BUREAU OF 

PRISONS

Improvements Needed 

in Bureau of Prisons’ 

Monitoring and 

Evaluation of Impact 

of Segregated Housing

Report to Congressional Requesters

May 2013

GAO-13-429

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-429 a report to 

congressional requesters 

May 2013 

BUREAU OF PRISONS 

Improvements Needed in Bureau of Prisons’ 

Monitoring and Evaluation of Impact of Segregated 

Housing 

Why GAO Did This Study

BOP confines about 7 percent of its 

217,000 inmates in segregated 

housing units for about 23 hours a day. 

Inmates are held in SHUs, SMUs, and 

ADX. GAO was asked to review BOP’s 

segregated housing unit practices. This 

report addresses, among other things: 

(1) the trends in BOP’s segregated 

housing population, (2) the extent to 

which BOP centrally monitors how 

prisons apply segregated housing 

policies, and (3) the extent to which 

BOP assessed the impact of 

segregated housing on institutional 

safety and inmates. GAO analyzed

BOP’s policies for compliance and 

analyzed population trends from fiscal 

year 2008 through February 2013. 

GAO visited six federal prisons 

selected for different segregated 

housing units and security levels, and 

reviewed 61 inmate case files and 45 

monitoring reports. The results are not 

generalizable, but provide information 

on segregated housing units. 

What GAO Recommends 

GAO recommends that BOP (1) 

develop ADX-specific monitoring 

requirements; (2) develop a plan that 

clarifies how BOP will address 

documentation concerns GAO

identified, through the new software 

program; (3) ensure that any current 

study to assess segregated housing 

also includes reviews of its impact on 

institutional safety; and (4) assess the 

impact of long-term segregation. BOP 

agreed with these recommendations 

and reported it would take actions to 

address them.

What GAO Found 

The overall number of inmates in the Bureau of Prisons’ (BOP) three main types 

of segregated housing units—Special Housing Units (SHU), Special 

Management Units (SMU), and Administrative Maximum (ADX)—increased at a 

faster rate than the general inmate population. Inmates may be placed in SHUs

for administrative reasons, such as pending transfer to another prison, and for 

disciplinary reasons, such as violating prison rules; SMUs, a four-phased 

program in which inmates can progress from more to less restrictive conditions; 

or ADX, for inmates that require the highest level of security. From fiscal year 

2008 through February 2013, the total inmate population in segregated housing 

units increased approximately 17 percent—from 10,659 to 12,460 inmates. By 

comparison, the total inmate population in BOP facilities increased by about 6 

percent during this period. 

BOP has a mechanism to centrally monitor segregated housing, but the degree 

of monitoring varies by unit type and GAO found incomplete documentation of 

monitoring at select prisons. BOP headquarters lacks the same degree of 

oversight of ADX-specific conditions of confinement compared with SHUs and 

SMUs partly because ADX policies are monitored locally by ADX officials. 

Developing specific requirements for ADX could provide BOP with additional 

assurance that inmates held at ADX are afforded their minimum conditions of 

confinement and procedural protections. According to a selection of monitoring 

reports and inmate case files, GAO also identified documentation concerns

related to conditions of confinement and procedural protections, such as 

ensuring that inmates received all their meals and exercise as required. 

According to BOP officials, in December 2012, all SHUs and SMUs began using 

a new software program that could improve the ability to document conditions of 

confinement in SHUs and SMUs. However, BOP officials acknowledged the 

recently implemented software program may not address all the deficiencies 

GAO identified. Since BOP could not provide evidence that it addressed the 

documentation deficiencies, GAO cannot determine if it will mitigate the 

documentation concerns. BOP expects to complete a review of the new software 

program by approximately September 30, 2013, which should help determine the 

extent to which the software program addresses documentation deficiencies 

GAO identified. 

BOP has not assessed the impact of segregated housing on institutional safety 

or the impacts of long-term segregation on inmates. In January 2013, BOP 

authorized a study of segregated housing; however, it is unclear to what extent 

the study will assess the extent to which segregated housing units contribute to 

institutional safety. As of January 2013, BOP is considering conducting mental 

health case reviews for inmates held in SHUs or ADX for more than 12 

continuous months. However, without an assessment of the impact of 

segregation on institutional safety or study of the long-term impact of segregated 

housing on inmates, BOP cannot determine the extent to which segregated 

housing achieves its stated purpose to protect inmates, staff and the general 

public.

View GAO-13-429. For more information, 

contact David C. Maurer at (202) 512-

9627 or maurerd@gao.gov. 
Page i GAO-13-429 Segregated Housing Units

Letter 1 

Background 5

Segregated Housing Unit Population and Number of Cells Have 

Increased since Fiscal Year 2008 14

BOP’s Monitoring of Segregated Housing Policies Varies by Type of 

Unit, and Some Facilities’ Documentation Is Incomplete 16

BOP Estimates that Segregated Housing Costs More than Housing 

Inmates in General Population 29

BOP Has Not Evaluated the Impact of Segregated Housing Units on 

Institutional Safety or the Impacts of Long-Term Segregation on 

Inmates 33

Conclusions 41

Recommendations for Executive Action 42

Agency Comments and Our Evaluation 42

Appendix I Objectives, Scope, and Methodology 45

Appendix II Communications Management Units 52

Appendix III Location and Length of Stay in BOP Segregated Housing 

Units 59

Appendix IV Comments from the Bureau of Prisons 61

Appendix V GAO Contact and Staff Acknowledgments 66

Tables

Table 1: Results of Our Independent Analysis of 51 Selected Inmate 

Case Files: Inmate Review and Procedural Protections 

Issues, Fiscal Years 2011-2012 27

Table 2: BOP Average Daily Inmate Costs per Capita by Security 

Level, BOP-wide, for Fiscal Year 2012 30

Contents 
Page ii GAO-13-429 Segregated Housing Units

Table 3: BOP Estimated Daily Inmate Costs per Capita in Selection 

of Institutions and Different Types of Segregated Housing 

Units, by Security Level for Fiscal Year 2012 32

Table 4: Site Visits to BOP Institutions 46

Figures

Figure 1: Comparison of Segregated Housing Unit Policies: SHU 

and SMU 7

Figure 2: Comparison of Segregated Housing Unit Policies: ADX 9

Figure 3: Required Procedures for Special Housing Unit (SHU)-

Disciplinary Segregation 11

Figure 4: Proportion of BOP Inmates in General Population and in 

Segregated Housing Types, as of February 2013 13

Figure 5: Trends in Inmate Population by Type of Segregated 

Housing Unit, Fiscal Year 2008 through February 2013 16

Figure 6: Special Housing Unit Cell, U.S. Penitentiary, 

Leavenworth, Kansas 20

Figure 7 : Outdoor Recreation Area, Special Management Unit, U.S. 

Penitentiary, Lewisburg, Pennsylvania 21

Figure 8: Interior of Single-Bunked Cell, U.S. Administrative 

Maximum Facility, Florence, Colorado 23

Figure 9: Outdoor Recreation Areas, U.S. Administrative Maximum 

Facility, Florence, Colorado 24

Figure 10: Common Findings from Our Analysis of 45 Monitoring 

Reports 26

Figure 11: Overview of Communications Management Units 53

Figure 12: Communications Management Unit Cell, Terre Haute, 

Indiana 56

Figure 13: Communications Management Unit Common Area, 

Marion, Illinois 57

Figure 14: Locations of Segregated Housing Units within BOP 

Facilities 59
Page iii GAO-13-429 Segregated Housing Units

Abbreviations

ACA American Correctional Association

ADX Administrative Maximum

BOP Bureau of Prisons

CMU Communications Management Unit

CPD Correctional Programs Division

DHO Discipline Hearing Officer

DOJ Department of Justice

FCC Federal Correctional Complex

GP General Population

HQ Headquarters

PDS Psychology Data System

IPPA Information, Policy, and Public Affairs Division

OJP Office of Justice Programs

ORE Office of Research and Evaluation

PRD Program Review Division

SAM Special Administrative Measure

SHU Special Housing Unit

SMU Special Management Unit

USP United States Penitentiary

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

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

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-429 Segregated Housing Units

United States Government Accountability Office

Washington, DC 20548

May 1, 2013

The Honorable Richard J. Durbin

Chairman

Subcommittee on the Constitution,

Civil Rights and Human Rights

Committee on the Judiciary

United States Senate

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight

 and Government Reform

House of Representatives

The Honorable Robert C. Scott

Ranking Member

Subcommittee on Crime, Terrorism, 

 Homeland Security, and Investigations

Committee on the Judiciary

House of Representatives

Since the late 1980s, America’s federal prison population increased by 

more than 400 percent, accompanied by the use of certain types of 

segregated housing units where prisoners are kept apart from the general 

inmate population in at times highly restrictive conditions. The 

Department of Justice’s (DOJ) Bureau of Prisons (BOP) is responsible for 

the custody and care of approximately 217,000 federal inmates.1

 

1

As of February 2013, BOP held the majority of inmates in its custody in 119 BOPoperated federal prisons. BOP held about 41,700, or about 19 percent, of the total BOP 

federal inmate population in community confinement (residential reentry and home 

confinement) and 15 privately managed prisons. We are focusing only on the 119 BOPoperated facilities for the purposes of this review. 

 BOP’s 

mission is to confine federal inmates in the controlled, safe, secure, 

humane, and cost-efficient environments of prisons and communitybased facilities, and to provide work and other self-improvement 

opportunities to assist offenders in becoming law-abiding citizens. BOP 

operates several types of segregated housing units to separate inmates 

from the general inmate population for different purposes, such as 

 
 

Page 2 GAO-13-429 Segregated Housing Units

administrative detention, disciplinary reasons, gang-related activity or 

assaulting staff. Specifically, these units are the (1) Special Housing Units 

(SHU), where inmates can be placed for administrative reasons, such as 

pending transfer to another prison, and for disciplinary reasons, such as 

violating prison rules; (2) Special Management Units (SMU), a four-level 

program in which inmates can progress from more restrictive to less 

restrictive conditions; and (3) the Administrative Maximum (ADX) facility 

in Florence, Colorado, for inmates that require the highest level of 

security. As of February 2013, BOP confined approximately 12,460 

federal inmates—or about 7 percent of inmates in BOP-operated 

facilities—in segregated housing units. According to BOP, these 

segregated housing units help ensure institutional safety for inmates and 

staff. Approximately 435 individuals in ADX are held in what is commonly 

referred to as solitary confinement, or single cells alone, for about 23 

hours a day.2

There is little publicly available information on BOP’s use of segregated 

housing units. Given the potential high costs, lack of research on their 

effectiveness, and possible long-term detrimental effects on inmates, you 

requested that we review BOP’s segregated housing unit practices, 

including BOP’s standards, reasons for segregating inmates, and costs. 

Specifically, this report addresses the following objectives:

1. What were the trends in BOP’s segregated housing unit population 

and number of cells from fiscal year 2008 through February 2013?

2. To what extent does BOP centrally monitor how individual facilities 

document and apply policies guiding segregated housing units?

3. To what extent has BOP assessed the costs to operate segregated 

housing units and how do the costs to confine an inmate in a 

segregated housing unit compare with the costs of confining an 

inmate in a general inmate population housing unit?

4. To what extent does BOP assess the impact of segregated housing 

on institutional safety and the impacts of long-term segregation on 

inmates?

Overall, to address our objectives, we reviewed BOP statutory authority 

and policies and procedures related to each type of segregated housing 

 

2 According to BOP officials, BOP does not hold anyone in solitary confinement because 

BOP staff interacts with inmates who are held in single cells alone.
 

Page 3 GAO-13-429 Segregated Housing Units

unit and interviewed BOP management officials responsible for inmate 

placement and security, monitoring and program compliance, facility and 

financial management, and research. To address our first objective, we 

obtained and analyzed BOP’s inmate population and number of cells data 

for each type of segregated housing unit for the past 5 fiscal years to the 

most recent data available—from fiscal year 2008 through February 2013. 

We also compared the total inmate population in BOP-operated facilities 

with the total segregated housing unit population data to identify trends in 

the segregated housing unit population as a share of the total inmate 

population in BOP-operated facilities during this period. We assessed the 

reliability of BOP’s segregated housing unit inmate population and cell 

data by reviewing relevant documentation, interviewing knowledgeable 

agency officials about how they maintain the integrity of their data, and 

examining the data for obvious errors and inconsistencies. We found the 

segregated housing unit inmate population and cell data were sufficiently 

reliable for the purposes of this report. We also interviewed BOP 

headquarters officials to discuss reasons for the trends in BOP’s 

segregated housing unit inmate population and cells.

To address our second objective, we assessed BOP’s monitoring for 

each type of segregated housing unit by reviewing monitoring policies, 

guidelines and reports. We analyzed BOP’s segregated housing unit 

policies and monitoring guidance and compared them against criteria in 

Standards for Internal Control in the Federal Government. We also 

analyzed BOP’s policies and procedures pertinent to the monitoring of 

individual prisons’ compliance with BOP policies, including those of 

BOP’s Program Review Division (PRD), which leads monitoring reviews. 

In addition, to observe the conditions of confinement, procedural 

protections and inmate placement in segregated housing, we conducted 

visits to 6 of BOP’s 119 institutions. We chose these institutions to reflect 

a range in the types of segregated housing units and security levels.3

 

3

We selected six federal prisons, three of which were complexes that contained multiple 

facilities. Thus, our six selected sites contained 11 BOP facilities, 10 of which we visited. 

See appendix I for the specific facilities we visited. 

