Audit of the Federal Bureau of
Prisons' Management and Oversight
of its Chaplaincy Services Program

***
21-091

JULY 2021

EX ECUTIVE SUMMARY
Audit of the Federal Bureau of Prisons' Management
and Oversight of its Chaplaincy Services Program

Objective

Recommendations

The objective of this audit was to assess the Federal
Bureau of Prisons' (BOP) management and oversight of
its Chaplaincy Services Program to support faith-based
activities and its effectiveness in preventing security risks
and misuse of program resources.

We make five recommendations to the BOP to improve
the delivery of religious services to the inmate population
and to help diversify and alleviate shortages in its
chaplain staff.

Audit Results

Results in Brief

During the BOP’s intake processing, inmates are asked to
state their religious affiliation, if applicable. Inmates
indicating a preference are designated as a member of one
of the faith groups identified in the BOP’s SENTRY system.
As of March 2020, approximately 70 percent of the BOP’s
inmate population officially identified with a faith group.

The BOP, through its Chaplaincy Services Branch, seeks to
ensure that inmates in its custody are afforded the
opportunity to practice their religion of choice. At the
institution level, BOP chaplains are primarily responsible
for the implementation of the BOP’s religious services
programs, which includes, among other things, the
facilitation of religious worship and the provision of
religious spaces and other items needed for religious
observances.

We found that the BOP lacks adequate chaplaincy resources
to meet this demand for religious services. Specifically,
we determined that, in order to meet the BOP staffing
guidelines, as of March 2020, the BOP’s chaplaincy should
have consisted of 357 chaplains and 122 religious services
assistants; instead, we found that the BOP employed only
236 chaplains and 64 assistants, approximately 30 percent
below the BOP’s guidelines. We further found that, although
the BOP’s required minimum staffing level is one chaplain
and one assistant per institution, as of March 2020, three of
the BOP’s institutions had no chaplain at all and nearly half of
BOP’s institutions had no religious services assistant.

We found that a significant shortage in the number of
chaplains and other chaplaincy services staff impairs the
BOP’s ability to implement a safe and effective religious
services program. In addition, we found that a lack of
faith diversity among the BOP’s chaplaincy staff leaves
some inmate faith groups significantly underrepresented.
As a result, many institutions rely on alternative religious
services options, such as inmate-led services. However,
we found that the BOP often undertook these alternative
options without ensuring adequate supervision and
oversight of them. For example, we found that some
institutions permitted inmates with a known nexus to
international or domestic terrorism to lead religious
services. Finally, we found that the BOP has not
considered a strategy to leverage existing technologies
that could allow for certain religious services to be shared
virtually across institutions.

Further, the lack of diversity among the faith groups of
chaplaincy staff leaves the BOP with few low risk options
for providing services, especially to smaller population
faith groups. As of March 2020, 199 of the BOP’s 236
chaplains (84 percent) represented a Protestant Christian
faith (including Adventist) even though inmates
identifying with the Protestant Christian faith make up
about 34 percent of inmates claiming a faith preference.
Further, the remaining 37 chaplains represent only 7
additional faith groups, leaving at least 16 groups without
any chaplains, and two groups that comprise the second
and third largest faith groups – Catholics and Muslims –
significantly underrepresented among the BOP
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into them due to a poorly maintained library database
and the inability to adequately screen foreign language
materials. This creates a risk that libraries may contain
media that is inappropriate for a correctional institution,
including items we found during our audit that advocated
violence and extremism.

chaplaincy. We concluded that the BOP has not taken
adequate steps to address its long-standing chaplaincy
staffing issues, including issues arising from the increasing
religious diversity within the inmate population.
Chaplaincy Shortages and Diversity Challenges Present
Risks

Inmate Contact with Volunteer Faith Providers

In the absence of a fully-staffed and diverse chaplaincy,
the BOP's institutions are unable to adequately staff their
religious services programs, prompting many institutions
to turn to alternatives such as inmate-led services and
heavy reliance on contract faith providers and minimally
vetted volunteer faith providers to fill the gaps in the
chaplaincy staff. These staffing shortages and
alternatives present risks.

With limited exceptions, BOP policy prohibits external
volunteer service providers, including those for religious
services, from contacting inmates outside of the prison
setting to reduce opportunities for inappropriate relationships
to develop. However, our testing found instances of
apparent inappropriate contact via telephone and email
by volunteer faith providers with inmates, as well as
weaknesses in the BOP’s system for tracking terminated
and previously disciplined volunteer faith providers.

