.

• U.S. Penitentiary (USP) Yazoo City. BOP estimated in fiscal year 

2009 that USP Yazoo City would be fully activated by fiscal year 

2013. However, BOP subsequently revised this estimate to fully 

activate USP Yazoo City in fiscal year 2014 because it had not 

received congressionally directed activation funding. BOP received 

congressionally directed activation funding in fiscal years 2013 and 

2014. According to BOP, it has not completed activation of the 

institution because it was waiting for a congressional response to its 

spend plan relating to fiscal year 2014 funding. BOP received 

responses from the Senate and House Committees on Appropriations 

in April and May 2014, respectively, supporting BOP’s plans to 

activate USP Yazoo City. As of August 2014, USP Yazoo City has not 

admitted any inmates.

• Administrative USP Thomson. BOP initially estimated that 

Administrative USP Thomson would be fully activated by fiscal year 

2011. However, BOP subsequently revised this estimate to fully 

activate Administrative USP Thomson in fiscal year 2014 because it 

had not received congressionally directed activation funding in fiscal 
Appendix I: Description of Schedule Slippages 

due to Delays in Receiving Congressionally 

Directed Activation Funding

Page 42 GAO-14-709 Bureau of Prisons

year 2012 or 2013. BOP received conflicting congressional direction 

regarding activation funding for Administrative USP Thomson in the 

committee reports corresponding to the DOJ/BOP fiscal year 2014 

annual appropriations act.3

 3

Section 4 of the Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, § 4 128 Stat. 

5, 7, referenced an explanatory statement regarding the act, printed in the House of 

Representatives section of the Congressional Record, 160 Cong. Rec. H475, H507 (Jan. 

15, 2014). The explanatory statement, which was to have the same effect as if it were a 

joint explanatory statement of a committee of conference, stated that report language 

included in House Report 113-171 or Senate Report 113-78 that is not changed by the 

explanatory statement or the act is approved. House Report 113-171, at 47, stated “[t]he 

Committee continues to prioritize maintaining staff levels at institutions and the 

continuation of activation activities, as necessary, at the four institutions which received 

fiscal year 2013 activation funding. No funding is included for the activation of the 

Thomson, Illinois facility.” However, Senate Report 113-78, at 79, stated “[t]he Committee 

fully funds the requests to activate prisons that currently sit empty or partially empty due to 

prior year budget constraints. These funds will complete the activation of a mediumsecurity prison located in Berlin, New Hampshire, and a medium-security prison for female 

inmates in Aliceville, Alabama, and begin activations of a high-security prison in Yazoo, 

Mississippi, a medium-security prison in Hazelton, West Virginia, and a high-security 

prison in Thomson, Illinois.”

BOP subsequently included funding to 

activate that institution in its fiscal year 2014 spend plan, which was 

submitted to the Committees on Appropriations. BOP received 

responses from the Senate and House Committees on Appropriations 

in April and May 2014, respectively. However, those responses also 

included conflicting direction regarding activation funding for 

Administrative USP Thomson. As of August 2014, Administrative USP 

Thomson has not admitted any inmates.
Appendix II: Analysis of BOP’s Human 

Resources Data

Page 43 GAO-14-709 Bureau of Prisons

We analyzed data from the Office of Personnel Management’s (OPM) 

human resources database, Enterprise Human Resources Integration 

(EHRI) Statistical Data Mart,1 on staffing levels at the three institutions in 

our review that are partially activated and found that each faced obstacles 

hiring staff up to authorized levels (see table 4).2 Specifically, although 

FCI Aliceville, FCI Berlin, and FCI Mendota are all partially activated, 

none has a full complement of staff, as demonstrated by the number of 

employees on board each fiscal year.3 For example, FCI Berlin is 

authorized to fill 378 positions and has been staffing the institution since 

fiscal year 2010, even though BOP first received activation funds for that 

institution in fiscal year 2012, but it was only 67 percent staffed at the end 

of fiscal year 2013.

 1

EHRI is a collection of human resources, payroll, and training data that facilitates 

management of personnel in the federal government.

