Evaluation and Inspections Division 18-05 September 2018

Office of the Inspector General

U.S. Department of Justice

OVERSIGHT INTEGRITY GUIDANCE

Review of the Federal Bureau of 

Prisons’ Management of Its Female 

Inmate Population
i 

Executive Summary

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

Population

Introduction

As of September 2016, the Federal Bureau of Prisons 

(BOP) incarcerated 10,567 sentenced female inmates, 

representing 7 percent of the total BOP sentenced 

inmate population of 146,084. Though female inmates 

compose a small percentage of the nationwide 

incarcerated population, correctional officials have 

recognized that in some areas female and male inmates 

have different needs and BOP has adopted genderresponsive programs and policies that account for these 

needs. As a continuation of prior U.S. Department of 

Justice Office of the Inspector General (OIG) reviews 

examining BOP’s management of certain subpopulations 

of inmates, including aging inmates and inmates with 

mental illness in restrictive housing, OIG initiated this 

review of BOP’s management of female inmates, 

specifically BOP’s efforts and capacity to ensure that 

BOP-wide policies, programs, and decisions adequately 

address the distinctive needs of women. Our decision 

to initiate this review was also informed by members of 

Congress and public interest groups recently raising 

concerns about what they consider to be deficiencies in 

BOP’s current management of female inmates. 

Results in Brief

We concluded that BOP has not been strategic in its 

management of female inmates. We determined that 

BOP needs to take additional steps at the Central Office 

level to ensure that female inmate needs are met at the 

institution level. Our review identified instances in 

which BOP’s programming and policy has not fully 

considered the needs of female inmates, which has 

made it difficult for inmates to access certain key 

programs and supplies. Further, while BOP is adhering 

to federal regulations and BOP policies requiring that 

only female Correctional Officers conduct strip searches 

of female inmates, BOP’s method for ensuring 

compliance with these requirements assigns staff 

inefficiently. Finally, we found that BOP’s conversion of 

Federal Correctional Institution (FCI) Danbury to house 

male inmates negatively affected certain female 

inmates who had been housed there. 

BOP’s Approach to Managing Female Inmates Has Not 

Been Strategic, Resulting in Weaknesses in Its Ability to 

Meet Their Specific Needs 

We found that during the period of our review BOP 

could not ensure that its institutions adhered to policies 

pertaining to female inmates because BOP had only 

recently taken steps to formalize a process for verifying 

compliance. As of April 2018, BOP was drafting 

planning documents that it believes will enhance its 

ability to perform internal oversight of these policies 

and better ensure compliance with female inmatefocused policies and protocols. 

Further, while BOP established a Central Office branch 

that serves as BOP’s source of expertise on the 

management of female inmates in BOP custody, this 

branch may not have adequate staffing to fully fulfill its 

mission. Female inmates are just one of six special 

populations about which the Women and Special 

Populations Branch is responsible for providing national 

direction and subject matter expertise and for ensuring 

that the needs of each of these populations are met at 

BOP institutions. For example, this branch designs and 

delivers training to institution staff and ensures that 

programming run by other BOP divisions is responsive 

to the needs of each subpopulation. Given the branch’s 

wide range of responsibilities, its four staff members 

may not be sufficient to accomplish its mission and to 

ensure that BOP adequately addresses the distinctive 

needs of women in its custody. 

Additionally, BOP requires all staff in its female institutions 

to take training on the management of female inmates, as 

well as training in trauma-informed correctional care for the 

management of inmates who have experienced trauma. 

However, BOP does not require the same training for its 

Executive Staff and, as a result, National Executive Staff 

officials may develop policy and make decisions that affect 

female inmates without awareness of their needs. 

BOP’s Programming and Policy May Not Fully Consider 

the Needs of Female Inmates 

We identified three areas in which BOP’s programming 

and policy decisions did not fully consider the needs of 

female inmates: trauma treatment programming, 

pregnancy programming, and feminine hygiene. 

BOP relies on research that shows that physical and 

emotional trauma affects as many as 90 percent of the 

female inmate population. Research also recommends 

that female inmates undergo trauma treatment early 

during incarceration to enhance their ability to benefit 

from all institutional programming. However, we found 

that BOP may not be able to provide its trauma 

treatment program to all eligible female inmates until 

late in their incarceration, or ever, because it has 

assigned only one staff member at each institution to 

offer this program. The lack of sufficient staff is most 

noticeable at larger female institutions, where inmates 

face delays in completing each of the program’s two 

prerequisites, as well as the program’s treatment 

phases. 

In addition to female inmates being unable to use BOP 

trauma treatment programs, we estimate that only 

37 percent of sentenced pregnant inmates participated 
ii

Executive Summary

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

Population

in BOP’s pregnancy programs between fiscal year (FY) 

2012 and FY 2016. Further, we confirmed that these 

programs had additional capacity to include more 

pregnant inmates during this period. We believe that 

participation is low because BOP inmates and staff lack 

awareness of these programs. We also determined that 

BOP staff may apply eligibility criteria more restrictively 

than intended by BOP headquarters officials and that 

BOP lacks data to assess inmate interest and 

participation in its pregnancy programs. 

In visits to several BOP institutions housing female 

inmates, we found that the distribution methods for 

feminine hygiene products provided to inmates varied 

by institution and did not always ensure that inmates 

had access to a sufficient quantity of products to meet 

their needs. BOP issued new guidance in August 2017 

to standardize the range of products available free of 

charge. However, BOP still lacks a method to ensure 

sufficient access because the guidance did not address 

how products should be distributed to inmates. 

BOP’s Lack of Gender-specific Posts Results in 

Inefficiencies at Female Institutions 

We found that BOP’s practice of assigning Correctional 

Officers to posts solely by seniority has resulted in male 

Correctional Officers being assigned to posts at which 

staff must regularly conduct searches of female 

inmates. Because the Prison Rape Elimination Act of 

2003 and BOP policy prohibit cross-gender searches of 

female inmates, female Correctional Officers must leave 

other assigned posts to conduct these searches, leading 

to an inefficient use of Correctional Officer resources. 

Both female and male institution staff suggested that a 

small number of posts in female institutions, particularly 

some of the posts in the Special Housing Unit (SHU)—a 

unit used to separate inmates from the general 

population for protective or disciplinary purposes—and 

the visiting room, be reserved for female staff to ensure 

that they can conduct inmate searches without 

disrupting other operations. We agree that BOP should 

implement this or another approach to ensure the 

availability of female staff at locations in female 

institutions where inmate searches are common. 

BOP’s Decision to Convert Federal Correctional 

Institution Danbury to a Male Institution Negatively 

Affected Female Inmates Transferred to Metropolitan 

Detention Center Brooklyn 

As a case study, we also examined BOP’s 2013 decision 

to convert FCI Danbury from a female institution to a 

male institution as part of a larger plan to increase bed 

space for low security female and male inmates 

throughout BOP institutions. Although concerns were 

raised that the conversion would cause female inmates 

to be incarcerated farther from home, we found that, 

while 19 percent of U.S. citizen inmates were 

transferred farther from their homes, the overwhelming 

majority were transferred closer to their homes. 

The conversion resulted in 366 low security sentenced 

female inmates serving a portion of their sentences in 

Metropolitan Detention Center (MDC) Brooklyn, a 

detention center intended for short-term confinement. 

The National Association of Women Judges found that 

the conditions of confinement at MDC Brooklyn 

amounted to a violation of the American Bar Association 

Standards on Treatment of Prisoners, as well as the 

United Nations Standard Minimum Rules for the 

Treatment of Prisoners. When we visited MDC 

Brooklyn, we found that BOP offered female inmates no

access to outdoor space, less natural light, and fewer 

programming opportunities than what would otherwise 

be available to female inmates at BOP facilities designed 

to house sentenced inmates in long-term confinement. 

In addition, a separate OIG criminal investigation 

determined that, during the time that sentenced female 

inmates were assigned to MDC Brooklyn, multiple 

custody staff sexually assaulted female inmates, 

resulting in the convictions of two Lieutenants and a 

Correctional Officer. 

In December 2016, after reversing its decision not to 

house female inmates at FCI Danbury, BOP opened a 

new low security institution for female inmates at 

FCI Danbury. However, because FCI Danbury was 

constructed without a SHU, we found that managing 

female inmates who needed to be placed in a SHU 

disrupted institution operations because BOP had to 

transfer these inmates to Federal Detention Center 

Philadelphia for SHU placement. 

Recommendations

In this report, we make 10 recommendations to 

improve BOP’s management of its female inmate 

population. These recommendations include training 

executive leaders on issues important to managing 

female inmates, enhancing the capacity of BOP’s 

trauma treatment program, communicating information 

about pregnancy programs, and clarifying guidance on 

the distribution of feminine hygiene products. 
iii 

TABLE OF CONTENTS 

INTRODUCTION ............................................................................................ 1

Background ........................................................................................ 1

RESULTS OF THE REVIEW ............................................................................ 11

BOP’s Approach to Managing Female Inmates Has Not Been Strategic, 

Resulting in Weaknesses in Its Ability to Meet Their Specific Needs ........... 11

BOP’s Programming and Policy May Not Fully Consider the Needs of 

Female Inmates ................................................................................ 18

BOP’s Lack of Gender-specific Posts Results in Inefficiencies at Female 

Institutions ....................................................................................... 32

BOP’s Decision to Convert Federal Correctional Institution Danbury to a 

Male Institution Negatively Affected Female Inmates Transferred to 

Metropolitan Detention Center Brooklyn ................................................ 35

CONCLUSION AND RECOMMENDATIONS ........................................................ 43

Conclusion ........................................................................................ 43

Recommendations ............................................................................. 43

APPENDIX 1: METHODOLOGY OF THE OIG REVIEW ........................................ 45

Standards ......................................................................................... 45

Purpose and Scope ............................................................................ 45

Methodology ..................................................................................... 45

APPENDIX 2: MAP OF BOP INSTITUTIONS FOR SENTENCED FEMALE INMATES ... 48

APPENDIX 3: BOP’S RESPONSE TO THE DRAFT REPORT .................................. 49

APPENDIX 4: OIG ANALYSIS OF BOP’S RESPONSE.......................................... 52
1 

INTRODUCTION 

Background 

According to the U.S. Department of Justice’s (Department, DOJ) Bureau of 

Justice Statistics, state and federal prisons had jurisdiction over more than 

1.5 million inmates at the end of 2015. Of these inmates, approximately 111,500, 

or 7 percent, were female.1 The percentage of female inmates in the Federal 

Bureau of Prisons’ (BOP) custody as of September 2016 was also 7 percent 

(10,567) of BOP’s total population of 146,084 sentenced inmates.2

 While female 

inmates compose a small percentage of the nationwide inmate population, BOP 

recognized that in some areas female and male inmates have different needs. 

Accordingly, BOP developed gender-responsive programs and policies to account for 

female inmates’ distinctive needs. 

As a continuation of several prior Office of the Inspector General (OIG) 

reviews examining BOP’s management of certain subpopulations of inmates, 

including aging inmates and inmates with mental illness in restrictive housing, OIG 

initiated this review of BOP’s management of female inmates.3 Our decision to 

initiate this review was also informed by members of Congress and public interest 

groups recently raising concerns about what they considered to be deficiencies in 

BOP’s current management of female inmates.4

In this report, we assess BOP’s efforts and capacity to ensure that BOP-wide 

policies, programs, and decisions address the unique needs of female inmates. 

Specifically, we assess female inmates’ access to BOP’s trauma treatment and 

pregnancy programs, which are significant for female inmates and their families 

and can play important roles in successful reentry into society. Additionally, we 

discuss BOP’s gender-responsive policies and evaluate how they affect the 

1

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

2

 For this review, we examined sentenced inmates incarcerated in BOP-managed institutions 

only. We excluded approximately 22,000 male inmates who were incarcerated in contract institutions, 

approximately 12,000 female and male inmates who were in halfway houses, and approximately 

12,000 female and male pretrial detainees in the custody of the U.S. Marshals Service. BOP does not 

incarcerate female inmates in contract institutions. 

3

 DOJ OIG, The Impact of an Aging Inmate Population on the Federal Bureau of Prisons,

Evaluation and Inspections Report 15-05 (May 2015), and DOJ OIG, Review of the Federal Bureau of 

Prisons’ Use of Restrictive Housing for Inmates with Mental Illness, Evaluation and Inspections 

Report 17-05 (July 2017). 

4

 In July 2017, four U.S. Senators introduced legislation designed to increase familial 

visitation and female inmates’ access to feminine hygiene products. See Dignity for Incarcerated 

Women Act of 2017, 115th Congress, 1st sess., S. 1524. The Arthur Liman Public Interest Program at 

Yale Law School also wrote about the management of female inmates affected by BOP’s decision to 

convert Federal Correctional Institution (FCI) Danbury from a female to male institution in Dislocation 

and Relocation: Women in the Federal Prison System and Repurposing FCI Danbury for Men 

(September 2014). This issue was also discussed in “Female Inmates from Danbury Still in Limbo, 

Lacking Key Services,” Slate Magazine, September 3, 2014, and “Female Inmate Transfers to 

Resume; Senators Say Relocation Disrupts Women’s Lives, Vow to Fight Bureau of Prisons’ Decisions; 

Danbury Federal Correctional Institution,” Hartford Courant, October 5, 2013. 
2 

conditions of confinement for female inmates. We pay particular attention to 

policies relevant to inmate access to feminine hygiene products and physical 

searches of female inmates. Lastly, we examine as a case study how BOP’s 

decision to convert its low security institution in Danbury, Connecticut, from a 

female institution to a male institution affected female inmates. 

Characteristics of BOP’s Female Inmate Population 

As shown in Table 1, the overall population of sentenced female inmates 

decreased between fiscal years (FY) 2012 and 2016. The ratio of female inmates to 

male inmates has remained constant during this period and is approximately equal 

to the nationwide ratio, as mentioned previously. 

Table 1 

Female and Male Sentenced Inmate Population 

FYs 2012–2016 

Fiscal Year

2012 2013 2014 2015 2016

Female 

Inmates

Number of 

Inmates 11,737 12,154 11,868 11,214 10,567

Percentage of 

BOP Population 7% 7% 7% 7% 7%

Male 

Inmates

Number of 

Inmates 152,803 152,676 149,663 143,655 135,517

Percentage of 

BOP Population 93% 93% 93% 93% 93%

Total BOP Population 164,540 164,830 161,531 154,869 146,084

Source: BOP SENTRY

BOP data shows that between FYs 2012 and 2016 the majority of both female 

and male inmates were incarcerated for drug offenses; but male inmates were much 

more likely to have been convicted of weapons, sex, or other violent crime offenses 

than were female inmates. Further, research shows that female inmates 

incarcerated for drug crimes were often accessories to the broader criminal activity of 

a male partner, rather than being the instigator of a crime.5

 Female inmates also 

tend to have shorter sentences than male inmates. For example, as of September 

5

 Darrell Steffensmeier and Emilie Allan, “GENDER AND CRIME: Toward a Gendered Theory 

of Female Offending,” Annual Review of Sociology 22 (1996): 459–487. BOP cited this particular 

point as part of its own research, which found that gender is a powerful predictor of risk for serious 

violence and other serious misconduct while incarcerated. Miles D. Harer and Neal P. Langan, “Gender 

Differences in Predictors of Violence: Assessing the Predictive Validity of a Risk Classification System,” 

Crime and Delinquency 47 (2001): 513–536. Because of this internal BOP research, BOP determines 

security levels for female and male inmates separately and, as a result, classifies nearly all female 

inmates as minimum or low security. 
3 

2016, the median total sentence length for female inmates in BOP custody was 

5 years, whereas the median total sentence length for male inmates was 10 years. 

BOP has four security classification levels for inmates: high, medium, low, 

and minimum. Nearly all sentenced female inmates are classified as low or 

minimum security. BOP does not classify female inmates as medium security but 

does classify a small number as high security.6 BOP institutions are also assigned 

security levels, and BOP generally assigns inmates to institutions that correspond 

with their security level.7 

Twenty-nine BOP locations throughout the United States house one or more 

female institutions.8 BOP manages female inmates in 20 institutions designed for 

the long-term incarceration of sentenced inmates.9 We describe these below: 

 Minimum security institutions, also known as Federal Prison Camps (FPC), 

have dormitory-style housing and limited or no perimeter fencing. As of 

December 2017, BOP managed 13 of these institutions for female inmates. 

