U.S. Department of Justice
Federal Bureau of Prisons

Program
Statement

OPI:
NUMBER:
DATE:
SUBJECT:

CPD/CPB
P5322.13
5/16/2014
Inmate Classification and
Program Review

RULES EFFECTIVE: 7/24/2006

1. PURPOSE AND SCOPE. This Program Statement provides policy
and procedure for the classification and subsequent review of the
security, custody and program needs of inmates who have been
designated for service of sentence.
2. SUMMARY OF CHANGES.
Statement include:

Significant changes to this Program



Inmates subject to Sex Offender Registration and Treatment
Notification pursuant to Title 18 U.S.C. § 4042(c)) will be
notified at initial classification via a copy of the Program
Review Report;



Appendix A (Federal regulations published in the Federal
Register, June 23, 2006 [71 FR 26007]) has been corrected;



References to “SENTRY-generated” Program Review Report and
Triennial Progress Report have been deleted.

3. PROGRAM OBJECTIVES.
Statement are:

P5322.13
5/16/2014
Page 2
The expected results of this Program

a. All Initial Classification and Program Review decisions
will be made by a team of correctional specialists;
b. All departments will have the opportunity to contribute to
the classification and program review process;
c. All inmates will have the opportunity to communicate
directly with the staff who make classification, custody and
program review decisions; and
d. All inmates will be classified within appropriate time
frames in accordance with their security, custody, and program
needs.
4.

DIRECTIVES AFFECTED

a.

Directive Rescinded
P5322.12

b.

Inmate Classification and Program Review
(11/29/06)

Directives Referenced
P1330.18
P5070.10
P5070.12
P5100.08
P5110.15
P5110.17
P5111.03
P5140.40
P5215.05
P5290.14
P5290.15
P5321.07
P5325.07
P5350.28
P5380.08

Administrative Remedy Program (1/6/14)
Responses to Judicial Recommendations and U.S.
Attorney Reports (6/30/97)
Forensic and Other Mental Health Evaluations
(4/16/08)
Inmate Security Designation and Custody
Classification (9/12/06)
Notifications of Release to State and Local Law
Enforcement Officials (8/30/00)
Notification Requirements Upon Release of Sex
Offenders, Violent Offenders, and Drug Traffickers
(5/16/14)
Mariel Cuban Detainees (10/25/99)
Transfer of Offenders To or From Foreign
Countries (8/4/11)
Youth Corrections Act (YCA), Inmates and
Programs (3/17/99)
Admission and Orientation Program (4/3/03)
Intake Screening (3/30/09)
Unit Management Manual (9/16/99)
Release Preparation Program (12/31/07)
Literacy Program (GED Standard) (12/1/03)
Inmate Financial Responsibility Program
(8/15/05)

P5322.13
5/16/2014
Page 3
P5800.11
P5803.08
P7331.04
T5802.02

Inmate Central File, Privacy Folder, and Parole
Mini-Files (12/31/97)
Progress Reports (2/27/14)
Pretrial Inmates (1/31/03)
SENTRY General Use Technical Reference Manual
(7/10/00)

c. Rules cited in this Program Statement are contained in
28 CFR 524.10-11 and 551.107 see Attachment A)
5.

STANDARDS REFERENCED

a. American Correctional Association 3rd Edition Standards for
Adult Local Detention Facilities: 3-ALDF-IE-06, 3-ALDF-4B-01, and
3-ALDF-4B-02
b. American Correctional Association 4th Edition Standards for
Adult Correctional Institutions: 4-4295, 4-4296, 4-4297, 4-4298,
4-4299, 4-4300, 4-4301, 4-4302, and 4-4303
6. PRETRIAL/HOLDOVER AND/OR DETAINEE PROCEDURES. Procedures for
pretrial inmates are specified in the Pretrial Inmate Program
Statement. This Program Statement is not applicable to holdover
inmates. Additional direction regarding long-term detainees may
be found in the Mariel Cuban Detainees Program Statement, which
also includes procedures on Mariel Cubans serving federal
sentences.
7. CLASSIFICATION TEAM. At a minimum, each unit team will
include the inmate’s assigned Unit Manager or designee, Case
Manager, and Correctional Counselor. An Education Advisor and a
Psychology Services representative are also ordinarily members of
the team.
The Education Advisor is the unit team's consultant and expert
regarding all education, recreation, and vocational training
matters. The Education Advisor may be assigned to one or more
unit teams and, therefore, may not be able to attend all Initial
Classification or Program Review meetings.
While attendance at these meetings is preferred and strongly
recommended, a local variance may be granted with the Warden's
written approval.
When not in attendance, the Education Advisor will provide the
unit team with a written report of the progress and/or measurable
needs of all unit inmates relative to education, recreation, and
vocational training matters at each Initial Classification and

P5322.13
5/16/2014
Page 4
subsequent Program Review using the Education Progress Report
(Attachment B). This written report will be provided to the Unit
Manager prior to the team meeting. Education recommendations or
requirements should include target time frames for program
completion, and measurable assessments during participation in
courses.
The Unit Psychologist is not required to serve as a regularly
attending unit team member. However, Unit Psychologists are
responsible for providing the unit team with written
psychological reports for inmates who are scheduled for Initial
Classification or Program Review who have regular contact with
Psychology Services staff. This written report will be provided
to the Unit Manager prior to the team meeting.
Health Services staff will ensure that SENTRY Medical Duty Status
(MDS) assignments are accurate and current.
8. INITIAL CLASSIFICATION AND PROGRAM REVIEWS. There are two
types of regularly scheduled unit team meetings, Initial
Classification and Program Reviews. The Unit Manager monitors
the scheduling of unit team meetings and, therefore, must ensure
Case Managers meet Initial Classification and Program Review time
requirements.
When practicable, unit staff will hold an Initial Classification
or Program Review as scheduled when the inmate is held in the
Special Housing Unit. However, any delay should ordinarily not
exceed two weeks from the originally scheduled review and the
reason for the delay should be documented on the Program Review
Report.
a. The purpose of Initial Classification is to develop a
program plan for the inmate during his/her incarceration. This
plan should include work and programming activities which will
assist the inmate to develop skills to make a successful
transition back into the community.
Initial Classification occurs within 28 calendar days of
arrival at the designated institution for each newly committed
inmate (new commit, parole, mandatory release and supervision
violators) following sentencing or return to custody as a
violator.
Former Study and Observation cases should be scheduled for
Initial Classification within 28 calendar days of receipt of the
Inmate Central File, but no later than 90 calendar days after
arrival if no Inmate Central File is available.