2

We included three of the four partially activated institutions because the staffing data for 

FCI Hazelton included staff on board across the entire complex, rather than by individual 

institution. As a result, we could not calculate the number of employees staffed by fiscal 

year or the percent currently staffed for that particular institution. Additionally, we did not 

include data on Administrative U.S. Penitentiary (USP) Thomson or USP Yazoo City 

because BOP has not begun activating those institutions. According to BOP officials, 

Administrative USP Thomson had two employees on staff to maintain the institution. We 

were unable to determine the number of staff at USP Yazoo City because, as with FCI 

Hazelton, staffing data were by the entire Yazoo City complex. As a result, we could not 

calculate the number of employees staffed by fiscal year or the percentage currently 

staffed for that particular institution.

3

Staff “on board” at an agency refers to personnel employed as of September 30 of the 

reporting period. Staff “hired” refers to new appointments that occur within the fiscal year.

Appendix II: Analysis of BOP’s Human 

Resources Data 
Appendix II: Analysis of BOP’s Human 

Resources Data

Page 44 GAO-14-709 Bureau of Prisons

Table 4: Staff On Board at Partially Activated Federal Bureau of Prisons’ (BOP) Institutions from Fiscal Years 2010 through 

2013

Number of employees on board by 

fiscal year

Institution 2010 2011 2012 2013

Number of 

authorized 

positions

Number of authorized 

positions unfilled in 

fiscal year 2013

Percentage 

staffed

Federal Correctional Institution 

(FCI) Aliceville

84 240 378 138 63

FCI Berlin 2 16 123 252 378 126 67

FCI Mendota 55 171 250 261 359 98 73

Source: GAO analysis of Office of Personnel Management (OPM) data. I GAO-14-709

Note: These data reflect the number of staff on board on September 30 of each fiscal year. We 

included three of the four partially activated institutions because the staffing data for FCI Hazelton 

included staff on board across the entire complex, rather than by the individual institution. As a result, 

we could not calculate the number of employees on board by fiscal year or the percentage currently 

staffed for that particular institution. Additionally, we did not include data on Administrative U.S. 

Penitentiary (USP) Thomson because BOP has not begun activating that institution. As of June 2014, 

Administrative USP Thomson had two employees on staff to maintain the institution. Further, we were 

unable to determine the number of staff at USP Yazoo City because, as with FCI Hazelton, staffing 

data were by the entire Yazoo City complex. As a result, we could not calculate the number of 

employees staffed by fiscal year or the percentage currently staffed for that particular institution.

Furthermore, our analysis of OPM data demonstrates that two of the 

three partially activated institutions have experienced increases in the 

number of staff they hire each fiscal year through fiscal year 2013, when 

institutions hired greater numbers of staff in each consecutive year 

although authorized positions remained unfilled (see table 5). As a result, 

these staffing challenges have implications for activating institutions 

because, as BOP officials told us, being able to receive additional 

inmates and thereby reach rated capacity relies, in part, on having 

enough staff to provide adequate security for those inmates.
Appendix II: Analysis of BOP’s Human 

Resources Data

Page 45 GAO-14-709 Bureau of Prisons

Table 5: Staff Hired at Partially Activated Federal Bureau of Prisons’ (BOP) Institutions from Fiscal Years 2010 through July 

2014

Number of employees

hired by fiscal year

Institution 2010 2011 2012 2013 2014 Total employees hired 

Federal Correctional Institution (FCI) Aliceville - - 52 71 25 148

FCI Berlin - 1 39 72 34 146

FCI Mendota 40 64 55 31 50 240

Source: GAO analysis of Office of Personnel Management (OPM) data and BOP personnel data. I GAO-14-709

Note: We included three of the four partially activated institutions because the staffing data for FCI 

Hazelton included staff on board across the entire complex, rather than by the individual institution. 

As a result, we could not calculate the number of employees hired by fiscal year for that institution. 

Additionally, we did not include data on Administrative U.S. Penitentiary (USP) Thomson because 

BOP has not yet begun activating that institution. As of June 2014, Administrative USP Thomson had 

two employees on staff to maintain the institution. Further we were unable to determine the number of 

staff at USP Yazoo City because, as with FCI Hazelton, staffing data were by the entire Yazoo City 

complex. As a result, we could not calculate the number of employees hired for that particular 

institution. We used Office of Personnel Management (OPM) data to report hires through the end of 

each fiscal year. To report the most current data on hires in fiscal year 2014, we relied on BOP to 

provide this information from its personnel database. BOP’s data include hires that occurred between 

October 2013 and July 2014. We determined that these data are comparable to OPM’s data and are 

reliable for the purposes of our report.