Although the results of our site visits are not generalizable, they provided 

insights about BOP monitoring. Further, to assess the methodology and 

system BOP employs to monitor, identify, and address deficiencies at 

prisons, we requested a selection of monitoring reports from BOP, which 

BOP provided for a variety of facilities. Specifically, we analyzed 45 of 

187 PRD monitoring reports from 20 of 98 prisons from fiscal years 2007 
 

Page 4 GAO-13-429 Segregated Housing Units

to 2011. We also reviewed related follow-up monitoring reports to 

determine the extent that these prisons resolved deficiencies. Further, we 

independently assessed compliance with segregated housing policies for 

selected inmates at 2 institutions we visited. For example, we selected a 

random sample of 61 case files from inmates housed in segregated 

housing units, including SHUs. Although our selection of case files was 

not generalizable to all inmates in all types of segregated housing units, it 

provided insights into whether these 2 institutions were following BOP 

policy. We also reviewed information related to BOP’s new software 

program, that includes the SHU application, and compared it against best 

practices for project management and criteria in BOP’s monitoring 

documentation policies.

To address the third objective, we reviewed BOP fiscal year 2012 

average inmate per capita costs for institutions at each security 

classification: high security, medium security, low security, minimum 

security, administrative, and Federal Correctional Complex.4

To address the fourth objective, we analyzed BOP’s policies, including 

program objectives, for each segregated housing unit and policies 

governing the provision of mental health services to inmates in 

segregated housing units. We also reviewed BOP lockdown information 

from fiscal years 2007 through 2012. In addition, we interviewed senior 

BOP officials to discuss the extent that BOP has assessed the impact of 

segregated housing on institutional safety and their views on the impact 

of long-term segregation on inmates. Further, we identified and reviewed 

Further, we 

analyzed a BOP estimate of fiscal year 2012 inmate per capita costs that 

BOP provided in January 2013. We interviewed knowledgeable BOP 

officials to understand their processes for developing these cost data and 

estimates, and we found the average inmate per capita costs and 

estimated inmate per capita costs data to be sufficiently reliable for the 

purposes of this report. We also used BOP’s estimated segregated 

housing unit versus general population housing inmate per capita cost 

data, combined with fiscal year 2012 BOP inmate population data, to 

illustrate the possible costs of housing the inmate population in 

segregated housing units compared with the costs of housing these same 

inmates in general population housing for fiscal year 2012.

 

4

BOP operates Federal Correctional Complexes (FCC), which have different missions and 

security levels. 
 

Page 5 GAO-13-429 Segregated Housing Units

actions five states have taken regarding segregated housing units. We 

selected these five states because they were involved in addressing 

segregated housing unit reform and had taken actions to reduce the 

number of inmates in segregated housing units. For each of the five 

selected states, we reviewed relevant documents on segregated housing, 

including placement policies, and we interviewed corrections officials in 

these states to understand the reasons for and impact of segregated 

housing unit reforms. We visited correctional facilities in two of the five 

states—Kansas and Colorado. While the results from our interviews are 

not representative of all prisons, they provided us with perspectives on 

state actions. We also analyzed studies and reports that describe, 

evaluate, or analyze the impact of segregated housing units on 

institutional safety and inmates held in these units. We compared BOP’s 

mechanisms for evaluating the impact of segregated housing units on 

institutional safety, and the impacts of long-term segregation on inmates, 

with BOP’s policies and mission statements. Appendix I includes more 

details about our scope and methodology.

We conducted this performance audit from January 2012 to April 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions for our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

BOP operates three main types of segregated housing units: (1) SHUs, 

(2) SMUs, and (3) the ADX facility in Florence, Colorado.

5

 

5

BOP also operates other types of segregated housing units, including protective custody 

units for inmates requiring protection, sex offender management units for convicted sex 

offenders, and a Special Confinement Unit to hold inmates on death row, among others.

BOP also 

operates Communications Management Units (CMU), where conditions of 

confinement are similar to general population and inmates are allowed to 

congregate outside their cells for up to 16 hours per day. For information 

about CMUs see appendix II. According to BOP policy, all three types of 

segregated housing units have the same purpose, which is to separate 

inmates from the general inmate population to protect the safety, security, 

and orderly operation of BOP facilities, and to protect the public. 

However, the specific placement criteria and conditions of confinement 

Background
 

Page 6 GAO-13-429 Segregated Housing Units

vary for each type of segregated housing unit. In addition, inmates in 

SHUs, SMUs, and ADX are confined to their cells approximately 23 hours 

per day.6

 

6

 Inmates in segregated housing units may be confined to their cells for fewer or more 

hours per day, depending on their unit. For example, inmates in Phase 3 of the ADX StepDown Unit may recreate outside of their cells for three hours per day, or are confined to 

their cells for 21 hours per day. Inmates in other types of segregated housing units, such 

as SMUs, are permitted five hours of recreation per week, ordinarily on different days, in 

which case they would be confined to their cells 24 hours per day on at least two days. 

For more information about the number of hours of out-of-cell recreation per segregated 

housing unit, see figure 1.

See figures 1 and 2 for a comparison of differences among the 

three units.
 

Page 7 GAO-13-429 Segregated Housing Units

Figure 1: Comparison of Segregated Housing Unit Policies: SHU and SMU

a

According to BOP policy, BOP may place inmates in SHU-administrative detention status who are 

removed from the general population because they pose a threat to other inmates and staff or the 

orderly running of an institution and are (1) under investigation or awaiting a hearing for possibly 
 

Page 8 GAO-13-429 Segregated Housing Units

violating a BOP rule or criminal law, (2) pending transfer to another facility or location, (3) placed in a 

SHU for the inmate’s own protection, or (4) in post-disciplinary detention status. 

b

BOP lists 91 different types of prohibited acts, which have different punitive measures depending on 

their severity, including greatest, high, moderate, and low severity acts. Examples of greatest severity 

prohibited acts are killing, attempted or accomplished serious physical assaults and encouraging 

others to riot. Examples of high severity prohibited acts are fighting with others and threatening bodily 

harm. Examples of moderate severity prohibited acts are indecent exposure, and refusing to obey an 

order. Inmates who commit low severity offenses are not eligible to receive disciplinary segregation 

as a sanction. 

c

BOP provided SHU number of cells data as of fiscal year 2012, and SMU number of cells data as of 

November 2012. The population data for both SHUs and SMUs is as of February 2013. Also, the total 

SHU population does not include inmates in SHUs within the Florence Administrative Maximum 

facility or SHUs within SMUs. These SHU inmates are counted under the ADX and SMU total inmate 

populations, respectively. For example, the total SMU population in figure 1 includes inmates in the 

SHU within each SMU.

d

SMUs consist of a four-level, 18- to 24-month program. According to BOP policy, an inmate may 

progress through the levels depending on his compliance with behavioral expectations, ability to 

demonstrate positive “community” interaction skills, and preparedness to function in a general 

population setting with inmates from various group affiliations. 
 

Page 9 GAO-13-429 Segregated Housing Units

Figure 2: Comparison of Segregated Housing Unit Policies: ADX

a

The ADX houses BOP inmates who require the tightest controls. The ADX operates five types of 

housing unit programs: the Control Unit, a Special Housing Unit, the Special Security Unit, General 

Population Units, and the Intermediate Phase (Phase 2) of the Step Down Program. The Transitional 

Phase (Phase 3) and Pre-Transfer Phase (Phase 4) of the ADX Step Down Program are physically 

located in the United States Penitentiary (USP) Florence (high security) facility. 
 

Page 10 GAO-13-429 Segregated Housing Units

b

If the Designation and Sentence Computation Center (DSCC) staff determine the inmate warrants 

consideration for ADX placement, the Chief, DSCC, is to forward the referral packet to the BOP 

National Discipline Hearing Administrator, who is to designate a Hearing Administrator who is 

experienced in working with and observing inmates and is familiar with the criteria for inmate 

placement in different institutions, with an emphasis on ADX. 

c

Inmates may be reviewed to be placed in a double-bunked cell, after an initial placement of three 

months in a single cell in Phase 4. 

d

BOP provided the number of cells data as of fiscal year 2012. The population data are as of 

February 2013. The ADX number of cells and population data include the total number of ADX cells 

and population physically located in ADX, including the ADX SHU, and the total number of cells and 

population in Phases 3 and 4 of the ADX Step Down Unit, physically located at USP Florence. For 

example, the total ADX population includes inmates held in the ADX SHU (67 inmates). 

e

For more information about BOP policies related to the ADX Control Unit, see BOP program 

statement 5212.07 (February 20, 2001), available on BOP’s website. 

f

The Executive Panel is composed of the Regional Director of the region where the control unit is 

located and the Assistant Director, Correctional Programs Division. 

g

Special administrative measures (SAM), which must be authorized by the Attorney General, primarily 

limit communication with others, through restricted telephone, correspondence, and visiting privileges. 

SAMs based on a substantial risk of death or serious bodily injury may be imposed for a period of up 

to 120 days, or, with the approval of the Attorney General, up to one year and may be renewed. 

SAMs based on national security threat may be imposed for a period of up to 1 year and may be 

renewed. The BOP Director may renew special restrictions within the SAMs if the Attorney General or 

federal law enforcement or intelligence agency provides written notification of continued substantial 

risk of death or serious bodily injury or threat to national security related to the inmate’s 

communications or contacts with other persons. See 28 C.F.R. §§ 501.2, 501.3. 

BOP has specific procedural and conditions of confinement policies that 

govern each of the three types of segregated housing units. For example, 

BOP’s procedural policies govern how determinations are made to place 

inmates in each type of segregated housing unit. These determinations 

vary based on the level of security and supervision an inmate requires as 

well as any prohibited acts committed (e.g., assault against staff or gang 

activity). BOP policies require hearings to determine whether an inmate 

should be placed in an SMU, SHU-disciplinary segregation, or ADX.7

 

7

According to BOP, the hearing process is intended to meet the prison disciplinary system 

due process requirements established in Wolff v. McDonnell, 418 U.S. 539 (1974). This 

includes providing the inmate advance written notice of the alleged violation, and 

permitting the inmate to (1) attend the hearing and make a statement, (2) call witnesses, 

(3) present documentary evidence, and (4) have staff representation. The inmate is also 

provided a written statement of the evidence and reasons for the disciplinary action taken.

In 

general, a discipline hearing officer (DHO) not involved in the alleged 

infraction presides over the hearing, and inmates have a right to testify

and call witnesses. (See fig. 3 for the required procedures for SHUdisciplinary segregation). In addition, BOP’s procedural policies state that 

BOP Segregated Housing 

Unit Policies
 

Page 11 GAO-13-429 Segregated Housing Units

staff are to periodically review inmates’ status to determine whether they 

should remain in SHUs, SMUs, and ADX.

8

Figure 3: Required Procedures for Special Housing Unit (SHU)-Disciplinary Segregation

Further, according to BOP regulations, BOP administers an 

Administrative Remedy Program which includes formal procedural 

protections and provides all inmates in its custody—including those in 

segregated housing units—a method for filing a complaint about their 

placement, treatment or conditions while in custody, including placement 

in a segregated housing unit.9

 

8

Inmates placed in SHU-administrative detention do not receive a hearing prior to 

placement. However, BOP policy requires officials to review the inmates’ records within 3 

work days of being placed in SHU-administrative detention, and to review their detention 

status within 7 calendar days of their placement and every 30 calendar days thereafter. 

In addition, BOP has specific policies 

9

The Administrative Remedy Program is BOP’s process for filing a complaint, such as 

concerns about the appropriateness of placements, or allegation of improper physical or 

verbal abuse against facility staff, along with any aspect of an inmate’s confinement and 

appeals of disciplinary decisions.
 

Page 12 GAO-13-429 Segregated Housing Units

governing the conditions of confinement of inmates by segregated 

housing unit, such as minimum number of hours of exercise per week, 

minimum number of telephone calls and visits, and other privileges.

BOP also requires all of its facilities to be accredited and follow standards 

developed by the American Correctional Association (ACA).10

According to BOP officials, BOP does not hold anyone in solitary 

confinement because BOP staff frequently visit inmates held in singlebunked cells alone.

 BOP 

policies state that all facilities, security level and housing unit 

notwithstanding, must provide the same minimum conditions of 

confinement, including clean housing units; nutritionally adequate meals 

that meet dietary requirements (such as vegetarian or religious diet); 

access to educational, occupational, and leisure time programming; basic 

medical and mental health care; and access to a chaplain and basic 

religious items according to the inmate’s religious beliefs.

11 BOP officials stated BOP staff regularly interact with 

inmates during their required monitoring rounds and while providing 

meals to inmates. In addition, BOP officials stated that inmates who are in 

single cells can interact with other inmates during recreation while in 

either the same or separate recreation areas and they are also able to 

talk to each other in adjoining cells. However, inmates in these three 

types of segregated housing units are subject to more restrictive 

conditions of confinement than their counterparts in the general 

population.

BOP has segregated housing units in prisons located throughout the 

country. (See app. III for more information about the location of 

segregated housing units). With more inmates held under more restrictive 

conditions, often for months or years at a time, segregated housing 

represents an important part of BOP’s effort to achieve its goal of 

 

10ACA’s mission includes the development and promotion of effective standards for the 

care, custody, training, and treatment of offenders. 

11BOP holds all inmates in single-bunked cells alone at ADX. Inmates in Phase 4 of the 

ADX Step Down program may be double-bunked and are physically located at USP 

Florence. As of February 2013, ADX held 435 inmates in single-bunked cells alone. In 

addition, as of November 2012, BOP had 360 single-bunked SHU cells and 17 singlebunked SMU cells across its facilities in which inmates are confined to their cells alone for 

about 23 hours per day. 

Population of Segregated 

Housing Units
 

Page 13 GAO-13-429 Segregated Housing Units

confining inmates in a safe, secure, and cost-efficient environment. Of all 

federal inmates in BOP facilities, about 7 percent are held in segregation 

and, as of February 2013, BOP held the majority of segregated inmates—

81 percent, or 10,050 inmates—in SHUs. The second largest population 

held in segregation is SMU inmates, who comprise about 16 percent of all 

segregated inmates, or about 1,960 inmates. ADX holds 450 inmates, 

including 15 inmates in the ADX Step Down Units at the high security 

United States Penitentiary (USP) Florence. See figure 4 for inmate 

population by segregated unit type as a percentage of the total inmate 

population in BOP facilities as of February 2013.