Inmate-led Services
BOP staff members consistently told us that inmate-led
services presented safety and security risks. One
particular concern was the potential for an inmate to use
a religious leadership role to engage in prohibited
activities or as a method to obtain power and influence
among the inmate population. Additionally, we found
that the BOP’s policies do not restrict certain inmates
from leading services and appear to be inconsistent
regarding the level of required monitoring. We
determined that inmates incarcerated for terrorismrelated crimes, or with known connections to terrorist
organizations, were permitted to lead religious services at
4 of the 12 BOP facilities we visited.

Strategies to Improve Chaplaincy Shortages, Faith
Diversity Imbalance, and Recruiting Methods
We identified several improvements that the BOP can
make to its chaplaincy hiring efforts and to its existing
programs that can alleviate some of the BOP’s staffing
and diversity issues. First, we were told that several
factors have impacted the BOP’s efforts to recruit a more
representative chaplaincy. Two of the most significant
factors appear to be the BOP’s formal educational
requirements and age restrictions that must be satisfied
in order to qualify for a Chaplain position. Additionally,
we learned that the BOP’s recruitment and hiring process
for chaplains is complex and hindered by time
constraints.

Monitoring of Chaplaincy Services Spaces
Depending upon the resources available at an institution,
a single chaplain may be responsible for simultaneously
monitoring multiple chapels, classrooms, hallways,
restrooms, offices, and storage areas for improper inmate
activities. To assist chaplaincy staff, these spaces are
typically equipped with audio and visual monitoring
equipment. However, two institutions we visited did not
have monitoring equipment in spaces where religious
services were conducted.

The BOP has implemented alternative methods to
address chaplaincy shortages and the lack of diversity,
such as the use of contract and volunteer faith providers.
However, the rates of participating faith contractors and
volunteers have declined in recent years, shifting much of
the burden of seeking more resources to field chaplains.
We believe the BOP would benefit from a centralized
effort to develop working relationships with national faith
organizations that can encourage their members to work
with the BOP’s institutions in their community.

Oversight of Chapel Libraries

Finally, we found that the BOP already has the
technological capability to implement alternatives to
inmate-led services, such as live streaming chaplain-led
services to multiple institutions. We also noted that, with
the onset of the COVID-19 pandemic, virtual services can
allow inmates to receive services they may not otherwise
have been able to access.

Collectively, the BOP’s chapel libraries contain nearly
800,000 individual items including religious texts, books
with religious themes, and audio and video recordings.
While these libraries help to facilitate the free exercise of
religion by inmates, we found that BOP staff does not
maintain adequate control over the materials permitted

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Table of Contents
Introduction .............................................................................................................................................................. 1
BOP Chaplaincy Staff ................................................................................................................................................1
Contract and Volunteer Faith Providers .................................................................................................................3
OIG Audit Approach ..................................................................................................................................................4
Effect of the COVID-19 Pandemic on the Audit ..............................................................................................4
Audit Results ............................................................................................................................................................. 6
Risks Resulting from Chaplaincy Shortages and Diversity Challenges ..............................................................7
Inmate-Led Services ...........................................................................................................................................7
Monitoring of Chaplaincy Services Spaces and Activities .............................................................................9
Oversight of Faith Group Lockers ................................................................................................................. 11
Chapel Libraries, Foreign Language Materials and Chapel Library Database ........................................ 12
Advisories Regarding Inappropriate Chapel Library Materials ................................................................. 14
Volunteer Faith Providers - Inmate Contact................................................................................................. 16
Volunteer Faith Provider Data Management ............................................................................................... 18
Strategies to Improve Chaplaincy Shortages, Faith Diversity Imbalance, and Existing Recruitment
Methods ................................................................................................................................................................... 19
Chaplaincy Services Staffing Guidelines and Shortages ............................................................................ 19
Faith Representation Disparities ................................................................................................................... 21
Position Requirements that Hinder Chaplaincy Recruitment Efforts ....................................................... 24
Internal Conditions and Hiring Processes That Hinder Chaplaincy Recruitment Efforts ...................... 25
External Factors That Hinder Chaplaincy Recruitment Efforts .................................................................. 27
Potential Improvements to the BOP’s Existing Chaplaincy Recruitment Efforts .................................... 27
Recruitment Strategies for Contract and Volunteer Faith Providers ........................................................ 28
Extended Periods of Absence ........................................................................................................................ 31
Utilization of Existing Programs and Technologies..................................................................................... 31
Conclusion and Recommendations ...................................................................................................................... 34
APPENDIX 1: Objectives, Scope, and Methodology ............................................................................................. 37
Objectives ................................................................................................................................................................ 37
Scope and Methodology........................................................................................................................................ 37
Statement on Compliance with Generally Accepted Government Auditing Standards ........................ 37
Internal Controls .............................................................................................................................................. 37
Compliance with Laws and Regulations ....................................................................................................... 38