In addition to facing challenges recruiting qualified applicants, officials 

from two of the six institutions we visited reported that they faced 

challenges in retaining both new hires and experienced BOP staff that 

transferred from other BOP institutions. Officials said that BOP staff 

transfer to activating institutions to gain experience before receiving 

promotions elsewhere, so some staff do not stay in those new institutions 

over time. Further, officials from all of the institutions we visited noted that 

certain positions, such as those for medical staff, are particularly 

challenging to fill because, among other things, it is difficult to provide 

competitive salaries for those positions compared with what those staff 

could make in the private sector. Officials from BOP’s Central Office also 

noted that recruiting medical staff, such as doctors and nurses, was a 

challenge system-wide, not just within the institutions undergoing 

activation. In fact, one of BOP’s objectives in its strategic plan is to attract 

and retain competent health care professionals using a range of 

strategies, including recruitment and retention bonuses. Similarly, our 

analysis of OPM data demonstrates that partially activated institutions 

have had staff sever employment with BOP (see table 6). For instance, 

each year more staff have separated from employment at FCI Mendota 
Appendix II: Analysis of BOP’s Human 

Resources Data

Page 46 GAO-14-709 Bureau of Prisons

than in the prior year, for a total of 40 employees—about 21 percent of its 

total hires—from fiscal years 2010 through 2013.

4

Table 6: Staff Separations for Partially Activated Federal Bureau of Prisons’ (BOP) 

Institutions from Fiscal Years 2010 through July 2014

Additionally, according 

to data provided by BOP from its personnel database for fiscal year 

2014—through July—an additional 11 employees separated from FCI 

Mendota.

Institution

Number of staff 

hired from fiscal 

years 2010 

through July 2014

Number of staff 

separated from 

BOP from fiscal 

years 2010 

through July 2014

Separations as a 

percentage of 

hired staff from 

fiscal years 2010 

through July 2014

Federal Correctional 

Institution (FCI) 

Aliceville

148 30 20.3%

FCI Berlin 146 21 14.4

FCI Mendota 240 51 21.3

Source: GAO analysis of Office of Personnel Management (OPM) data and BOP personnel data. I GAO-14-709

Note: Separations include, among other things, voluntary and mandatory retirement, resignations, 

terminations, and death of hired or existing staff. We used EHRI data to report hires and separations 

through the end of each relevant fiscal year. To report the most current data on hires in fiscal year 

2014, we relied on BOP to provide this information from its personnel database. BOP’s data include 

hires that occurred between October 2013 and July 2014. We determined that these data are 

comparable to OPM’s data and are reliable for the purposes of our report.

 4

These transfers may include existing BOP staff that transferred in and out of that 

institution during this time frame. 
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 47 GAO-14-709 Bureau of Prisons

We determined that BOP’s schedules for activating the six institutions in 

our review are not reliable based on our assessment of whether those 

schedules met best practices as outlined in our Schedule Assessment 

Guide.

1

In May 2012, we issued GAO’s Schedule Assessment Guide to provide 

guidance to auditors in evaluating government programs. According to 

that guide, the success of a program depends, in part, on having an 

integrated and reliable master schedule that defines when and how long 

work will occur and how each activity is related to the others. A schedule 

is necessary for government programs for many reasons. The program 

schedule provides not only a road map for systematic project execution, 

but also the means by which to gauge progress, identify and resolve 

potential problems, and promote accountability at all levels of the 

program. A schedule provides a time sequence for the duration of a 

program’s activities and helps those involved understand both the dates 

for major milestones and the activities that drive the schedule. A program 

schedule is also a way to develop a budget that incorporates the time it 

will take to complete phases of the project. Moreover, the schedule is an 

essential basis for managing trade-offs among cost, schedule, and scope. 

Among other things, scheduling allows program management to decide 

between possible sequences of activities, determine the flexibility of the 

schedule according to available resources, predict the consequences of 

managerial action or inaction on events, and allocate contingency plans 

to mitigate risks. Moreover, an integrated and reliable schedule can show 

when major events are expected to occur as well as the completion dates 

for all activities leading up to them, which can help determine if the 

program’s parameters are realistic and achievable.

Our research has identified 10 best practices associated with effective 

schedule estimating, which can be collapsed into four general 

characteristics:

• comprehensive,

• controlled,

• well constructed, and

• credible.

 1

GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules, 

GAO-12-120G (Washington, D.C.: May 2012).

Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Purpose and Scope of the 

Schedule Guide
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 48 GAO-14-709 Bureau of Prisons

After reviewing documentation BOP submitted for its activation schedule 

estimates and conducting interviews with BOP officials involved in 

activations, we determined that the documents used as schedules by the 

six activating institutions are not reliable.2 Collectively, the six BOP 

institutions minimally met two of the four characteristics of a reliable 

schedule and did not meet the remaining two characteristics, as 

summarized in table 7. To arrive at this determination, we examined the 

extent to which each of BOP’s six activating institutions adhered to each 

of the 10 best practices. We then assigned a corresponding score. We 

took the average score for all six institutions, by best practice, and 

collapsed the 10 best practices into the four characteristics to get an 

average that reflected an overall assessment by schedule characteristic.3

Table 7: Summary Assessment of the Federal Bureau of Prisons’ (BOP) Schedule Estimates for Six Institutions Compared 

against Best Practices

Characteristic

Best practice 

related to 

schedules

Average assessment 

score for all six institutions 

per best practice

Overall assessment 

by schedule 

characteristic

Comprehensive schedules include

a

• all activities, as defined in the project’s work 

breakdown structure, which defines work necessary 

to accomplish objectives;

• the labor, materials, travel, facilities, equipment, and 

the like needed to do the work;

• whether resources identified above will be available 

when needed; and

• how long each activity will take, allowing for discrete 

progress measurement, with specific start and finish 

dates.

Schedule 

captures all 

activities.

2 Minimally met (score 

of 1.72 b

Schedule has 

resources 

assigned to all 

activities.

)

2

Schedule 

establishes the 

durations of all 

activities.

1.17

 2

A schedule is considered reliable if the overall assessment ratings for each of the four 

characteristics are substantially or fully met. If any of the characteristics are not met, 

minimally met, or partially met, then the schedule cannot be considered reliable.

3

We first scored each of the six institutions on the 10 best practices: not met equaled 1, 

minimally met equaled 2, partially met equaled 3, substantially met equaled 4, and met 

equaled 5. Then, we took the average of the institutions’ ratings for each best practice to 

determine the average assessment score for all six institutions per best practice. We then 

took the average of the assessment scores per best practice within each schedule 

characteristic. The resulting average becomes the “overall assessment by schedule 

characteristic” using the same scoring categories: not met equaled 1.0 to 1.4, minimally 

met equaled 1.5 to 2.4, partially met equaled 2.5 to 3.4, substantially met equaled 3.5 to 

4.4, and met equaled 4.5 to 5.0.
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 49 GAO-14-709 Bureau of Prisons

Characteristic

Best practice 

related to 

schedules

Average assessment 

score for all six institutions 

per best practice

Overall assessment 

by schedule 

characteristic

Controlled schedules are

a

• updated periodically by schedulers trained in critical 

path method scheduling;

• statused using actual progress and logic to 

realistically forecast dates for program activities;

c

• compared against a documented baseline schedule 

to determine variances from the plan;

• accompanied by a corresponding baseline 

document that explains the overall approach to the 

project, defines assumptions, and describes unique 

features of the schedule; and

• subject to a process to manage changes to the 

baseline schedule.

Schedule is 

updated with 

actual progress 

and logic. 

1.5 Minimally met

(score of 1.83)

Baseline 

schedule is 

maintained. 

2.17

Well-constructed schedules include

• all activities, logically sequenced with predecessor 

and successor logic;

• limited amounts of unusual or complicated logic 

techniques that are justified in the schedule 

documentation;

• a critical path that determines which activities drive 

the project’s earliest completion date; and

• total float, or slack, that accurately determines the 

schedule’s flexibility.

Schedule shows 

the sequence of 

all activities.

d

1 Not met

(score of 1.0)

Schedule 

confirms that the 

critical path is 

valid.

1

Schedule 

ensures there is 

reasonable total 

float. 

1

Credible schedules include

• the order of events necessary to achieve aggregated 

products or outcomes;

• varying levels of activities, supporting activities, and 

subtasks;

• key dates that can be used to present status 

updates to management;

• a level of confidence in meeting a project’s 

completion date based on data about risks and 

opportunities for the project; and

• necessary schedule contingency and high priority 

risks based on conducting a robust schedule risk 

analysis.

Schedule can be 

verified that it is 

traceable 

horizontally and 

vertically. 

1 Not met

(score of 1.0)

Schedule risk 

analysis 

conducted. 