P5322.13
5/16/2014
Page 5
b. At Program Reviews, progress in recommended programs will
be reviewed, and new programs recommended based upon skills the
inmate has gained during incarceration. Program Reviews occur at
least once every 180 calendar days.
When an inmate is within 12 months of the projected release
date, staff will conduct a Program Review at least once every 90
calendar days. When an inmate is re-designated, a Program Review
must be held within 28 calendar days of the inmate’s arrival at
the new institution.
In some cases, a Program Review date may occur while an inmate
is away from the institution, or in the custody of other law
enforcement agencies. Then, the unit team must conduct a Program
Review meeting within two weeks of the inmate's return.
Otherwise, the inmate's next Program Review will occur as
scheduled.
Unit team members are to review all relevant information before
Initial Classification or a Program Review. Additionally, each
team member will provide the following specific information at
the team meeting.
(1) Ordinarily, the Unit Manager will chair all Initial
Classifications and Program Reviews where CCC referral decisions
are considered. Other Program Reviews may be chaired by another
staff member. The Unit Manager will monitor the scheduling of an
inmate's appearance before the unit team and all other team
actions. The Unit Manager’s or Chairperson’s signature on the
Program Review Report indicates that:
(a)

The information contained on the Acknowledgment of
Inmate forms (BP-407 and 408) is correct,
complete, and filed in Section 3 of the Inmate
Central File;

(b)

The Judgment(s) in a Criminal Case and the
Statement of Reasons were reviewed to ensure any
judicial recommendations requiring unit team
actions are addressed;

(c)

The inmate's trust fund record is obtained for all
Program Reviews (data will include deposit,
balance, and purchase activity from the prior
Initial Classification or Program Review to the
present team meeting);

P5322.13
5/16/2014
Page 6
(d)

The Program Review Report (replaces the BP-571) is
signed, certifying that all required team members
are present and that the Program Review Report is
current and accurate; and

(e)

All SENTRY data is current, accurate and complete,
including:
•

Assignments in the work, drug, religion,
Inmate Financial Responsibility Program,
Victim Witness Program categories, and all
case management activity (CMA) assignments;

•

Identifying data and numbers;

•

Sentence related transactions;

•

Security Designation Data, CMC Clearance and
Separatee Data, and Custody Classification
forms; and

•

Chronological Disciplinary Record (as
compared with incident report(s)and
associated hearing.

(2) The Case Manager schedules the inmate's appearance
before the unit team, and provides a verbal summary of the
inmate's:
•

Current offense;

•

Prior record;

•

Social situation;

•

Security/custody classification;

•

Central Inmate Monitoring System (CIM) concerns;

•

Financial Responsibility Program obligations; and

•

Release Preparation Program participation, and
special programming considerations (Drug Abuse
Program, Mental Health Program, etc.).

(3) The Correctional Counselor provides a verbal summary of
the inmate’s:

P5322.13
5/16/2014
Page 7
•

Work performance;

•

Participation in individual or group counseling;

•

General adjustment;

•

Living quarters sanitation;

•

The Correctional Counselor also contacts Health
Services staff, when necessary, to ensure SENTRY
MDS assignments are current and accurate; and

•

When the Education Advisor is unable to attend a
unit team meeting, the Correctional Counselor
provides a summary of the inmate's education test
results, recommended educational program needs,
and progress toward completion of education and
other applicable release readiness programs, using
Attachment B, provided by the Education Advisor.

c. A team docket will be prepared for each unit team meeting
(Initial Classification or Program Review), listing the name and
register number of each inmate scheduled for appearance and the
date and time of the meeting.
Dockets will be posted conspicuously in the unit at least 48
hours prior to the meeting (or inmates must be otherwise notified
by staff at least 48 hours prior if they do not have access to
such posting). The inmate may waive the 48-hour notice in
writing.
The inmate’s attendance at Initial Classification or Program
Review is expected. Ordinarily, if the team meeting is properly
scheduled and the inmate fails to appear, disciplinary action
will be taken. If the inmate refuses to appear, staff will
document on the Program Review Report the inmate’s refusal, and
if known, the reason. A copy of the Program Review Report will
be forwarded to the inmate.
d. Staff must complete a Program Review Report at the
inmate's Initial Classification and all subsequent Program
Reviews. This report ordinarily includes information on the
inmate’s needs and offers a correctional program designed to
meet those needs.
All correctional programs will be stated in measurable terms,
establishing time limits, performance levels, and specific,
expected program accomplishments.

P5322.13
5/16/2014
Page 8
Note:

On the Program Review Report, in the Section
“GOALS FOR NEXT PROGRAM REVIEW
MEETING” no dates are necessary as it is clear the
time limit is by the next Program Review. Under
“LONG TERM GOALS” a target date should be
established and monitored at each Program Review
for adjustment if necessary.

Example A: GOALS FOR NEXT PROGRAM REVIEW MEETING: Recommend
enrollment in Anger Management counseling group. Enroll in
General Equivalency Diploma (GED) program.
Example B: LONG TERM GOALS: Complete GED by MM/YY. Enroll
in Release Preparation Program (list specific course) by
MM/YY.
Inmates who are classified as CIM cases will be reviewed and
that review documented on the Program Review Report. This
notation will indicate whether the CIM assignment is
appropriate or whether declassification procedures will be
initiated.
e. At Initial Classification, a sentenced inmate is assigned
to a work detail if cleared for duty by Health Services staff.
The unit team must consider the inmate's financial
responsibilities and obligations when considering a work
assignment.
At Initial Classification, staff must notify, in writing, newly
designated inmates, who meet the applicability criteria of Title
18 U.S.C. § 4042(b) and/or (c), that they are subject to
notification and/or registration.
f. Inmates subject to VCCLEA notification pursuant to
Title 18 U.S.C. § 4042(b):
•

Will be notified via a copy of the Program Review
Report; and

•

A copy of the Program Review Report with the
notification statement will be filed in Section 5
(Release Processing) of the Inmate Central File.

g. Inmates subject to Sex Offender Registration and Treatment
Notification pursuant to Title 18 U.S.C. § 4042(c)):

P5322.13
5/16/2014
Page 9
•

Will be notified at initial classification via a copy
of the Program Review Report;

•

Will be renotified at the last program review prior to
release via a copy of the Sex Offender Registration and
Treatment Notification form (BP-A0648); and

•

The original Sex Offender Registration and Treatment
Notification form (BP-A0648) will be filed in Section
5 (Release Processing) of the Inmate Central File.