 Low security institutions, also known as Federal Correctional Institutions 

(FCI) or Federal Satellite Lows, have perimeter fencing and either dormitorystyle or cell-style housing. As of December 2017, BOP managed six of these 

institutions for female inmates. 

 Federal Medical Centers (FMC) are used to treat sentenced inmates of all security 

levels who have serious or chronic medical problems. As of December 2017, 

BOP managed one medical center, FMC Carswell, for female inmates. This 

institution also housed the small number of BOP’s high security female inmates. 

In addition to these 20 institutions, BOP houses female inmates in 12 detention 

centers, which generally are designed for the short-term incarceration of pretrial 

 

6

 Two officials in BOP’s Designation and Sentence Computation Center, the BOP office 

responsible for determining where inmates should be housed, told us that nearly all female inmates 

can be managed in minimum security or low security settings because they are less prone to 

behaviors such as violence and escape attempts. The small number of female inmates who cannot be 

managed in these settings are designated as high security and housed in BOP’s sole high security 

female unit at FMC Carswell. 

7

 Throughout this report, we will use the term “female institutions” to refer to all of BOP’s 

institutions designed to house sentenced female inmates, regardless of security level. 

8

 During our fieldwork, BOP housed female inmates in 28 locations throughout the United 

States. BOP added a 29th location in late 2017 by converting a minimum security institution in Pekin, 

Illinois, which had formerly housed male inmates, into a female institution. Because Pekin did not 

house female inmates during the time we conducted the analyses used in our report, these analyses 

do not include data or information from Pekin. 

9

 Eight of these female institutions are a part of larger facilities that also contain at least one 

other female institution. Such facilities include a low security institution and a minimum security 

institution in Aliceville, Alabama; a low security institution and a minimum security institution in 

Dublin, California; a low security institution and a minimum security institution in Danbury, 

Connecticut; and a minimum security institution and a female inmate medical facility in Fort Worth, 

Texas. As a result, BOP’s 20 female institutions are in 16 locations throughout the country. 
4 

detainees, as well as a transfer center that houses inmates in transit to other BOP 

facilities. Unlike institutions designed for long-term incarceration, detention centers 

and the transfer center house both female and male inmates. 

Figure 1 shows the number of sentenced female inmates assigned to each of 

the three types of institutions described above. A map showing the locations of BOP’s 

female institutions designed for long-term incarceration can be found in Appendix 2. 

Figure 1 

Number of Sentenced Female Inmates, by Institution Type 

September 2016 

Source: BOP SENTRY 

BOP Policy on the Management of Female Inmates 

In August 1997, BOP developed a formal policy, known as a program 

statement, on the Management of Female Offenders. While this program statement 

recognized that BOP programs and services should meet the different physical, 

social, and psychological needs of female offenders, the Women and Special 

Populations Branch Administrator told us that this policy was not substantive and was 

difficult to enforce. In an effort to strengthen existing policy, BOP issued a new 

Minimum Security,

4,363 Female Inmates

(41%)

Low Security,

4,584 Female Inmates 

(44%)

Medical Center,

1,082 Female 

Inmates (10%)

Detention Centers and 

Transfer Center,

538 Female Inmates

(5%)
5 

Female Offender Manual in November 2016.10 The new manual expanded on the 

prior policy by incorporating gender-responsive language on how BOP should classify 

and designate female inmates; discipline female inmates; provide gender-responsive 

programming; and address birth control, pregnancy, child placement, and abortion. 

The Female Offender Manual also identifies the Women and Special 

Populations Branch, within BOP’s Reentry Services Division, as BOP’s source of 

expertise on classification, management, and intervention programs and practices 

for females in BOP custody.11 Further, the Female Offender Manual delegates a 

wide range of responsibilities to the Women and Special Populations Branch. For 

female inmates specifically, these responsibilities include advising BOP management 

and institution staff on issues affecting female inmates, developing staff training on 

these issues, and ensuring that programs managed by other BOP branches are 

gender responsive.12

 As of November 2017, the Women and Special Populations 

Branch comprised one Branch Administrator and three staff members.13 

Gender-responsive Approaches to Corrections 

The BOP defines gender-responsive approaches to corrections as those that 

are based on an understanding of the ways female inmates are different from male 

inmates and that specifically aim to address those differences. In particular, BOP 

has established gender-specific policies pertaining to access to female and 

reproductive health services, to the provision of feminine hygiene products, and to 

the implementation of regulatory requirements that ensure female inmates are 

physically searched only by female BOP employees.14 

 

10

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

11

 BOP’s Reentry Services Division aims to prepare inmates for reentry by focusing on 

programming and community transition. The Reentry Services Division is composed of six branches: 

(1) National Reentry Affairs, (2) Education Services, (3) Chaplaincy Services, (4) Residential Reentry 

Management, (5) Women and Special Populations, and (6) Psychology Services. 

12

 BOP also delegates to the Women and Special Populations Branch the responsibility of 

ensuring that BOP policy and practices are inclusive of the needs of other special populations. BOP 

identifies special populations to include female inmates, juvenile inmates, transgender inmates, 

inmates with disabilities, inmates who are parents, and inmates who are veterans. The Women and 

Special Populations Branch Administrator told us that she considers “special populations” to be any 

group of inmates that is not part of the male majority. 

13

 In response to a working draft of this report, BOP stated that all four staff in the Women and 

Special Populations Branch, including the Branch Administrator, focus on program or training work. 

14

 Federal regulations and BOP policies mandate that strip searches be conducted by a staff 

member who is the same gender as the inmate being searched. See 28 C.F.R. § 552.11(c) and BOP 

Program Statement 5521.06, Searches of Housing Units, Inmates, and Inmate Work Areas, June 4, 

2015, 4. See also 28 C.F.R. § 115.15(a). Additionally, federal regulations and BOP policies mandate 

that only female staff can pat search female inmates. See 28 C.F.R. § 115.15(b); BOP Program 

Statement 5521.06, 3; and BOP Program Statement 5324.12, Sexually Abusive Behavior Prevention 

and Intervention Program, June 4, 2015, 17.
6 

Trauma-informed Correctional Care 

An important but less obvious difference between female and male inmates 

has to do with past traumatic experiences. While many studies support the 

conclusion that female inmates experience very high rates of trauma before 

incarceration, BOP used one particular study as a basis for emphasizing the need to 

account for past trauma in its management of female inmates. This study found that 

as many as 90 percent of women in prison have experienced trauma and that the 

most common type of traumatic experience for female inmates is repeated sexual 

violence, followed by intimate partner violence.15

 Male inmates are less likely to 

have been a direct victim of violence, but they more commonly have experienced or 

witnessed a singular traumatic event such as a shooting.16 

Research also shows that the effects of trauma manifest themselves 

differently for female and male inmates. For example, female inmates who 

experience trauma can develop chronic depression, eating disorders, or difficulty 

managing emotions, while trauma in male inmates is more likely to manifest itself 

externally, resulting in emotional outbursts or violence.17

 Although female inmates 

are more likely to internalize their trauma, a Resolve Coordinator we interviewed 

told us that female inmates are generally more willing to discuss their trauma than 

are male inmates. 

To address the effects of past trauma on inmates, BOP implemented a 

“trauma-informed correctional care approach.” The BOP Psychology Services 

Branch describes trauma-informed care as a comprehensive approach to 

corrections in which all policies recognize, and actions of staff reflect, the concept 

that trauma is a “real and prevalent occurrence, and that any opportunity to avoid 

re-traumatizing an inmate is an opportunity for healing.” The Psychology Services 

Branch stated that there is not a strict method for applying trauma-informed 

correctional care approaches, but it identifies important principles for traumainformed staff to consider. These principles include: 

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

 ensuring that, when practicable, staff interventions highlight strengths that 

can be used as a foundation for improvement, as opposed to focusing only on 

problems; 

 ensuring that information and training about trauma are available to inmates 

and staff; and 

 

15

 Niki A. Miller and Lisa M. Najavits, “Creating Trauma Informed Correctional Care: A 

Balance of Goals and Environment,” European Journal of Psychotraumatology (2012): 2. BOP asserts 

that the 90 percent statistic is likely a low estimate because traumatic experiences are often 

underreported by victims. 

16

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

17

 Miller and Najavits, “Creating Trauma Informed Correctional Care,” 3.
7 

 using communication methods that deescalate conflict and avoid triggering

memories of past traumatic experience. (See the text box.) 

Gender-responsive Programs 

Below, we highlight three genderresponsive programs because of their 

importance to female inmates and their 

families. These programs are 

administered by branches within the 

Reentry Services Division.

Resolve Program 

The Resolve program, managed by 

BOP’s Psychology Services Branch and 

offered at 14 of BOP’s 15 female 

institutions, is a national treatment 

program for female inmates with a history 

of trauma-related mental illnesses.18 

According to the Psychology Services 

Branch, the objective of the Resolve 

program is to promote positive behavioral changes that decrease the incidence of 

trauma-related psychological disorders and improve inmates’ level of functioning.19 

Psychology Services staff emphasized the importance of this program because of 

the high number of female inmates with a history of trauma or victimization prior to 

incarceration. All inmates undergo an intake interview with a Psychologist at the 

beginning of their BOP incarceration.20

 If a female inmate describes a history of 

trauma during this intake interview, the Psychologist will recommend that she sign 

up for the Resolve program’s introductory workshop. Participation in the Resolve 

program is voluntary. 

All elements of the Resolve program, outlined in Table 2 below, are managed 

by a Resolve Coordinator, who is a Psychologist. One Resolve Coordinator is 

assigned to each of the 14 female institutions that offer the program.21

 According 

to BOP’s program statement on Psychology Treatment Programs, inmates with a 

history of trauma or victimization initiate the Resolve program by taking the 

 

18

 FCI Phoenix did not offer the Resolve program during the scope of our review because it 

had not been allocated a Resolve Coordinator position. Resolve is not offered at the 12 detention 

centers or the Federal Transfer Center because those institutions are exempt from most BOP 

programming requirements. As of September 2016, only 5 percent of the sentenced female inmate 

population was in a detention center or the Federal Transfer Center. 

19

 BOP employs psychology, psychiatry, and mental health staff to offer services, beyond the 

scope of the Resolve program, to inmates who require mental health treatment. 

20

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

21

 BOP operates multiple female institutions at 4 of the 14 locations where it offers the 

Resolve program to female inmates. BOP also offers the Resolve program, with a modified malespecific curriculum, to male inmates at two institutions. 

Potential Effects of Past Trauma on

Female Inmates 

Awareness of how female inmates 

are affected by trauma is important in all 

aspects of BOP operations. For example, 

an inmate having her teeth cleaned is 

lying on her back, with someone leaning 

over her and something in her mouth 

that she cannot remove. These 

sensations can trigger flashbacks for 

victims of sexual abuse. It is therefore 

important for all BOP staff who work with 

female inmates to be aware of the 

potential for such reactions and how to 

respond to them. 

Source: Interview with DOJ Civil Rights 

Division official 
8 

introductory workshop during the first 12 months of incarceration. BOP policy 

states that the Resolve program takes approximately 40 weeks to complete, but it 

also notes that scheduling conflicts may extend the length of the program. 

Table 2 

Structure of the Resolve Program for Female Inmates 

Segment of Program Name Description

Prerequisites

Introductory 

Workshop Trauma in Life

Educational workshop that provides female 

inmates with psychological information on 

trauma and its potential impact in their lives 

Screening Psychological Testing Psychological eligibility assessment to

diagnose the related traumaa

Active Treatmentb

Phase I Seeking Safety

Therapy group that emphasizes the 

acquisition of basic skills, with a focus on 

coping and interpersonal skills

Phase II

Cognitive Processing 

Therapy

Therapy group for inmates with a diagnosis

of post-traumatic stress disorder, major 

depression, or substance abuse

Dialectical Behavioral 

Therapy

Therapy group for treatment of inmates 

with borderline personality disorder

Post Treatment

Maintenance Maintenance Group

Skills group for maintaining treatment gains 

for inmates whose symptoms, if present, no 

longer interfere with daily functioning

a

 In response to a working draft of this report, BOP stated that it completes psychological 

eligibility assessments to provide diagnostic clarity and accuracy prior to a formal diagnosis. 

b

 In response to a working draft of this report, BOP stated that the group sessions used during 

the Active Treatment phases of the Resolve program are psychotherapy groups.

Note: The Psychologist who performs the screening determines which version of the Phase II 

therapy is most appropriate for each inmate, depending on her specific diagnosis. 

Source: BOP 

Female Integrated Treatment Program 

In the fall of 2017, the Psychology Services Branch, in coordination with the 

Women and Special Populations Branch, piloted the Female Integrated Treatment 

(FIT) program at BOP’s low security female institution in Danbury, Connecticut.22

 

According to BOP, the FIT program offers evidence-based treatment for trauma, 

substance abuse, and mental health in a comprehensive, holistic program. The 

program begins with a 4-month educational curriculum that includes a Trauma in 

Life workshop as well as basic drug and mental health education. After completing 

 

22

 The FIT program is available only for inmates in Danbury’s low security female institution. 

Inmates in Danbury’s minimum security female institution take the Resolve program instead. 
9 

the introductory portion of the program, each inmate participates in a treatment 

curriculum tailored to her individual trauma, substance abuse, or mental health 

needs. Inmates in FIT requiring trauma treatment take the Resolve curriculum 

described in Table 2 above. All female inmates designated to the low security 

female institution in Danbury participate in the FIT program.23 

Mothers and Infants Nurturing Together Program 

The Mothers and Infants Nurturing Together (MINT) program, managed by 

BOP’s Residential Reentry Management Branch, is a community-based residential 

program in which pregnant inmates prepare for delivery and bond with their infant 

after giving birth.24 According to BOP’s Female Offender Manual, pregnant inmates in 

BOP custody are eligible to serve a portion of their sentence at a MINT program site if 

they are pregnant upon incarceration with an expected delivery date prior to release, 

have less than 5 years remaining on their sentence, are eligible for halfway house 

placement, and assume financial responsibility for their child’s care.25 Female inmates 

are generally eligible to transfer to a MINT program site during the last 2 months of 

pregnancy. After birth, the Female Offender Manual requires BOP to allow 

participating inmates at least 3 additional months to bond with their infant, although 

the manual recommends 6 months. Once an inmate completes the MINT program, 

BOP returns the inmate to a BOP institution for the remainder of her sentence. 

Residential Parenting Program 

According to the Female Offender Manual, BOP’s female inmates, no matter 

their location, may also participate in the Washington State Department of 

Corrections’ Residential Parenting Program. In contrast to the MINT program, 

Residential Parenting Program participants and their infants reside in the minimum 

security unit of the Washington Corrections Center for Women in Gig Harbor, 

Washington, for up to 30 months after birth.26 Female inmates who participate in 

 

23

 In response to a working draft of this report, the Administrator of the Women and Special 

Populations Branch elaborated on the terminology of this model, stating that “the entire facility 

operates as a ‘modified therapeutic community.’”

24

 During the scope of this review (FYs 2012–2016), MINT program sites were located in San 

Francisco, California; Tallahassee, Florida; Phoenix, Arizona; Fort Worth, Texas; Springfield, Illinois; 

Hartford, Connecticut; and Hillsboro, West Virginia. As of December 2017, the sites in San Francisco 

and Hartford no longer accepted MINT inmates because they were unable to comply with some of the 

contract requirements for hosting the MINT program. 

25

 The Female Offender Manual further states that inmates with more than 5 years remaining 

on their sentences, or who become pregnant while on furlough, or who plan to place their infants up 

for adoption are not eligible for the MINT program. 

BOP provides prenatal care and covers the financial costs associated with delivery for all 

pregnant inmates, regardless of whether they participate in this program. 

26

 The eligibility requirements for the Residential Parenting Program are established by the 

Washington State Department of Corrections and are stricter than those for BOP’s MINT program. For 

example, only minimum security inmates are eligible to participate in the Residential Parenting 

Program, whereas both minimum and low security inmates are eligible to participate in the MINT 

program. We discuss the eligibility requirements for the Residential Parenting Program in greater 

detail in a text box later in this report. 
10

this program receive credit toward their federal sentence for any time served at the 

Gig Harbor facility. BOP Social Workers are responsible for providing pregnant 

inmates with information about the two pregnancy programs. 