1

Source: GAO analysis of BOP schedules. I GAO-14-709

a

Met—BOP provided complete evidence that satisfies the entire criterion, substantially met—BOP 

provided evidence that satisfies a large portion of the criterion, partially met—BOP provided evidence 

that satisfies about half of the criterion, minimally met—BOP provided evidence that satisfies a small 

portion of the criterion, and not met—BOP provided no evidence that satisfies any of the criterion.

b

We first scored each of the six institutions on the 10 best practices: not met equaled 1, minimally met 

equaled 2, partially met equaled 3, substantially met equaled 4, and met equaled 5. Then, we took 

the average of the institutions’ ratings for each best practice to determine the average assessment 

score for all six institutions per best practice. We then took the average of the assessment scores per 

best practice within each schedule characteristic. The resulting average becomes the “overall 
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 50 GAO-14-709 Bureau of Prisons

assessment by schedule characteristic” using the same scoring categories: not met equaled 1.0 to 

1.4, minimally met equaled 1.5 to 2.4, partially met equaled 2.5 to 3.4, substantially met equaled 3.5 

to 4.4, and met equaled 4.5 to 5.0.

c

The critical path method for scheduling is a process used to identify the activities that cannot be 

delayed without delaying the end date of a program.

d

Total float, or slack, is the amount of time by which a predecessor activity can slip before the delay 

affects the program’s estimated finish date.

As summarized above, BOP’s six activating institutions minimally met two 

of the four characteristics of a reliable schedule and did not meet the 

remaining two characteristics. Each of the sections below provides 

greater detail about where BOP’s practices were deficient.

Comprehensive. We reviewed the activation handbooks and staffing 

timeline documents that each of the six institutions completed and 

found that they minimally met the requirements for a comprehensive 

schedule, as illustrated by table 8.

Table 8: Extent to Which Federal Bureau of Prisons’ (BOP) Schedules Were 

Comprehensive

Characteristic Characteristic description Assessment 

Comprehensive A schedule should reflect all activities as defined in 

the program’s work breakdown structure, including 

activities to be performed; the resources (e.g., labor, 

materials, and overhead) needed to do the work; and 

how long each activity will take.

Minimally met

Source: GAO analysis of BOP schedules. I GAO-14-709

To guide activation, BOP’s Central Office provides each activating 

institution with a standard activation handbook template and general 

staffing timeline. With respect to the activation handbook template 

provided to activating institutions, this document contains some elements 

of a work breakdown structure, which is an important feature in a 

comprehensive schedule. In particular, the activation handbook template 

lists necessary tasks, organized by responsible departments or 

contractors. However, the activation handbook template provides the 

tasks, or activities, in the list in a general way, but none of the six 

institutions tailored the tasks to meet their specific requirements, which 

limits the bureau’s ability to oversee all activation activities. Similarly, the 

activation handbook template does not fully include all work associated 

with each deliverable and does not identify the specific personnel within 

the department responsible for each activity—and none of the six 

institutions modified the template to provide this information. For example, 
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 51 GAO-14-709 Bureau of Prisons

the activation handbook template specifies that the Correctional Services 

department is responsible for coordinating with on-site project staff to 

evaluate all entrances, doors, locks, intercoms, cameras, and so forth. 

However, it does not provide additional detail about what is required as 

part of these evaluations, how these requirements might differ by 

institution, which specific staff should be executing or overseeing these 

activities, or what the costs associated with this activity might be. Two of 

the six institutions adapted the activation handbook template to provide 

detail on some resource costs associated with activation. In the case of 

FCI Berlin, that institution’s activation handbook included details on the 

associated costs by department, such as Correctional Services, Food 

Services, or Medical Services, and the materials those departments 

would need to provide services to inmates, such as vaccines. However, 

FCI Berlin’s activation handbook did not provide sufficient information 

about why the specific resources would be needed to keep the activation 

on schedule and the impact of not having the resources. Finally, none of 

the six institutions included any reference to project duration in its 

respective modified activation handbook. For example, the activation 

handbook template provided by BOP to activating institutions states that 

the Case Management Coordinator is responsible for establishing transfer 

arrangements for inmates and coordinating assignments for the transfers’

work areas, but it does not provide an indication of how long the activity 

may take to complete. Without information about the estimated length of 

time required to complete each activity, management cannot accurately 

identify the staffing resources required to complete it, assess the progress 

of the activation process, or establish realistic dates for institution 

activation.