The Program Review Report will document the inmate's Release
Preparation Program CMA assignments and staff will identify
specific courses recommended and/or courses that the inmate is
currently enrolled in. Staff should refer to the Program
Statement Release Preparation Program for further instruction.
h. The inmate is to be provided with, and must sign for, a
copy of the Program Review Report. If the inmate refuses to
sign for a copy of this report, staff witnessing the refusal
will place a signed statement to that effect on the report.
The Program Review Report is to be filed in Section 2 of the
Inmate Central File. Signatures and unit team actions will be
maintained on the Program Review Report since duplication is not
required on the Inmate Activity Log and the team docket.
The previous six Program Review Reports must be maintained.
9. EFFECT OF A DETAINER ON AN INMATE'S PROGRAM. The existence
of a detainer, by itself, ordinarily does not affect the inmate's
program participation. An exception may occur where the program
is contingent on a specific issue (for example, custody) which is
affected by the detainer.
10. UNSCHEDULED REVIEWS. Institution staff may schedule an
inmate for a Program Review more frequently than regularly
scheduled. Upon request of either the inmate or staff, and with
the concurrence of the Unit Manager, an ad hoc Program Review may
be held. The inmate must be notified by staff at least 48 hours
prior to an ad hoc Program Review. The inmate may waive the 48hour notice in writing.

P5322.13
5/16/2014
Page 10
11. APPEALS PROCEDURE. An inmate may appeal, through the
Administrative Remedy Program, a decision made at Initial
Classification or at a Program Review.
12. TRAINING RESPONSIBILITIES. The Case Management Coordinator
and Unit Manager will ensure that Case Managers and Correctional
Counselors are familiarized with this Program Statement's
requirements during the on the job training periods which are
required for these positions.

/s/
Charles E. Samuels, Jr.
Director

P5322.13
5/16/2014
Attachment A, Page 1
Attachment A. Code of Federal Regulations on Classification of Inmates
§524.10 Purpose.
The purpose of this subpart is to explain the Bureau of Prisons (Bureau) process
for classifying newly committed inmates and conducting program reviews for all
inmates except:
(a) Pretrial inmates, covered in 28 CFR part 551; and
(b) Inmates committed for study and observation.
§524.11 Process for classification and program reviews.
(a) When:
(1) Newly committed inmates will be classified within 28 calendar days of arrival
at the institution designated for service of sentence.
(2) Inmates will receive a program review at least once every 180 calendar days.
When an inmate is within twelve months of the projected release date, staff will
conduct a program review at least once every 90 calendar days.
(b) Inmate appearance before classification team:
(1) Inmates will be notified at least 48 hours before that inmate's scheduled
appearance before the classification team (whether for the initial classification or
later program reviews).
(2) Inmates may submit a written waiver of the 48-hour notice requirement.
(3) The inmate is expected to attend the initial classification and all later program
reviews. If the inmate refuses to appear at a scheduled meeting, staff must
document on the Program Review Report the inmate’s refusal and, if known, the
reasons for refusal, and give a copy of this report to the inmate.

P5322.13
5/16/2014
Attachment A, Page 2
(c) Program Review Report: Staff must complete a Program Review Report at
the inmate’s initial classification. This report ordinarily includes information on
the inmate’s apparent needs and offers a correctional program designed to
meet those needs. The Unit Manager and the inmate must sign the Program
Review Report, and a copy must be given to the inmate.
(d) Work Programs: Each sentenced inmate who is physically and mentally able
is assigned to a program at initial classification. The inmate must participate in
this work assignment and any other program required by Bureau policy, court
order, or statute. The inmate may choose not to participate in other voluntary
programs.

P5322.13
5/16/2014
Attachment B, Page 1

Education Progress Report
To:

, Unit Manager

Prepared by:
Education Advisor
Inmate Name

Register Number

Date

Initial Classification Information
GED/High School: Completed (YES/NO)
Year or Highest Grade Completed
ESL: Completed (YES/NO)
Date of Education Interview:
Recommendations/Comments (Please include information regarding
recommended classes and target enrollment date):

Program Review Information
Class:
Performance:
Attendance:
Target Completion Date:
Hours Completed:
Class:
Performance:
Attendance:
Target Completion Date:
Hours Completed:

Instructor:

Progress: Satisfactory/Unsatisfactory
Instructor:

Progress: Satisfactory/Unsatisfactory

Recommendations/Comments (Please include information regarding
recommended classes and target enrollment date):


U.S. Department of Justice
Civil Rights Division

U.S. Department of Education
Office for Civil Rights
Office of the General Counsel

May 8, 2014
Dear Colleague:
Under Federal law, State and local educational agencies (hereinafter “districts”) are required to
provide all children with equal access to public education at the elementary and secondary level.
Recently, we have become aware of student enrollment practices that may chill or discourage the
participation, or lead to the exclusion, of students based on their or their parents’ or guardians’
actual or perceived citizenship or immigration status. These practices contravene Federal law.
Both the United States Department of Justice and the United States Department of Education
(Departments) write to remind you of the Federal obligation to provide equal educational
opportunities to all children residing within your district and to offer our assistance in ensuring that
you comply with the law. We are writing to update the previous Dear Colleague Letter on this
subject that was issued on May 6, 2011, and to respond to inquiries the Departments received
about the May 6 Letter. This letter replaces the May 6 Letter.
The Departments enforce numerous statutes that prohibit discrimination, including Titles IV and VI
of the Civil Rights Act of 1964. Title IV prohibits discrimination on the basis of race, color, or
national origin, among other factors, by public elementary and secondary schools. 42 U.S.C.
§ 2000c-6. Title VI prohibits discrimination by recipients of Federal financial assistance on the basis
of race, color, or national origin. 42 U.S.C. § 2000d. Title VI regulations, moreover, prohibit
districts from unjustifiably utilizing criteria or methods of administration that have the effect of
subjecting individuals to discrimination because of their race, color, or national origin, or have the
effect of defeating or substantially impairing accomplishment of the objectives of a program for
individuals of a particular race, color, or national origin. See 28 C.F.R. § 42.104(b)(2) and 34 C.F.R.
§ 100.3(b)(2).
Additionally, the United States Supreme Court held in the case of Plyler v. Doe, 457 U.S. 202 (1982),
that a State may not deny access to a basic public education to any child residing in the State,
whether present in the United States legally or otherwise. Denying “innocent children” access to a
public education, the Court explained, “imposes a lifetime hardship on a discrete class of children
not accountable for their disabling status. . . . By denying these children a basic education, we deny