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Sample-based Testing ..................................................................................................................................... 38
Computer-Processed Data ............................................................................................................................. 38
APPENDIX 2: BOP Correctional Facilities Reviewed or Visited ............................................................................ 39
BOP Correctional Facilities Selected for Review ................................................................................................. 39
BOP Correctional Facilities Visited During Prior Review ................................................................................... 39
APPENDIX 3: The BOP’s Response to the Draft Audit Report ............................................................................. 41
APPENDIX 4: Office of the Inspector General Analysis and Summary of Actions Necessary to Close the
Audit Report............................................................................................................................................................ 48

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Introduction
The Federal Bureau of Prisons (BOP), through its Chaplaincy Services Branch, seeks to ensure the
Constitutional religious rights of inmates. The BOP’s chaplains, contracted faith providers, and trained
community faith volunteers facilitate religious worship and scriptural studies across faith lines, and provide
pastoral care, spiritual guidance, and counseling. Inmates are permitted to participate in religious
observances, wear religious items, observe religious holidays, and access religious materials. As of March
2020, approximately 70 percent of the BOP’s inmate population self-identified as having a religious
preference among more than 24 different faith traditions or groups. 1
The BOP’s Central Office Chaplaincy Services Branch (CSB) manages and provides oversight of the BOP’s
religious services programs at a national level. 2 Its primary mission is to accommodate the free exercise of
religion for inmates by providing pastoral care and facilitating the opportunity for inmates to pursue their
individual religious beliefs and practices in accordance with the law, federal regulations, and BOP policy.
The CSB seeks to accomplish these goals through the development of religious services-related policy,
effective chaplaincy recruitment, multi-faith training of its chaplains, and connecting with outside faithbased organizations. The CSB also maintains the Chapel Library Database (CLD). Further, the BOP’s religious
services program also includes the operation of the Life Connections and Threshold programs. 3
At the institution level, Chaplaincy Services Departments facilitate faith-based services for their inmates by
providing a range of programming, religious media, access to ceremonial items, time and space for weekly
services and study groups, and crisis counseling. The BOP’s staffing and supplemental guidelines specify
that the chaplaincy services department at each facility should have a minimum of one chaplain and one
religious services assistant, with supplemental chaplaincy staff for specialized facilities such as those with a
major medical center. However, as we describe throughout this report, many of the BOP institutions do not
meet these minimum staffing requirements.

BOP Chaplaincy Staff
Dispersed among the BOP’s 122 institutions, chaplains serve as the frontline of the BOP’s efforts to provide
services to a large and religiously diverse inmate population. To accommodate the needs of this diverse
population, BOP chaplains must minister within a pluralistic community and be impartial and inclusive.
While these inmates self-identified as having a religious preference, not all actively participate in religious services or
access the BOP’s chaplaincy services resources.
1

The CSB has a staff of nine employees, including the Chief of Chaplaincy Services, an Administrative Officer, an
Assistant Chaplaincy Administrator, two Administrative Program Managers, a Faith Based Program Coordinator, and
three Chaplaincy Services Coordinators (CSCs). CSCs aid institutions with chaplain hiring and provide pastoral care,
advocacy, and technical assistance to chaplains in the field. Each CSC is assigned two regional territories.
2

The BOP’s Life Connections Program is an 18-month faith-based residential program open to inmates of all religious
traditions, including those who do not claim a religious preference. Established in 2002 in response to the White House
Faith-Based Initiative, the program was designed to assist inmate participants in developing one's faith, moral and social
responsibility, and applying these beliefs into practical life skills in order successfully transition back to their respective
communities and families. As of March 2020, the program is currently operating at five locations. The Threshold
Program has similar faith-based programming and is taught by chaplains and community volunteers at 110 institutions
for a 6 to 9 month time period. We did not audit these programs as part of this review.