Figure 4: Proportion of BOP Inmates in General Population and in Segregated 

Housing Types, as of February 2013
 

Page 14 GAO-13-429 Segregated Housing Units

From fiscal year 2008 through February 2013, the total inmate population 

in segregated housing units increased approximately 17 percent—from 

10,659 to 12,460 inmates.12 The total inmate population in segregated 

housing units increased since fiscal year 2008, but the trends in inmate 

population vary by type of segregated housing unit. By comparison, the 

total inmate population in BOP facilities increased by about 6 percent 

since fiscal year 2008. In addition, the total number of segregated 

housing cells in BOP facilities increased by nearly 16 percent.13

SHUs. From fiscal year 2008 through February 2013, the total SHU 

population remained about the same at 10,070 and 10,050, 

respectively.

The main 

reason for the increase in segregated inmates was the creation of the 

SMU program in fiscal year 2008.

14

 

12The percentage of the total inmate population in segregated housing increased from 6 

percent in fiscal year 2008 to 7 percent as of February 2013. The total inmate population 

in segregated housing units includes the total inmate population in ADX, all SHUs, and all 

SMUs in BOP facilities. 

BOP generally double-bunks inmates in SHUs; however, 

BOP has the capability to hold some SHU inmates in single cells. For 

example, as of November 2012, BOP had 6,731 double-bunked SHU 

cells and 360 single-bunked SHU cells. BOP officials also stated they 

13 BOP uses different units of measurement to calculate capacity for its segregated 

housing units. BOP calculates the number of inmates SMUs and ADX can hold in terms of 

each unit’s rated capacity. Rated capacity reflects the number of prisoners a facility or unit 

was designed to house safely and securely and in which BOP can provide inmates 

adequate access to services, necessities for daily living, and programs designed to 

support their crime-free return to the community. A facility’s rated capacity excludes 

medical and SHU bed space, and BOP does not maintain rated capacity data for SHUs. 

Instead, BOP provided SHU capacity in terms of number of cells. For the purposes of 

analyzing trends in segregated housing unit capacity over time, we used the number of 

cells in SHUs, SMUs, and ADX to have the same unit of measurement for all segregated 

housing units. BOP provided number of cells data for fiscal years 2008 through 2012 for 

SHUs and ADX and number of cells data for fiscal year 2008 through November 2012 for 

SMUs. 

14Based on data that BOP provided, these data do not include the inmate population in 

SHUs within ADX or SMUs. The SHU inmate population in these units is included under 

the total ADX and SMU populations, respectively. Also, based on our analysis, although 

the SHU population increased since fiscal year 2008, there has been a decline recently. 

According to BOP officials, the SHU population trend might be following the trend in total 

population in BOP facilities, which increased from fiscal years 2008 through 2011, then 

declined slightly in fiscal year 2012. 

Segregated Housing 

Unit Population and 

Number of Cells Have 

Increased since Fiscal 

Year 2008
 

Page 15 GAO-13-429 Segregated Housing Units

may add beds to some SHU cells to accommodate the population at a 

given facility.15

SMUs. As shown in figure 5, from fiscal year 2008 through February 

2013, the SMU population increased at a faster rate than SHUs and 

ADX—from 144 inmates in fiscal year 2008 to 1,960 inmates as of 

February 2013.16

ADX. From fiscal year 2008 through February 2013, the total ADX inmate 

population declined by approximately 5 percent from 475 inmates to 450 

inmates. During this period, ADX cells remained stable at 623 cells.

BOP developed SMU capacity by converting existing 

housing units in five BOP facilities to 1,270 total SMU cells, as of 

November 2012. By March 2013, BOP closed SMUs in two facilities and 

moved those SMU inmates into other SMUs or released them from prison 

after serving their sentence.

17

 

15According to BOP officials, many SHUs contain at least one single-bunked cell to hold

inmates on a temporary basis who require being placed alone to maintain institutional 

safety. In addition, although the SHU at USP Marion has 50 single-bunked cells, the 

warden at USP Marion double-bunked and in some cases triple-bunked the SHU when 

several inmates needed to be placed in SHU following a large inmate fight in November 

2011. 

According to BOP officials, the ADX population has declined overall since 

2008 because of the transfer of inmates out of ADX Step Down to the 

general population of another high security prison or because inmates are 

being placed in SMUs instead of being placed in ADX. (See fig. 5 for the 

trends in population growth for SHUs, SMUs, and ADX from fiscal year 

2008 through February 2013).

16These data include inmates in the SHUs within each SMU. 

17These ADX inmate population and cell data include ADX SHU inmates and cells.
 

Page 16 GAO-13-429 Segregated Housing Units

Figure 5: Trends in Inmate Population by Type of Segregated Housing Unit, Fiscal Year 2008 through February 2013

BOP Headquarters (HQ) has a mechanism in place to centrally monitor 

how prisons implement most segregated housing unit policies, but the 

degree of BOP monitoring varies depending on the type of segregated 

housing unit. In addition, we identified concerns related to facilities’ 

documentation of monitoring conditions of confinement and procedural 

protections.

BOP’s Monitoring of 

Segregated Housing 

Policies Varies by 

Type of Unit, and 

Some Facilities’ 

Documentation Is 

Incomplete

BOP Monitors Compliance 

Differently across the 

Three Types of Segregated 

Housing
 

Page 17 GAO-13-429 Segregated Housing Units

BOP monitors the extent to which individual prisons implement BOP 

policies. BOP’s monitoring includes specific steps to check compliance 

with requirements for SHUs and SMUs, but not for ADX. BOP’s Program 

Review Division is to perform reviews at least once every 3 years to 

ensure compliance with BOP policies. However, BOP can review prisons 

more frequently if it identifies performance deficiencies. These follow-ups 

can occur at 6-month, 18-month, 2-year or 3-year intervals.18

To help HQ ensure that PRD monitoring teams are consistently assessing 

the extent that individual prisons are complying with general BOP 

correctional program and correctional services policies, BOP provides 

training for all program review staff. Additionally, new PRD staff are 

provided training and accompany experienced staff before being allowed 

to conduct a review independently.

These PRD 

reviews assess compliance with a variety of BOP policies for inmates in 

the general population prison and segregated housing. For example, PRD 

assesses compliance with BOP policies on conditions of confinement, 

such as whether inmates are given three meals a day, provided exercise 

time 5 days a week, and are allowed telephone and other privileges. 

Following a review at a facility, PRD issues a program review report, 

noting deficiencies and findings at the BOP facility. These PRD 

monitoring reviews are done on a prison complex basis, which may

include a variety of housing types, including low, minimum, medium, high 

security prisons, and the three types of segregated housing units (e.g., 

SHUs, SMUs, and ADX).

19

 

18Generally, PRD conducts 15 program reviews covering 15 different areas of BOP 

operations at a minimum of every 3 years but may conduct reviews more frequently if prior 

reviews identify overall performance deficiencies. 

This training also covers examiner 

independence and how to conduct program reviews. BOP also has a 

system designed to address problems identified at the individual prisons, 

including PRD follow-up with each prison to assess whether PRD 

recommendations were implemented. For example, PRD requires 

individual prisons to issue reports within 30 days to explain how they 

implemented the PRD recommendations to address problems identified in 

19According to BOP officials, BOP provides training for PRD program review staff to 

conduct on-site monitoring. For example, on-site monitoring generally includes a team of 

an average of about five examiners, depending on the size and security level of the 

facility. Before a staff member leads an on-site monitoring visit, he or she is required to 

shadow an experienced staff member for about 1 year. BOP also trains all employees in 

basic correctional duties and inmate supervision. For example, BOP requires all new 

examiners to participate in annual refresher training.
 

Page 18 GAO-13-429 Segregated Housing Units

program reviews. If PRD determines that the prison response is 

insufficient, PRD can request that the prison take corrective actions in a 

subsequent follow-up report.

We reviewed 43 PRD follow-up reports and found that PRD concluded 

that the facilities generally addressed deficiencies identified in all of the 

43 reports. For example, one follow-up report was completed within 30 

days and identified steps taken by the prison to address each of the four 

problem areas—administrative operations, operational security, inmate 

management, and intelligence operations—identified in the PRD report. 

To address one of the deficiencies related to improper documentation of 

exercise, meals, and supervisor assignments in SHUs, PRD required 

additional training for the SHU staff. Following training, the prison 

determined that it was in compliance with the relevant requirement, 

deficiencies were addressed and PRD closed the recommendation. As 

part of PRD’s monitoring process, once the facilities document steps 

taken to address deficiencies in their follow-up reports, PRD determines 

whether to close the recommendations.

As part of the monitoring process discussed above, PRD also checks 

compliance with selected SHU- and SMU-specific policies, but has no 

requirement to monitor ADX-specific policies. According to documentation 

that BOP provided, we determined that BOP’s monitoring system is 

designed to assess whether individual BOP prisons are in compliance 

with SHU and SMU procedural policies, such as why an inmate is placed 

in segregation, and with the specific conditions of confinement. For 

example, BOP’s SHU policy requires that prison staff review the inmate’s 

status within 3 days of being placed in administrative detention. To 

assess compliance with this SHU policy, BOP monitoring guidance 

requires PRD staff to review whether the inmate’s status was reviewed 

within 3 days of being placed in administrative detention as required. In 

addition, PRD also is to verify that prisons completed their quarterly 

audits and operational reviews to ensure that procedural protections for 

inmates have been followed and that inmates are housed according to 

BOP policies.20

 

20Operational reviews conducted by individual facilities provide a status update on all 

areas identified by PRD in the previous program review, including operational issues, such 

as human resources, financial management, as well as BOP programs in the facility, such 

as SHUs. Individual facilities perform operational reviews about 10 to 22 months between 

BOP program reviews, depending on the rating the facility received. 

However, as discussed below, BOP does not have 
 

Page 19 GAO-13-429 Segregated Housing Units

requirements in place to monitor similar compliance for ADX-specific 

policies. BOP’s monitoring policies for each type of segregated housing 

unit are described below.

SHU. BOP policies require that PRD monitor SHU policies and review 

documentation of 10 percent of inmates held in SHUs in each facility. 

BOP policies also require PRD to select 10 inmate files from those held in 

SHU disciplinary segregation for a review of procedural protections and 

disciplinary procedures. Further, BOP requires PRD to monitor SHU 

specific policies that cover additional requirements to monitor conditions 

of confinement and procedural protections.21

 

21BOP’s Correctional Services Program Review Guidelines requires that PRD review 23 

SHU specific policies.

BOP incorporates ACA 

monitoring standards as part of its SHU policy. See figure 6 for a 

photographic example of a SHU cell, which PRD is required to monitor to 

ensure the prison provides conditions of confinement for inmates held in 

SHUs.
 

Page 20 GAO-13-429 Segregated Housing Units

Figure 6: Special Housing Unit Cell, U.S. Penitentiary, Leavenworth, Kansas
 

Page 21 GAO-13-429 Segregated Housing Units

SMU. According to BOP policy, PRD is required to monitor a prison’s 

compliance with SMU-specific policies, including those SMU-specific 

policies that require prisons to provide specific conditions of confinement 

and procedural protections. PRD reviews are required to check 

compliance with nine SMU-specific policies such as providing inmates 

with 5 hours of recreation per week; an opportunity to shower a minimum 

of three times per week; and access to visits, correspondence, and 

medical and mental health care. According to BOP officials, BOP 

incorporates ACA monitoring standards as part of its SMU policy. BOP 

also requires PRD to review 25 SMU inmate case files that cover 

conditions of confinement for SMU inmates. See figure 7 for a 

photographic example of a SMU recreation area, which PRD is required 

to monitor to ensure the prison provides conditions of confinement for 

inmates held in SMUs.

Figure 7 : Outdoor Recreation Area, Special Management Unit, U.S. Penitentiary, 

Lewisburg, Pennsylvania
 

Page 22 GAO-13-429 Segregated Housing Units

ADX. ADX inmates are included in any PRD program review that covers 

the entire Florence prison complex. While PRD has some oversight over 

ADX, PRD does not monitor ADX to the same degree that it monitors 

SHUs and SMUs. According to BOP officials, except for inmates held in 

ADX-SHUs, PRD is not required to monitor ADX-specific conditions of 

confinement–such as exercise, telephone, and visitation–as they do for 

SHUs or SMUs. For example, PRD reviews do not check for compliance 

with ADX-specific policies, such as whether inmates are afforded a 

minimum of 7 hours of recreation per week or the minimum of one 15-

minute phone call per month in the Control Unit.

The ADX-specific policies for recreation, telephone calls, and visits 

allowed vary in each of the three ADX housing units: the Control Unit, the 

Special Security Unit, and the Step Down Units. (See fig. 2). According to 

BOP officials, PRD does not have monitoring requirements for ADXspecific policies because BOP management has not identified ADX as a 

high-risk area that needed specific monitoring requirements due to other 

oversight mechanisms. For example, BOP HQ reviews the referral and 

placement of all inmates in ADX, including a review of each inmate 

placed in the Control Unit every 60 to 90 days to determine the inmate’s 

readiness for release from the unit. BOP officials also told us that ADXspecific policies are monitored locally by ADX officials.

However, conditions of confinement in ADX housing units are generally 

more restrictive than those in SHUs and SMUs. For example, unlike 

SHUs and SMUs, nearly all inmates in ADX are confined to single cells 

alone for about 23 hours per day.22

 

22Inmates in Phase 3 of the Special Security Unit and Phases 3 and 4 of the ADX Step 

Down Unit may be allowed additional recreation time and interaction with others, and 

inmates in Phase 4 of the ADX Step Down Unit may be double-bunked. See figure 2 for a 

comparison of conditions of confinement by ADX program unit. 

