DRO is responsible for the detention of aliens in its custody pending civil administrative immigration removal proceedings. According to ICE, as of the week ending December 31, 2006, there were 27,607 aliens detained in ICE custody at 330 adult detention facilities nationwide. The majority of ICE’s alien detainee population is housed with general population inmates in about 300 state and local jails that have intergovernmental service agreements with ICE. In addition to being housed in these state and local facilities, alien detainees are also housed in 8 ICE-owned service processing centers and 6 contract detention facilities operated by private contractors specifically for ICE alien detainees. In addition to these adult detention facilities, ICE contracts for the operation of 19 juvenile and 3 family detention facilities. According to ICE officials, they maintain custody of one of the most highly transient and diverse populations of any correctional or detention system in the world. This diverse population includes individuals from different countries; with varying security risks (criminal and noncriminal); with varying medical conditions; and includes males, females, and families of every age group. As of January 2007, the countries with the largest numbers of alien detainees in ICE custody were Mexico, El Salvador, Guatemala, Honduras, the Dominican Republic, and Haiti. See appendix II for additional information on alien detention population statistics. ICE’s National Detention Standards are derived from the American Correctional Association Third Edition, Standards for Adult Local Detention Facilities. ICE officials said that they were currently in the process of revising the National Detention Standards based on American Correctional Association Fourth Edition, Performance-Based Standards for Adult Local Detention Facilities. In most cases ICE standards mirror American Correctional Association (ACA) standards. However, in some cases ICE standards exceed or provide more specificity than ACA standards to address the unique needs of alien detainees. As an example, ICE standards specify that a detainee should receive a tuberculosis test upon intake, while ACA standards do not. Further, ICE standards require a detailed list of immigration-related legal reference materials be made available in law libraries, while ACA standards do not specify the type and nature of legal materials to be made available. Also, exceeding ACA standards, ICE standards specify that, when possible, use of force on detainees be videotaped and that certain informational materials provided to detainees, such as fire evacuation instructions and detainee handbooks, be available in Spanish. The ICE National Detention Standards are to apply to ICE-owned detention facilities and those state and local facilities that house alien detainees. The standards are not codified in law and thus represent guidelines rather than binding regulations. According to ICE officials, ICE has never technically terminated an agreement for noncompliance with its detention standards. However, under ICE’s Detention Management Control Program policies and procedures, ICE may terminate its use of a detention facility and remove detainees or withhold payment from a facility for lack of compliance with the standards. Separate standards addressing the treatment of juvenile aliens are used for juvenile secure detention and shelter facilities. Both adult and juvenile detention facility standards are used at ICE’s family shelter facilities because of the unique classification of family shelters. There are 38 ICE National Detention Standards for adult detention facilities; 18 standards are related to detainee services, 4 are related to detainee health services, and 16 are related to security and control. More detailed information on each of these standards is provided in appendix IV. According to ICE officials, in addition to being required to comply with ICE’s National Detention Standards, some ICE detention facilities are accredited by ACA. For example, seven of eight ICE service processing centers and five of six contract detention facilities are accredited by ACA. In addition, according to ICE officials, some of the over 300 intergovernmental service agreement facilities are also accredited by ACA. Moreover, some facilities are also accredited by the Joint Commission on Accreditation of Health Care Organizations (JCAHO), the predominant standards-setting and accrediting body in health care, and the National Commission on Correctional Health Care (NCCHC), which offers a health services accreditation program to determine whether correctional institutions meet its standards in their provision of health services. Our field observations at 23 alien detention facilities showed systemic telephone system problems at 16 of 17 facilities that use the pro bono telephone system, but no pattern of noncompliance for other standards we reviewed. Problems with the pro bono telephone system restrict detainees’ abilities to reach their consulates, nongovernmental organizations, pro bono legal assistance providers, and the OIG complaint hotline. ICE and facility officials told us that they did not know the specific nature and extent of the problem prior to our review. ICE’s lack of awareness and insufficient internal controls appear to have perpetuated telephone system problems for several years. Similarly, there were