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While BOP chaplains lead services and ceremonies within their own faith tradition, they also provide
pastoral care to all inmates in the form of counseling or crisis management, facilitate religious services for
other faith groups through contract and volunteer faith providers and, in many cases, inmates themselves.
As of March 2020, the BOP reported 236 chaplains on staff, some of whom are supported by 64 religious
services assistants (RSAs). However, these 236 chaplains only represent 8 unique faith groups, with the
overwhelming majority (84 percent) being of a Protestant Christian faith. Table 1 below lists the 26 specific
designations that the BOP currently uses to identify inmates’ faith in its SENTRY system, and the number of
the BOP’s chaplains affiliated with each of the faiths. 4

SENTRY is the BOP’s primary information system and is used to collect and store information relating to the care,
classification, subsistence, protection, discipline, and programs of its inmates. SENTRY currently includes 26
designations for inmate faith classification as shown in Table 1. Notably, in practice, the BOP considers Atheists to be a
faith group and it considers the Adventist faith to be part of the broader Protestant Christian faith group. The system
also includes an “other” category which captures faith groups not specifically listed in SENTRY. Some faith group
categories include associated subgroups. For example, the Pagan faith group includes inmates who identify as Asatru
or Wiccan. Further, SENTRY contains another designation of “no preference.” Because these inmates chose not to
identify with a particular faith group, we have not included them in Table 1.
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Table 1
BOP Recognized Faith Groups and Chaplaincy Faith Representation
As of March 2020
Faith Group

Chaplains

Adventist

0*

Atheist

Faith Group

Chaplains
0

0**

Moorish Science
Temple
Mormon

American Indian

0

Muslim

13

Baha’i
Buddhist
Catholic
Christian Scientist
Church of Christ
Hindu

0
2
15
0
0
0

Nation of Islam
Non-Trinitarian
Orthodox Christian
Pagan
Pentecostal
Protestant Christian

0
0
2
0
0
199

Humanist
Jehovah’s Witness
Jewish

0
0
4

Rastafarian
Santeria
Sikh

0
0
0

Messianic

1

Other Faith Groups

0

0

Note: Faith groups recorded in bold text are those represented by chaplains of the same or closely associated
faith group.
* We list the Adventist faith group separately in Table 1 to reflect how that faith is captured in the BOP’s SENTRY
system. According to the BOP, it considers the Adventist faith to be a sub-group of the Protestant Christian faith,
which is represented by its Protestant Christian chaplains.
** The SENTRY system includes a faith group designation for inmates who identify themselves as “atheist”.
According to the BOP, it considers atheist inmates to be represented by its chaplaincy because, as trained religious
experts, the BOP’s chaplains of any faith could provide counsel to atheist inmates if needed.
Source: BOP

Contract and Volunteer Faith Providers
Because the BOP’s chaplaincy composition does not include representation for all faith groups, it must rely
on external faith providers (contract and volunteer faith providers) to supplement chaplaincy staff, when
possible. Ordinarily, the BOP’s contract and volunteer faith providers must be ordained or hold a
recognized religious and ministerial position in their faith tradition in order to conduct worship services, but
they are not required to have the same level of education or training as BOP chaplains. Contract and
volunteer faith providers are permitted to perform ministry when staff chaplains are unavailable and are
also permitted to assist in weekly services or rites for inmates of their faith. 5 All contract and volunteer faith
There are two types of volunteers within the BOP, and both assist BOP chaplaincy with providing religious services to
inmates. Level 1 volunteers are authorized to assist the BOP 4 days or less per year. Level 2 volunteers assist the BOP
more than 4 days a year. Both Level 1 and Level 2 volunteers must complete the required volunteer training prior to
interacting with inmates or shortly after acceptance of their application.
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providers must receive and provide the BOP with an endorsement from their religious organization and are
also subject to a “moderate” background investigation or a National Crime Information Center (NCIC)
criminal check. All contractors and certain volunteers at the BOP may also be subject to an interview prior to
inmate contact. 6
As of September 2019, the BOP reported the use of 117 contract and 3,698 volunteer faith providers
collectively representing 22 different faith groups to provide some form of religious services programming
to its inmates throughout its facilities. While the need for external religious services providers is great, the
current number of contract and volunteer faith providers working with the BOP has decreased by
approximately 28 percent since 2015.