Also, although BOP HQ has 

mechanisms to monitor some procedural protections, and ADX officials 

locally monitor ADX-specific policies, BOP HQ lacks oversight over the 

extent to which ADX staff are in compliance with many ADX-specific 

requirements related to conditions of confinement and procedural 

protections to the same degree that it has for SHUs and SMUs. According 

to PRD officials, PRD does not assess the extent to which ADX provides 

conditions of confinement or procedural protections as required under 

ADX policy and program statements because it is not required to do so. 

As a result, PRD cannot report to BOP management on the extent of 
 

Page 23 GAO-13-429 Segregated Housing Units

compliance with these ADX-specific requirements. With such oversight, 

BOP headquarters would have additional assurance that inmates held in 

BOP’s most restrictive facility are afforded their minimum conditions of 

confinement and procedural protections. See figures 8 and 9 for 

examples of a cell in the ADX housing unit and recreation areas, which 

PRD is required to monitor to some extent to ensure the prison provides 

conditions of confinement for inmates held in ADX.

Figure 8: Interior of Single-Bunked Cell, U.S. Administrative Maximum Facility, 

Florence, Colorado
 

Page 24 GAO-13-429 Segregated Housing Units

Figure 9: Outdoor Recreation Areas, U.S. Administrative Maximum Facility, 

Florence, Colorado

Standards for Internal Controls in the Federal Government states that an 

effective internal control environment is a key method to help agency 

managers achieve program objectives. The standards state, among other 

things, that monitoring activities are an integral part of an entity’s 

planning, implementing, reviewing, and accountability for stewardship of 

government resources and achieving effective results. Specific 

requirements for PRD to monitor ADX-specific policies to the same 

degree that these requirements exist for SHUs and SMUs could help 

provide BOP HQ additional assurance that ADX officials are following 

BOP policies to hold inmates in a humane manner, in its highest security, 

most restrictive facility. The Acting Assistant Director of PRD agreed that 

developing such requirements would be useful to help ensure these 

policies are followed.
 

Page 25 GAO-13-429 Segregated Housing Units

BOP has a mechanism in place to centrally monitor how prisons 

implement most segregated housing unit policies. However, given a 

selection of PRD monitoring reports from 20 prisons and our independent 

analysis of inmate case files at two federal prisons, we identified concerns 

related to how facilities are documenting that inmates received their 

conditions of confinement and procedural protections, which are 

described below.

PRD monitoring reports. We reviewed 45 PRD monitoring reports from 

20 prisons that assessed compliance at general population units and 

SHUs and SMUs. PRD identified deficiencies in 38 of these reports, 

including documentation concerns in 30 reports.

23 As part of our review, 

we found PRD monitoring reports identified deficiencies, such as missing 

SHU forms, or incomplete documentation that inmates held in 

segregation for at least 22 hours per day received all their meals and 

exercise as required.24

According to our review of 45 PRD reports from 20 prisons, we found that 

BOP rated 15 prisons as generally compliant with both BOP policies and 

policies specific to SHUs and SMUs.

For example, segregated inmates in SHUs and 

SMUs are entitled the opportunity to have 1 hour of exercise per day but 

the documentation at these prisons did not clearly indicate that these 

standards were always observed.

25

 

23From fiscal years 2007 through 2011, PRD conducted 187 correctional services 

program reviews at 98 BOP prisons. 

However, while BOP found that 

these prisons were generally in compliance with segregated housing unit 

policies, most of these prisons had some deficiencies. For example, our 

analysis of the PRD reports found that, in 38 of the 45 reviews, PRD 

identified deficiencies such as missing documentation, monitoring rounds 

not being consistently conducted, or inmate review policies not fully 

implemented. (See fig. 10 for common deficiencies.)

24For example, some monitoring reports state SHU-specific deficiencies related to missing 

BP-A292 forms, which document meals, recreation, and other conditions of confinement. 

25BOP rated these 15 prisons as generally compliant, with ratings such as acceptable, 

good or superior. For the remaining 6 prisons, BOP did not provide similar ratings 

because they were based on SHU program review observation reports, or part of 

quarterly, summary program reports covering several facilities and programs. According to 

BOP policy, program review reports for individual facilities are often assigned an overall 

rating ranging from superior, good, acceptable, or deficient to at risk. None of the selected 

reports rated individual facilities as deficient or at risk. 

Selected Facilities’ 

Documentation Problems 

Related to Conditions of 

Confinement and Inmate 

Placement Raise Concerns 

about the Monitoring of 

Inmates Placed in 

Segregation
 

Page 26 GAO-13-429 Segregated Housing Units

Figure 10: Common Findings from Our Analysis of 45 Monitoring Reports

Notes: Seven reports contained no deficiencies.

a

Cleanliness refers to the living, sanitary conditions of cells where inmates are held. 

b

Documentation covers several issues, such as whether medical staff were signing Special Housing 

Unit forms daily as required, inmate files adequately processed and documented inmates’ conditions 

of confinement, and information was appropriately keyed into the BOP inmate management data 

system, SENTRY, and other databases. 

c

Monitoring refers to monitoring of inmate status and segregated housing unit policies, such as SHU 

monitoring rounds conducted on every shift, or every 30-minute period, and 10 percent of inmate calls 

monitored in the past 12 months.

d

Policy refers to monitoring review policies, investigation, inmate classification and program policies. 

e

Procedural protections covers compliance with procedural policies, including whether disciplinary 

sanctions were appropriately implemented, informal resolutions in place, and incident reports 

expunged for appropriate reasons.

f

Security protocol refers to investigative operational policies, ensuring that key equipment is regularly 

checked and hot lists are available to alert staff of inmates who pose a security threat. 

g

Timeliness refers to conducting monitoring and operational reviews in a timely fashion, and ensuring 

that staff investigations are forwarded to BOP HQ within 120 days as required. 

h

Training refers to staff training requirements. 

To assess how PRD staff conducted monitoring at prisons, we observed 

PRD conducting reviews at one prison complex that included two medium 

and high security BOP facilities with SHUs. For example, we found that 

PRD staff (1) performed monitoring rounds at SHUs, (2) reviewed log 

books, and (3) reviewed inmate files, to determine if the facilities followed 

the required procedural protections steps. Given our observations, we 

concluded that PRD staff monitored these facilities’ compliance with BOP 

policies, as called for in PRD’s monitoring guidelines.

Independent analysis of inmate case files. We also conducted an 

independent analysis of BOP compliance with SHU-specific policies at 
 

Page 27 GAO-13-429 Segregated Housing Units

three facilities. Specifically, we reviewed a total of 51 segregated housing 

files for inmates held in administrative detention and disciplinary-SHU for 

fiscal years 2011 and 2012 at three facilities.

26 We found that these three

facilities were generally complying with BOP policies related to inmate 

placement and ensuring procedural protections for inmates placed in 

SHU-disciplinary segregation, in light of our review of these selected 

files.27

Table 1: Results of Our Independent Analysis of 51 Selected Inmate Case Files: Inmate Review and Procedural Protections 

Issues, Fiscal Years 2011-2012 

For example, 42 out of 51 inmate case files we analyzed provided 

reasons for inmate placement in SHUs, as required by BOP policies. 

However, of the 35 case files we reviewed for inmates held in 

administrative-SHU – in which we reviewed conditions of confinement, 

monitoring, and procedural protections –only 4 files consistently 

documented that the inmates were afforded their rights to recreation and 

procedural protections. For example, these 4 files consistently 

documented that these inmates in SHUs received 1 hour of exercise a 

day, 5 days per week, and that the inmates’ status in segregation was 

consistently reviewed within 7 days of being placed in the SHU, as well as 

meals and recreation, as required by BOP policy. The remaining 31 of the 

35 files did not consistently document that the inmates were afforded 

these rights. (See table 1.) 

Type of segregated housing policy Description 

Number of inmate case 

files in compliance 

Documentation provided to inmate 

about placement

Inmate was provided a copy of administration detention order 

when placed into special housing units (SHU); or inmate 

received discipline hearing officer (DHO) report that explained 

reasons for placement in disciplinary segregation in SHU. 

42 out of 51a

BOP regularly monitors inmate status, 

conditions of confinement, and 

procedural protections

Inmate in SHU received recreation 5 hours per week; inmate 

status in SHUs reviewed on a regular basis (e.g., every 3 days 

and 7 days).

4 out of 35b

(subset)

Procedural protections provided in 

disciplinary segregation

Inmate provided a hearing process and advised of right to appeal 

the decision

16 out of 17 c

(subset)

Source: GAO analysis of BOP (2011-2012) inmate files.

 

26 In addition to 51 inmate SHU case files, we reviewed 10 CMU case files, which are 

described in appendices I and II. 

27 Out of a total of 51 inmate case files, we reviewed 35 inmate files related to monitoring 

of inmate status, conditions of confinement, and procedural protections in administrative 

segregation; and 17 inmate files related to procedural protections in disciplinary 

segregation. In fiscal year 2012, the total segregated housing inmate population at these 

three facilities was 405. 
 

Page 28 GAO-13-429 Segregated Housing Units

a

One inmate in the sample file was randomly selected in both administrative-SHU and disciplinarySHU. 

b

According to a selected sample of 35 SHU inmates, which we selected from the sample size of 10 

percent of SHU inmates that PRD inspectors use when conducting monitoring reviews. For details, 

please see appendix I. 

c

Given a selected sample of 17 disciplinary –SHU inmates and their hearing packets, which we 

selected largely based on the sample size that PRD inspectors use when conducting monitoring 

reviews. For details, please see appendix I. 

Given (1) our review of 45 BOP monitoring reports and (2) our 

independent analysis of 51 selected inmate case files at three facilities, 

we found that that the facilities did not consistently document conditions 

of confinement and procedural protections as required under BOP policy

guidelines. For example, 38 out of the 45 reports identified deficiencies 

such as missing documentation, monitoring rounds not being consistently 

conducted, or inmate review policies not fully implemented. In our 

independent analysis of 51 segregated housing unit case files, we 

reviewed 35 files focused on determining if BOP regularly monitors 

inmates’ status, conditions of confinement, and procedural protections, 

and found documentation-related concerns in 31 out of 35 files.

While our selection of reports and site visits cannot be generalized to all 

BOP facilities, the extent of documentation concerns indicates a potential 

weakness with facilities’ compliance with BOP policies. Without proper 

documentation of inmates’ rights and conditions of confinement, neither 

we nor BOP HQ can determine whether facility staff have evidence that 

facilities complied with policies to grant inmates exercise, meals, and 

other rights, as required. In January 2013, BOP officials agreed with our 

finding that BOP monitoring reports regularly identified problems with 

documentation. BOP officials said that they believed these were 

documentation problems caused by correctional officers forgetting to 

document the logs, and not instances where inmates were not getting 

their food, exercise, and procedural protections granted under BOP 

guidelines. They noted that inmates can use the formal grievance 

process, called the Administrative Remedy process, if they believe they 

have not been granted these rights.

According to BOP officials, in December 2012, BOP began using a new 

software program, called the SHU application in all SHUs and SMUs. 

BOP officials told us that this new software program could improve the 

documentation of the conditions of confinement in SHUs and SMUs, but 

acknowledged it may not address all the deficiencies that we identified. 

Because this new software was recently implemented, and BOP did not 

provide evidence to the extent that it addressed the documentation 
 

Page 29 GAO-13-429 Segregated Housing Units

deficiencies, we cannot determine if it will mitigate the documentation 

concerns. In addition, BOP does not have a plan that provides the 

specific objectives of the software program, how it will address the 

documentation deficiencies, or specific steps BOP will use to verify that 

the software will resolve the documentation problems we identified. 

According to best practices in project management, the establishment of 

clear, achievable objectives can help ensure successful project 

completion.28 A plan that clarifies the objectives and goals of the new 

software program and the extent to which they will address 

documentation issues we identified, along with time frames and 

milestones, could help provide BOP additional assurance that inmates in 

these facilities are being treated in accordance with BOP guidance.

BOP does not regularly track or calculate the cost of housing inmates in 

segregated housing units. BOP computes costs by facility or complex, 

and does not separate or differentiate the costs for segregated housing 

units, such as SHUs, SMUs, and ADX that may be within the complex. 

For example, Federal Correctional Complex (FCC) Florence in Florence, 

Colorado, contains four different facilities, including ADX, one high 

security, one medium security, and one minimum security facility, as well 

as different types of housing units within most facilities.

29 Specifically, 

within the high security facility, there is a SHU and a SMU. According to 

BOP officials, segregated housing unit costs are not separated because 

most of the costs to operate a facility or complex apply to inmates housed 

in all housing units within the facility or complex.

30

 

28Project Management Institute, The Standard for Program Management © (2006). 

BOP officials further 

reported that inmates in a segregated housing unit within a facility share 

the same costs under the facility’s total obligations, such as utilities, food 

services, health services, and facility maintenance, among other things. 

BOP officials also stated that BOP aggregates the cost data for an entire 

29BOP Federal Correctional Complexes include several institutions with different missions 

and security levels located in proximity to one another. 

30 BOP applies support costs to an institution’s daily inmate per capita costs based on the 

percentage of overall support cost to total BOP obligations. Support costs are institutionrelated expenses that are paid by BOP HQ due to centralized billing procedures, such as 

phone charges, workers compensation, payroll processing, information technology 

support, and costs of Regional and Central Office and Training Center staff. The inmate 

daily per capita rate does not include any one time non-routine costs or construction and 

renovation costs.

BOP Estimates that

Segregated Housing 

Costs More than 

Housing Inmates in 

General Population
 

Page 30 GAO-13-429 Segregated Housing Units

facility or complex to reduce paperwork and streamline operations. BOP 

also computes an overall average daily inmate per capita cost by security 

level for each fiscal year. See table 2 for BOP’s computation of average 

daily inmate per capita costs by security level for fiscal year 2012.

Table 2: BOP Average Daily Inmate Costs per Capita by Security Level, BOP-wide, 

for Fiscal Year 2012

BOP security level

Actual average daily inmate costs per capita by 

security level, BOP-wide

Minimum security $59.27

Low security $74.22

Medium security $72.91

High security $93.02

Source: BOP (2011-2012).