Page 2 – Dear Colleague Letter: School Enrollment Procedures

them the ability to live within the structure of our civic institutions, and foreclose any realistic
possibility that they will contribute in even the smallest way to the progress of our Nation.” Plyler,
457 U.S. at 223. As Plyler makes clear, the undocumented or non-citizen status of a student (or his
or her parent or guardian) is irrelevant to that student’s entitlement to an elementary and
secondary public education.
To comply with these Federal civil rights laws, as well as the mandates of the Supreme Court, you
must ensure that you do not discriminate on the basis of race, color, or national origin, and that
students are not barred from enrolling in public schools at the elementary and secondary level on
the basis of their own citizenship or immigration status or that of their parents or guardians.
Moreover, districts may not request information with the purpose or result of denying access to
public schools on the basis of race, color, or national origin. To assist you in meeting these
obligations, we provide below some examples of permissible enrollment practices, as well as
examples of the types of information that may not be used as a basis for denying a student
entrance to school.
In order to ensure that its educational services are enjoyed only by residents of the district, a
district may require students or their parents to provide proof of residency within the district.
See, e.g., Martinez v. Bynum, 461 U.S. 321, 328 (1983). 1 For example, a district may require copies
of phone and water bills or lease agreements to establish residency. While a district may restrict
attendance to district residents, inquiring into students’ citizenship or immigration status, or that of
their parents or guardians would not be relevant to establishing residency within the district. A
district should review the list of documents that can be used to establish residency and ensure that
any required documents would not unlawfully bar or discourage a student who is undocumented
or whose parents are undocumented from enrolling in or attending school.
As with residency requirements, rules vary among States and districts as to what documents
students may use to show they fall within State- or district-mandated minimum and maximum age
requirements, and jurisdictions typically accept a variety of documents for this purpose. A school
district may not bar a student from enrolling in its schools because he or she lacks a birth certificate
or has records that indicate a foreign place of birth, such as a foreign birth certificate.

1

Homeless children and youth often do not have the documents ordinarily required for school enrollment such as
proof of residency or birth certificates. A school selected for a homeless child must immediately enroll the homeless
child, even if the child or the child’s parent or guardian is unable to produce the records normally required for
enrollment. See 42 U.S.C. § 11432(g)(3)(C)(1).

Page 3 – Dear Colleague Letter: School Enrollment Procedures

Moreover, we recognize that districts have Federal obligations, and in some instances State
obligations, to report certain data such as the race and ethnicity of their student population. While
the Department of Education requires districts to collect and report such information, districts
cannot use the acquired data to discriminate against students; nor should a parent’s or guardian’s
refusal to respond to a request for this data lead to a denial of his or her child’s enrollment.
Similarly, we are aware that many districts request a student’s social security number at enrollment
for use as a student identification number. A district may not deny enrollment to a student if he or
she (or his or her parent or guardian) chooses not to provide a social security number. See 5 U.S.C.
§552a (note). 2 If a district chooses to request a social security number, it shall inform the individual
that the disclosure is voluntary, provide the statutory or other basis upon which it is seeking the
number, and explain what uses will be made of it. Id. In all instances of information collection and
review, it is essential that any request be uniformly applied to all students and not applied in a
selective manner to specific groups of students.
As the Supreme Court noted in the landmark case of Brown v. Board of Education, 347 U.S. 483
(1954), “it is doubtful that any child may reasonably be expected to succeed in life if he [or she] is
denied the opportunity of an education.” Id. at 493. Both Departments are committed to
vigorously enforcing the Federal civil rights laws outlined above and to providing any technical
assistance that may be helpful to you so that all students are afforded equal educational
opportunities. As immediate steps, you first may wish to review the documents your district
requires for school enrollment to ensure that the requested documents do not have a chilling
effect on a student’s enrollment in school. Second, in the process of assessing your compliance
with the law, you might review State and district level enrollment data. Precipitous drops in the
enrollment of any group of students in a district or school may signal that there are barriers to their
attendance that you should further investigate.
We are also attaching frequently asked questions and answers and a fact sheet that should be helpful
to you. Please contact us if you have additional questions or if we can provide you with assistance in
ensuring that your programs comply with Federal law. You may contact the Department of Justice,
Civil Rights Division, Educational Opportunities Section, at (877) 292-3804 or education@usdoj.gov,
the Department of Education Office for Civil Rights (OCR) at (800) 421-3481 or ocr@ed.gov or the
Department of Education Office of the General Counsel at (202) 401-6000. You may also visit
http://wdcrobcolp01.ed.gov/CFAPPS/OCR/contactus.cfm for the OCR enforcement office that serves

2

Federal law provides for certain limited exceptions to this requirement. See Pub. L. No. 93-579, § 7(a)(2).

Page 4 – Dear Colleague Letter: School Enrollment Procedures

your area. For general information about equal access to public education, please visit our websites
at http://www.justice.gov/crt/edo and http://www2.ed.gov/ocr/index.html.
We look forward to working with you. Thank you for your attention to this matter and for taking
the necessary steps to ensure that no child is denied a public education.
Sincerely,

/s/

/s/

/s/

Catherine E. Lhamon
Assistant Secretary
Office for Civil Rights
U.S. Department of Education

Philip H. Rosenfelt
Deputy General Counsel
Delegated the Authority to
Perform the Functions and
Duties of the General Counsel
U.S. Department of Education

Jocelyn Samuels
Acting Assistant Attorney General
Civil Rights Division
U.S. Department of Justice

Attachments


U.S. Department of Justice
Civil Rights Division

U.S. Department of Education
Office for Civil Rights
Office of the General Counsel

Information on the Rights of All Children to Enroll in School:
Questions and Answers for States, School Districts and Parents
These Questions and Answers are intended to assist states and school districts in meeting their
legal obligations to ensure that their enrollment1 policies and practices at the elementary and
secondary school levels do not discriminate on the basis of race, color, or national origin, and do
not bar or discourage students’ enrollment in elementary and secondary school based on their or
their parents’ actual or perceived immigration status. The U.S. Departments of Education and
Justice encourage states and districts to proactively implement supportive enrollment policies and
practices that create a welcoming and inclusive environment for all students.2
Documentation
Q - 1. Should a district inquire into the immigration or citizenship status of a student or parent 3
as a means of establishing the student’s residency in the district?
A - 1. No. Immigration or citizenship status is not relevant to establishing residency in the district,
and inquiring about it in the context of establishing residency is unnecessary and may have a
chilling or a discouraging effect on student enrollment.
Q - 2. Are students, except homeless students as provided by Federal statute, required to show
current residency in a district in order to enroll in a district school?
A - 2. A state or district may establish bona fide residency requirements and thus might require
that all prospective students, except homeless students as defined and provided by the Federal
McKinney-Vento Homeless Assistance Act, 42 U.S.C. §§ 11301 et seq., furnish proof of residency
within the district.