Scope of the OIG Review 

BOP has implemented gender-responsive policies and programs that affect 

the conditions of confinement for female inmates. OIG initiated this review to 

examine BOP’s management of its female inmate population between FYs 2012 and 

2016. We focused our analysis on how the Women and Special Populations Branch 

and other relevant BOP branches implement gender-responsive trauma-treatment 

and pregnancy programs. Additionally, we examined how BOP has implemented 

policies relevant to inmate access to feminine hygiene products and physical 

searches of female inmates. We also examined how BOP’s decision to convert its 

low security institution in Danbury, Connecticut, from a female institution to a male 

institution affected female inmates transferred from Danbury. We held in-person, 

telephone, and video teleconference interviews with BOP officials responsible for or 

involved in the management of federal female inmates, as well as with state 

correctional officials to learn how non-federal correctional agencies manage their 

female inmates. 
11

RESULTS OF THE REVIEW 

BOP’s Approach to Managing Female Inmates Has Not Been Strategic, 

Resulting in Weaknesses in Its Ability to Meet Their Specific Needs 

We found that over time BOP has made efforts to improve its management of 

female inmates. However, we identified several additional steps BOP should take to 

ensure female inmate needs are addressed appropriately. First, BOP has only 

recently taken steps to formalize a process for verifying staff compliance with 

policies related to the management of female inmates. Second, we found that 

while BOP established a Central Office branch with responsibilities that include 

providing national direction and subject matter expertise on the treatment, 

management, and programming of female inmates, the branch may not have 

adequate staffing to fulfill its mission. Finally, while BOP requires all personnel 

working in female institutions to take training on current best practices in the 

management of female inmates, it does not require its National Executive Staff to 

take any training related to female inmates. As a result, National Executive Staff 

may develop policy or make decisions without awareness of female inmates’ needs. 

As we will discuss later in this report, we also identified similar limitations in certain 

BOP programs and policies of significance to female inmates. For BOP to be fully 

effective at appropriately managing female inmates, we believe that it must take a 

holistic approach at the Central Office level to identify and address issues affecting 

this population. 

BOP Has Not Fully Implemented Internal Controls to Ensure Institutions Follow 

Policies Related to the Management of Female Inmates 

The Female Offender Manual is BOP’s primary policy on the management of 

female inmates. The Assistant Director of the Reentry Services Division told us that 

it is important for institutions housing female inmates to be in compliance with the 

Female Offender Manual.27 While BOP has recently taken its first initial steps to 

verify compliance with the manual, it has not yet fully implemented these efforts. 

Specifically, BOP is still in the interim stage of establishing a program review to 

evaluate the implementation of its Female Offender Manual.28

 

In 1997, BOP created its first policy on the management of female inmates.29

 

This four-page policy only briefly described BOP’s role in identifying the appropriate 

programs and services to meet the different physical, social, and psychological 

needs of female inmates; but it never explained what those needs were and it 

27

 Subsequent to our interview, the Assistant Director of the Reentry Services Division was 

named the Acting BOP Director. 

28

 BOP develops program reviews to assess an institution’s internal controls, programs, and 

operations in a topic area. Most program reviews summarize the overall findings with a rating of 

Superior, Good, Acceptable, Deficient, or At Risk. 

29

 BOP Program Statement 5200.01, Management of Female Offenders, August 4, 1997. 
12

lacked specific guidance that would help institutions identify and address those 

needs. Further, BOP did not conduct program reviews to verify compliance with 

this policy. 

To address the deficiencies in its initial policy concerning female inmates, 

BOP issued its Female Offender Manual in November 2016.30 This manual is much 

more comprehensive than the 1997 policy in the topics covered, and it offers more 

guidance about how BOP should handle a range of policy and management issues 

pertaining to female inmates. For example, it describes how BOP should classify 

and designate female inmates; discipline female inmates; provide genderresponsive programming; and address birth control, pregnancy, child placement, 

and abortion.31 While the new manual is more comprehensive, we found that BOP 

has not yet finalized a mechanism to ensure that institutions housing female 

inmates comply with it. 

During interviews, three managers in the Reentry Services Division 

emphasized the importance of establishing a program review to ensure institutions 

are managing female inmates consistently with the Female Offender Manual. For 

example, the Senior Deputy Assistant Director of the division described the 

establishment of a program review as critical for ensuring that BOP’s female 

institutions are held accountable for how they manage female inmates. He and the 

Women and Special Populations Branch Administrator described the program review 

as the most important factor in ensuring compliance with the Female Offender 

Manual and said that the absence of a program review has weakened the branch’s 

ability to ensure that institutions are implementing BOP’s primary policy on the 

management of female inmates. 

Program reviews are also important because BOP policy requires reviewed 

institutions to implement corrective action plans, monitored by the BOP Central 

Office, to correct any deficiencies identified during the course of the review. In 

response to a working draft of this report, the Senior Deputy Assistant Director of 

the Program Review Division described these follow-up requirements as critical 

aspects of all program reviews to ensure accountability. 

We found that BOP had not begun to implement any review mechanism to 

evaluate institutions’ compliance with the Female Offender Manual until November 

2017, a year after its release, and, as of June 2018, BOP has not fully implemented 

these efforts.32

 According to a Senior Deputy Assistant Director of BOP’s Program 

 

30

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

31

 BOP Program Statement 5200.02. 

32

 In response to a working draft of this report, BOP stated that it began the process to 

establish this review mechanism in March 2017 by scheduling a management assessment, which 

initiates BOP’s formal process for designing program reviews. BOP further stated that the management 

assessment was scheduled within the timeframe required by policy based on the release date of the 

Female Offender Manual. 
13

Review Division, BOP created an interim program review in November 2017 with 

the intention of establishing a permanent program review in the near future.33 

We reviewed BOP’s interim program review plan and found that BOP 

conducted it entirely remotely, rather than on site at the institutions. We also 

learned that under the interim plan BOP did not intend to issue an institution a 

formal compliance rating at the close of the review. After BOP conducted its first 

remote program review, a Senior Deputy Assistant Director of BOP’s Program 

Review Division told us that BOP intended to change its program review 

methodology to conduct future program reviews on site and provide the institution 

a rating on compliance with the Female Offender Manual. 

We are encouraged that BOP plans to implement a rated, on-site program 

review. Although the Program Review Division’s Assistant Director and Senior 

Deputy Assistant Director told us that on-site reviews may stretch limited 

resources, an on-site program review would allow BOP to assess compliance with 

the Female Offender Manual in part through direct observation, which BOP’s 

Management Control and Program Review Manual describes as “the most 

dependable type of evidence, and...essential in determining the adequacy of internal 

controls.”34

 Additionally, we believe that some of the criteria in BOP’s interim 

program review guidelines and other guidance are particularly suited to direct 

observation.35 For example, the interim program review guidelines for the Female 

Offender Manual require Program Review Division staff to assess whether 

institutions offer gender-responsive programs to inmates and whether institutions 

widely advertise those programs “in visible areas in the institution,” such as bulletin 

boards, electronic message boards, and resource centers to assist in raising inmate 

awareness of the availability of those programs. In addition, BOP’s August 2017 

guidance on the accessibility and availability of feminine hygiene products, which 

we discuss in more detail later in our report, also lends itself to direct observation. 

We believe that a physical visit to the institution being reviewed would allow the 

Program Review Division staff to confirm that institutions are complying with BOP 

 

We focus on November 2017 in this report because that was the date that BOP’s Central Office 

notified the Wardens of the female institutions that a program review to evaluate institutions’ 

compliance with the Female Offender Manual had been designed, and that the reviews would begin. 

33

 The Program Review Division conducted its first program review of the Female Offender 

Manual in December 2017, using the interim program review plan, and provided results to the 

reviewed institution in January 2018. 

34

 BOP Program Statement 1210.23, Management Control and Program Review Manual, 

August 21, 2002, Chapter 2, p. 8. This policy establishes BOP’s standards for conducting program 

reviews. 

35

 Officials in the Program Review Division told us that they could not create program review 

guidelines for all sections of the Female Offender Manual because some portions were too broadly 

written. The Women and Special Populations Branch Administrator said that some sections of the 

Female Offender Manual were written this way as a result of negotiations with the union before the 

policy was implemented. The Assistant Director of the Program Review Division said that a more 

detailed Female Offender Manual would allow for more robust oversight of how female institutions 

implement the policy. 
14

policy on the management of female inmates and to better identify any deficiencies 

that should be monitored through a corrective action plan. 

BOP’s Management Control and Program Review Manual generally requires 

that program reviews provide a rating that summarizes the review’s findings and 

reflects the reviewer’s overall judgment as to how well the institution accomplishes 

the program area’s mission and objectives. Currently, all program reviews are 

rated except for the Prison Rape Elimination Act of 2003 (PREA) program review.36 

The Senior Deputy Assistant Director for the Reentry Services Division said that it is 

important for the Female Offender Manual program review to be rated to ensure 

that the female institutions take the findings from the review seriously. 

We agree that ratings would promote accountability, and we believe that 

ratings for the Female Offender Manual will make it easier for the Program Review 

Division to identify trends in an institution’s results, potentially allowing BOP to 

identify deficiencies and systemic issues across BOP institutions over time.37 The 

Senior Deputy Assistant Director for the Reentry Services Division said that it is 

important to rate female institutions on their management of female inmates so 

that the significance of meeting these standards does not get diluted across 

multiple reviews that cover items related to female inmates as well as items related 

to all inmates. He also said that a rated program review of the Female Offender 

Manual will make it easier for the Reentry Services Division to spot problems 

multiple institutions have in managing female inmates and identify areas where 

broader action is needed. 

At the time of our review, BOP was in the early stages of implementing a 

system of formal oversight and enforcement for the Female Offender Manual. This 

accountability mechanism will provide BOP with a key tool for determining whether 

institutions are complying with policy governing the management of female 

inmates. 

The Women and Special Populations Branch’s Staffing May Not Be Sufficient to Fully 

Accomplish its Mission 

BOP created the Women and Special Populations Branch in the Reentry 

Services Division of BOP’s Central Office to address the needs of special 

 

36

 A Senior Deputy Assistant Director of BOP’s Program Review Division said that the PREA 

program review does not receive a rating because the goal of the PREA program review is to help 

institutions prepare for the formal PREA audits conducted by outside auditors. 

37

 We asked BOP whether program review ratings were taken into account during Wardens’ 

annual performance evaluations. BOP’s Management Control and Program Review Manual (Program 

Statement 1210.23) states that a program review rating is a measure of a program’s performance, 

not directly related to a program manager’s performance. BOP’s Human Resource Management 

Division further reported that a program review rating was taken into account only if it directly related 

to a specific performance measure described in a Warden’s performance work plan.
15

populations, including female inmates.38 However, we found that the number of 

staff members BOP allocated to this branch may not be enough to carry out all of 

the responsibilities it has given to the branch. In February 2014, the branch had 

only 1 staff position (of the Reentry Services Division’s 247 positions). As of 

November 2017, the branch had four full-time employees, making up 2 percent of 

the Reentry Services Division’s staffing.

39

 The four staff members are responsible

for six separate inmate special populations that, when combined, make up a large 

share of BOP’s total inmate population.

40 While there is bound to be some overlap 

in the inmates that are a part of these populations, each population has distinct 

needs. 

The Women and Special Populations Branch’s responsibilities require it to 

coordinate regularly nationwide and across all BOP divisions at the Central Office 

and regional levels, at all female institutions, and with external organizations. The 

branch is required to perform a broad range of responsibilities for each special 

population, potentially independently of one another. For example, the following 

duties, among many others, demonstrate the broad scope of duties for this branch: 

 developing, implementing, and maintaining national programs for female 

inmates, inmates with disabilities, children of incarcerated parents, and other 

special populations, which require extensive knowledge of mental health, 

case management, custody/discipline, vocational/workforce, education, life 

skills, release preparation, and community placement; 

 representing BOP in the day-to-day dealings with outside agencies and with 

other BOP branches and institutions regarding female inmates or inmates 

from special populations; and 

 serving as the BOP National Executive Staff’s primary resource concerning 

female inmate and special population issues. The Women and Special 

Populations Branch also provides information and advice to other Branch 

Chiefs and management, including the BOP Director, regarding the needs of 

female or special population inmates and programs for these inmates.41

 

 

38

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

Introduction. 

39

 The Women and Special Populations Branch Administrator is included in this staffing level. 

In response to a working draft of this report, BOP stated that all four staff in the Women and Special 

Populations Branch, including the Branch Administrator, focus on program or training work. 

40

 Female inmates account for approximately 7 percent of the inmate population, as we state 

in the Introduction. We could not determine the number of inmates with disabilities from the BOP 

data we analyzed; but, in response to a working draft of this report, BOP estimated that inmates with 

disabilities account for approximately one-third of the inmate population. 

41

 The items we highlight here represent just a fraction of the Women and Special Populations 

Branch’s responsibilities. The Administrator’s position description includes seven pages of 

responsibilities. 
16

To accomplish these duties, the branch must collaborate with Health Services staff, 

Psychology Services staff, Education Services staff, and staff located in any other 

area of BOP, as necessary, to address the needs of female inmates. The Senior 

Deputy Assistant Director of the Reentry Services Division said that it is challenging 

for the branch to ensure institutions are complying with policy when the branch has 

only four staff, all of whom are located at Central Office. He noted that BOP might 

need to consider a variety of staffing arrangements, including placing staff at 

regional offices or individual institutions, as the branch continues to develop 

additional policies that each need to be implemented for different special 

populations. 

The Women and Special Populations Branch Administrator told us that the 

branch’s range of responsibilities and current level of staffing left it unable to 

provide training on current best practices for managing female inmates. She told 

us that she would like the branch to conduct more in-person, interactive trainings 

on the management of female inmates for staff at female institutions. In 2017, the 

branch conducted one such training at an institution; several Psychologists who 

attended told us that it was very useful because it enhanced staff members’ 

understanding of trauma, how trauma impacts female inmates, and how to more 

effectively communicate with female inmates. A Social Worker at another female

institution had not received in-person training but told us that given the mental 

health effects of abuse and the high rate of trauma in the female inmate 

population, Correctional Officers would benefit from increased training on effectively 

managing the needs of inmates with mental illness.42

 

As we described above, the Women and Special Populations Branch is 

responsible for overseeing BOP’s management of multiple special populations, 

which includes coordinating across BOP’s many divisions at the Central Office, as 

well as with individual institutions. Given these multiple responsibilities, we believe 

that BOP should evaluate the breadth of the branch’s mission and ensure that the 

branch has sufficient staff to accomplish that mission. 

BOP Does Not Require Its National-Level Executives to Take Training on Managing 

Female Offenders 

We found that while BOP has implemented mandatory training on the 

management of female inmates for staff who work in female institutions, BOP has 

not required its National Executive Staff to take this or other training pertaining to 

female inmates.43

 As a result, the officials who make decisions affecting the 

 

42

 OIG’s review of BOP’s management of inmates with mental illness in restrictive housing 

recommended additional mental health training for staff monitoring the behavior of inmates in 

restrictive housing. DOJ OIG, Review of the Federal Bureau of Prisons’ Use of Restrictive Housing for 

Inmates with Mental Illness, Evaluation and Inspections Report 17-05 (July 2017), 66. 

43

 BOP’s National Executive Staff consists of the BOP Director, Deputy Director, 6 Regional 

Directors, and 10 Assistant Directors in BOP’s Central Office. The trauma-informed correctional care 

(Cont’d)
17

conditions of confinement for female inmates may not be fully aware of the unique 

needs of female inmates. According to BOP’s primary training video on the 

management of female inmates, these unique needs include the prevalence of 

trauma in the female inmate population and how trauma affects female inmates’ 

behavior; communication strategies that BOP recommends staff use when working 

with female inmates to avoid triggering memories of previously experienced 

trauma; BOP policies that impact female inmates differently, such as the inmate 

search policy; female inmate healthcare needs; relationships, especially 

relationships with their minor children; and educational and release needs. We will 

discuss actions BOP has taken to address some of these needs in later sections of 

this report. 

BOP has made training on the management of female inmates mandatory 

only for staff who work in female institutions and directly with female inmates. 

When staff begin working at a female institution for the first time, they are required 

to take two trainings that were prepared by the Women and Special Populations 

Branch: a 1.5-hour video on the management of female inmates, accompanied by 

discussions moderated by an on-site trainer, and a 24-minute video on traumainformed correctional care.44

 Both of these trainings have been updated since 2016 

to reflect BOP’s current practices in the management of the female inmate 

population. A Correctional Officer who watched the trauma-informed correctional 

care video described the training as very powerful and said it made her more 

empathetic toward female inmates because it helped her understand how past 

traumas influence how female inmates express frustration and react to staff. 