Note: Using two databases, an accounting system known as the Financial Management Information 

System and the population management system known as SENTRY, BOP calculates the inmate daily 

per capita costs by dividing the total obligations under the Salaries and Expenses account by total 

inmate days for the entire institution, including general population and segregated housing units. 

Total inmate days equal the average inmate daily population multiplied by the number of calendar 

days for the fiscal year. Inmate days are obtained via the SENTRY Population Management System. 

BOP prepares a report reflecting the overall average and annual daily inmate per capita costs and the 

average annual and daily inmate per capita costs by security level for each fiscal year. BOP obtains 

the average annual and daily per capita costs by security level by consolidating the information for 

each institution within that security level to arrive at an “average” inmate per capita cost for that 

security level. 

BOP officials stated that segregated housing units are more costly than 

general prison population housing units because segregated housing 

units require more resources—specifically staff— to operate and 

maintain. According to BOP officials, the staff-to-inmate ratio in 

segregated housing is significantly higher than in the general prison 

population, which makes segregated housing units more expensive to 

operate. For example, at one high security facility we visited, we 

estimated there was an average of 41 inmates to one correctional officer 

in the SHU during a 24-hour period. This contrasts to an inmate-tocorrectional-officer ratio of about 124:1 in general population housing 

units in the same facility during a 24-hour period.31

 

31Based on staffing ratios that BOP officials provided, we estimated the average number

of correctional officers assigned to a segregated housing unit. For example, the number of 

correctional officers assigned to a SHU varies by shift (e.g., morning, daytime, and 

evening shifts), and we estimated the average number of correctional officers assigned to 

the SHU in a 24-hour period, based on the different staffing ratios in each shift.

BOP officials at 
 

Page 31 GAO-13-429 Segregated Housing Units

facilities we visited stated that ADX, SMUs, and SHUs require more staff 

than general population housing because most of the inmates are 

confined to their cells for approximately 22 to 24 hours per day. As a 

result, they are dependent on the correctional officers for many of the 

activities that those in the general inmate population do for themselves.

For example, at least two correctional officers are needed to escort SHU 

and SMU inmates to showers and to recreation cells. Some high security 

inmates at SMUs require a three-officer escort each time they leave the 

cell. Staff are required to bring meals to inmates in their cells in SHUs, 

SMUs and ADX three times each day. In addition, staff are also required 

to provide laundry services, daily medical visits, and weekly 

psychological, educational, and religious visits to inmates in their cells in 

SHUs, SMUs and ADX. In contrast, inmates in general population units 

can generally access services in other areas of the facility freely, and 

therefore can perform these activities without assistance from correctional 

officers.

On January 31, 2013, BOP budget officials provided a snapshot estimate 

that compares the daily inmate per capita costs in fiscal year 2012 at 

ADX, a sample SMU, a SHU at a sample medium security facility, and a 

SHU at a sample high security facility. For example, BOP estimates the 

daily inmate per capita costs at ADX are $216.12 compared with $85.74 

at the rest of the Florence complex. According to BOP estimates, the 

inmate per capita costs at the sample SMU facility are $119.71, which are

higher than per capita costs in general population in BOP’s sample high 

security facility, which are $69.41.(see table 3). For its estimates of the 

costs to operate SHUs, BOP selected Federal Correctional Institution 

(FCI) Beckley for a sample medium security facility and U.S. Penitentiary 

(USP) Lee for a sample high security facility. According to a senior BOP 

official, BOP did not select these facilities because of costs but because 

these facilities are a “typical” medium security and high security facility. 

The estimated daily costs per inmate at these two sample facilities in 

table 3 are lower and not directly comparable to the system-wide average 

daily costs per inmate for medium and high security facilities, as shown in 

table 2. Please see appendix I for a description of how BOP calculated its 

estimated costs.
 

Page 32 GAO-13-429 Segregated Housing Units

Table 3: BOP Estimated Daily Inmate Costs per Capita in Selection of Institutions and Different Types of Segregated Housing 

Units, by Security Level for Fiscal Year 2012

Estimated daily costs per inmate at sample BOP 

facilities

BOP sample institution and security level 

General 

population 

unitsa Segregated housing units

Total facility, including 

general population and 

segregated housing units

Sample Medium Security, Federal Correctional Institution (FCI) Beckley $57.41 $78.21 (SHU) $58.74

Sample High Security facility, U.S. Penitentiary (USP) Lee $69.41 $93.04 (SHU) $72.39

Sample Special Management Unit (SMU) facility, (USP) Lewisburg n/a $119.71 (SMU) $97.51b

Federal Correctional Complex (FCC), Florence, including the 

Administrative Maximum facility (ADX) 

$85.74c $216.12 (ADX) $105.25

Source: BOP estimates. 

Notes: BOP provided estimates of costs, which are defined as salary and non salary obligations.

a

These costs exclude the staffing costs for segregated housing units within each facility. BOP 

selected FCI Beckley for the sample medium security facility and USP Lee for the sample high 

security facility. According to a senior BOP official, BOP did not select these facilities based on costs 

but because they considered them to be a “typical” medium security facility and a high security 

facility. 

b

These costs include the costs of USP Lewisburg, which is an entirely SMU facility, and a minimum 

security prison camp. 

c

BOP’s estimate of the daily costs per inmate for the Florence FCC excludes the staffing costs for 

ADX and includes the staffing costs for the rest of the complex—the general population in the 

medium security, high security and camp facilities, the USP Florence SMU, and the SHUs within the 

medium and high security facilities.

According to these cost estimates that BOP provided, we estimated that 

the total cost of housing 1,987 inmates in SMUs in fiscal year 2012 was 

$87 million. If these inmates were housed in a sample BOP medium or 

high security facility, the total cost would have been about $42 million and 

$50 million, respectively. Also, given BOP estimates, we calculated that 

the total cost to house 435 inmates in ADX in fiscal year 2012 was about 

$34 million. If these inmates were housed in a medium security or high 

security facility, the total costs would have been about $9 million and $11 

million, respectively. Moreover, the estimated costs of housing 5,318 SHU 

inmates at the cost estimated by BOP for the sample medium security 

facility, FCI Beckley, would be $152 million, which is more expensive than 

housing inmates in medium security general population housing units 

which would cost an estimated $112 million. Similarly, the estimated cost 

of housing 2,701 SHU inmates at the cost estimated by BOP for the 

sample high security facility, USP Lee, would be $92 million, compared 

with housing inmates in high security general population housing units, 

which costs an estimated $69 million.
 

Page 33 GAO-13-429 Segregated Housing Units

According to BOP officials, the use of SMUs can reduce BOP costs. The 

officials said that SMUs resulted in reduced assault rates and a reduction 

in the number of facility lockdowns.32 Senior BOP budget officials noted 

that there are significant financial costs associated with keeping disruptive 

inmates in the general prison population who can cause a serious 

incident and lead to costly lockdowns. For example, according to BOP 

data, from fiscal years 2007 through 2011, lockdowns and disturbances 

led to losses totaling about $23 million. These officials explained that, 

during a lockdown, a facility has to use its entire staff to perform security 

and custodial duties at the expense of other duties.

BOP has not assessed the extent to which all three types of segregated 

housing units—SHUs, SMUs, and ADX— impact institutional safety for 

inmates and staff.33

 

32According to BOP, a lockdown is an emergency security practice in which inmates are 

locked in their cells and movement is restricted (e.g., dining, showering, recreating, and 

programming outside of cells is halted) for immediate or long-term control of a crisis or to 

prevent a crisis situation. In addition, BOP officials noted the number of lockdowns 

declined during a time frame when the total BOP inmate population rose. 

Although BOP has not completed an evaluation of the 

impact of segregation, BOP senior management and prison officials told 

us that they believed segregated housing units were effective in helping 

to maintain institutional safety. According to BOP officials, SMUs helped 

33BOP’s Office of Research and Evaluation (ORE), which conducts research and 

evaluations of BOP programs, reported in March 2012 that a SMU study was underway. 

However, as of February 2013, BOP officials could not confirm when the SMU study 

would be completed. 

BOP Has Not 

Evaluated the Impact 

of Segregated 

Housing Units on 

Institutional Safety or 

the Impacts of LongTerm Segregation on 

Inmates

BOP Has Not Assessed the 

Extent to Which 

Segregated Housing 

Impacts Institutional 

Safety
 

Page 34 GAO-13-429 Segregated Housing Units

reduce assault rates BOP-wide and reduced the number of lockdowns 

due to conflict and violence from 149 in fiscal year 2008 to 118 in fiscal 

year 2010, during a period when the overall inmate population increased. 

BOP, however, could not provide documentation to support that these 

reductions resulted from the use of SMUs.

Although state prison systems may not be directly comparable to BOP, 

there may be relevant information from efforts states have taken to 

reduce the number of inmates held in segregation.34 Five states we 

reviewed have reduced their reliance on segregation—Colorado, Kansas, 

Maine, Mississippi, and Ohio—prompted, according to state officials, by 

litigation and state budget cuts, among other reasons. These states 

worked with external stakeholders, such as classification experts and

correctional practitioners, to evaluate reasons why inmates were placed 

in segregation and implemented reforms that reduced the number of 

inmates placed in segregated housing units.35

 

34For example, both state departments of corrections and BOP are required to house, 

clothe, and feed inmates in a safe and secure setting, but BOP noted the federal 

correctional system and states are subject to different sentencing laws, which affect the 

types of inmates and types of segregation each system manages. 

After implementing 

segregated housing unit reforms that reduced the numbers of inmates 

held in segregation, officials from all five states we spoke with reported 

little or no adverse impact on institutional safety. While these states have 

not completed formal assessments of the impact of their segregated 

housing reforms, officials from all five states told us there had been no

increase in violence after they moved inmates from segregated housing 

to less restrictive housing. In addition, Mississippi and Colorado reported 

cost savings from closing segregated housing units and reducing the 

administrative segregation population. For example, Colorado closed a 

high security facility in 2012, which state officials reported led to cost 

savings of nearly $5 million in fiscal year 2012 and $2.2 million in fiscal 

year 2013. According to Colorado officials, segregation reform efforts 

helped lead to the closure of this high security facility. In Mississippi, 

reforms in segregation also led to the closure of a supermax facility in 

35State administrative segregation units, some of which are referred to as supermax 

facilities, are designed to hold the most dangerous inmates. Supermax facilities are 

designed to separate violent or disruptive inmates from general prison population and 

generally require confining inmates in a single cell up to 23 hours per day, with minimal 

contact with staff or other inmates. Some states have implemented segregated housing 

reforms earlier than others. For example, Ohio initiated segregated housing reforms about 

a decade ago. 
 

Page 35 GAO-13-429 Segregated Housing Units

early 2010, which Mississippi Department of Corrections officials reported 

saved the state nearly $6 million annually.

All five states changed their criteria for placing inmates in segregated 

housing, which helped them reduce their segregated inmate populations. 

Of the five states, three—Colorado, Mississippi, and Ohio—reviewed and 

changed the classification for placing inmates in administrative SHUs and 

two—Kansas and Maine—established new or modified the criteria for

placement of inmates in SMUs. For example, in 2007, Mississippi found 

that approximately 800 inmates (or 80 percent) did not meet its revised 

criteria for placement in administrative segregation. Before reforms, 

inmates would generally be transferred directly from admittance to 

administrative segregation without consideration of the inmate’s offense 

and would generally remain in segregation without regular review of the 

inmate’s status irrespective of whether the inmate had committed any 

serious misconduct. After implementing reforms, Mississippi adopted new 

criteria that stated inmates could be held in administrative segregation 

only if they committed serious infractions, were active high-level members 

of a gang, or had prior escapes or escape attempts from a secure facility. 

According to Mississippi officials, this reform did not lead to an increase in 

violence, assault rates, or serious incidents.

In 2011, after a study with external stakeholders that reviewed and 

recommended changes to Colorado’s administrative segregation 

operations, Colorado revised its policies for placement of inmates in 

segregated housing. Subsequent to the external study’s completion, 

Colorado began reviewing all offenders that had been in administrative 

segregation for longer than 12 months and found that nearly 37 percent 

or about 321 inmates in administrative segregation could be moved to 

close custody general population.36

 

36 Custody levels in Colorado refer to level of supervision and are identified as minimum, 

minimum restricted, medium, and close.

 After Colorado revised its 

classification criteria and increased oversight of the inmate review 

process, the number of inmates held in segregation decreased from 60 

per month in 2011 to approximately 20 to 30 per month in 2012. 

According to Colorado state officials, these reforms did not lead to an 

increase in violence.
 

Page 36 GAO-13-429 Segregated Housing Units

In addition, in 2011, Maine’s Department of Corrections reformed its 

inmate placement policies for SMUs. After changing the criteria and 

classification for holding inmates in SMUs, Maine significantly reduced 

the number of inmates in its 132-cell SMU, by closing a 50-cell section of 

its supermax SMU. Inmates removed from the SMU were reintegrated 

into a less restrictive, general population setting, and according to 

officials, there was no increase in incidents of violence.

While the policies and procedures for segregated housing vary between 

states and BOP, and their experiences may not be directly comparable, 

there may be lessons for BOP in the states’ experiences reducing their 

reliance on segregated housing. According to BOP officials, BOP 

generally uses larger states, such as California, Texas, or New York, for 

comparison, and that the five states included in our report may not be 

comparable with BOP. BOP officials also told us, in response to the 

findings from these states, that BOP has more comprehensive 

classification criteria, reviews, and procedural protections than the states. 