1

For purposes of this guidance, the term “enrollment” also means registration, matriculation, or attendance in school.

2

This Questions and Answers document accompanied the Dear Colleague letter on the Rights of All Children to Enroll
in School, issued by the U.S. Departments of Education and Justice on May 6, 2011. This document has been updated
to respond to additional questions received since the Dear Colleague letter was issued in 2011.
3

For purposes of this guidance, the term “parent” also means guardian or other responsible person under state or local
law.

Revised as of May 8, 2014

Page 2 – Questions and Answers: School Enrollment Procedures

Q - 3. How can students meet requirements to show current residency in a school district?
A - 3. Rules vary among states and districts on what forms of documentation can be used to prove
residency within a district. Districts typically accept a variety of documents as proof of residency,
such as a telephone or utility bill, mortgage or lease document, parent affidavit, rent payment
receipts, a copy of a money order made for payment of rent, or a letter from a parent’s employer
that is written on company letterhead.
A parent must be permitted to establish residency using any of the alternative methods provided
for by state or local law. States and districts cannot apply different rules, or apply the same rules
differently, to children based on their or their parents’ actual or perceived race, color, national
origin, citizenship, immigration status, or other impermissible factor. All students must be treated
equally.4
A district should review the list of documents that can be used to establish residency to ensure that
any required documents would not unlawfully bar or discourage a student who is undocumented
or whose parents are undocumented from enrolling in or attending school.
For example, while a district may choose to include a parent’s state-issued identification or driver’s
license among the documents that can be used to establish residency, a school district may not
require such documentation to establish residency or for other purposes where such a
requirement would unlawfully bar a student whose parents are undocumented from enrolling in
school.
Q - 4. Can a homeless child, including an undocumented homeless child, ever be required to
show residency in a district in order to enroll in a district school?
A - 4. No. Even where a district has valid proof of residency requirements, it must exempt from
those requirements all children and youth who are considered homeless under the Federal
McKinney-Vento Homeless Assistance Act. These children and youth have a right to enroll in
school, even if their families cannot produce the documents that would otherwise be required to
prove residency.
The McKinney-Vento Act defines the term “homeless children and youth” as including, in part,
“children and youths who are sharing the housing of other persons due to loss of housing,
4

Title IV of the Civil Rights Act of 1964, which is enforced by the Department of Justice, prohibits school districts from
taking actions that deprive students of equal protection of the laws. Title VI of the Civil Rights Act of 1964, which is
enforced by the Department of Education, and by the Department of Justice upon referral from a Federal funding
agency or through intervention in an existing lawsuit, prohibits discrimination on the basis of race, color, or national
origin.

Revised as of May 8, 2014

Page 3 – Questions and Answers: School Enrollment Procedures

economic hardship, or a similar reason; are living in motels, hotels, trailer parks, or camping
grounds due to the lack of alternative adequate accommodations; are living in emergency or
transitional shelters; are abandoned in hospitals; or are awaiting foster care placement,” as well as
children of migratory agricultural workers. Additional information regarding the McKinney-Vento
Homeless Assistance Act is available at www.ed.gov/programs/homeless/guidance.pdf.
Q - 5. How can students show they meet a school’s age requirements?
A - 5. As with residency requirements, rules vary among states and districts as to what documents
students may use to show they fall within state- or district-mandated minimum and maximum age
requirements, and jurisdictions typically accept a variety of documents for this purpose.
Depending on the state or district, alternative documents could include, but are not limited to: a
religious, hospital, or physician’s certificate showing date of birth; an entry in a family bible; an
adoption record; an affidavit from a parent; a birth certificate; previously verified school records;
or any other documents permitted by law. School districts should make parents aware of any
alternatives that exist as part of their efforts to ensure a welcoming and inclusive environment for
all students.
Requests for documents such as birth certificates must not unlawfully bar or discourage a
prospective student from enrolling and attending school, including a student who is undocumented
or has parents who are undocumented, or a child or youth who is homeless as defined by the
McKinney-Vento Homeless Assistance Act (see Q-4, above). A school district may not bar or
discourage a student from attending school because the student lacks a birth certificate or has
records that indicate a foreign place of birth, such as a foreign birth certificate. Requests for
documentation also may not discriminate, or have the effect of discriminating, on the basis of race,
color, or national origin. All students must be treated equally in the enrollment process.
A district, moreover, should not use a student’s birth certificate or other documentation provided
by a parent as a basis for inquiring into the immigration status of the student, his or her parents, or
other family members. Such requests would likely have a discouraging effect on the enrollment of
a student on the basis of immigration status.
Q - 6. What if a parent is reluctant to provide a copy of his or her child’s foreign birth certificate,
fearing that doing so would lead to questions about the child’s or the parent’s immigration or
citizenship status?
A - 6. School districts are encouraged to take proactive steps to educate parents about their
children’s rights and to reassure them that their children are welcome in district schools. For
example, state laws typically permit a district to use a variety of documents to establish the age of