insufficient internal controls at the facilities to ensure posted phone numbers were kept up to date or otherwise accurate. For instance, one facility told us that the only means to know if a posted phone list was out of date or inaccurate was if a detainee complained. In addition to telephone problems, we also observed a lack of compliance with one or more aspects of other individual detention standards at 9 of the 23 sites we visited. These instances of noncompliance varied across facilities that we visited, and unlike the telephone system problems, did not appear to show a persistent pattern of noncompliance. Other examples of deficiencies included food service issues such as kitchen cleanliness and menu rotation, failure to follow medical care policy at intake, hold room policy violations such as lack of logbooks and overcrowding, and potential use of force violations such as the potential for use of dogs and/or Tasers, since some facilities had the use of Tasers either authorized in policy or facility officials stated they used these methods. Last, we also observed detainees being housed in numbers that exceeded the rated capacity at 4 of the 23 sites we visited. ICE alien detention standards specify that detainees be provided the ability to make telephone calls, at no charge to themselves or to the recipients, to their respective consulates, designated pro bono legal service providers, and the OIG complaint hotline, among others. The pro bono telephone system is to ensure that detainees have access to authorized legal representatives, that aliens who wish to retain counsel are not prevented from doing so, and to allow detainees to contact their home country consulates to seek assistance. The pro bono telephone system is also to ensure that detainees can voice complaints regarding their conditions of confinement to organizations with responsibility for investigating or monitoring detainee treatment. In order to meet the telephone access standard, ICE contracted with Public Communications Services (PCS) to provide a pro bono telephone system to enable detainees to contact the aforementioned parties at no charge. The term of the contract is January 22, 2004, to January 21, 2009, and consists of a 12-month base period and four 12-month options. Of the 23 detention facilities we visited, 17 facilities utilize the PCS detainee telephone system. We performed telephone tests at all 17 of these facilities. Our tests consisted of dialing the OIG’s complaint line, consulates, nongovernmental organizations, and pro bono legal service providers from the numbers posted next to the telephones to determine if we could get a connection. All of the phones were in good working order, and we observed that detainees could successfully place personally funded phone calls using calling cards purchased from the facility. However, we often could not connect to the telephone numbers for the OIG, consulates, and pro bono legal providers. At 16 of 17 detention facilities where we performed test calls through the pro bono telephone system, we encountered numerous failures that ranged from incomplete and inaccurate phone number postings to a variety of technical system failures that would not permit the caller to make the desired connections. For example, during our facility visits, we observed posters advertising the OIG complaint hotline 1-800 number. However, we found that the OIG number was blocked or otherwise restricted at 12 of the facilities that we tested. Typical problems that we encountered when dialing the OIG’s complaint line included getting a voice prompt stating that “this number is restricted,” “this is an invalid number,” or “a call to this number has been blocked by the telephone service provider.” Also, at 14 of the facilities using the PCS detainee telephone system, we could not complete phone connections to some consulates. We received messages such as a message stating that “all circuits are busy, call back at a later time” and “this number is restricted.” At the Pamunkey Regional Jail in Virginia we requested that the on-site Systems Administrator call PCS to determine why its pro bono telephone system was not working properly. The PCS service department informed him that there was a problem with the PCS system and it seemed to be at all facilities. Figure 1 shows a telephone with posted pro bono numbers at the Denver Contract Detention Facility, where we identified telephone system problems during our testing. Further, we found the PCS detainee telephone system to be cumbersome and complicated to use. For example, at Pamunkey Regional Jail, the automated system required eight different actions by the user to place a call. One of these actions added further confusion by instructing a detainee to select “collect call” in order to make a pro bono telephone system call. Similarly, at the Northwest Detention Center, detainees were offered only two voice prompt options when attempting to place a call using the pro bono telephone system: (1) to place a “collect call” and (2) to place a “credit card call.” In some cases, we found that the pro bono telephone system requires detainees to input their Alien Registration Number (commonly referred to as an “A” number) as part of the process for making a pro bono telephone call. In at least one facility, however, this in itself provided enough confusion among detainees to prevent them from making a successful call.