However, BOP National Executive Staff exposure to this training is ad hoc. 

One National Executive Staff member with decision-making authority over female 

inmates said that he had not received training on the management of female 

inmates because he had never worked at an institution that housed female 

inmates.45

 Another member of the BOP National Executive Staff told us that he had 

training on the management of female inmates in the 1990s because at that time 

he worked at an institution that housed female inmates. The Senior Deputy 

Assistant Director of the Reentry Services Division said that he believes it is 

 

training video was incorporated into BOP’s annual refresher training curriculum one time, in FY 2016, 

and all staff employed by BOP that year, including National Executive Staff, saw the video. BOP has 

an ongoing requirement that all staff assigned to a female institution for the first time take the 

trauma-informed correctional care training. However, because BOP does not also require this training 

at the time of promotion to BOP’s National Executive Staff, it is possible for an individual to be 

promoted to an executive position without ever having taken the training. BOP reported to us that its 

National Executive Staff are required only to complete and maintain certification in a series of 

standard government manager and supervisory trainings. 

44

 Three April 2018 program reviews of the Female Offender Manual conducted by BOP found 

that three different female institutions were failing to provide all institution staff with these trainings 

as required by BOP policy. 

45

 During the course of this review, we interviewed three members of the BOP National Executive 

Staff who oversee aspects of BOP operations directly related to the management of female inmates. 
18

important for Regional Directors to take this training because they oversee such 

institutions in their respective regions. He further recommended that the BOP 

Director take any training associated with a program statement he signs.46 

Although the Assistant Director of the Reentry Services Division told us that he 

does not believe that requiring National Executive Staff to take training on the 

management of female inmates is important, he also acknowledged that, if left to 

its own devices, BOP is not gender responsive. We are concerned that, without 

such training, members of the National Executive Staff who are in a position to 

make decisions that affect the female inmate population may not be fully aware of 

female inmates’ unique needs.

Individuals inside and outside BOP described training as an effective method 

for helping staff recognize the unique needs of female inmates, as well as an 

effective tool to convey support from agency leadership. A DOJ Civil Rights Division 

official who works closely with BOP on issues related to female inmates emphasized 

the importance of support from top BOP officials in ensuring that the incarceration 

of women is gender responsive in all areas. The Women and Special Populations 

Branch Administrator added that it is important for BOP leadership to be exposed to 

female inmate-specific issues so they understand the importance of those issues 

when making decisions. A Deputy Commissioner from the Alabama Department of 

Corrections told us that providing multidisciplinary training in gender-responsive 

corrections was “probably one of the most impactful” things the Department of 

Corrections has done to make its culture more understanding of female inmates. 

The Deputy Commissioner said that the training created significant buy-in from 

staff across all levels about understanding the unique needs of female inmates and 

recognizing the differences between female and male inmates. 

Accordingly, we believe that BOP should ensure that all staff, including the 

National Executive Staff, who work with or have management decision authority 

over female inmates receive the current mandatory training on the unique needs of 

female inmates. 

BOP’s Programming and Policy May Not Fully Consider the Needs of Female 

Inmates 

We identified concerns with the way BOP implements two programs for 

female inmates, as well as a concern with how BOP’s implementation of its inmate 

grooming policy affects female inmates. First, BOP has not staffed its trauma 

treatment program for female inmates at a level that ensures that all female 

inmates who are eligible for the program can participate in it before they are 

released. Second, a lack of staff awareness and a lack of data may limit access to 

BOP’s residential programs for pregnant inmates. Third, the distribution methods 

for feminine hygiene products did not always ensure that inmates had sufficient 

access to the quantity of products they needed. 

46

 We note that the six Regional Directors plus the BOP Director account for more than a third 

of the BOP officials who make up the National Executive Staff. 
19

BOP’s Trauma Treatment Program Is Inadequately Staffed Compared to the Level of 

Need

Based on research we previously referred to in the Introduction of this 

report, BOP’s training materials acknowledge that the prevalence of trauma in the 

female inmate population is high—approximately 90 percent. Some of the inmates 

we interviewed described a range of traumatic experiences they had faced prior to 

incarceration, including homelessness, sexual abuse, and domestic violence. To 

treat the psychological and interpersonal difficulties that can result from traumatic 

life experiences, BOP offers the Resolve trauma therapy program at 14 of its 

15 female institutions. One Resolve Coordinator said that the goal of the program 

is to help inmates improve their ability to function on a daily basis through 

treatment that reduces psychological symptoms, improves behavior, and decreases 

an inmate’s need for medication. A BOP Mental Health Treatment Coordinator told 

us that, ideally, an inmate should take the Resolve program during the first 

12 months of her sentence because the program can help the inmate adjust to 

being in an institution and prepare for other psychological programming, such as 

residential drug treatment. BOP Psychologists inform female inmates about the 

Resolve program at the start of incarceration and encourage all female inmates with 

a history of trauma to sign up for the introductory workshop. Participation in the 

Resolve program is voluntary. 

Several of the inmates we interviewed who had taken Resolve told us that 

the program helped them come to terms with their past and prepare for life after 

prison. One inmate praised the Resolve program for helping her recover from 

severe domestic violence, saying, “I’m trying to better myself while in prison. I 

don’t want to walk in here and walk out the same way.” She also praised the 

Resolve Coordinator for helping her understand her marriage and how to heal from 

the abuse she suffered.

Although BOP considers Resolve to be an especially important program for 

female inmates, we found that due to current staffing BOP may not be able to 

ensure that all inmates who are eligible for the program can participate in it before 

their release from BOP custody. We learned that, regardless of the size of the 

institution’s female inmate population, BOP allocates one position, known as a 

Resolve Coordinator, to administer and facilitate the Resolve program, its two 

prerequisites, and other tasks that are part of the program.47

 As we explain below 

in our discussion of the ramifications of BOP’s current staffing model for Resolve, 

we estimate that the 40-week Resolve program can accommodate only 336 female 

inmates nationwide at a time, and 24 per institution at a time, representing roughly 

3 percent of BOP’s sentenced female inmate population.48

 

47

 During the time of our review, BOP was piloting the Resolve program for male inmates at 

two institutions. At all other institutions, the Resolve program was available only to female inmates, 

even if the institution as a whole housed both female and male inmates. 

48

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

institutions. 
20

As a result of this limited staffing, inmates at larger institutions are often 

delayed from beginning each separate step of the program. This presents a 

challenge for BOP because female inmates generally have shorter sentences than 

male inmates. We also identified an unfilled need for trauma programming among 

non-English speaking inmates because BOP offers Resolve only in English. Finally, 

we found that Resolve’s staffing level is significantly lower than several other BOP 

psychological treatment programs. 

To determine an inmate’s eligibility for the Resolve program, BOP policy 

requires that she complete two prerequisites: the Trauma in Life seminar and 

psychological screening tests (see Table 2 above). A Resolve Coordinator explained 

that the psychological screening tests determine whether an inmate meets certain 

traumatic stress criteria and is therefore eligible for the Resolve treatment. Typical 

diagnoses indicating eligibility include post-traumatic stress disorder, anxiety, or 

depression but may also include conditions such as schizophrenia if the condition is 

triggered or worsened by the traumatic experience. We found that inadequate 

staffing creates delays for inmates in completing the prerequisites, which may 

result in eligible inmates not being able to complete the treatment phases until later 

in their sentence, and possibly not at all. BOP cannot easily determine how many 

female inmates complete the Resolve program because, while BOP tracks 

completion of individual segments of the Resolve program, it does not track 

completion of the program as a whole. 

For example, the Trauma in Life seminar, the first prerequisite for 

determining eligibility in the Resolve program, is an 8-hour course and is typically 

taught in four 2-hour sessions over 4 weeks. Trauma in Life is intended to provide 

female inmates with information on trauma and its potential impact on their lives, 

as well as to identify inmates who need trauma treatment and to motivate them to 

participate in the Resolve program. As shown in Table 3 below, we found that 

waiting lists for Trauma in Life seminars can be lengthy, particularly in BOP’s seven 

large, all-female institutions. We found this troubling because, as of September 

2016, 70 percent of BOP’s sentenced female population was in one of the seven allfemale institutions. 
21

Table 3 

Trauma in Life Waiting Lists at All-female and Mixed-gender 

BOP Institutions, August 2017

Type of 

Institution

Average 

Female 

Population

Average Number of Female 

Inmates on a Trauma in Life 

Waiting List

OIG Estimate of Months 

Needed to Teach Trauma 

in Life to All Inmates on an 

Average Waiting Lista

All femaleb 1,103 172 8

Mixed genderc 318 47 3

a

 BOP institutions told us that Trauma in Life courses can accommodate a maximum of 

24 inmates at a time. Therefore, our analysis assumes that each Trauma in Life seminar can 

accommodate 24 inmates. 

b

 The seven all-female institutions were Federal Prison Camp (FPC) Alderson, Federal Correctional 

Institution (FCI) Aliceville, FPC Bryan, Federal Medical Center Carswell, FCI Dublin, FCI 

Tallahassee, and FCI Waseca. 

c

 The eight mixed-gender institutions were FPC Coleman, Federal Satellite Low and FPC Danbury, 

FPC Greenville, Secure Female Facility Hazelton, FPC Lexington, FPC Marianna, FPC Phoenix, and 

FPC Victorville. At these institutions, BOP housed female and male inmates in buildings separated 

by fences and enforced strict operational rules to keep female and male inmates apart at all times. 

Notes: The BOP’s detention centers and Federal Transfer Center Oklahoma City all housed female 

inmates, but we excluded them from this analysis because they did not offer the Resolve program.

We used August 2017 population data for this analysis to more accurately reflect the female 

population at the time we collected the waiting lists. 

Sources: BOP data on Resolve program waiting lists; institution population data on BOP’s website 

as of August 30, 2017; and OIG analysis

We found that 6 of BOP’s 15 female institutions had Trauma in Life waiting 

lists of 150 inmates or more. We concluded that inmates at the end of a waiting 

list of 150 could wait at least 6 months before they could take the first step toward 

determining whether they were even eligible for the Resolve program.49 However, 

this may understate the amount of time that individual inmates must wait to enroll 

in the program because BOP organizes its program waiting lists by release date, not 

the date an inmate is added to the waiting list. A Social Worker told us that, as a 

result, female inmates with longer sentences may spend years rather than months 

on a program waiting list, including the Trauma in Life waiting list.50

 

After inmates complete Trauma in Life, they must undergo a psychological 

assessment to determine whether they have a psychological diagnosis related to a 

traumatic life event. Such a diagnosis is a requirement for inmates to begin 

Resolve’s treatment phases. Making such a diagnosis requires the Resolve 

 

49

 One institution reported to us that its Trauma in Life waiting list was 311 inmates. At this 

institution, we estimate the wait for the Trauma in Life course could be as long as a year. 

50

 BOP policy states that inmates should enroll in the Trauma in Life seminar during the first 

12 months of incarceration. An inmate was always placed on the Trauma in Life seminar’s waiting list 

based on her release date, even if she did not sign up for the Trauma in Life seminar until after her 

first 12 months of incarceration. BOP policy does not establish a timeframe for completing the rest of 

the Resolve program. 
22

Coordinator to perform a screening assessment that includes several psychological 

tests and a review of the inmate’s file. One Resolve Coordinator said that the 

process of interviewing an inmate, performing the psychological tests, and 

reviewing the inmate’s file takes several hours for each inmate. Another Resolve 

Coordinator at a large female institution said that the amount of psychological 

testing required for Resolve is a lot of work for a single staff member, especially 

given all of a Resolve Coordinator’s responsibilities. 

During our fieldwork, 5 of BOP’s female institutions reported that 45 or more 

inmates were awaiting a screening assessment to determine whether they were 

eligible for Resolve. At 1 of these institutions, 180 inmates, representing 

18 percent of the institution’s population, were on the waiting list for screening.51

 

The second-longest waiting list for screening assessments, 82 inmates, represented 

5 percent of that institution’s population. 

After inmates complete Trauma in Life and receive a psychological 

assessment that results in a diagnosis related to a traumatic event, they are eligible 

to begin the Resolve program. However, according to BOP Psychologists, the single 

Resolve Coordinator running the program can manage a caseload of only 

24 inmates at a time in the treatment phases. The caseload of inmates in the 

treatment phases does not include inmates who are taking the Trauma in Life 

seminar, are undergoing the psychological screening assessment, or have 

completed the treatment phases and are in the maintenance group. With a current 

staffing level of one Resolve Coordinator per institution, eligible inmates will not 

necessarily begin a Resolve program right after completing the two prerequisites. 

Additionally, we found that the existing waiting lists for Resolve programming 

may underrepresent the actual level of need because Resolve is offered only in 

English and, therefore, waiting lists generally include only inmates who speak fluent 

English. BOP Psychologists at multiple institutions expressed concern that BOP is 

not able to provide sufficient trauma treatment for non-English speaking female 

inmates, specifically Spanish-speaking female inmates. While the fact that Resolve 

is taught only in English could be an impediment for any non-English speaking 

inmate, institution staff told us that Spanish is by far the most common non-English 

language spoken by inmates. A Warden and a Chief Psychologist from two female 

institutions told us that their greatest unmet programming need was for Spanish 

Resolve. According to the Chief Psychologist, “There’s horrific history, but we just 

can’t get to them.” 

Psychological staff at multiple female institutions expressed concern that 

having only one position dedicated to administering all aspects of Resolve at each 

institution, regardless of the size of the institution, was inadequate. We note that 

this is particularly problematic for the three female institutions that have both a low 

security institution and a minimum security camp because security considerations 

 

51

 BOP’s Chief of Mental Health Services attributed the backlog to the fact that the Resolve 

Coordinator position at this institution was vacant, noting that BOP has found it challenging to keep 

the Resolve Coordinator position filled at this rural institution. 
23

require the low and minimum security inmates to be separated. The Resolve 

Coordinator from one of these institutions said that if she offered treatment to both 

low and minimum security inmates at the same time, she must do so in separate 

treatment groups. Another Resolve Coordinator worried that, as a result of low 

staffing levels, “you have people going home without the treatment, although we 

identified that they needed it.” 

The Chief of Mental Health Services described this staffing model as “not 

ideal” and noted that it worked better at camps, which typically have populations of 

around 300 female inmates, than at larger institutions. She further explained that 

BOP had not added staff to the Resolve program as of the time of our review 

because it had to balance competing priorities for psychological resources and had 

chosen in recent years to prioritize the treatment of serious mental illness.52

 

Finally, the Chief of Mental Health Services said that, because Resolve is run by a 

single coordinator in each institution, any time that position is vacant the program 

goes dormant until a replacement is hired. A September 2016 BOP statistical 

report summarizing staffing levels and inmate participation in psychology treatment 

programs showed that 5 of the 14 Resolve Coordinator positions in female 

institutions were vacant at that time. As a result, the Resolve program was not 

available to the female inmates at these institutions until the positions were filled. 

We found that Resolve’s staffing model allotted fewer staff than several of 

BOP’s other psychology treatment programs, including the Residential Drug Abuse 

Program (RDAP), the Brave program, and the Challenge program.53 BOP policy 

requires the RDAP, Brave, and Challenge programs each to be staffed by a Program 

Coordinator and multiple Treatment Specialists, allowing these programs to treat 

more inmates concurrently than Resolve can, as shown in Table 4 below, because 

each Treatment Specialist maintains a caseload of inmates. Meanwhile, Resolve is 

the only psychological treatment program with a capacity not established in policy, 

although BOP’s Chief of Mental Health Services told us that the general expectation 

is that each Resolve Coordinator will treat 24 inmates at a time. The Chief 

Psychologist at a large female institution said that BOP does a great job treating 

substance abuse through RDAP because it allocates sufficient resources and staffing 

to RDAP; but it does not do the same for trauma treatment through Resolve. 

 

52

 Based on concerns about insufficient mental health staff, OIG’s review of BOP’s

management of inmates with mental illness in restrictive housing recommended that BOP prioritize 

and incentivize hiring mental health staff at institutions that have inmates with mental illness in longterm restrictive housing. DOJ OIG, Use of Restrictive Housing, 65.

53

 The Brave program is an institutional adjustment program for male inmates who are 

medium security, age 32 or younger, serving their first BOP sentence, and beginning a sentence of at 

least 5 years. The Challenge program is for male inmates who are high security and have either a 

history of substance abuse or a severe mental health diagnosis. 