As a result, they indicated that BOP might not have the same reductions 

in costs and inmates in SHUs found at the state level. However, without 

an assessment of the impact of segregated housing, BOP cannot 

determine the extent to which placement of inmates in segregation 

contributes to institutional safety and security. Such an assessment is 

also important to inform DOJ and congressional decision making about 

the extent to which segregation meets BOP’s key programmatic goals for 

institutional safety. Our past work and the experience of leading 

organizations have demonstrated that measuring and evaluating 

performance allows organizations to track progress they are making 

toward intended results—including goals, objectives, and targets they 

expect to achieve—and gives managers critical information on which to 

base decisions for improving their programs.37

 

37For example, see GAO, Information Sharing, DHS Could Better Define How it Plans to 

Meet Its State and Local Mission and Improve Performance Accountability, GAO-11-223 

(Washington, D.C.: Dec. 16, 2010), Managing for Results: Enhancing Agency Use of 

Performance Information for Management Decision Making, GAO-05-927 (Washington, 

D.C.: Sept. 9, 2005); Program Evaluation: Studies Helped Agencies Measure or Explain 

Program Performance, GAO/GGD-00-204 (Washington, D.C.: Sept. 29, 2000); Agency 

Performance Plans: Examples of Practices That Can Improve Usefulness to 

Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999); and 

Managing for Results: Strengthening Regulatory Agencies’ Performance Management 

Practices, GAO/GGD-00-10 (Washington, D.C.: Oct. 28, 1999). 
 

Page 37 GAO-13-429 Segregated Housing Units

Given that BOP maintains data on assault, violence, and lockdown rates 

across all prison facilities, BOP senior officials reported that evaluating 

the relationship between assault rates and segregation might help them 

evaluate the impact of segregated housing. An assessment of the 

effectiveness of segregation, including consideration of practices across 

local and state correctional systems, could better position BOP to 

understand the extent to which different types of segregated housing 

units meet BOP mission goals to ensure institutional safety for inmates 

and staff.

On January 31, 2013, BOP officials told us that the BOP Director had 

authorized the solicitation of an independent review of segregated 

housing and, once a contract is awarded, they expect the study to be 

completed during fiscal year 2014. BOP officials explained that the 

study—with the objective of identifying improvement in BOP’s practice 

and policy—is to review segregated housing, including identifying best 

practices across the correctional spectrum, such as inmate management, 

and mental health, among other areas. According to BOP, the statement 

of work for this solicitation requires the recipient to provide an 

assessment of the use and practices of segregated housing units in BOP. 

However, it is unclear to what extent the review will assess the extent that 

segregated housing units contribute to the safety and security of inmates 

and staff and ensures that BOP meets its mission goals.
 

Page 38 GAO-13-429 Segregated Housing Units

BOP psychologists are required to provide an initial intake screening of 

each inmate within 30 days of the inmate’s arrival in a BOP facility. 

Moreover, BOP requires that psychological staff visit inmates in 

segregated housing on a weekly basis and provide psychological 

assessments after 30 consecutive days in the SHUs, SMUs, and ADX

Control and Special Security Units.

38

While BOP conducts regular assessments of mental health of inmates, 

BOP has not evaluated the impact of long-term segregation on inmates. 

BOP’s Office of Research and Evaluation (ORE) officials said they have 

not studied the impact of long-term segregation on inmates because of 

competing priorities related to studying impacts of prisoner reentry, drug 

treatment, and recidivism.

According to BOP’s Psychology 

Services Branch Administrator, these weekly visits and psychological 

assessments provide staff an opportunity to intervene when and if they 

find that an inmate is having difficulty in segregation. BOP also has a 

suicide prevention program, which includes training for all staff and 

additional supplemental training for staff working in segregation. In 

addition, inmates receive information on suicide prevention upon their 

arrival at an institution and the availability of mental health services while 

in segregated housing. BOP also develops “hot list” memos that are 

posted in SHUs to help inform staff of inmates who may have specific 

mental health concerns or suicidal tendencies.

39

 

38For example, the 30-day psychological assessment is to include an interview with the 

inmate, assessment of each inmate’s adjustment to his or her surroundings, and any 

threat the inmate poses to self, staff, and other inmates. We currently have work under 

way for the House Committee on Oversight and Government Reform and the House 

Judiciary Committee, which is reviewing the extent to which BOP monitors and assesses 

the cost and quality of inmate mental health. 

 In addition, BOP officials explained that there 

are methodological concerns related to finding an appropriate control 

group of inmates to compare with inmates held in segregation. We 

recognize the methodological limitations; however, a 2010 Colorado study 

that was funded by DOJ identified a comparison group of inmates in order 

to evaluate the psychological impact of segregation.

39 BOP’s Office of Research and Evaluation (ORE), which reported that BOP is in the 

early stages of a study dedicated to evaluating the impact of SMUs on offenders. BOP 

does not yet have an estimated completion date for the study. 

BOP Conducts Regular 

Assessments of the Mental 

Health of Inmates in 

Segregated Housing, but 

Has Not Conducted an 

Evaluation of Impacts of 

Long-Term Segregation on 

Inmates 
 

Page 39 GAO-13-429 Segregated Housing Units

BOP officials, including psychologists, at four of the six facilities we visited 

reported little or no adverse impact of segregation on inmates.40 Some of 

these psychologists and BOP HQ officials cited the 2010 DOJ-funded 

study of the psychological impacts of solitary confinement in the Colorado 

state prison system.41

We reviewed several studies on the impact of segregated housing on 

inmate mental health, and several suggest that long-term segregation or 

solitary confinement can cause significant adverse impacts. See appendix 

I for information about criteria used to select studies in our review. These 

reports describe possible adverse impacts of segregation, including 

exacerbation or recurrence of preexisting illnesses, illusions, 

oversensitivity to stimuli, and irrational anger, among other symptoms, 

although it is unclear how applicable the conditions studied are to BOP 

segregated housing. Other reports addressed the possible effect of 

segregation on other outcomes, such as recidivism or new convictions 

after release from prison.

This study showed that segregated housing of up 

to 1 year may not have greater negative psychological impacts than non

segregated housing on inmates. While the DOJ-funded study did not 

assess inmates in BOP facilities, BOP management officials told us this 

study shows that segregation has little or no adverse long-term impact on 

inmates. BOP’s Psychology Services Branch Administrator explained that 

the impact is dependent on each individual inmate. For example, she told 

us that a small number of inmates with mental disorders, such as 

schizophrenia, actively seek placement in segregation, and some appear 

to function reasonably well in this environment.

42

 

40The psychologist at one facility reported that segregation could adversely impact an 

inmate’s mental health. 

Few reports, however, incorporate a 

comparison between inmates in segregation versus inmates not in 

41Maureen L. O’Keefe et al, Colorado: One Year Longitudinal Study of the Psychological 

Effects of Administrative Segregation, National Institute of Justice Report, U.S. 

Department of Justice, Washington, D.C. (2010). 

42For an example of some studies we reviewed, see S. Grassian, “Psychiatric Effects of 

Solitary Confinement, “ Journal of Law & Policy, vol. 22, no. 325 (2006); D. Lovell, L. C. 

Johnson and K. C. Cain, “Recidivism of Supermax Prisoners in Washington State,” Crime 

& Delinquency, vol. 53, no. 4 (2007); D. P. Mears and W. D. Bales, “Supermax 

Incarceration and Recidivism,” Criminology, vol. 47, no. 4 (2009); H. A. Miller and G. R. 

Young, “ Prison Segregation: Administrative Detention Remedy or Mental Health 

Problem,” Criminal Behaviour and Mental Health, vol. 7:85-94 (1997); and P. Smith, “The 

Effects of Solitary Confinement on Prison Inmates: A Brief History and Review of the 

Literature,” Crime and Justice, vol. 34:441-568 (2006). 
 

Page 40 GAO-13-429 Segregated Housing Units

segregation, limiting the ability to draw conclusions about the impact of 

segregation. A comparison of inmates held in segregation with those in 

general population would be important for understanding the extent to 

which any adverse psychological impacts are unique to long-term 

segregation.

While most BOP officials told us there was little or no clear evidence of 

mental health impacts from long-term segregation, BOP’s Psychology 

Services Manual explicitly acknowledges the potential mental health risks 

of inmates placed in long-term segregation. Specifically, it states that 

BOP “recognizes that extended periods of confinement in Administrative 

Detention or Disciplinary Segregation Status may have an adverse effect 

on the overall mental status of some individuals.” In addition, according to 

BOP’s mission statement, BOP protects society by confining offenders in 

prisons that are, among other things, safe and humane. In our prior work, 

we reported that DOJ stresses the importance of evidence-based 

knowledge in achieving its mission. Specifically, DOJ’s Office of Justice 

Programs (OJP) supports DOJ’s mission by sponsoring research to 

provide objective, independent, evidence-based knowledge to meet the 

challenges of crime and justice, such as the 2010 Colorado state prison 

system study. In addition, BOP’s ORE is responsible for conducting 

research and evaluation of BOP programs, but ORE has not conducted 

studies on the impact of long-term segregation on inmates. Further, 

according to generally accepted government auditing standards, 

managers should evaluate programs to provide external accountability for 

the use of public resources to understand the extent to which the program 

is fulfilling its objectives.43

To help BOP HQ assess inmates placed in segregation, BOP maintains a 

psychology data system (PDS) that is used to document all mental health 

screenings and staff visits by psychologists and treatment specialists, and 

a Bureau Electronic Medical Record (BEMR) that documents all staff 

visits by physicians and medication provided. Given that BOP’s PDS and 

BEMR systems maintain data on the mental health of inmates and BOP’s 

Psychological Services Manual states there may be potential adverse 

effects from long-term segregation, a study that uses existing information 

to assess the impact of segregation on inmates would better position 

 

43See GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: 

January 2012). 
 

Page 41 GAO-13-429 Segregated Housing Units

BOP to understand the effects of segregation, including any related to 

inmates’ mental health. BOP’s Psychology Services Branch Administrator 

agreed that such a study would be useful. As of January 2013, BOP

announced that the bureau is considering the development of procedures 

for conducting individualized mental health case reviews of inmates held 

in long-term segregation, i.e., inmates housed in SHUs or the ADX 

Control Unit for more than 12 continuous months and inmates who fail to 

progress through the SMU or ADX General Population Step Down 

phases in a timely manner. These reviews would be conducted at BOP 

HQ, and if the review found any concerns, the reviewers would contact 

prison staff to discuss strategies to reduce or eliminate the identified 

mental health concerns. However, the proposal is still under 

consideration, has not yet been implemented across all prison facilities, 

and we cannot determine the extent to which this proposal will 

systematically assess the long-term impact of segregated housing on 

inmates.

Over the past 5 years, the number of BOP inmates in segregated housing 

has grown at a faster rate than the general inmate population. With more 

inmates held under more restrictive conditions, often for months or years 

at a time, segregated housing represents an important part of BOP’s 

effort to achieve its primary goal of confining inmates in a safe, secure, 

and cost-efficient environment. While BOP has a mechanism to centrally 

monitor many of its segregated housing unit policies, BOP does not 

centrally monitor the policies specific to its most restrictive segregated 

prison, the ADX facility. As a result, BOP has less assurance that ADX 

staff consistently follows ADX-specific policies to the same degree that 

these requirements are followed for SHUs and SMUs. We also found that 

prison officials were not consistently documenting that inmates’ conditions 

of confinement, such as food and exercise privileges, were being met. 

BOP has taken initial steps toward addressing these documentation 

issues by implementing new software that may help track the monitoring 

of SHUs and SMUs. However, BOP has not developed a plan to clarify 

the objectives and goals of the new software program, with time frames 

and milestones that explain the extent to which it will address 

documentation issues we identified.

BOP officials believe that segregated housing helps maintain institutional 

safety. Given BOP’s increased reliance on segregated housing and the 

higher costs associated with its use, it is notable that BOP has not studied 

the impact of segregated housing on inmates, staff, and institutional 

safety. As BOP considers options for conducting a study of segregated 

Conclusions
 

Page 42 GAO-13-429 Segregated Housing Units

housing, BOP may want to consider lessons learned from some state 

initiatives that reduced the number of inmates held in segregation without 

significant, adverse impacts on violence or assault rates. In addition, 

BOP’s own policies recognize that long-term segregation may have a 

detrimental effect on inmates. While BOP does regularly check the mental 

health of inmates in segregated housing, BOP has not conducted an 

assessment of the long-term impact of segregation on inmates.

To improve BOP’s ability to centrally oversee the implementation of 

segregated housing policies, we recommend that the Director of the 

Bureau of Prisons take the following two actions:

(1) develop ADX-specific monitoring requirements and

(2) develop a plan that clarifies the objectives and goals of the new

software program, with time frames and milestones, and other means, 

that explains the extent to which the software program will address 

documentation concerns we identified. 

To ensure that BOP’s use of segregated housing furthers BOP’s goal to 

confine inmates in a humane manner and contributes to institutional 

safety without having a detrimental impact on inmates held there for long 

periods of time, we recommend that the Director of the Bureau of Prisons 

take the following two actions:

(1) ensure that any current study to assess segregated housing units also 

includes an assessment of the extent that segregated housing contributes 

to institutional safety, and consider key practices that include local and 

state efforts to reduce reliance on and the number of inmates held in 

segregated housing and

(2) assess the impact of long-term segregation on inmates in SHUs, 

SMUs, and ADX.

We provided a draft of this report to DOJ for its review and comment. 

BOP provided written comments on this draft, which are reproduced in full 

in appendix IV. BOP concurred with all of our recommendations. BOP 

also provided technical comments on the report on April 19, 2012, which 

we incorporated as appropriate. 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation 
 

Page 43 GAO-13-429 Segregated Housing Units

BOP concurred with the first recommendation that BOP develop ADXspecific monitoring requirements. BOP stated that it will conduct a 

Management Assessment to identify aspects of the Control Unit at ADX 

that are vulnerable to violations of policy. BOP further noted that it would 

develop guidelines, as appropriate, to be incorporated into the program 

review guidelines. If fully implemented across all ADX housing units, 

BOP’s planned actions will address the intent of this recommendation. 