OIG Audit Approach
The objective of our audit was to assess the BOP’s management and oversight of its religious services
program to support faith-based activities and its effectiveness in preventing security risks and misuse of
program resources. The scope of our audit generally covers activities from October 2013 through March
2020 in the chaplaincy services departments of the BOP’s 122 BOP institutions, which includes BOP
chaplains, contract faith providers, and faith-based volunteers. We also observed and reviewed the BOP’s
oversight of chapel spaces, such as libraries, storage rooms, and classrooms used for religious education.
To accomplish the audit objective, we conducted interviews with over 70 BOP representatives, including
officials from the CSB, a BOP regional office located in Atlanta, Georgia, and 12 individual BOP facilities of
varying security levels. 7 While at these facilities we observed religious services and other religious
programming for multiple faith groups, as well as chaplaincy spaces, such as libraries and assigned faith
group lockers. We also reviewed a sample of volunteer faith provider files to determine if BOP policies and
procedures were followed. Lastly, we utilized evidence related to BOP’s religious services program gathered
during the OIG’s recent Audit of the BOP’s Monitoring of Inmate Communications to Prevent Radicalization. 8

Effect of the COVID-19 Pandemic on the Audit
We visited the 12 BOP facilities listed in Appendix 2 prior to February 2020. We learned that the BOP’s
ability to provide religious services has been significantly impacted by the COVID-19 pandemic. In March
2020, the BOP issued guidelines regarding the management of its facilities, including chaplaincy services
programs. The implementation of these guidelines as they related to chaplaincy services and religious
programs generally varied by institution and required all chaplains to make daily visits to accommodate the
spiritual needs of inmates in confinement. Contract faith providers were permitted to continue serving
facilities, subject to the health screening and other protocols of the location, although many institutions

NCIC is an electronic clearinghouse of criminal records managed through a shared management concept between the
FBI and federal, state, local, and tribal law enforcement users. As explained in greater detail below, volunteers are
designated as “Level 1” or “Level 2.” Only volunteer candidates designated as Level 2 are subject to an interview.

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7

Please see Appendix 2 for a listing of facilities visited in support of this audit.

U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), Audit of the Federal Bureau of Prisons’
Monitoring of Inmate Communications to Prevent Radicalization, Audit Report 20-042 (March 2020),
https://oig.justice.gov/sites/default/files/reports/a20042.pdf.
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chose to limit the use of these contractors. The services of volunteer faith providers were suspended across
the BOP at that time.
In September 2020, the BOP began to allow modified programming in the chapel spaces. Some of the
modifications included rotating inmate faith groups to the chapel and conducting services with inmates
from different housing units, using social distancing and safety practices, as well as the development of
institutional plans to safely celebrate religious holidays. In November 2020, the BOP resumed the use of
religious volunteers to meet the religious needs of inmates during holiday observances.
This audit does not address the effectiveness of the pandemic-related changes made to the BOP’s
chaplaincy services operations. However, the OIG has implemented a robust program related to oversight
of the BOP’s operations after the onset of the pandemic, including a series of remote inspections. For more
information on the effect of the pandemic on the BOP operations and the OIG’s oversight of those efforts,
please see the OIG’s pandemic resource page at https://oig.justice.gov/coronavirus.