BOP’s program statement for Psychology Treatment Programs describes four additional 

programs for mental health treatment. We excluded these programs from our analysis because they 

are for inmates whose mental health diagnoses require intensive treatment services. 
24

Table 4 

Psychology Treatment Program Average Participation Levels and 

Onboard Staffing Levels, September 2016

Program Average Program Staff 

per Institution

Average Inmate 

Participants per 

Institution at a Time

Resolve 1 24

RDAP 6 118

Brave 5.5 75

Challenge 4 65

Notes: We excluded three institutions from our analysis of Resolve program 

participation because the Resolve Coordinator positions at those institutions were 

vacant.

The staffing levels of RDAP, Brave, and Challenge varied slightly, usually ranging 

between four and six staff per program location. Additionally, some BOP institutions 

operated multiple RDAPs at a single institution. 

Source: OIG analysis of BOP data on psychology treatment programs 

RDAP, Brave, and Challenge 

differ from Resolve also because they 

are residential programs, meaning that 

all inmates in the program also live 

together in a single housing unit 

separate from the institution’s general 

population. BOP residential programs 

are more intensive than non-residential 

programs, requiring more programming 

hours to complete.54 Residential 

programs have more staff to account 

for these differences. While we 

recognize that residential programs are 

frequently of a greater intensity than 

non-residential programs such as 

Resolve, we believe that BOP’s current 

approach to staffing Resolve does not 

take into account the importance of 

female inmates completing this 

program as close as possible to the 

beginning of their incarceration. For a description of a new trauma treatment 

program that BOP was piloting during the time of our review, see the text box. 

 

54

 Typical residential programs require inmates to participate in group sessions for 3–4 hours 

per day. Resolve consists of group sessions that meet for approximately 1–2 hours per week. 

Female Integrated Treatment

BOP has taken a promising first step in its 

efforts to enhance the capacity of its trauma 

treatment programming at one female institution. 

The Female Integrated Treatment (FIT) program 

being piloted at the low security female 

institution in Danbury, Connecticut, has positions 

for a FIT Program Coordinator, two Psychologists, 

and four Treatment Specialists. BOP anticipated 

that, when fully staffed, FIT would be able to 

provide treatment to up to 96 women at a time. 

The capacity of the low security female institution 

in Danbury is 192 inmates, meaning that, unlike 

Resolve, the FIT program will be able to 

accommodate a relatively high proportion of 

Danbury’s low security female population.

Sources: OIG interviews of BOP staff and BOP 

documents describing the FIT program
25

A 2003 National Institute of Corrections report stated that “among women, 

the most common pathways to crime are based on survival (of abuse and poverty) 

and substance abuse.”55 The Women and Special Populations Branch Administrator 

described sexual assault in particular as the pipeline to prison for many female 

inmates. BOP recognizes that trauma treatment programs are an important tool to 

disrupt this pathway. A 2012 study on trauma-informed correctional care reported 

that histories of sexual abuse could interfere with female inmates’ ability to benefit 

from other institution programs; the study stated that addressing trauma should be 

a priority for female inmates.56

 Also, these programs have been in high demand 

among female inmates, as evidenced by waiting lists for the Trauma in Life seminar 

that extend for 6 months or more. However, we found that BOP’s staffing level for 

these program is inadequate to meet the demand. As a result, BOP cannot ensure 

that all eligible female inmates receive trauma treatment before their release. 

BOP’s Pregnancy Programs May Be Underutilized 

To further address the unique needs of female inmates, BOP offers two 

programs for its pregnant inmates. The first is the BOP-sponsored Mothers and 

Infants Nurturing Together (MINT) program, which allows female inmates to serve 

a portion of their sentence living in a halfway house with their infants after birth. 

According to BOP, the MINT program was designed to teach parenting skills and 

facilitate mother-child bonding so that inmates will be more likely to provide a 

stable home environment upon release from BOP custody. The second program, 

which has similar goals to the MINT program, is the Washington State Department 

of Corrections’ Residential Parenting Program. BOP maintains an agreement with 

the Washington State Department of Corrections that allows BOP female inmates 

and their infants to participate in the program, which is housed inside a Washington 

state minimum security female institution. 

The Female Offender Manual requires BOP Social Workers to meet with 

pregnant inmates to provide information regarding the MINT program and the 

Residential Parenting Program. The Social Worker must document this meeting in 

the inmate’s electronic medical record and notify the Women and Special 

Populations Branch Administrator, Regional Social Worker, and institution Clinical 

Director of any inmate wishing to participate in either pregnancy program.57 The 

 

55

 BOP National Institute of Corrections, Gender-Responsive Strategies: Research, Practice 

and Guiding Principles for Women Offenders (June 2003), 52–54. The report discussed female 

inmates in both federal and state prison systems. 

The National Institute of Corrections provides training, technical assistance, information 

services, and policy and program development assistance to federal, state, and local correctional 

agencies. 

56

 Niki A. Miller and Lisa M. Najavits, “Creating Trauma Informed Correctional Care: A 

Balance of Goals and Environment,” European Journal of Psychotraumatology (2012): 3.

57

 Not every female institution employs a Social Worker. When an institution does not have a 

Social Worker, the Women and Special Populations Branch Administrator told us that the Regional 

Social Worker is responsible for meeting with a pregnant inmate. 
26

MINT program is open to inmates who do not plan to place their infant up for 

adoption, are pregnant upon incarceration with an expected delivery date prior to 

release, have less than 5 years remaining on their sentence and are eligible for 

halfway house placement, and can assume financial responsibility for the child’s 

care.58 During the scope of this review (FYs 2012–2016), MINT program sites were 

located across the country in multiple regions.59 

If a pregnant inmate is interested in either program, the inmate’s Unit Team 

is responsible for preparing a referral packet and forwarding the packet to the 

Residential Reentry Management Branch within the Reentry Services Division for a 

final decision about the inmate’s eligibility and placement. After completing the 

MINT program, inmates who have time remaining to serve on their sentence 

transfer their infant to another legal guardian and return to a BOP institution or are 

transferred to a halfway house or home confinement. 

One MINT Coordinator told us that she believes that MINT is valuable to 

inmates because it helps them bond with their infants and can increase the 

likelihood that those inmates will assume parental responsibilities when they are 

released, therefore motivating them to avoid future criminal behavior. Participants 

in the MINT program told us that the residential placement during and after 

pregnancy has helped them learn important parenting skills and develop a bond 

with their infants. 

Despite the benefits that the MINT program can provide to pregnant inmates, 

we found that the program may be underutilized. Between FYs 2012 and 2016, 

there were 951 pregnant inmates in BOP’s custody, 558 of whom were in 

institutions designed to house sentenced inmates. Of these 558 sentenced 

pregnant inmates, we estimate that only 204 (37 percent) participated in MINT or 

the Residential Parenting Program.60

 

We believe that the low levels of participation likely can be attributed to four 

causes. First, we found that pregnant inmates may not always be told about 

available pregnancy programs. Social Workers are responsible for informing 

inmates about these programs, but Social Worker positions are often vacant. In 

fact, we found that 5 of the 15 female institutions had Social Worker vacancies in 

September 2017. Additionally, underscoring the importance of program reviews, 

BOP’s first review of its policies on the management of female inmates in December 

2017 concluded that Social Workers at one institution were not meeting with 

pregnant inmates to discuss pregnancy programming, as required. Although we 

 

58

 The Residential Parenting Program has a separate set of eligibility criteria, established by 

the Washington State Department of Corrections. We discuss these criteria in a text box below. 

59

 As of December 2017, the sites in San Francisco, California, and Hartford, Connecticut, no 

longer accepted MINT inmates. BOP ended the MINT program at these locations because the sites 

were unable to comply with some of the contract requirements for hosting MINT programs. 

60

 For this review, we evaluated participation for those inmates who were in institutions 

designed to house sentenced inmates only. Additionally, BOP Program Statement 7310.04,

Community Corrections Center Utilization and Transfer Procedure, December 16, 1998, states that 

pretrial detainees are not eligible for halfway house placement. 
27

also found that some institution staff did not fully understand the eligibility criteria 

for the pregnancy programs, the Health Services Administrator of one female 

institution said that staff there inform pregnant inmates of either MINT or the 

Residential Parenting Program only if the staff believes that the inmate meets the 

eligibility criteria for those programs, to avoid disappointing inmates who are not 

eligible.

In addition to a lack of program awareness among inmates, we also found 

that BOP institution staff were generally unaware of the Washington State 

Department of Corrections’ Residential Parenting Program, for which some BOP 

pregnant inmates were eligible. We believe that this general lack of awareness has, 

in part, contributed to low BOP inmate participation in the Residential Parenting 

Program. Specifically, only five inmates entered the program between FYs 2012 

and 2016, most recently in FY 2013. This was the case despite the fact that 

Washington State Department of Corrections officials told us that the program had 

excess capacity. We describe the Residential Parenting Program, and its eligibility 

criteria, in the text box. 

Third, we found that BOP institution staff may be applying policy more 

restrictively than intended by Central Office policymakers. BOP policy states only 

that inmates must be eligible for halfway house placement to participate in the 

MINT program and does not explicitly bar inmates from participation based on 

security level; however, we learned that some BOP institution officials may apply a 

more restrictive eligibility standard. For example, a Warden of a female institution 

told us that only minimum security inmates qualify for MINT, because, she 

believed, that low security inmates had not proven they were ready for halfway 

house style housing. However, the former Chief of BOP’s Designation and Sentence 

Computation Center, which has responsibility for determining where inmates should 

be housed, told us that security level designation alone should not prevent an 

interested inmate from participating in MINT. BOP’s policy on halfway house 

Residential Parenting Program

During the course of our review, we learned that BOP inmates may participate in the 

Washington State Department of Corrections’ Residential Parenting Program. Unlike the MINT 

program, which provides a shorter period of mother-infant bonding time in a halfway house 

setting, the Residential Parenting Program offers 30 months of mother-infant bonding time in 

the minimum security unit of the Washington Corrections Center for Women in Gig Harbor, 

Washington. If an inmate is interested in the program after learning about it from a BOP Social 

Worker, the inmate’s Unit Team submits a referral packet to BOP’s Residential Reentry 

Management Branch for review and placement. 

The eligibility requirements for the Residential Parenting Program are stricter than those for 

the MINT program. For example, only minimum security inmates are eligible to participate in 

the Residential Parenting Program, whereas both minimum and low security inmates can be 

eligible to participate in the MINT program. To be eligible for the Residential Parenting Program, 

inmates must meet certain disciplinary and work evaluation criteria and must have no history of 

violence, sex offenses, or child abuse. Inmates must also be eligible for release or home 

confinement within 30 months of their expected delivery date. 

Sources: Washington State Department of Corrections officials, BOP officials, and BOP policies
28

eligibility calls for case-by-case consideration of each interested MINT participant 

and her likelihood to pose a threat, rather than a blanket disqualification based on 

her security level.61

 

Fourth, we found that BOP does not collect data that would allow it to identify 

barriers to participation and monitor pregnant inmates’ awareness of, interest in, 

and enrollment in the MINT program or the Residential Parenting Program. The

Women and Special Populations Branch Administrator told us that collecting 

sufficient data on pregnant inmates historically has been a challenge for BOP. It 

was not until 2016 that BOP added a code to its inmate tracking system to indicate 

that an inmate is pregnant. Additionally, four of the interim remote program 

reviews that BOP conducted on Female Offender Manual compliance between 

December 2017 and May 2018 found inconsistencies in tracking pregnant inmates. 

During the time of our review, BOP did not track data that would allow it to ensure 

that pregnant inmates were informed about pregnancy programs, as required by 

the Female Offender Manual. Additionally, BOP did not collect data that would allow 

it to determine the specific eligibility criteria that preclude program participation, 

such as whether a pregnant inmate faced financial barriers to supporting her baby 

during mother-infant bonding time or planned to pursue adoption, either of which 

would render the inmate ineligible for participation in MINT. 

Lastly, BOP did not track the length of time a pregnant inmate spent at a 

MINT program site. Tracking duration of stay could help BOP better determine the 

ideal amount of time an inmate should spend at a MINT program site to achieve the 

program’s goals. During the time of our review, policy allowed institution staff to 

exercise discretion as to how long an inmate may stay at a MINT program site;

inmates must be allotted 3 months after birth, but the policy recommended that 

inmates be allowed to participate for 6 months after giving birth.62 Multiple MINT 

Coordinators told us that many inmates stay at the MINT program site for only 

3 months after birth. 

We learned from MINT capacity data and interviews with BOP and 

Washington State Department of Corrections officials that both the MINT program 

and the Residential Parenting Program can accept additional eligible BOP inmates. 

Therefore, we determined that low levels of inmate participation in pregnancy 

programs were not caused by limited program capacity. Instead, we found that low 

participation was likely due to BOP staff members’ failure to fully communicate 

program opportunities and eligibility criteria to staff and pregnant inmates and to 

collect relevant data to assess pregnant inmates’ interest and participation in the 

MINT program and the Residential Parenting Program. As a result, we believe that 

pregnancy program participation will remain low until BOP addresses these issues. 

61

 BOP Program Statements 7310.04 and 5200.02. 

62

 MINT Coordinators believe that when inmates participate in MINT for at least 6 months 

after birth, they are more likely to achieve the program’s goals of learning parenting skills and 

bonding with their infants. One region’s MINT program site allows any inmate who enrolls there to 

participate for 12 months. 
29

BOP Recently Implemented New Guidance on Access to Feminine Hygiene Products, 

but This Guidance Is Silent on How These Products Should be Distributed 

In addition to managing female inmates’ needs related to pregnancy, BOP 

must also appropriately manage female inmates’ distinct needs related to feminine 

hygiene. During our fieldwork, we found that the distribution methods for feminine 

hygiene products and the type of products provided to inmates free of charge 

varied by institution and did not always ensure that inmates had access to a 

quantity of products sufficient to meet their needs. Even though BOP issued an 

Operations Memorandum on the Provision of Feminine Hygiene Products 

(Operations Memorandum) expanding the availability of products, which appears to 

have made some important improvements, we note that the policy lacked 

specificity in how institutions should distribute the products.63 Because our 

fieldwork ended around the same time as this policy was issued, we could not 

confirm that it has addressed our concern that some institutions were not making 

these products sufficiently accessible. 

All BOP institutions that house female inmates provide some feminine 

hygiene products to inmates free of charge, as required by the BOP grooming 

policy, which states, “for women, products for female hygiene needs shall be 

available.”

64 However, we found that distribution practices varied across 

institutions. All of the institutions we visited provided sanitary pads free of charge, 

and a few also provided tampons. Female inmates could also purchase at their own 

expense both pads and tampons at the commissary. 

We found that the method of distribution generally varied by the type of 

institution. For example, minimum security institutions stored feminine hygiene 

products in central locations such as bathrooms or a container that was accessible 

to all inmates at all times. In contrast, at several low security institutions, BOP 

correctional staff issued each inmate a predetermined number of feminine hygiene 

products per month, usually 25 to 30, regardless of individual need. One BOP staff 

member we interviewed told us that the number of feminine hygiene products 

distributed was determined largely by dividing the number received from the 

warehouse by the number of inmates. One inmate we interviewed from an 

institution that issued a preset number of hygiene products said that the amount 

she received from the institution each month was not enough to meet her 

menstrual needs. At one institution we visited, officials told us that feminine 

hygiene products were centrally distributed because the inmates had been misusing 

 

63

 BOP Operations Memorandum 001-2017, Provision of Feminine Hygiene Products, 

August 1, 2017. 

64

 BOP Program Statement 5230.05, Grooming, November 4, 1996, is BOP’s policy on 

standards of grooming for all inmates in BOP custody. The policy describes standards of grooming 

regarding bathing, clothing, and hygiene for all inmates. In addition, the policy states that BOP 

institutions are to provide feminine hygiene products free of charge to all female inmates. 
30

them for purposes such as cleaning their cells.65 Inmates told us that the 

centralized distribution was problematic because hygiene products were no longer 

accessible in the housing units and the amount inmates received was limited. 

We also found that, if inmates needed more feminine hygiene products than 

were issued, their ability to receive additional products varied. At institutions 

where access was tightly controlled, inmates who needed additional feminine 

hygiene products had to request them from a counselor. One inmate we 

interviewed told us that she had requested additional sanitary pads from a 

counselor and the counselor told her that the amount she received should be 

enough. In other institutions, inmates must go to health services to request 

additional products and, in some instances, going to health services also required 

permission from correctional staff.66 Inmates at these institutions indicated that 

they interpreted this as a quota system because they could not necessarily obtain 

additional hygiene products beyond the number issued, even if they asked for 

them; or if they asked, they might be questioned about why they needed more. 