Revised as of May 8, 2014

Page 4 – Questions and Answers: School Enrollment Procedures

a child. A district should publicize that it will use a foreign birth certificate, baptismal record, or
alternative document in the same manner that it will use a United States birth certificate,
baptismal record, or alternative document: that is, solely to establish the age of a child.
As previously emphasized, a district must apply its rules and standards for documentation of age or
residency in the same way to everyone, regardless of race, color, national origin, citizenship, or
immigration status. A foreign-born child who is unable or unwilling to furnish a birth certificate
should have the same options to enroll in school and should be treated no differently than a United
States citizen child who does not have or otherwise may not be able to produce a birth certificate.
Q - 7. In light of the Dear Colleague letter, should districts refrain from asking for students’ social
security numbers?
A - 7. The Federal government does not prohibit states or districts from collecting the social
security numbers of prospective or current students. States and local school districts must decide,
however, whether they have a legally permissible reason to collect this information. If they choose
to collect social security numbers, they should take steps to ensure the confidentiality of the social
security numbers and that they are stored securely. In addition, they must follow Federal laws
regulating the use of that information. For example, under governing Federal laws, if a district
requests social security numbers, it must inform individuals that the disclosure is voluntary, and
must explain both the statutory or other basis for seeking the numbers and how the district intends
to use the numbers. See Privacy Act of 1974, Pub. L. No. 93-579, § 7, 5 U.S.C. § 552a (note),
available at http://www.ssa.gov/OP_Home/comp2/F093-579.html.
As the Dear Colleague letter makes clear, a district cannot deny enrollment to a student if he or she
(or his or her parent) chooses not to provide the student’s social security number.5 Districts have
alternatives to requesting social security numbers. For example, a district seeking to have student
identification numbers could decide to assign a randomly selected number to each student. In this
way, the state or district would avoid any chilling effect that a request for social security numbers
may have on the enrollment of students because of their race, color, national origin, citizenship, or
immigration status.
A school district that opts to request social security numbers should make clear in all enrollment
and registration documents, including forms, websites, and communications with parents, that the
provision of the child’s social security number is voluntary, and that choosing not to provide a
social security number will not bar a child’s enrollment.

5

Similarly, a school district cannot deny a student enrollment if his or her parent chooses not to provide his or her own
social security number.

Revised as of May 8, 2014

Page 5 – Questions and Answers: School Enrollment Procedures

Q - 8. How can a school district distinguish between (a) information that it should or must
collect, and (b) information that it may not collect because doing so may discourage enrollment
or attendance?
A - 8. There is typically only minimal information that a district is required to collect under state
law for a student to be able to enroll, such as proof of age, immunization history, and residency
within the district. Both the state and the district must act in compliance with the U.S. Constitution
and valid Federal or state laws, including their obligations not to discriminate, or implement
policies that have the effect of discriminating, on the basis of race, color, or national origin. In
doing so, states and districts should also assess their current policies to determine whether they
are doing anything that may have the effect, albeit unintended, of discouraging the enrollment of
undocumented children, such as asking for immigration papers or social security numbers, or
requiring a driver’s license or state-issued identification from a parent. Such practices and policies,
once identified, should be changed to eliminate any possible chilling effect on enrollment.
Q - 9. In order to avoid discouraging enrollment, should a school district enroll any child who
comes its way and ask for documentation later, after the child is enrolled?
A - 9. As noted above, school districts might require that prospective students furnish proof of
residency in a district and/or age prior to enrollment, except for any children and youth who are
considered homeless under the Federal McKinney-Vento Homeless Assistance Act. However,
districts may also choose to wait until students are already enrolled before asking for any
additional documentation that may be required under state or Federal law, such as student
demographic data. By choosing to wait to collect additional information, districts may create a
more welcoming and inclusive atmosphere for all prospective students. Requests for
documentation must not discriminate, or have the effect of discriminating, on the basis of race,
color, national origin, citizenship, or immigration status.
Q - 10. Once in possession of personal information about a student, are there circumstances
when a school district may disclose that information from a student’s education records without
the consent of the student or a parent?
A - 10. There are circumstances when a school district may disclose information from a student’s
education records, but these are limited and unlikely to be applicable in the majority of situations
school districts confront. The Family Educational Rights and Privacy Act of 1974 (FERPA) generally
prohibits school districts that receive Federal funds from the Department of Education from
disclosing information from a student’s education records that alone or in combination with other
information can identify that student, without the prior written consent of a parent or the student
(if that student is 18 years of age or older or attends a postsecondary institution). See 20 U.S.C.
Revised as of May 8, 2014

Page 6 – Questions and Answers: School Enrollment Procedures

§1232g. There are some limited exceptions in FERPA to the requirement that written consent must
be obtained before disclosing personally identifiable information from students’ education records,
see 34 C.F.R. § 99.31, as well as narrow, enumerated circumstances under which Federal
immigration laws require or permit a school district to provide specific information about a student
to another Federal, state, or local government entity. One such circumstance is where the issuance
of a non-immigrant visa to a student—and the maintenance of that student’s non-immigrant
status—is conditioned on the student’s attendance at a specific school. Note that in that case, a
school district would have preexisting information about the student that he or she would have
presented to the school in order to obtain the underlying visa, and so the school would not have
any reason to initiate a request for information about immigration status.
Q - 11. How should a school district communicate the requirements for enrollment with parents
who have limited proficiency in English?
A – 11. For limited English proficient parents of a student seeking to enroll in a school, a district
must meaningfully communicate material information about enrollment – e.g., translate a
document into languages other than English and have some method of responding to those
parents’ questions – as required by Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, and
the Equal Educational Opportunities Act, 20 U.S.C. § 1703. Material information could include
alternative means to establish state-permitted residency and age requirements, if any. If a district
asks for a social security number, material information would also be the fact that a district cannot
deny enrollment to a student if he or she (or his or her parent or guardian) chooses not to provide
a social security number.
Additional Proactive Support Measures That States and Districts Can Take
Q - 12. What can schools do proactively to show parents that their children are welcome,
regardless of their immigration or citizenship status?
A - 12. The Dear Colleague letter encourages states and districts to review enrollment policies and
practices carefully to make sure they are consistent with the law and do not have a chilling effect
on the willingness of parents to enroll their children. Any problems should be corrected.
In addition, the U.S. Departments of Education and Justice encourage districts to be proactive in
notifying parents of their rights to send their children to public school. For example, districts can
conduct outreach to communities to inform parents that all students who are residents in the
district are welcome to attend the district’s schools.