With respect to the general staffing timeline template BOP’s Central 

Office provides, this document roughly identifies when particular staff 

resources are needed based on the anticipated activation date. For 

example, the general staffing timeline template specifies that 7 months 

prior to activation, the institution should hire the Warden, Executive 

Assistant, and Secretary within the Executive Staff department. However, 

the general staffing timeline template is based on the anticipated 

activation date rather than based on the activities each of these 

individuals would be doing—and none of the six institutions made 

modifications to elaborate on these activities. According to best practices 

for comprehensive schedules, resources, such as staff, should be 

assigned to particular activities in order to facilitate completion of these 

activities.
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 52 GAO-14-709 Bureau of Prisons

Because of these deficiencies, the information contained in each of the 

six institutions’ activation handbooks and staffing timelines does not 

assist management in forecasting whether activities will be completed as 

scheduled or as budgeted. Further, these documents do not allow insight 

into the allocation of resources, increasing the likelihood that the 

activation process will not be completed as anticipated and limiting BOP’s 

ability to ensure accountability for the total scope of work.

Controlled. The activation handbooks and staffing timeline templates 

that each of the six institutions modified minimally met the 

requirements for a controlled schedule, as illustrated in table 9.

Table 9: Extent to Which Federal Bureau of Prisons’ (BOP) Schedules Were 

Controlled

Characteristic Characteristic description Assessment 

Controlled A schedule should be updated periodically using logic 

and actual progress to realistically forecast dates for 

program activities. A schedule narrative should 

accompany the updated schedule to provide decision 

makers and auditors a log of changes and their effect, 

if any, on the schedule time frame. The schedule 

narrative should contain key dates, a description of 

critical paths, and significant variances between 

planned and actual performance. This analysis is 

especially important for those variations that affect 

activities identified as being in a program’s critical path 

and that can affect a scheduled completion date. A 

baseline schedule should be used to manage the 

program scope, the time period for accomplishing it, 

and the required resources.

Minimally met 

Source: GAO analysis of BOP schedules. I GAO-14-709

Two of the activating institutions provided versions of BOP’s activation 

handbook and staffing timeline templates that contained some indication 

that information on key dates and activities was updated at some point in 

time by the activating institutions. However, those activation handbook 

and staffing timeline templates modified by each institution did not 

indicate whether they had been updated at regular intervals, or that they 

reflected the actual status of the respective activations. For example, the 

activation handbook and staffing timeline templates modified by officials 

at FCI Aliceville that were used to guide that activation included 

handwritten dates for when specific steps in the activation process were 

expected to be completed, but these did not appear to be updated 

systematically or include an indication of when or if those activities had 
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 53 GAO-14-709 Bureau of Prisons

been completed. Further, none of the activating institutions’ activation 

handbooks or staffing timelines included the status of key milestone 

dates, such as whether specific activities had been completed, or when 

the activation should be completed. In addition, none of the activating 

institutions used activation handbooks or staffing timelines that described 

the critical risks that the institution faced in meeting its goals for activation 

or contingencies if those risks were realized. As BOP officials have noted, 

meeting scheduled dates for activation is often dependent on receiving 

specific activation funding as planned, and, according to best practices for 

a controlled schedule, such risks should be documented to ensure 

reliability. Without regularly updating the schedule based on the current 

status of the activation at each respective institution, BOP is limited in its 

ability to monitor activation progress or make decisions on how to mitigate 

risk or allocate resources for activating institutions.

Well constructed. The activation handbooks and staffing timeline 

documents that each of the six institutions modified did not meet the 

requirements for a well-constructed schedule, as illustrated in table 

10.

Table 10: Extent to Which Federal Bureau of Prisons’ (BOP) Schedules Were Well 

Constructed

Characteristic Characteristic description Assessment 

Well constructed A schedule should be planned so that critical project 

dates can be met. To meet this objective, all activities 

should be logically sequenced—that is, listed in the 

order in which they are to be carried out. In particular, 

activities that must finish prior to the start of other 

activities (i.e., predecessor activities), as well as 

activities that cannot begin until other activities are 

completed (i.e., successor activities), should be 

identified. The establishment of a critical path 

between one activity and its successor is necessary 

for examining the effects of any activity slipping along 

this path. The calculation of a critical path determines 

which activities drive the project’s earliest completion 

date. The schedule should also identify total float, or 

the amount of time a predecessor activity can slip, so 

that the schedule’s flexibility can be accurately 

determined.