We believe that any distribution method that tightly controls access to feminine 

hygiene products and requires inmates to request more from staff, with no 

guarantee that their requests will be granted, places an excessive burden on 

inmates and does not meet BOP’s grooming policy requiring that such products 

“shall be available” to female inmates. 

Advocacy groups also have stated that access to and affordability of feminine 

hygiene products has been a concern for incarcerated women. Feminine hygiene 

products are costly relative to the salary inmates earn in prison. Additionally, advocacy 

groups have raised concerns that limited access to feminine hygiene products creates 

anxiety and is dehumanizing for incarcerated women. Several U.S. Senators 

introduced legislation on this topic in 2017, as we discuss in the text box below. 

We found that some state correctional systems made feminine hygiene 

products more readily available for their inmates. Some states made the products 

freely available in several locations throughout the institution, including search 

areas, housing units, programming areas, and bathrooms, rather than distributing a 

preset number to each inmate per month. One state official we interviewed told us 

that at one time there were issues with inmates hoarding feminine hygiene 

products. He explained that the hoarding stopped once the inmates believed they 

would have regular access to the products for their menstrual needs. Other state 

officials told us that if inmates were misusing feminine hygiene products for other 

 

65

 No BOP staff member told us that feminine hygiene products were misused in a manner 

that presented a security concern. When we asked the Women and Special Populations Branch 

Administrator whether making them accessible could be a security concern, she said that they could 

not be.

66

 We note that not all of the reasons for which a female inmate might need additional 

feminine hygiene products are indicative of a medical problem. For example, a female inmate whose 

menstrual period began as frequently as every 21 days would be considered medically normal. 

However, if she received feminine hygiene products every 28 days she would not have enough. 
31

purposes, they would address the issue with 

the individual inmates rather than changing 

the distribution method for all inmates. 

We believe that the Operations 

Memorandum that BOP distributed to all 

institutions in 2017 is a positive step in that 

it required all institutions to provide sanitary 

pads, tampons, and panty liners free of 

charge to inmates. Even though the 

Operations Memorandum did not explicitly 

address how products should be dispersed, 

BOP’s Women and Special Populations Branch 

Administrator told us that the intent of the 

Operations Memorandum was to ensure that 

these products were freely available and that 

institutions should not be dispersing a preset 

amount of hygiene products to female 

inmates. She added that during the 

quarterly conference calls with Wardens of 

female institutions, she instructed them that 

placing quotas on or issuing a preset amount

of feminine hygiene products was prohibited. 

We could not validate that our 

concerns about inmates having insufficient 

access to products were addressed because 

the Operations Memorandum was issued at 

the end of our fieldwork.67

 Further, BOP’s 

interim program reviews of the Female 

Offender Manual, implemented in November 2017, also assessed only whether an 

institution provided the products required in the Operations Memorandum, but did 

not assess the accessibility of the products to inmates.68 Although the new 

guidance is in place and BOP has taken some steps to bring institutions into 

compliance, we are concerned that BOP still lacks a method to ensure sufficient 

 

67

 The Assistant Director of the Reentry Services Division told us that even after the new 

guidance was issued he became aware that six institutions had not implemented it as promptly as 

expected. He told us that the Regional Directors, who directly supervise the Wardens of each 

institution, had to intervene to bring those institutions into compliance. 

68 Program Review G5200I.01, Interim Remote Guideline Steps, November 2017, evaluated 

how well an institution was providing vital services to female offenders. The review included an 

assessment of the following: Classification, Staff Training, Inmate Programs, Pregnancy/Child 

Placement, Pregnancy/Programming, High Security Administrative Units, Trust Fund/Commissary, and 

Feminine Hygiene Products. 

2017 Legislation on Providing 

Feminine Hygiene Products for 

Inmates 

In July 2017, four U.S. Senators 

introduced the “Dignity for 

Incarcerated Women Act of 2017.” 

Among other provisions, the bill, if 

passed, would permanently prohibit 

federal prisons from charging female 

inmates for essential healthcare 

items, including sanitary napkins and 

tampons. The proposed legislation 

received widespread attention, and 

some states were reviewing their 

policies on sanitary napkins and 

tampons to make them more 

accessible for women. 

In May 2018, the House 

Judiciary Committee passed the 

“FIRST STEP Act,” a bill intended to 

improve the federal prison system 

through the implementation of 

corrections policy reforms. This bill 

included language that would require 

BOP to make sanitary napkins and 

tampons available for free, in a 

quantity that is appropriate to the 

healthcare needs of each inmate. 

Sources: U.S. Congress website, 

media articles
32

access. As noted previously, in-person program reviews may provide a way to 

ensure institutions have implemented the Operations Memorandum as intended. 

BOP’s Lack of Gender-specific Posts Results in Inefficiencies at Female 

Institutions 

In addition to programming, pregnancy, and hygiene matters, another issue 

we identified in BOP’s management of its female inmate population relates to BOP’s 

policy prohibiting cross-gender searches. The Prison Rape Elimination Act of 2003

(PREA) and BOP policy prohibit cross-gender searches of female inmates.69 We 

found that BOP did not take this policy into account when assigning posts for its 

Correctional Officers. BOP assigned Correctional Officers to posts solely based on 

seniority, which resulted in male Correctional Officers being assigned to posts at 

which staff regularly conducted searches of female inmates. This means that 

female Correctional Officers had to leave other assigned posts to conduct these 

searches, which we found to be inefficient and disruptive. This problem is more 

acute at institutions where the inmate population is entirely female and female 

Correctional Officers must perform all inmate searches. 

BOP policy requires that staff conduct strip searches of inmates in certain 

situations, most commonly when they enter or leave the Special Housing Unit 

(SHU) and before and after they have contact with the public, such as when they 

receive visitors in the institution’s visiting room, appear in court, or have a medical 

appointment outside the institution.70

 Therefore, conducting strip searches is 

among the inherent duties of the Correctional Officer posts in those locations. 

However, BOP cannot currently ensure that there is a female Correctional Officer on 

each post where strip searches are required. 

The fact that every inmate search at BOP’s female institutions—both strip 

searches and pat searches—must be done by female staff can be disruptive to 

operations when female inmate searches are needed at a post staffed only by male 

69

 In August 2012, the Department issued a final rule adopting national standards to prevent, 

detect, and respond to prison rape, as required by PREA. This rule banned male staff from conducting 

pat searches of female inmates (known as cross-gender pat searches) beginning in August 2015. See 

28 C.F.R. § 115.15(b). BOP updated multiple policies to incorporate the ban after the rule was issued. 

See BOP Program Statements 5521.06, Searches of Housing Units, Inmates, and Inmate Work Areas, 

June 4, 2015, 3, and 5324.12, Sexually Abusive Behavior Prevention and Intervention Program, 

June 4, 2015, 17. 

The Department chose not to ban cross-gender pat searches of male inmates when 

promulgating the PREA regulations because it found that male inmates are less likely than female 

inmates to have a history of sexual abuse and are also less likely to experience re-traumatization as a 

result of a cross-gender pat search. Further, the Department concluded that in correctional agencies 

where the percentage of female correctional staff is substantial, but the percentage of female inmates 

is small, banning cross-gender pat searches of male inmates could have a significant adverse impact 

on employment opportunities for female staff. 

70

 Federal regulations and BOP policies mandate that strip searches also be conducted by a 

staff member who is the same gender as the inmate being searched. See 28 C.F.R. § 552.11(c) and 

BOP Program Statement 5521.06, 4. See also 28 C.F.R. § 115.15(a).
33

staff. Female Correctional Officers we interviewed at female institutions told us 

that in these instances they are required to leave their post and go to the post 

where the search is needed.71 A female Correctional Officer at an all-female 

institution told us that in a recent 3-month period she was called to the SHU an 

average of 3 or 4 times each week to search female inmates because all of the 

Correctional Officers assigned to the SHU were male. Similarly, another female 

Correctional Officer told us that when all of the visiting room posts at her institution 

were filled by males she had to juggle the duties of her own post as well as theirs. 

At BOP’s mixed-gender institutions, the need for female staff to search 

female inmates is more manageable. While female Correctional Officers represent 

only a fraction of the staff, female inmates represent only a fraction of the 

population. The challenge at mixed-gender institutions is physical distance. BOP 

policy requires female institutions, including mixed-gender institutions, to have at 

least one female staff member on duty during every shift but does not specify 

where the female staff should be posted. Correctional Officers at mixed-gender 

institutions told us that, while there was always a female officer on duty, the duty 

location could be so far away that the female Correctional Officer would have to 

drive to respond to the search request. 

In our interviews, BOP staff expressed widespread support for BOP requiring 

certain posts, such as in the visiting rooms and SHUs at female institutions, to be 

staffed by female Correctional Officers, citing as an impediment to operations the 

frequent need to call female staff from other posts to strip search and pat search 

female inmates.72

 Nearly two-thirds (15 of 23) of both supervisory and nonsupervisory custody staff at female institutions with whom we discussed the topic 

were in favor of establishing a small number of gender-specific posts at female 

institutions.73

 This includes 9 of the 11 female custody staff, who are the most 

affected by BOP’s current policies, and 6 of the 12 male custody staff we spoke to. 

The Women and Special Populations Branch Administrator echoed these views. 

 

71

 BOP’s policy on inmate searches states that except when circumstances are such that delay 

would constitute an immediate threat to the inmate, staff, others, property, or institution security, a 

female staff member should come to a post to pat search a female inmate rather than invoke an 

exemption in the PREA regulations that permits cross-gender pat searches in “exigent circumstances.” 

BOP Program Statement 5521.06, 3. 

The PREA regulations define “exigent circumstances” as those that require immediate action in 

order to combat a threat to the security or institutional order of a facility. Institution staff did not 

describe to us any situations where they had to invoke the exemption. 

72

 These disruptions occur despite the fact that, on average, nearly 40 percent of Correctional 

Officers in BOP’s seven female institutions are female. 

73

 BOP staff specifically recommended that BOP require at least one of the Correctional 

Officers assigned to a female visiting room or female SHU be female. 

We reviewed the written directives describing the specific duties of these posts, known as post 

orders, from four of BOP’s female institutions and found that the post orders anticipated that the 

Correctional Officers working the posts would routinely strip search and pat search female inmates. 
34

State correctional officials we interviewed told us that their agencies had 

recognized this issue and had taken several different approaches to address it. 

Officials from two of the five state correctional agencies told us that they had 

established gender-specific posts in specific areas of their female institutions, such 

as the SHU and the visiting room, to ensure that only female Correctional Officers 

search female inmates without interfering with operations.74 Officials from two 

additional state correctional agencies told us that their agencies did not have any 

gender-specific posts in their female institutions, but that the institutions had 

enough female staff to handle all search needs. The fifth agency obviated the need 

for gender-specific posts by assigning only female staff to work at its female 

institution. 

We found differences of opinion about whether the establishment of genderspecific posts is allowable under the Master Agreement that governs BOP labor 

practices and working conditions and even whether gender-specific posts are 

needed.75

 Specifically, BOP’s Assistant Director of the Correctional Programs 

Division stated that the terms of the Master Agreement do not expressly allow for 

gender-specific posts and that he was not aware of any problems that would 

require the establishment of gender-specific posts.76 He also expressed concern 

that having such posts could lead to an increase in staff complaints or grievances. 

Further, institution custody supervisors told us that they believed seniority was the 

only factor they could consider in determining assignments. They explained that 

Correctional Officers bid for their preferred posts quarterly in order of seniority and 

institution staff create a roster based on “reasonable efforts” to grant the requests. 

The Master Agreement defines “reasonable efforts” to mean that “management will 

not arbitrarily deny such requests.”77

 

In contrast, BOP’s General Counsel said that the Master Agreement could 

allow female institutions to establish a few gender-specific posts because, in his 

view, having enough staff on a post to complete the work efficiently is not arbitrary. 

Further, while in his opinion an institution could not establish a blanket rule that all 

posts in a particular location could be filled only by staff from one gender, 

 

74

 One of these two correctional agencies said that the agency had not faced challenges from 

male staff as a result of establishing gender-specific posts in female institutions, although the official 

we interviewed acknowledged that the agency’s lack of a public sector union may also be a reason 

why the posts have not been challenged. See Appendix 1 for the methodology of our review, 

including the officials we interviewed. 

75

 The current Master Agreement between BOP and the Council of Prison Locals, the union 

that represents BOP’s bargaining unit employees, went into effect in July 2014. Master Agreement 

between the Federal Bureau of Prisons and Council of Prison Locals, July 21, 2014–July 20, 2017. 

76

 The Master Agreement does not discuss gender-specific posts. Instead, BOP’s program 

statement on inmate searches prohibits the establishment of gender-specific posts and requires 

institutions to evaluate operational needs consistent with the Master Agreement and collective 

bargaining obligations. BOP Program Statement 5521.06, 3. 

77

 Master Agreement, Article 18, Section d, para. 2d. This Master Agreement was in effect 

during the scope of our review. 
35

institutions could require that a certain portion of them be filled by staff from one 

gender.78 

We note that the Master Agreement went into effect in 2014, but the PREA 

regulations and BOP policies that ban cross-gender pat searches of female inmates 

did not go into effect until 2015. Given that cross-gender pat searches of female 

inmates were banned after the Master Agreement came into effect, BOP may need 

to reexamine its blanket ban on gender-specific posts. We recommend that BOP 

improve the availability of female staff at locations in female institutions where 

inmate searches are common, through the establishment of gender-specific posts 

or other methods. 

BOP’s Decision to Convert Federal Correctional Institution Danbury to a Male 

Institution Negatively Affected Female Inmates Transferred to Metropolitan 

Detention Center Brooklyn 

Our broader evaluation of BOP’s management of female inmates also 

encompassed a more specific review of the circumstances and results of BOP’s 

decision to convert Federal Correctional Institution (FCI) Danbury to a male 

institution. We believe that the effects of this decision, described below, serve as a 

case study that highlights BOP’s ongoing challenges in strategically managing its 

female inmate population. 

In April 2014, BOP converted FCI Danbury, its low security female institution 

in Danbury, Connecticut, to a male institution.79

 As a result of the conversion, BOP 

eliminated its only low security female institution in its Northeast Region. Members 

of Congress and other stakeholders expressed concern that without a comparable 

facility in the region BOP would send local inmates to BOP institutions farther from 

their homes, making it difficult for families to visit inmates throughout their 

incarceration.80 As a result of this concern, and the concern of other criminal 

justice stakeholders that following the conversion sentenced female inmates were 

housed in inappropriate conditions in Metropolitan Detention Center (MDC) 

Brooklyn, we examined how BOP’s decision to convert FCI Danbury affected female 

inmates. 

First, we found that, although the Danbury conversion resulted in 19 percent 

of U.S. citizen female inmates being transferred farther from home, far more were 

transferred to facilities closer to home. Second, we found that BOP offered female 

78

 The post orders we reviewed indicated that visiting rooms and SHUs were staffed by 

multiple Correctional Officers. 

79

 According to a September 2013 BOP projection, BOP would see a reduction in both the 

male and female low security overcrowding rates by opening FCI Aliceville as a low security female 

institution and converting FCI Danbury to a low security male institution. Specifically, BOP estimated 

that these changes would reduce the low security female overcrowding rate from 48 percent to 

23 percent and the low security male overcrowding rate from 38 percent to 36 percent. 

80

 In August 2013, Senators Christopher Murphy (Connecticut) and Kirsten Gillibrand (New 

York) sent a letter to then BOP Director Charles Samuels expressing concern regarding the conversion 

of FCI Danbury. 
36

inmates at MDC Brooklyn no access to outdoor space, less natural light, and fewer 

programming opportunities than what would otherwise be available to female 

inmates at a BOP facility designed to house sentenced inmates for long periods of 

time. Third, although BOP opened a new low security institution for female inmates 

from the Northeast in December 2016, during the course of our fieldwork we found 

that BOP built the new institution without a SHU for female inmates, which has 

created challenges for disciplining female inmates. We discuss each of these 

findings below. 

Most Female Inmates Transferred from FCI Danbury Moved Closer to Home 

In response to congressional concerns that the conversion of FCI Danbury 

would cause female inmates to be housed farther from their homes, we analyzed 

the distances from home for female inmates transferred from FCI Danbury. We 

found that 81 percent of Danbury’s U.S. citizen female inmates were transferred 

closer to or remained the same distance from home and 19 percent were 

transferred farther from home. 