BOP concurred with the second recommendation that BOP develop a 

plan with timeframes and milestones, to explain the extent the software 

program will address documentation concerns. BOP stated that the goal 

of the new software program is to help ensure compliance with 

requirements to maintain accurate and complete records on conditions 

and events in segregated housing units. BOP indicated that they will 

conduct a program review by September 30, 2013 to determine if the 

SHU documentation deficiencies have been reduced. If fully 

implemented, BOP’s planned actions will address the intent of this 

recommendation. 

BOP concurred with the third recommendation that BOP ensure any 

current study to assess segregated housing units also includes an 

assessment of the extent that segregated housing contributes to 

institutional safety. BOP stated that the current scope of work for the 

Special Housing Review and Assessment will include an assessment of 

how segregated housing units contribute to institutional safety. BOP 

further noted that the scope of work will include consideration of key 

practices of local and state correctional systems. If fully implemented, 

BOP’s planned actions will address the intent of this recommendation. 

BOP concurred with the fourth recommendation that BOP assess the 

impact of long-term segregation on inmates in SHUs, SMUs, and ADX. 

BOP stated that the assessment of mental health of inmates is consistent 

with its public safety mission. BOP stated that BOP will develop and 

distribute an expanded mental health screening tool for psychology staff, 

which will help conduct a longitudinal assessment of: (1) inmates housed 

in SHUs or the ADX Control Unit for more than 12 continuous months; 

and (2) those inmates who fail to progress through the SMU or ADX 

General Population Step Down phases in a timely manner. In addition, 

BOP stated that its review of segregated housing units will include an 

evaluation of inmate mental health history and a review of BOP’s mental 

health assessment process. If fully implemented, BOP’s planned actions 

will address the intent of this recommendation. 
 

Page 44 GAO-13-429 Segregated Housing Units

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, 

Director of the Bureau of Prisons, selected congressional committees, 

and other interested parties. In addition, the report will be available at no 

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

Should you or your staff have any questions concerning this report, 

please contact David Maurer at (202) 512-9627 or by email at 

maurerd@gao.gov. Contact points from 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
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-13-429 Segregated Housing Units

Our objectives for this report were to address the following questions:

1.What were the trends in the Bureau of Prison’s (BOP) segregated 

housing unit population and number of cells from fiscal year 2008 through 

February 2013?

2.To what extent does BOP centrally monitor how individual facilities 

document and apply policies guiding segregated housing units?

3.To what extent has BOP assessed the costs to operate segregated 

housing units and how do the costs to confine an inmate in a segregated 

housing unit compare with the costs of confining an inmate in a general 

inmate population housing unit?

4.To what extent does BOP assess the impact of segregated housing on 

institutional safety and the impacts of long-term segregation on inmates?

Overall, to address our questions, we analyzed BOP’s statutory authority 

and policies and procedures (e.g., BOP’s inmate placement, procedural 

protections, and general conditions of confinement for segregated 

housing units—Special Housing Units (SHU), Special Management Units 

(SMU), and the Florence Administrative Maximum facility (ADX)—and 

Communications Management Units (CMU)). BOP considers CMUs as 

self-contained general population housing units. However, since CMU 

inmates are separated from general inmate population and have 

restrictive conditions, such as 100 percent of their communications 

monitored and noncontact visits, we include CMUs within the scope of our 

review, as described in appendix II.

To address the first question, we obtained and analyzed BOP’s number of 

cells and inmate population data for each type of segregated housing unit 

and the CMUs. We focused our data analysis on the period of fiscal year 

2008 through February 2013 or the past five fiscal years to the most 

recent data available.

1

 

1

BOP provided population data at the end of each fiscal year for fiscal years 2008, 2009, 

2010, 2011, 2012, and as of February 2013. BOP also provided number of cells data from 

fiscal years 2008 through 2012 for SHUs, ADX and CMUs, and from fiscal year 2008 

through November 2012 for SMUs. 

We assessed the reliability of the inmate 

population and number of cells data by (1) participating in an electronic 

demonstration of the SENTRY database that BOP uses to generate 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-13-429 Segregated Housing Units

required inmate population, (2) reviewing existing information about the 

data and the system that produced them, (3) examining the data for 

obvious errors and inconsistencies, and (4) interviewing BOP officials 

knowledgeable about the data. We determined that the required data 

elements were sufficiently reliable for the purposes of this report. 

To address the second question, we analyzed BOP’s policies and 

procedures pertinent to the monitoring of individual prisons’ compliance 

with segregated housing unit policies. To observe the conditions of 

confinement, procedural protections, and inmate placement in segregated 

housing, we conducted visits to 6 of 119 BOP federal institutions. We 

chose these institutions because of different types of segregated housing 

units and varying security levels they contain. As shown in table 4, the six 

prisons we visited cover the three main types of segregated housing 

units—SHUs, SMUs, and ADX—as well as CMUs.

Table 4: Site Visits to BOP Institutions 

Institution name 

Types of segregated 

housing units Included 

Security level of the 

individual facilities 

we visited

Federal Correctional Complex 

(FCC) Allenwood Complex 

SHUs, SMUs High security, medium 

security 

U.S. Penitentiary (USP) Lewisburg SHUs, SMUs High security 

FCC Florence SHUs, SMUs, ADX Administrative 

maximum, high 

security, medium 

security 

U.S. Penitentiary (USP) 

Leavenworth 

SHUs Medium security

USP Marion SHUs, CMUs Medium security 

FCC Terre Haute SHUs, CMUs High security, medium 

security 

Source: GAO analysis of BOP information.

During the site visits, we interviewed institutional management officials 

and toured the prison to observe inmate housing, recreational areas, food 

service, and educational and vocational programming. We also 

interviewed officials from BOP’s Program Review Division (PRD), which

leads monitoring reviews, and officials from BOP’s Correctional Programs 

Division (CPD), which has primary responsibility for inmate placement 

and procedural policies at segregated housing units. Because we did not 

visit all BOP facilities and did not randomly select the facilities we visited, 

our results are not generalizable to all BOP facilities. However, we 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-13-429 Segregated Housing Units

selected the sites to provide perspectives on different types of segregated 

housing units and varying security levels, which were useful in 

understanding population trends, BOP monitoring of conditions of 

confinement and procedural policies, cost, and the impact of segregated 

housing.

Further, for our second question, we assessed BOP’s monitoring for each 

type of segregated housing unit by reviewing monitoring policies, 

guidelines, and reports. We analyzed BOP’s segregated housing unit 

policies and monitoring guidance and compared them against criteria in 

Standards for Internal Control in the Federal Government. We also 

assessed the methodology and system BOP employs to monitor, identify, 

and address deficiencies at prisons; we reviewed 45 of 187 PRD 

monitoring reports from 20 of 98 facilities that PRD monitored during the 

period from fiscal years 2007 to 2011. We requested a selection of PRD 

correctional services monitoring reports, which BOP provided for a variety 

of facilities during this time period. In addition, we requested monitoring 

reports for the facilities we visited for our site visits. We also reviewed 43 

follow-up monitoring reports related to the 45 monitoring reports to 

determine the extent that prisons resolved deficiencies identified in the 

monitoring reports.

We reviewed these PRD monitoring reports to summarize common 

findings and deficiencies relevant to our engagement related to 

cleanliness, conditions of confinement, documentation, procedural 

protection, monitoring, policy, security protocols, timeliness, and training. 

We developed a methodology for selecting these areas to assess the 

extent that BOP monitored conditions of confinement, procedural policies, 

and other key issues identified in the monitoring reports. One analyst 

reviewed each report and highlighted any common findings and 

deficiencies noted in the report. A second analyst independently verified 

the findings and deficiencies identified. We also interviewed PRD officials 

responsible for doing on-site monitoring, and interviewed senior BOP 

officials who are responsible for developing monitoring policy guidance to 

understand the degree and methodology of monitoring used.

To provide an independent analysis of BOP compliance with segregated 

housing unit policies at selected prisons, we developed a data collection 

instrument (DCI) according to BOP’s monitoring policies, and guidance 

and questions. Our DCI is similar to questions used during PRD periodic 

on-site monitoring reviews of segregated housing unit policies at SHUs, 

SMUs, and general prison policies at CMUs. We selected two of the six 

institutions we visited—FCC Terre Haute and USP Marion. At each 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-13-429 Segregated Housing Units

institution, we selected a random sample of case files from fiscal years 

2011 to 2012, of inmates currently housed in segregated housing units—

including SHU-administrative detention, SHU-disciplinary segregation, 

and CMUs—totaling 61 files. These 61 inmate case files include 51 SHU 

inmate case files, and 10 CMU inmate case files. We selected the inmate 

case files from SHUs using the same sample size BOP PRD inspectors 

use when conducting correctional services monitoring reviews of SHUs. 

For example, according to BOP PRD monitoring guidance for correctional 

services reviews of SHUs, PRD inspectors are to review documentation 

of 10 percent of inmates currently in SHU to determine whether the 

inmates are afforded specific conditions of confinement, inmates’ 

placement and status in SHU are regularly reviewed, and other SHU 

policies are followed. Accordingly, we selected the case files of 10 

percent of inmates in SHUs in the two institutions for our analysis. 

According to PRD monitoring guidance for the review of disciplinary-SHU, 

PRD inspectors are to review 10 disciplinary hearing packets. For our 

review, we selected 17 disciplinary inmate case files and hearing packets 

because we were interested in understanding the extent to which BOP 

provided procedural protections for inmates held in disciplinary-SHU. We 

randomly selected the inmate case files from both SHUs and CMUs from 

a roster of inmates in each SHU or CMU at the time of our visit. Although 

our selection of files was not generalizable to all inmates in all types of 

segregated housing units, it provided insights into whether these 

institutions were following BOP policy. We used the DCIs to extract 

information relevant to BOP’s monitoring policies, inmate placement, 

conditions of confinement and procedural protections for inmates held in 

SHU-administrative detention, SHU-disciplinary segregation, and CMUs. 

One analyst summarize information from the inmate case file, and a 

second analyst verified the DCI information collected. A third analyst 

reviewed and summarized information collected from the DCIs. In 

addition, we observed PRD staff conduct on-site monitoring of SHUs and 

CMU at two facilities. 

We also reviewed information and documentation received related to 

BOP’s new software program, that includes the SHU application, 

compared against best practices for project management and criteria in 

BOP’s monitoring documentation policies. For example, we reviewed 

implementation dates and plans, training materials used across BOP 

facilities, and analyzed BOP monitoring policies, and interviewed PRD 

officials to understand to what extent the new SHU application addresses 

any documentation concerns we identified during our engagement.
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-13-429 Segregated Housing Units

To address the third question, we reviewed BOP fiscal year 2012 average 

inmate per capita costs for prisons at each major security level: high 

security, medium security, low security, and minimum security levels. 

These inmate per capita costs cover all costs associated with the day-today operation of the entire institution, including health services, uniform, 

food, programming, and contractual services and equipment costs related 

to each prison. According to BOP, the inmate daily per capita costs are 

calculated as total obligations as reported in BOP’s Salaries and 

Expenses appropriations account divided by total inmate days. Further, in 

January 2013, BOP provided a snapshot estimate of fiscal year 2012 

inmate per capita costs broken out by segregated housing versus general 

population housing at four institutions: (1) USP Lewisburg, a SMU facility; 

(2) FCC Florence, which includes ADX Florence; (3) a sample medium 

security facility (FCI Beckley); and (4) a sample high security facility (USP 

Lee), which both include SHUs. We interviewed BOP officials from the 

Administration Division, who have responsibility over financial and facility 

management, about their processes for developing the estimates. 

According to senior BOP officials, BOP selected these facilities because 

they considered them “typical” medium security and high security 

facilities. We found BOP’s segregated housing versus general population 

housing inmate per capita cost data to be sufficiently reliable for the 

purposes of presenting an overview of possible costs. For illustration 

purposes, we also used BOP’s estimated segregated housing versus 

general population housing inmate per capita cost data, combined with 

BOP inmate population data, to estimate the costs of housing the number 

of inmates in ADX, all SMUs, and all SHUs, BOP-wide, as of fiscal year 

2012 compared with the costs to house these same amount of inmates in 

general population housing units for fiscal year 2012. For example, to 

estimate the total costs of housing the total SMU inmate population in 

SMUs, BOP-wide, for fiscal year 2012, we multiplied BOP’s estimated 

daily inmate per capita costs for USP Lewisburg SMU by the total SMU 

population times 366 days, or the number of calendar days in 2012. To 

estimate the costs of housing this same number of SMU inmates in 

general population housing in a medium security or high security facility, 

we multiplied the total SMU population, BOP-wide, by BOP’s estimated 

daily inmate per capita costs for the sample medium facility, FCI Beckley, 

times 366 days, and estimated daily inmate per capita costs for the 

sample high security facility, USP Lee, times 366 days, respectively.

To address the fourth question, we reviewed BOP’s policies, including 

program objectives, for each segregated housing unit and policies 

governing the provision of mental health services to inmates in 

segregated housing units. We also reviewed BOP lockdown data from 
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-13-429 Segregated Housing Units

fiscal year 2008 through fiscal year 2012. We also interviewed officials 

from BOP’s Correctional Programs Division (CPD), which also includes 

the Psychology Services Branch that is responsible for mental health 

services. We also interviewed officials from BOP’s Office of Research and 

Evaluation (ORE), who produce reports and research corrections-related 

topics. During these interviews, we discussed the lack of BOP studies 

that assess the impact of segregated housing units on institutional safety 

and inmates and staff, and their views on the impact of long-term 

segregation, including their views on the impact of segregation on 

inmates, including those with mental illness. We also discussed the 

impacts of segregation with officials from the Council of Prison Locals, the 

union that represents all nonmanagement staff working in BOP facilities.