Not met 

Source: GAO analysis of BOP schedules. I GAO-14-709

The activation handbook and staffing timeline templates modified by 

activating institutions did not always provide specific information 
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 54 GAO-14-709 Bureau of Prisons

regarding start and finish dates, durations, or sequencing of activationrelated activities. For example, BOP’s general staffing timeline template 

identifies the sequence in which staff should be hired, which is an 

important feature of a well-constructed schedule, but there is no 

sequencing of the activities listed in the activation handbook template. For 

example, the general staffing timeline specifies that within the Facilities 

department, the Communication Technician should be hired 7 months 

prior to activation, while the Facility Manager and Electrician and others 

should be hired 6 months prior to activation, but it does not provide 

contingencies if predecessor positions cannot be filled “on time” or 

describe the effects, if any, of filling positions out of sequence. Aside from 

staffing-related issues, the activation handbook template does not contain 

information on the order in which any of the activation tasks should occur. 

As a result, BOP does not have insight about the interdependencies 

between activities or the way in which early delays in some activities 

could affect activities later on as well as the overall activation completion 

date. Additionally, without identifying linkages between activities, BOP 

does not know the critical path of the activation process—that is, which 

activities can or cannot be delayed if the overall schedule is to be met. 

This prevents the agency from providing Congress with reliable timeline 

estimates or anticipated activation dates.

Credible. The activation handbook and staffing timeline templates 

that each of the six institutions modified did not meet the requirements 

for a credible schedule, as illustrated in table 11.

Table 11: Extent to Which Federal Bureau of Prisons’ (BOP) Schedules Were 

Credible

Characteristic Characteristic description Assessment 

Credible A schedule should be horizontally and vertically 

integrated. A horizontally integrated schedule links 

products and outcomes with other associated 

sequenced activities, which helps verify that activities 

are arranged in the right order to achieve aggregated 

products or outcomes. A vertically integrated schedule 

ensures that the start and completion dates for activities 

are aligned with such dates on subsidiary schedules 

supporting tasks and subtasks. Data about risks and 

opportunities are used to predict a level of confidence in 

meeting the project’s completion date. The level of 

necessary schedule contingency and high-priority risks 

and opportunities are identified by conducting a robust 

schedule risk analysis.

Not met 

Source: GAO analysis of BOP schedules. I GAO-14-709
Appendix III: Analysis of BOP’s Schedules 

against Best Practices

Page 55 GAO-14-709 Bureau of Prisons

With respect to the best practice of vertically and horizontally aligning 

activities, two institutions adapted BOP’s activation handbook template to 

insert targeted due dates for selected activities; however, neither 

identified subset activities or linked overall activities in any specific order. 

Without this vertical alignment, BOP is not positioned to ensure that 

subactivities are on track for an overall activity’s completion. Similarly,

without a clear sequencing of all activities, which is horizontal integration, 

BOP also is limited in the extent to which it can monitor overall progress 

toward activation. For risk assessment, neither the activation handbook 

template nor the staffing timeline contains a schedule risk analysis. Such 

an analysis typically focuses on key risks and how they affect the 

schedule’s activities. Without a schedule risk analysis, the likelihood of 

the project’s completion date or the activities or risks, such as funding 

details, most likely to delay activation cannot be determined.

The activation handbooks and general staffing timeline templates that 

BOP has developed and institutions have modified during activation are 

positive steps toward a baseline schedule that could be used to guide 

future institution activations, because they provide some level of detail 

regarding the activities required for activation. However, the activation 

handbook and general staffing timeline contain only limited information 

consistent with best practices and therefore cannot be used by 

management to reliably measure, monitor, or report on performance.
Appendix IV: Comments from the Department 

of Justice

Page 56 GAO-14-709 Bureau of Prisons

Appendix IV: Comments from the 

Department of Justice
Appendix IV: Comments from the Department 

of Justice

Page 57 GAO-14-709 Bureau of Prisons
Appendix IV: Comments from the Department 

of Justice

Page 58 GAO-14-709 Bureau of Prisons
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 59 GAO-14-709 Bureau of Prisons

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

In addition to the contact listed above, Joy Booth, Assistant Director; 

Pedro Almoguera; Billy Commons; Adam Couvillion; Emily Gunn; and Jan 

Montgomery made key contributions to this report. Also contributing to 

this report were Lorraine Ettaro, Susan Hsu, Elizabeth Kowalewski, Karen 

Richey, Rebecca Shea, and William Varettoni.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(441187)
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