We further describe the outcomes of our analysis below in Table 5, which 

shows that of the 1,127 female inmates transferred or released from FCI Danbury, 

497 were U.S. citizen female inmates who were transferred to other BOP 

institutions. Of those 497, we found that 401 were transferred to a BOP institution 

closer to their homes or were reassigned to a minimum security prison camp at FCI 

Danbury. Conversely, 96 were transferred to a BOP institution farther from home. 

Of those 96, 61 were from BOP’s Northeast Region.81

 We did not consider the nonU.S. citizen inmates whom BOP transferred from FCI Danbury in this analysis 

because the BOP data we analyzed did not always include a U.S. residence for 

these individuals. 

 

81

 These 61 inmates were transferred to 12 different institutions. BOP told us that it

considered multiple factors when making each transfer decision. These factors include distance from 

home, availability of programming, and physical and mental health needs. 
37

Table 5 

Geographic Outcomes of FCI Danbury Female Inmate Transfers 

1,127 Inmates Transferred or Released Between August 2013 and March 2014

675 U.S. citizens

445 non-U.S. citizens

7 U.S. citizens with incomplete data for geographical analysisa

675 U.S. Citizens

497 transferred to another BOP institution

45 released from BOP custody

133 transferred to a halfway house prior to release from BOP custody

497 Transferred to Another BOP Institution

373 transferred closer to home 

96 transferred farther from home 

28 not changed (transferred to Federal Prison Camp Danbury)b

96 Transferred Farther from Home

61 from BOP’s Northeast Regionc

35 from other BOP regions

a

 Of the 1,127 inmates BOP transferred or released from FCI Danbury, 682 were U.S. citizens. 

Due to data limitations, we were unable to conduct a distance analysis for seven of these U.S. 

citizen female inmates. 

b

 BOP reduced the security level of these inmates to minimum and assigned them to the 

minimum security Federal Prison Camp Danbury, which is adjacent to FCI Danbury. 

c

 For the purpose of this analysis, we used the 10 states that BOP designated as within its 

Northeast Region as our parameter for “Northeast.” These states are Connecticut, Maine, 

Massachusetts, New Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, and 

Vermont.

Sources: BOP Sentry and SAS geolocation library 

The Duration and Conditions of Confinement of Inmates Housed at MDC Brooklyn 

 After members of Congress expressed concern that the conversion of FCI 

Danbury would eliminate BOP’s only low security institution for female inmates in 

the Northeast, in October 2013 BOP announced that it would open a new low 

security institution in Danbury in order to keep low security female inmates from the 

Northeast closer to home. While BOP was constructing the new institution, it 

decided to house many of the displaced inmates from the Northeast at 

MDC Brooklyn, a detention center designed and generally used for short-term 

confinement. BOP housed these inmates at MDC Brooklyn between March 2014 and 

December 2016, significantly longer than the 18 months it had initially anticipated. 

According to the former Chief of the Designation and Sentence Computation 

Center, detention facilities such as MDC Brooklyn lack the physical infrastructure 

and programming opportunities appropriate for long-term incarceration. However, 

BOP officials decided that it would be better to house sentenced inmates at MDC 

Brooklyn in order to keep them closer to their families, as opposed to transferring 

them to institutions farther away from their homes that were suitable for long-term 
38

confinement.82 The former Chief of the Designation and Sentence Computation 

Center stated that BOP officials chose the former in part because they estimated 

that the inmates would be housed there only on a temporary basis until the new 

institution at Danbury was complete. 

In October 2013, BOP anticipated that the new institution would open 

18 months later, in March 2015. However, the construction did not actually begin 

until June 2015, or 20 months later, and the new institution at Danbury did not 

open until December 2016, causing 70 of the 366 female inmates to remain at MDC 

Brooklyn for longer than 18 months, with the longest stay lasting 34 months.83

 

Figure 2 provides a more detailed explanation of the period of confinement for 

sentenced female inmates at MDC Brooklyn. 

Figure 2 

Length of Confinement for Sentenced Female Inmates at MDC Brooklyn 

Notes: For the purpose of this analysis, we defined 1 month as 30 days.

This figure includes MDC Brooklyn’s U.S. citizen and non-U.S. citizen sentenced female inmates. 

For the purpose of this analysis, we use the 10 states that BOP designated as within its Northeast 

Region as our parameter for “Northeast.” These states are Connecticut, Maine, Massachusetts, New 

Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, and Vermont. 

Source: BOP SENTRY 

 

82

 We also note that, given the greater number of male institutions, BOP would be less likely 

to have to choose between institutions close to home and institutions suitable for long-term 

confinement if it had decided to convert or close one of its male institutions. For example, BOP 

operated four low security male institutions in its Northeast Region in 2013 (FCI Allenwood Low, FCI 

Elkton, FCI Fort Dix, and FCI Loretto), compared to one for women (FCI Danbury). Had the BOP 

decided to convert or close one of these low security male institutions at that time, the other three 

institutions would have remained options for low security male inmates from the Northeast. 

83

 According to BOP, the March 2015 estimate was always subject to change. OIG is currently 

completing an audit of the FCI Danbury construction contract. 

0

20

40

60

80

100

120

140

160

180

1-6

months

7-12

months

13-18

months

19-24

months

25-30

months

31-34

months

Number of Inmates

Length of Confinement

Non-Northeast

Northeast
39

Conditions of Confinement at MDC Brooklyn 

Between March 2014 and December 2016, members of the National 

Association of Women Judges (NAWJ) visited MDC Brooklyn multiple times and 

issued two reports detailing its concerns about the conditions of confinement at the 

facility.84

 NAWJ reported that BOP housed female inmates at MDC Brooklyn without 

access to an outdoor recreation space that had fresh air and exposure to sunlight, 

which, NAWJ believed, amounted to a violation of both the American Bar 

Association Standards on Treatment of Prisoners and the United Nations Standard 

Minimum Rules for the Treatment of Prisoners.85

 

During our visit to MDC Brooklyn in August 2017, we found that its female 

inmates had less access to fresh air and sunlight than what would have been 

available to them at FCI Danbury. Unlike female inmates at MDC Brooklyn, who 

rarely left the floor of their housing unit, low security inmates at FCI Danbury and 

those at most other BOP institutions designed for sentenced inmates have access to 

fresh air and sunlight not only during recreation, but throughout the day when they 

move from one part of the institution to another. Further, FCI Danbury and other 

BOP institutions have open outdoor recreation spaces, whereas the recreation space 

at MDC Brooklyn was directly attached to the female inmate housing unit and had

only two caged sides exposed to sunlight.86

 Because male inmates in the facility 

had a direct sightline into the exposed sides of the women’s recreation cage, 

MDC Brooklyn staff added metal sheeting to the exposed sides, which left only 

small portions, at the top and bottom, uncovered, further restricting the amount of 

natural light.87

 

Some BOP staff acknowledged that the limited access to sunlight for the 

sentenced female inmates was not ideal, and in our report on the Federal Bureau of 

 

84

 NAWJ Women in Prison Committee, Visit to BOP’s Metropolitan Detention Center (MDC), 

Brooklyn, New York (March 2015) and Second Visit to BOP’s MDC, Brooklyn, New York (June 2016). 

85

 In particular, NAWJ cited the American Bar Association Standards on Treatment of 

Prisoners, Standard 23-3.1(a) 3rd edition, 2011, which states that “a correctional facility should not 

deprive prisoners of natural light, of light sufficient to permit reading throughout prisoners’ housing 

areas, or of reasonable darkness during the sleeping hours.” Additionally, NAWJ cited a standard 

related to access to exercise and sports for inmates, which is outlined in the UN Standard Minimum 

Rules for the Treatment of Prisoners, 1977. The standard specifies that “every prisoner who is not 

employed in outdoor work shall have at least one hour of suitable exercise in the open air daily if the 

weather permits.”

86

 These differences exist because MDC Brooklyn is a high-rise building, with all of its 

departments housed in a single building. As a result, inmates rarely leave the floor their unit is on. 

FCI Danbury and other institutions designed for sentenced inmates consist of multiple smaller 

buildings surrounded by a perimeter fence. Inmates in these types of institutions have access to the 

outdoors daily because they must go outside to get from their housing units to the cafeteria, the 

medical clinic, classrooms, and other departments. 

87

 Judges belonging to NAWJ, who visited MDC Brooklyn in March 2015, estimated that there 

was an 18-inch opening at the top and a 6-inch opening at the bottom of the exposed walls. We did 

not take measurements at the time of our visit in August 2017 because most of the metal sheeting 

had been removed in late 2016. 
40

Prisons’ Use of Restrictive Housing for Inmates with Mental Illness, a BOP 

Psychologist explained that access to sunlight is important for an inmate’s mental 

and physical well-being.88 Although the level of natural light in the recreation space 

was below the level BOP generally considers appropriate for long-term confinement, 

a February 2015 American Correctional Association (ACA) accreditation report on 

MDC Brooklyn did not identify natural light levels as a concern.89 

We also found that female inmates assigned to MDC Brooklyn did not have 

the range of programming that is normally available at institutions for sentenced 

inmates. According to BOP’s program statement on Education, Training, and 

Leisure Time, detention centers are exempt from providing the same education 

programs that are offered at other BOP institutions.90 We believe that this 

exemption is reasonable when the only mission of a detention center is to provide 

short-term housing for pretrial inmates. However, in the case of MDC Brooklyn, the 

exemption limited the programming opportunities below the level BOP determined 

is appropriate for sentenced inmates. 

Additionally, we found that MDC Brooklyn did not offer the Resolve program 

(discussed above) because it did not have a Resolve Coordinator on staff. We 

found this surprising given the emphasis that BOP places on trauma-informed care. 

MDC Brooklyn’s Chief Psychologist told us that it was difficult to conduct those 

group psychology programs for which MDC Brooklyn did have sufficient staff 

because the population of sentenced inmates was too small to generate the number 

of interested inmates required for participation. When discussing the availability of 

programming at MDC Brooklyn, the Women and Special Populations Branch 

Administrator told us that in retrospect she believes that BOP should have better 

recognized the need to provide MDC Brooklyn with additional programming 

resources before it transferred sentenced female inmates there. 

Although not directly related to the work of this review, a separate OIG 

investigation determined that, during the time that sentenced female inmates were 

assigned to MDC Brooklyn, multiple custody staff sexually assaulted female 

inmates.91

 We discuss the findings of this investigation of staff in the text box

below. 

 

88

 DOJ OIG, Use of Restrictive Housing, 23.

89

 The accreditation report determined that MDC Brooklyn was compliant with all relevant 

light access requirements outlined in ACA’s Standards for Adult Local Detention Facilities. ACA’s 

standards for access to light, as relevant to our review, are the same for both detention facilities and 

adult correctional institutions. However, ACA’s accreditation report covers the institution as a whole 

and does not separately describe the female and male housing units. ACA, Standards for Adult Local 

Detention Facilities, 4th edition and 2012 Standards Supplement. 

90

 BOP Program Statement 5300.21, Education, Training, and Leisure Time Standards, 

February 18, 2002. 

91

 We note that as a result of OIG investigations, six BOP staff members from five additional 

female institutions have pled guilty to sexual abuse of a ward since January 2016. 
41

While BOP recognizes that detention centers offer sentenced inmates less 

suitable recreation space and fewer programming opportunities than would be 

available in other institutions, we found that BOP does not have a policy that limits 

the amount of time sentenced inmates can be assigned to a detention center. We 

recognize that, in the case of FCI Danbury, BOP made a difficult decision either to 

transfer some female inmates to institutions that offer the appropriate type of 

recreation space and programming opportunities or to transfer female inmates to a 

detention center closer to their homes. However, we believe that BOP may 

continue to confine sentenced inmates for an extended period of time in conditions 

it recognizes as inappropriate unless it establishes a policy that defines how long a 

sentenced inmate can be confined in a detention center or ensures that the 

conditions of confinement at a detention center more closely approximate those of 

a non-detention center when sentenced inmates are housed there. 

The Lack of a SHU for Female Inmates at Danbury Has Been Disruptive to Operations 

During our fieldwork, we found that changes at FCI Danbury have created a 

separate challenge for BOP in enforcing discipline on female inmates. In particular, 

we found that BOP built the new low security female institution on the FCI Danbury 

campus without a SHU, a unit used to separate inmates from the general 

OIG Investigation of Sexual Assaults at MDC Brooklyn

As a result of a nearly yearlong OIG investigation into allegations of sexual abuse of 

female inmates at MDC Brooklyn, the U.S. Attorney’s Office for the Eastern District of New 

York filed indictments in May 2017 alleging that Lieutenants Carlos Martinez and Eugenio Perez 

and Correctional Officer Armando Moronta engaged in criminal sexual acts with female inmates 

between 2013 and 2016. 

In January 2018, Martinez was found guilty on 20 counts that covered 4 sexual assaults 

between December 2015 and April 2016. The evidence at trial established that Martinez 

repeatedly raped a female inmate who spoke limited English and worked as a cleaner inside 

the prison. Specifically, Martinez raped his victim while she cleaned the Lieutenants’ office on 

the weekends, when that area of the institution is generally empty, and monitored security 

video footage of the surrounding area to make sure no one would discover him committing 

sexual assault. Martinez also threatened his victim with placement in the SHU and additional 

jail time if she told anyone what he had done. 

In May 2018, Perez was found guilty on 23 counts that covered sexual abuse of 5 women 

between January 2013 and September 2016. The evidence at trial established that Perez lured 

each of his victims into isolated situations by arranging for them to clean the Lieutenants’ 

office at night and then used physical force and intimidation to compel the victims to engage in 

various sexual acts with him, including oral sex. Perez used his authority over the inmates to 

ensure they did not report the abuse. 

In November 2017, Moronta pled guilty to four counts of sexual abuse of a ward. 

Specifically, between May and June 2016, Moronta engaged in criminal sexual contact and acts 

with three female inmates, including fondling a female inmate and causing inmates to perform 

oral sex on him while he was assigned to guard their unit. 

Sources: U.S. Attorney’s Office, Eastern District of New York, Press Releases, January 19, 

2018; May 14, 2018; and November 8, 2017
42

population for protective or disciplinary purposes.92 Because BOP does not house 

female inmates and male inmates in the same unit, Danbury staff cannot use the 

SHU at the all-male institution to house female inmates for whom the SHU is 

appropriate. As a result, when Danbury staff determine that a female inmate 

should be separated from the general population, they must transport the inmate 

more than 150 miles to Federal Detention Center (FDC) Philadelphia. 

We found that before construction on the new low security institution was 

completed, both the former and current Wardens of FCI Danbury expressed concern 

to BOP leadership that the construction plans did not include a SHU. They further 

explained that, without secure housing, Danbury staff would be forced to utilize 

secure housing in other facilities, which could cause operational problems. Despite 

these warnings, the BOP Central Office told OIG that it did not include a SHU in the 

construction plans because the new institution would have only a small number of 

low security inmates (its capacity is 192) and BOP did not believe this population 

necessitated the construction of a SHU. 

Danbury staff told us that it is difficult to enforce rules and investigate 

misconduct at the institution given this arrangement. During our visit to FCI 

Danbury, we found that the operational challenges predicted by the former and 

current Wardens have manifested themselves. According to the current Warden, 

Danbury staff are less likely to recommend SHU placement for an inmate who 

misbehaves because of the challenges of transporting those inmates to FDC 

Philadelphia. The Warden also told us that the female inmates understand these 

challenges and, on occasion, are emboldened to misbehave. 

FCI Danbury’s Lieutenant for Special Investigative Services also told us that 

it is difficult to investigate inmate misconduct once the suspected inmates have 

been transferred to FDC Philadelphia because the Lieutenant cannot conduct 

in-person interviews with Danbury inmates housed at FDC Philadelphia. Instead, 

he must rely on a Special Investigative Services investigator at FDC Philadelphia to 

conduct the interview. The Lieutenant said that, although he is satisfied with the 

quality of his FDC Philadelphia colleagues’ investigative work, he would prefer to 

conduct the interviews himself because he is more familiar with the inmates and 

the situation he is investigating than his colleagues in other institutions. 

The current Warden of FCI Danbury explained that in order to minimize the 

burden of transferring female SHU inmates long distances she was looking to 

identify a nearby jail that could house Danbury’s female SHU inmates. This solution 

has been implemented by at least one other similarly situated institution, which we 

visited during our review. However, as of August 2017 the Warden had not yet 

identified an appropriate jail. 