To identify actions states have taken regarding segregated housing that 

may be relevant to BOP, we reviewed actions taken by five states—

Colorado, Kansas, Maine, Mississippi, and Ohio. We selected these five 

states because they (1) were involved in addressing segregated housing 

reform and (2) had taken actions to reduce the number of inmates held in 

segregation. For each of the five selected states, we reviewed relevant 

documents on segregated housing, and in four states we reviewed 

placement policies. For four of the five selected states, we reviewed 

relevant reports on their segregated housing unit conditions for context. 

While conducting site visits to BOP prisons in Kansas and Colorado, we 

also visited state correctional facilities in those two states. We interviewed 

corrections officials at these facilities and the other states regarding 

reasons for reducing the segregated housing unit population and any 

reported impact of the segregated housing unit reforms on institutional 

safety. While the reports and results from our interviews are not 

representative, they provided us with perspectives on state actions to 

reduce segregated housing

There are dissimilarities between federal and state prison systems—

legally and structurally, to name a few––that limit the comparability 

between federal and state correctional systems. We are unable to 

generalize about the types of actions other states have taken to reform 

segregated housing policies and reduce the number of inmates held in 

segregation and any effects. Nevertheless, the information we obtained 

through these visits provided examples of state responses to reforming 

segregation and reducing inmates housed in segregated housing units. 

We also discussed with BOP officials the state actions we identified.

Further, to identify the universe of reports and studies that describe, 

evaluate, or analyze the impact of segregated housing, including any 
Appendix I: Objectives, Scope, and 

Methodology

Page 51 GAO-13-429 Segregated Housing Units

long-term impacts associated with mental illness, we used a multistaged 

process. First, we (1) conducted key word searches of criminal justice, 

legal, and social science research databases; (2) searched academic, 

nongovernment and stakeholder interest group-related Web sites, such 

as those of Vera, American Civil Liberties Union (ACLU), and Urban 

Institute, (3) reviewed bibliographies, published summaries, metaanalyses, and prior GAO reports on segregated housing; and (4) asked 

academic corrections experts to identify evaluations. Our literature search 

identified over 150 documents, which included articles, opinion pieces, 

published reports, and studies related to segregated housing. We further 

identified studies that compared inmates in segregated housing with 

inmates in the general population. We reviewed these reports and studies 

to gain a broader understanding of the potential impacts of segregated 

housing and of the extent and quality of research available on the subject. 

We compared BOP’s mechanisms for evaluating the impact of 

segregated housing units on institutional safety, or the impacts of longterm segregation on inmates, with BOP’s policies and mission 

statements.

We conducted this performance audit from January 2012 to April 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions given our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions for our audit objectives.
Appendix II: Communications Management 

Units

Page 52 GAO-13-429 Segregated Housing Units

BOP established CMUs in 2006 and 2008, in two institutions to house 

inmates who require increased monitoring of their communications with 

the public to protect the safety, security, and orderly operation of BOP 

facilities and the public.1 Inmates in CMUs have 100 percent of their 

communications monitored by BOP officials and are allowed only 

noncontact visits with family and friends. According to each prison’s 

institution supplement guidelines, CMUs are self-contained general 

population housing units in which inmates reside; eat; and participate in 

all educational, religious, visiting, unit management, and work 

programming in the unit, similar to general population inmates.2 From 

fiscal year 2008 to February 2013, the total CMU population increased 

from 64 inmates to 81 inmates.3

 

1

BOP operates CMUs in two medium security BOP facilities. BOP established a CMU at 

FCI Terre Haute in 2006 and a second CMU in USP Marion in 2008. As part of this 

review, we visited both CMUs. 

See figure 11 for an overview of CMUs.

2

According to BOP officials, BOP does not have a national policy governing CMUs. 

Rather, the prisons containing the CMUs have developed institution supplements, or local 

guidelines and procedures that govern the CMU inmate review process and conditions of 

confinement. The CMU institution supplements for FCI Terre Haute and USP Marion are 

generally the same. 

3 BOP has had 113 CMU inmate cells since fiscal year 2008. The CMU population and 

cell totals include the CMU SHUs. 

Appendix II: Communications Management 

Units 
Appendix II: Communications Management 

Units

Page 53 GAO-13-429 Segregated Housing Units

Figure 11: Overview of Communications Management Units

a

BOP promulgated a proposed rule in April 2010 to establish specific parameters for CMU operations 

and put inmates and the public on notice of CMUs; the comment period closed in June 2010, and a 

final rule has not been published. Under the proposed rule, BOP’s Assistant Director of the 

Correctional Programs Division would become the authorizing official for CMU designations. 

Communications Management Units. 75 Fed. Reg. 17,324 (proposed Apr. 6, 2010) (to be codified at 

28 C.F.R. pt. 540, subpt. J). 

b

The total CMU inmate population and number of cells includes SHUs within the CMUs. 

According to a BOP memorandum, BOP places inmates in CMUs for 

several reasons, including conviction, conduct or involvement related to 

Placement Criteria and 

Procedural Policies
Appendix II: Communications Management 

Units

Page 54 GAO-13-429 Segregated Housing Units

international or domestic terrorism, and commission of prohibited activity 

related to misuse or abuse of approved communication methods while 

incarcerated, or for other reasons.4

Inmates referred to CMUs do not receive a hearing prior to placement in 

CMUs.5

 According to the prison’s institution supplement guidelines, an 

inmate assigned to a CMU is to receive a notice of transfer to the CMU 

within 5 days of arrival in the unit, including reasons for placement and 

notice of the right to appeal the transfer through the administrative 

remedy process. At the institution, prison officials are to review the CMU 

inmate’s status every 6 months, according to BOP’s national policy that 

applies to all inmates in BOP custody. The guidelines also call for prison 

officials to regularly review an inmate’s readiness to be transferred out of 

a CMU by examining a number of factors, including programming needs 

and if the original reasons for CMU placement still exist. After conducting 

the review, prison officials may recommend to the warden that an inmate 

be transferred out of the CMU.

All CMU inmates are segregated from the general population in selfcontained housing units to regulate and monitor their communications 

with persons in the community. However, they are allowed to congregate 

outside their cells, but within these self-contained housing units, for 15 to 

16 hours per day like inmates in the general population.6 Inmates in 

CMUs require 100 percent live monitoring of their telephone calls and 

social visits, and a review of their incoming and outgoing social mail.7

 

4

According to BOP’s Memorandum for Continued CMU Designation, dated October 14, 

2009, BOP also refers inmates to CMUs for the following reasons: attempt or propensity to 

contact victims of the inmate’s current offense of conviction, and/or conviction or conduct 

indicating a propensity to coordinate illegal activity through communication with persons in 

the community, or evidence of a potential threat to the safety and security of prison 

facilities or the public, as a result of the inmate’s unmonitored communication with persons 

in the community.

All 

5

As of February 2013, there is litigation pending in federal court addressing the issue of 

whether the lack of a hearing prior to placement in a CMU adequately protects inmates’ 

constitutional rights. See Aref v. Holder, No. 10-0539 (D.D.C. filed Apr. 1, 2010). 

6

According to the CMU institution supplements, inmates in the USP Marion CMU will 

generally be housed in single-bunked cells, and inmates in the FCI Terre Haute CMU will 

generally be housed in double-bunked cells. 

7

Legal and special mail (e.g., attorney, federal courts) can be sealed and delivered to unit 

management. 

General Conditions of 

Confinement
Appendix II: Communications Management 

Units

Page 55 GAO-13-429 Segregated Housing Units

telephone calls and social visits are also recorded, and they must occur in 

English only, unless the call is previously scheduled and conducted 

through simultaneous translation monitoring. Other than increased 

communications monitoring, BOP officials stated that conditions of 

confinement in these units are the same as conditions of confinement for 

inmates in other medium security general population housing units. This 

includes (1) access to medical and mental health services; (2) meals that 

meet inmate dietary requirements served in common dining areas; (3) 

access to recreation and leisure in a common area daily up to 16 hours 

per day, including table games, television in the common areas, and 

some aerobic exercise equipment; (4) religious service opportunities; and 

(5) access to law library services.

Also, like general population housing, each CMU contains a SHU 

dedicated to housing inmates in need of being placed in SHUadministrative detention or SHU-disciplinary segregation status. See 

figures 12 and 13 for photographs of a CMU.
Appendix II: Communications Management 

Units

Page 56 GAO-13-429 Segregated Housing Units

Figure 12: Communications Management Unit Cell, Terre Haute, Indiana
Appendix II: Communications Management 

Units

Page 57 GAO-13-429 Segregated Housing Units

Figure 13: Communications Management Unit Common Area, Marion, Illinois

As previously discussed, BOP headquarters has a mechanism in place to 

centrally monitor how prisons implement most housing unit policies, but 

the degree of monitoring varies depending upon the type of housing. In 

addition, we reviewed PRD monitoring reports, assessed how PRD 

conducted monitoring at one of the two prisons with CMUs, and 

conducted an independent analysis of BOP compliance at these two 

prisons.

At one of the two prisons with CMUs we visited, we observed that PRD 

checked compliance with general prison policies, as well as SHU-specific 

policies, but PRD does not have requirements to monitor CMU-specific 

policies. CMU inmate files may be included in any PRD program review 

that covers the entire prison complex. According to BOP officials, 

although not required, BOP may randomly select some CMU inmate files 

BOP Monitoring of CMUs
Appendix II: Communications Management 

Units

Page 58 GAO-13-429 Segregated Housing Units

as part of the prison complex during periodic PRD reviews.8

As part of our review of PRD monitoring reports, we found that 8 of the 45 

monitoring reports covered these two prisons with CMUs. PRD found that 

these prisons were in general compliance with BOP policies, and none of 

these PRD monitoring reports identified any findings or deficiencies 

specific to the CMUs. To assess how PRD staff conducted monitoring at 

one of these prisons, we observed PRD conduct reviews at the CMUs in 

accordance with PRD guidelines. In light of our observations, we found 

that PRD staff (1) performed monitoring rounds at CMUs, (2) reviewed log 

books, and (3) reviewed inmate files, to determine if the prisons followed 

the required procedural protections steps. In addition, we also conducted 

an independent analysis of BOP compliance with CMU-specific policies at 

the two prisons with CMUs. Specifically, we reviewed a total of 10 files for 

inmates held in CMUs for fiscal years 2011 and 2012 at these two 

facilities. We found that all 10 inmate case files we analyzed provided 

reasons for inmate placement in CMUs, as required by BOP institution 

supplements. However, similar to the documentation problems we noted 

in the body of the report, we found documentation deficiencies during our 

review of the CMU files. For example, 2 out of the 10 inmate case files we 

reviewed did not include documentation that unit team staff regularly 

monitored the inmate’s CMU status every 6 months and ensured that 

inmates were afforded their rights to programming activities. Without 

complete documentation, BOP headquarters cannot be assured that 

inmates in CMUs are receiving the procedural protections and conditions 

of confinement to which they are entitled, as stated in BOP policy and 

institution supplements.

However, 

PRD does not have requirements to monitor CMU-specific policies found 

in the institution supplement guidelines. According to BOP officials, 

additional monitoring for CMUs is not required because they do not have 

the same kinds of restrictive conditions of confinement that are the 

subject of SHU- and SMU-specific monitoring steps.

 

8

According to BOP officials, BOP considers CMUs as general population housing, and 

thus does not require separate oversight like SHUs or SMUs. 
Appendix III: Location and Length of Stay in 

BOP Segregated Housing Units

Page 59 GAO-13-429 Segregated Housing Units

BOP has segregated housing units in prisons located throughout the 

country. For example, BOP has SHUs in 109 out of its 119 facilities. 

Three facilities have SMUs. See figure 14 for a map of the locations of 

each type of segregated housing unit.

Figure 14: Locations of Segregated Housing Units within BOP Facilities

According to BOP, the length of stay inmates serve in segregated 

housing units varies, and BOP does not track an inmate’s total length of 

stay or establish a maximum length of stay for inmates in any type of 

segregated housing unit. An inmate’s length of stay in segregated 

housing varies depending on the inmate’s program needs and status, 

Appendix III: Location and Length of Stay in 

BOP Segregated Housing Units 

Location of Segregated 

Housing Units

Length of Stay
Appendix III: Location and Length of Stay in 

BOP Segregated Housing Units

Page 60 GAO-13-429 Segregated Housing Units

reason for placement, and behavior while in the unit. BOP policy provides 

the expected length of stay for some segregated housing units. For 

example, according to BOP officials, placement of inmates in SHUs is 

intended to be temporary. Inmates may be sanctioned to 1 to 18 months 

in a SHU for disciplinary reasons, given the severity of infraction. Also, 

BOP policy states inmates placed in SMUs, the ADX Step Down Units, 

and ADX Special Security Unit may participate in structured, phased 

programs where they can progress or “step down” to general population 

after approximately 18 to 36 months if they maintain good behavior. 

However, according to BOP officials, an inmate may remain in any of the 

segregated housing units if the inmate continues to be disruptive or BOP 

officials determine through the review process that the inmate’s original 

reason for placement still exists.
Appendix IV: Comments from the Bureau of 

Prisons

Page 61 GAO-13-429 Segregated Housing Units

Appendix IV: Comments from the Bureau of 

Prisons 
Appendix IV: Comments from the Bureau of 

Prisons

Page 62 GAO-13-429 Segregated Housing Units
Appendix IV: Comments from the Bureau of 

Prisons

Page 63 GAO-13-429 Segregated Housing Units
Appendix IV: Comments from the Bureau of 

Prisons

Page 64 GAO-13-429 Segregated Housing Units
Appendix IV: Comments from the Bureau of 

Prisons

Page 65 GAO-13-429 Segregated Housing Units
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 66 GAO-13-429 Segregated Housing Units

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

In addition to the contact named above, Ned George, Assistant Director; 

Pedro Almoguera; Lori Achman; Carla Brown; Jennifer Bryant; Frances 

Cook; Michele Fejfar; Eric Hauswirth; Lara Miklozek; Linda Miller; Jessica 

Orr, Meghan Squires; Helene Toiv; and Yee Wong made key 

contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(441036)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.