Revised as of May 8, 2014

Page 7 – Questions and Answers: School Enrollment Procedures

Q - 13. Should districts provide staff training on how to avoid violating the law in this area?
A - 13. Staff training at the school and district level is encouraged. Ultimately, the state and
district have the legal responsibility to ensure that they are complying with Federal law. Staff
training helps facilitate that compliance.
Q - 14. What is the role of State Educational Agencies (SEAs) in ensuring that students are not
improperly excluded from school?
A - 14. The Dear Colleague letter issued May 6, 2011, and revised and reissued on May 8, 2014, is
intended to remind both districts and states of their obligations under existing law. As recipients of
Federal funds, SEAs are responsible for monitoring compliance with Federal anti-discrimination
laws. Because laws regarding school enrollment, including requirements for proof of age and
residency, vary from state to state, this is an area in which leadership from SEAs is needed and can
be particularly effective. SEAs are encouraged to review existing practices and policies and to assist
their districts in understanding the types of practices that will comply with state requirements
regarding school enrollment without violating constitutional and Federal anti-discrimination
requirements. Specifically, SEAs should work to ensure that their school districts’ enrollment
practices do not unlawfully discourage or bar students, including students who are undocumented
or have parents who are undocumented, from school.

Revised as of May 8, 2014


U.S. Department of Justice
Civil Rights Division

U.S. Department of Education
Office for Civil Rights
Office of the General Counsel

Fact Sheet: Information on the Rights of All Children to Enroll in School
All children in the United States are entitled to equal access to a basic public elementary and secondary
education regardless of their actual or perceived race, color, national origin, citizenship, immigration
status, or the status of their parents/guardians. School districts that either prohibit or discourage, or
maintain policies that have the effect of prohibiting or discouraging, children from enrolling in schools
because they or their parents/guardians are not U.S. citizens or are undocumented may be in violation
of Federal law.
Below are some examples of acceptable enrollment policies, such as requesting proof of residency in the
school district, as well as policies that may not be used by schools to deny enrollment to your child.
Proof of Residency in the School District.


School officials may request proof that you live within the boundaries of the school district. School districts
typically accept a variety of documents for this purpose, such as copies of phone and water bills, lease
agreements, affidavits, or other documents. A school district’s requirements to establish residency must be
applied in the same way for all children.



A school district may not ask about your or your child’s citizenship or immigration status to establish residency
within the district, nor may a school district deny a homeless child (including a homeless child who is
undocumented) enrollment because he or she cannot provide the required documents to establish residency.



While a school district may choose to include a parent’s state-issued identification or driver’s license among
the documents that can be used to establish residency, a school district may not require such documentation
to establish residency or for other purposes where such a requirement would unlawfully bar a student whose
parents are undocumented from enrolling in school.

Proof of Age.


School officials may request documentation to show that a student falls within the school district’s minimum
and maximum age requirements. School districts typically accept a variety of documents for this purpose,
such as a religious, hospital, or physician’s certificate showing date of birth; an entry in a family bible; an
adoption record; an affidavit from a parent; a birth certificate; or previously verified school records.



Although a school district might request documents such as those listed above to verify your child’s age, a
school district may not prevent or discourage your child from enrolling in or attending school because he or
she lacks a birth certificate or has records that indicate a foreign place of birth, such as a foreign birth
certificate.

U.S. Department of Justice
Civil Rights Division

U.S. Department of Education
Office for Civil Rights
Office of the General Counsel

Social Security Numbers.


Some school districts request a student’s social security number during enrollment to use as a student
identification number. If a school district requests a student’s social security number, it must: (1) inform
you and your child that providing it is voluntary and that refusing to provide it will not bar your child
from enrolling in or attending school, and (2) explain for what purpose the number will be used.



A school district may not prevent your child from enrolling in or attending school if you choose not to
provide your child’s social security number.



A school district may not require you to provide your own social security number in order for your child
to enroll in or attend school.

Race or Ethnicity Data.


School districts have some Federal and state obligations to report race and ethnicity data about the
students in their schools. A school district may request that you provide your child’s race or ethnicity for
this purpose.



However, a school district may not bar your child from enrolling if you choose not to provide your child’s
race or ethnicity.

If you want to learn more about your rights and the rights of your child when enrolling in public school, or if
you believe that a school district is violating Federal law, you may contact the following government
agencies:


Department of Justice, Civil Rights Division, Educational Opportunities Section
Telephone: (877) 292-3804 (toll-free)
Fax: (202) 514-8337
Email: education@usdoj.gov



Department of Education, Office for Civil Rights
Telephone: (800) 421-3481 (toll-free)
Email: ocr@ed.gov
If you wish to fill out a complaint form online with the Department of Education, you may do so at
http://www.ed.gov/ocr/complaintintro.html



Department of Education, Office of the General Counsel
Telephone: (202) 401-6000
Fax: (202) 205-2689
Page 2 of 2


U.S. Department of Justice
Federal Bureau of Prisons
CHANGE NOTICE
OPI:
CPD/CPB
NUMBER:
1330.15, CN-1
DATE:
05/02/2014

Commutation of Sentence, Petition for
/s/

Approved: Charles E. Samuels, Jr.
Director, Federal Bureau of Prisons

This Change Notice (CN) implements the following changes to Program Statement 1330.15,
Petition for Commutation of Sentence, dated August 23, 2001:
1. On p. 3, the following paragraph is deleted:
To expedite the Pardon Attorney’s consideration of an inmate’s petition for commutation of
sentence, the inmate must send the petition through the Warden to the U.S. Pardon Attorney.
2. On p. 3, the U.S. Pardon Attorney’s telephone number is deleted.
3. On p. 5, the address of the U.S. Pardon Attorney is changed as follows:
U.S. Pardon Attorney
1425 New York Avenue, NW.
Suite 11000
Washington, DC 20530

U.S. Department of Justice
Federal Bureau of Prisons

Program
Statement

OPI:
NUMBER:
DATE:
SUBJECT:

CPD
1330.15
8/23/2001
Commutation of
Sentence, Petition for

1.
[PURPOSE AND SCOPE §571.40. An inmate may file a petition
for commutation of sentence in accordance with the provisions of
28 CFR Part 1.
a. An inmate may request from the inmate's case manager the
appropriate forms (and instructions) for filing a petition for
commutation of sentence.
b. When specifically requested by the U.S. Pardon Attorney,
the Director, Bureau of Prisons will forward a recommendation on
the inmate's petition for commutation of sentence.]
Article II, Section 2 of the U.S. Constitution empowers the
President of the United States to grant Executive Clemency,
including pardon, commutation (reduction) of sentence, remission
of time and reprieve. Commutation of the term of a prison
sentence is considered only in the most exceptional
circumstances.
Rules governing petitions for Executive Clemency such as
commutation of sentence, are published in
28 CFR Part 1 (§1.1-1.10).
In accordance with 28 CFR 1.3, a petition for commutation of
sentence, including remission of fine, should be filed only if no
other form of relief is available, such as from a court of the
United States, U.S. Parole Commission, or upon motions under
18 U.S.C. §§ 3582(c) and 4205(g), or if unusual circumstances
exist, such as:
!
!

critical illness,
severity of sentence,

[Bracketed Bold - Rules]
Regular Type - Implementing Information

!
!