92

 With the opening of the new low security female institution, at the time of our review there 

were three institutions on the FCI Danbury campus: (1) FCI Danbury, a low security male institution 

that, prior to May 2014, was a low security female institution; (2) Federal Prison Camp Danbury, a 

minimum security female institution; and (3) Federal Satellite Low Danbury, the new low security 

female institution. We refer to BOP staff who work at any of the three institutions as “Danbury staff.”
43

CONCLUSION AND RECOMMENDATIONS 

Conclusion 

Overall, we concluded that BOP has not been strategic in its management of 

female inmates. At the Central Office level, we found that BOP only recently took 

initial steps to implement oversight of the Female Offender Manual. We also found 

that BOP may not have allocated sufficient resources to the Women and Special 

Populations Branch to fulfill its complete range of responsibilities with regard to 

female inmates and that it has not ensured that BOP decision makers understand 

how female inmates’ needs differ from those of male inmates. At the institution 

level, we identified deficiencies in how BOP staffs its trauma treatment program, 

makes staff and inmates aware of its pregnancy programs, distributes feminine 

hygiene products, and staffs correctional posts where female inmates are searched. 

Finally, we found that BOP’s conversion of FCI Danbury from a female to a male 

institution negatively affected female inmates transferred to MDC Brooklyn. For 

BOP to be fully effective at appropriately managing female inmates, we believe that 

it must take a holistic approach at the Central Office level to identify and address 

issues affecting this population. 

Recommendations 

To ensure that BOP is better positioned to identify and respond to female 

inmates’ needs at the Central Office level, provide female inmates with 

programming that addresses their unique needs, and consider female inmates’ 

needs in policy and operational decisions, we recommend that BOP: 

1. Fully implement ongoing plans to create a permanent program review for the

Female Offender Manual that includes in-person visits and an institutionspecific rating.

2. Determine the appropriate level of staffing that should be allocated to the

Women and Special Populations Branch based on an analysis of its broad

mission and responsibilities.

3. Ensure that all officials who enter into National Executive Staff positions have

taken appropriate, current training specific to the unique needs of female

inmates and trauma-informed correctional care.

4. Identify ways to expand the staffing of the Resolve program.

5. Improve the communication of its pregnancy program availability and

eligibility criteria to relevant staff and pregnant inmates to ensure consistent

understanding across BOP institutions.

6. Improve data tracking to allow it to more easily identify inmates who are

aware of, interested in, eligible for, or participating in pregnancy programs,

as well as to assess barriers to participation.
44

7. Clarify guidance on the distribution of feminine hygiene products to ensure 

sufficient access to the amount of products inmates need free of charge. 

8. Improve the availability of female staff at locations in female institutions 

where inmate searches are common, through the establishment of genderspecific posts or other methods. 

9. Establish policy that determines how long sentenced inmates can be confined 

in a detention center, or ensures that the conditions of confinement and 

inmate programming at a detention center more closely approximate those 

of a non-detention center when sentenced inmates are housed there. 

10. Explore options to procure female Special Housing Unit space closer to 

Federal Correctional Institution Danbury. 
APPENDIX 1 

45

METHODOLOGY OF THE OIG REVIEW 

Standards 

OIG conducted this review in accordance with the Council of the Inspectors 

General on Integrity and Efficiency’s Quality Standards for Inspection and 

Evaluation (January 2012). 

Purpose and Scope 

OIG conducted this review to examine BOP’s efforts and capacity to ensure 

that BOP-wide policies, programs, and decisions address the unique needs of 

female inmates. Our review analyzed BOP inmate population data, as well as BOP 

policies and programs from FY 2012 through FY 2016. We also included in our 

analysis the revised Female Offender Manual issued by BOP in November 2016, as 

well as new staff training materials that BOP launched in FY 2017, during the course 

of our fieldwork. We focused our analysis on how BOP’s Women and Special 

Populations Branch and other relevant BOP branches implement gender-responsive 

trauma treatment and pregnancy programs and examined how BOP has 

implemented policies relevant to physical searches of female inmates and inmate 

access to feminine hygiene products. Lastly, we examined how BOP’s decision to 

convert its low security institution in Danbury, Connecticut, from a female 

institution to a male institution affected the female inmates who had been housed 

there. Our review focused on federal offenders incarcerated in the 28 BOPmanaged institutions whose populations are all female or mixed gender. We 

excluded from our analysis inmates housed in contract halfway houses and contract 

state and local institutions. BOP does not house female inmates in private 

correctional institutions. 

Methodology 

Our fieldwork, conducted from July 2016 through September 2017, included 

interviews, data collection and analyses, and document reviews. We interviewed 

officials from six divisions of BOP’s Central Office. We conducted site visits to 12 of 

the 28 institutions where BOP houses female inmates, including 5 institutions 

through video teleconference and 7 institutions in person. For each site visit, we 

interviewed institution officials and staff. For those institutions that we visited in 

person, we also interviewed inmates, toured housing units and programming space, 

and observed the physical landscapes. We visited all three types of BOP institutions 

for female inmates: minimum security, low security, and administrative. Our site 

visits also encompassed female institutions; mixed-gender institutions, including a 

detention center; and BOP’s only Federal Medical Center for female inmates. 

The seven sites that we visited in person were Federal Correctional 

Institution (FCI) Aliceville, Federal Medical Center Carswell, Federal Prison Camp 

(FPC) Bryan, FCI Dublin, Secure Female Facility Hazelton, Metropolitan Detention 

Center (MDC) Brooklyn, and FCI Danbury. The five sites where we conducted video 

teleconferences were FPC Alderson, Federal Correctional Complex (FCC) Victorville, 

FCI Marianna, FCC Coleman, and FCI Phoenix. 
46

Data Analysis 

We analyzed both raw data and data reports provided by BOP, from its 

prisoner management system, SENTRY, to assess BOP’s inmate population and 

pregnancy program participation. Additionally, to determine whether BOP housed 

an inmate closer to or farther from home following the inmate’s transfer from FCI 

Danbury, we reviewed SENTRY zip code and transfer location data for the 

1,127 inmates transferred from FCI Danbury between August 2013 and March 

2014. We performed two SAS calculations to conduct this analysis. First, we 

calculated the distance between a transferred inmate’s home zip code and FCI 

Danbury’s zip code. Second, we calculated the distance between that inmate’s 

home zip code and the zip code of the BOP institution to which that inmate was 

transferred. 

We did not consider the 445 non-U.S. citizen inmates whom BOP transferred 

or released from FCI Danbury in this analysis because most of these inmates did 

not have a U.S. residence prior to incarceration. Due to data limitations, we were 

also unable to conduct a distance analysis for 7 of the 682 U.S. citizen female 

inmates transferred or released from FCI Danbury. 

Interviews 

We conducted 217 interviews during the course of this review. We 

interviewed Central Office officials, including the Assistant Director for the 

Correctional Programs Division, the General Counsel, a Senior Deputy Assistant 

Director for the Program Review Division, the Assistant Director of the Reentry 

Services Division, the Senior Deputy Assistant Director for the Reentry Services 

Division, the Women and Special Populations Branch Administrator, the Residential 

Reentry Management Branch Administrator, the Education Branch Assistant 

Administrator, the former and current Chiefs and a Section Chief of the Designation 

and Sentence Computation Center, the Acting Chief of the Construction and 

Environmental Assessments Branch, the Chief of Mental Health Services, a Mental 

Health Treatment Coordinator, and two Social Science Research Analysts in the 

Capacity Planning Branch. 

During our site visits, we interviewed 193 staff and inmates, including 

10 Wardens, 6 Associate Wardens, 1 Executive Assistant, 1 Captain, 9 Lieutenants, 

13 Correctional Officers, 5 Chief Psychologists, 1 Acting Chief Psychologist, 

4 Resolve Coordinators, 3 Psychologists, 1 Female Integrated Treatment Program 

Coordinator, 1 Chief Social Worker, 5 Social Workers, 6 Health Services 

Administrators, 5 Assistant Health Services Administrators, 2 Clinical Directors, 

1 Infectious Disease Coordinator, 1 Health Technician, 1 Pharmacy Technician, 

10 Supervisors of Education, 2 Assistant Supervisors of Education, 1 Supervisor of 

Recreation, 1 Case Management Coordinator, 1 Assistant Case Management 

Coordinator, 3 Reentry Services Coordinators, 3 Unit Managers, 14 Case Managers, 

14 Counselors, 1 Facilities Manager, 1 Maintenance Supervisor, 1 Supervisory 

Contract Specialist, and 61 inmates. Additionally, we interviewed the program 

coordinators from four different contract sites that operated BOP’s Mothers and 

Infants Nurturing Together residential program as of December 2017. 
47

Outside BOP, we interviewed a Section Chief from the DOJ Civil Rights 

Division, Special Litigation Section, as well as three judges from the National 

Association of Women Judges who were familiar with BOP operations related to 

female inmates. 

Finally, we interviewed officials from the correctional agencies of four states 

(Alabama, Kansas, Washington, and Wisconsin), as well as the U.S. Navy, to 

discuss how those agencies meet similar challenges in the management of their 

female inmate populations. In the report, we refer to the four states and the Navy 

collectively as five state correctional agencies. 
APPENDIX 2 

48

MAP OF BOP INSTITUTIONS FOR SENTENCED FEMALE INMATES 

1

9

6

5

1 1 3

4

2

7

8

1 0

1 3

1 4

1 5

1 6

1 2

Key to the Map 

# Name

Number of 

Female 

Institutions

on Site

Security Level(s) of 

Female Institution(s)

1 Federal Prison Camp Alderson 1 Minimum

2 Federal Correctional Institution Aliceville 2 Low and Minimum

3 Federal Prison Camp Bryan 1 Minimum

4 Federal Medical Center Carswell 2 Minimum and Administrative

5 Federal Correctional Center Coleman 1 Minimum

6 Federal Correctional Institution Danbury 2 Low and Minimum

7 Federal Correctional Institution Dublin 2 Low and Minimum

8 Federal Correctional Institution Greenville 1 Minimum

9 Federal Correctional Institution Hazelton 1 Low

10 Federal Medical Center Lexington 1 Minimum

11 Federal Correctional Institution Marianna 1 Minimum

12 Federal Correctional Institution Pekin 1 Minimum

13 Federal Correctional Institution Phoenix 1 Minimum

14 Federal Correctional Institution Tallahassee 1 Low

15 Federal Correctional Institution Victorville II 1 Minimum

16 Federal Correctional Institution Waseca 1 Low
APPENDIX 3 

49

BOP’S RESPONSE TO THE DRAFT REPORT 
50
51
APPENDIX 4 

52

OIG ANALYSIS OF BOP’S RESPONSE 

OIG provided a draft of this report to BOP for its comment. BOP’s response 

is included in Appendix 3 to this report. OIG’s analysis of BOP’s response and the 

actions necessary to close the recommendations are discussed below. Please 

provide a status update on the 10 recommendations by December 31, 2018. 

Recommendation 1: Fully implement ongoing plans to create a permanent 

program review for the Female Offender Manual that includes in-person visits and 

an institution-specific rating. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would fully implement ongoing plans to create a permanent program review for the 

Female Offender Manual that includes in-person visits and an institution-specific 

rating. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide a copy of program review guidelines for the 

Female Offender Manual that include in-person visits and an institution-specific 

rating, as well as a schedule of Female Offender Manual program reviews by 

institution for calendar year 2019. 

Recommendation 2: Determine the appropriate level of staffing that 

should be allocated to the Women and Special Populations Branch based on an 

analysis of its broad mission and responsibilities. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would determine the appropriate level of staffing that should be allocated to the 

Women and Special Populations Branch based on an analysis of its broad mission 

and responsibilities. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide a copy of the analysis BOP performed of the 

branch’s mission and responsibilities, including a conclusion about the appropriate 

staffing level for the work identified. 

Recommendation 3: Ensure that all officials who enter into National 

Executive Staff positions have taken appropriate, current training specific to the 

unique needs of female inmates and trauma-informed correctional care. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would ensure that all officials who enter into National Executive Staff positions have 
53

taken appropriate, current training specific to the unique needs of female inmates 

and trauma-informed correctional care. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide an update to the Bureau Mandatory Training 

Standards or other relevant policy showing how BOP will ensure that all officials 

entering into National Executive Staff positions have taken BOP’s current training 

specific to the unique needs of female inmates and trauma-informed correctional 

care. 

Recommendation 4: Identify ways to expand the staffing of the Resolve 

program. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would identify ways to expand the staffing of the Resolve program. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide OIG with a copy of BOP’s analysis of the Resolve 

program’s staffing needs and the option BOP selected. 

Recommendation 5: Improve the communication of its pregnancy program 

availability and eligibility criteria to relevant staff and pregnant inmates to ensure 

consistent understanding across BOP institutions. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would improve the communication of its pregnancy program availability and 

eligibility criteria to relevant staff and pregnant inmates to ensure consistent 

understanding across BOP institutions. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide a copy of any notices, operations memoranda, 

program statements, or other written materials used to communicate information 

about pregnancy program availability and eligibility criteria to inmates and 

institution staff. Please also include a description of how the materials were 

disseminated and a list of the institutions and position titles of the addressees who 

received them. 

Recommendation 6: Improve data tracking to allow it to more easily 

identify inmates who are aware of, interested in, eligible for, or participating in 

pregnancy programs, as well as to assess barriers to participation. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would improve data tracking to allow it to more easily identify inmates who are 
54

aware of, interested in, eligible for, or participating in pregnancy programs, as well 

as to assess barriers to participation. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please describe how BOP intends to track pregnant inmates to 

more easily identify inmate awareness of, interest in, eligibility for, participation in, 

and barriers to participation in BOP’s two pregnancy programs. 

Recommendation 7: Clarify guidance on the distribution of feminine 

hygiene products to ensure sufficient access to the amount of products inmates 

need free of charge. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would clarify guidance on the distribution of feminine hygiene products to ensure 

sufficient access to the amount of products inmates need free of charge. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide a copy of BOP policy clarifying that female inmates 

should have sufficient access to the amount of feminine hygiene products they need, 

free of charge, and a description of how the policy was disseminated, including a list 

of the institutions and position titles of the addressees who received it. 

Recommendation 8: Improve the availability of female staff at locations in 

female institutions where inmate searches are common, through the establishment 

of gender-specific posts or other methods. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would improve the availability of female staff at locations in female institutions 

where inmate searches are common, through the establishment of gender-specific 

posts or other methods. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please describe the method BOP selected to improve the 

availability of female staff at locations in female institutions where inmate searches 

are common. 

Recommendation 9: Establish policy that determines how long sentenced 

inmates can be confined in a detention center, or ensures that the conditions of 

confinement and inmate programming at a detention center more closely 

approximate those of a non-detention center when sentenced inmates are housed 

there. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would establish policy that determines how long sentenced inmates can be confined 
55

in a detention center, or ensures that the conditions of confinement and inmate 

programming at a detention center more closely approximate those of a nondetention center when sentenced inmates are housed there. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please provide a copy of BOP policy that defines the length of 

time sentenced inmates can be confined in a detention center or describe how BOP 

would ensure that the conditions of confinement and inmate programming at 

detention centers more closely approximates those of a non-detention center when 

sentenced inmates are housed there. 

Recommendation 10: Explore options to procure female Special Housing 

Unit space closer to Federal Correctional Institution Danbury. 

Status: Resolved. 

BOP Response: BOP concurred with the recommendation and stated that it 

would explore options to procure female Special Housing Unit space closer to 

Federal Correctional Institution Danbury. 

OIG Analysis: BOP’s planned actions are responsive to our 

recommendation. Please describe the options BOP considered to procure female 

Special Housing Unit space closer to Federal Correctional Institution Danbury, 

research conducted by BOP to assess each option considered, and the option BOP 

selected. 
U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL

950 Pennsylvania Avenue, Northwest

Suite 4760

Washington, DC 20530-0001

Also at Oversight.gov

The Department of Justice Office of the Inspector General (DOJ OIG) is a 

statutorily created independent entity whose mission is to detect and deter 

waste, fraud, abuse, and misconduct in the Department of Justice, and to 

promote economy and efficiency in the Department’s operations.

To report allegations of waste, fraud, abuse, or misconduct regarding DOJ 

programs, employees, contractors, grants, or contracts please visit or call the

DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

Website Twitter YouTube

oig.justice.gov @JusticeOIG JusticeOIG