2.

3.

ineligibility for parole, or
meritorious service rendered by the petitioner.

SUMMARY OF CHANGES.

This revision:

!

Requires inmates to submit petitions through their
Wardens if they wish expedited consideration by the
U.S. Pardon Attorney.

!

Clarifies what documents staff must send to the U.S.
Pardon Attorney with an inmate’s petition for
commutation of sentence.

!

Establishes procedures by which the inmate’s petition
is receipted and further processed.

PROGRAM OBJECTIVE.

The expected result of this program is:

All inmates will have access to the U.S. Pardon Attorney to
request a petition for commutation of sentence.
4.

DIRECTIVES AFFECTED

a.

Directive Rescinded
PS 1330.14

b.

Petition for Commutation of Sentence
(11/24/97)

Directives Referenced
PS 5803.07
PS 6000.05

Progress Reports (2/18/98)
Health Services Manual (10/28/97)

c. Rules cited in this Program Statement are contained in 28
CFR 571.40-41.
5.

STANDARDS REFERENCED.

None

6. PRETRIAL/HOLDOVER/DETAINEE PROCEDURES. The procedures
contained in this Program Statement apply only to sentenced
inmates.
7.

[PROCEDURES

§571.41

a. Staff shall suggest that an inmate who wishes to submit a
petition for commutation of sentence do so through the Warden to
the U.S. Pardon Attorney. This procedure allows institution
staff to forward with the application the necessary supplemental

information (for example, sentencing information, presentence
report, progress report, pertinent medical records if the
petition involves the inmate's health, etc.). Except as provided
in paragraph (b) of this section, no Bureau of Prisons
recommendation is to be forwarded with the package of material
submitted to the U.S. Pardon Attorney.]
To expedite the Pardon Attorney’s consideration of an inmate’s
petition for commutation of sentence, the inmate must send the
petition through the Warden to the U.S. Pardon Attorney.
Staff may not refuse to process an inmate's petition for
commutation of sentence, even when it appears that the inmate is
not eligible. When an inmate submits the petition for
commutation of sentence, the Case Manager will document the
petition’s receipt with a complete entry on the Inmate Activity
Record in the Inmate Central File.
Once the petition is received, the Case Manager will have 30
calendar days to compile the required documents and route
for the Warden’s signature.
When referring an inmate’s petition for commutation of
sentence, staff must include:
•
•
•
•

Petition for Commutation of Sentence (Form OPA-6);
Pre-sentence Investigation Report (if available);
Judgment in a Criminal Case; and,
The inmate’s most recent already existing Progress
Report (staff need not create or update a Progress
Report);

If available, staff should also include any other pertinent,
documented information.
The Pardon Attorney may later request the following, if
necessary:
•
•

All pertinent medical records if the petition involves
the inmate's health; and
An updated Progress Report.

In the event of a medical emergency certified by the physician
at the institution where the inmate is confined, staff must
expedite the petition at all levels. In such cases, the
documents cited above may be transmitted to the U.S. Pardon
Attorney's office via BOPNet Mail ID or Facsimile (Commercial
(202) 616-6069). The telephone number is (202) 616-6070.

The U.S. Pardon Attorney may delay and/or return petitions
received without proper documentation pending the remaining
documentation’s receipt.
When the U.S. Pardon Attorney needs additional information, a
request will be forwarded directly to the Warden of the
institution housing the inmate, with a copy to the Assistant
Director, Correctional Programs Division, Central Office,
Washington DC. In these cases, the Warden must ensure the
requested documents are forwarded to the U.S. Pardon Attorney
within 15 working days and a copy of the transmittal memorandum
provided to the Assistant Director, Correctional Programs
Division.
[b. When specifically requested by the U.S. Pardon Attorney,
the Director, Bureau of Prisons shall submit a recommendation on
the petition. Prior to making a recommendation, the Director may
request comments from the Warden at the institution where the
inmate is confined. Upon review of those comments, the Director
will forward a recommendation on the petition to the U.S. Pardon
Attorney.]
(1) The Director, through the Assistant Director,
Correctional Programs Division, will contact (ordinarily via
BOPNet) the Warden for comments, with an information copy sent to
the Regional Director.
(2) The Warden must submit a written response to the
Assistant Director, Correctional Programs Division (Attention:
Administrator, Correctional Programs Branch) within 10 days of
receiving the request, and forward an information copy to the
Regional Director.
(3) The Director, upon review of all available information,
forwards the Bureau's recommendation to the U.S. Pardon Attorney,
with a copy to the Warden and Regional Director.
The Director's recommendation is ordinarily one of several
reviewed by the U.S. Pardon Attorney and others concerned with
the disposition of Clemency Petitions. The Attorney General, or
designee, will provide a recommendation to the President on each
petition for commutation of sentence.
[c. When a petition for commutation of sentence is granted by
the President of the United States, the U.S. Pardon Attorney will
forward the original of the signed and sealed warrant of clemency
evidencing the President's action to the Warden at the detaining

institution, with a copy to the Director, Bureau of Prisons. The
Warden shall deliver the original warrant to the affected inmate,
and obtain a signed receipt for return to the U.S. Pardon
Attorney. The Warden shall take such action as is indicated in
the warrant of clemency.]
The Warden is to forward a copy of the warrant of clemency to
the Regional Director.
[(1) If a petition for commutation of sentence is granted,
institutional staff shall recalculate the inmate's sentence in
accordance with the terms of the commutation order.
(2) If the commutation grants parole eligibility, the
inmate is to be placed on the appropriate parole docket.
d. When a petition for commutation of sentence is denied, the
U.S. Pardon Attorney ordinarily notifies the Warden, requesting
that the Warden notify the inmate of the denial.]
The Warden is to forward a copy of the denial to the Regional
Director.
8. FORMS. The Case Management Coordinator or Executive
Assistant may obtain the necessary forms from the:
U.S. Pardon Attorney
500 First Street NW, 4th Floor
Washington DC 20530.
These forms shall also be available on BOPDOCS.

/s/
Kathleen Hawk Sawyer
Director