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Audit Results
The BOP lacks adequate chaplaincy resources and religious diversity among its Chaplaincy staff to meet the
demand for the provision of religious services at its institutions. As a result, the BOP frequently relies on
alternative religious services options, such as inmate-led services, contract faith providers, or minimally
screened volunteers. We found that such alternatives carry varying levels of risk, and these risks are
exacerbated by the fact that responsibility for monitoring alternative religious services options falls to
understaffed and overburdened institution-level Chaplaincy Services departments.
We determined that during the period covered by our audit the BOP’s chaplaincy was not staffed according
to the BOP’s guidelines at many institutions. As of March 2020, the BOP’s chaplaincy staff across all
institutions was comprised of 236 chaplains, which is approximately 30 percent below what the BOP’s
guidelines consider to be a fully staffed chaplaincy for the inmate population. Further, the lack of faith
diversity among current chaplaincy staff leaves the BOP with few low risk options for providing services,
especially to the smaller population faith groups. As a result, the BOP has increased its reliance on the
alternative religious services options described above. However, we found that the BOP often did so
without ensuring adequate supervision and oversight of these alternative options. For example, in some
institutions we found that BOP staff did not have monitoring equipment in areas where services are
conducted. The lack of monitoring equipment creates a risk because chaplains and other staff who are
primarily charged with real-time oversight of inmate programming cannot simultaneously monitor multiple
services. We also found that some institutions permitted inmates with a known nexus to international or
domestic terrorism (terrorist inmates) to lead religious services. 9 Along with their required real-time
monitoring responsibilities, chaplains are also responsible for managing chapel spaces. However, in at least
two of the institutions we visited we found that spaces assigned to faith groups were not adequately
controlled.
Overall, we concluded that the BOP has not taken adequate steps to address its long-standing chaplaincy
staffing issues, including the issues arising from increasing religious diversity within the inmate population.
For example, the BOP relies on strict educational guidelines for chaplains that may disqualify otherwise
qualified candidates. Further, wardens with limited budgets sometimes prioritize hiring lower-graded
correctional staff over the higher-graded chaplains to maximize staffing levels at their institutions. We also
found that the BOP has not considered a strategy to improve existing programs or leverage existing
technologies that could allow for certain religious services to be shared virtually across institutions. As we
describe throughout this report, we believe that the BOP should develop and implement strategies that
better address these critical problems in an innovative and flexible way that can achieve the delicate

9 We refer in this report to “terrorist inmates” as inmates that the BOP’s Counterterrorism Unit (CTU) designated as a
terrorist inmate.

The BOP’s terrorism definition follows 22 U.S.C. § 2656f(d)(2), which defines terrorism as “premeditated, politically
motivated violence perpetrated against noncombatant targets by subnational groups or clandestine agents.” In
designating an inmate as a terrorist inmate, which leads to enhanced monitoring, the CTU relies on information
provided by investigators, prosecutors, and the courts, as well as its own background research. Inmates designated by
CTU as terrorist inmates are not necessarily just those inmates convicted on terrorism charges. For example, if an
inmate is convicted on charges not directly related to terrorism, but a nexus to terrorism has otherwise been identified
through CTU’s research the inmate may be designated as a terrorist inmate.

6

balance between institutional security and maximizing inmate access to faith-based services, thereby
respecting their right to exercise their religion.

Risks Resulting from Chaplaincy Shortages and Diversity Challenges
According to the BOP’s Central Office Chaplaincy Services Branch (CSB), the BOP’s Chaplaincy Services
departments have faced severe staffing shortages - primarily among the BOP chaplains. In addition, there
has been a persistent imbalance between the religious affiliations of the BOP’s chaplains and the diverse
faith preferences among inmates. In the absence of a fully staffed and diverse chaplaincy, BOP institutions
are unable to adequately administer their religious programs, prompting many BOP institutions to turn to
alternatives that pose enhanced risks, such as inmate-led services and reliance on minimally vetted
volunteers. We believe the BOP must improve its efforts to bolster and diversify its chaplaincy.

Inmate-Led Services
When the BOP does not have adequate religious service coverage through the use of chaplains, contract
faith providers, or volunteers, it may allow inmates to lead religious services. While inmate-led services are
permissible under BOP policy, we found that the BOP’s policies do not speak to possible restrictions on
certain inmates leading services and also appear somewhat inconsistent concerning the level of BOP
monitoring required. Specifically, the BOP’s Technical Reference Manual (TRM) for chaplaincy states that
inmates may not preside or lead inmate worship except in instances when other resources (chaplains,
contract faith providers, or volunteers) are not available, and only under chaplaincy supervision. Further,
the TRM explains that the required supervision entails frequent visual surveillance and intermittent in-room
supervision. In contrast, the BOP Program Statement 5360.09 “Religious Beliefs and Practices” includes no
specific prohibition of inmate led services but states that “inmate-led religious programs require constant
staff supervision.” We believe these policies have created confusion and uncertainty among chaplaincy staff
on the eligibility of certain inmates to lead religious services and the proper level of monitoring when this
option is used.
Despite the uncertainty surrounding inmate-led service policy, we found consistent agreement among the
CSB officials, Special Investigative Services (SIS) staff, and chaplains we interviewed that inmate-led services
presented safety and security risks to BOP institutions. One concern raised by BOP staff was the potential
for an inmate to use a religious leadership role as a method to obtain power and influence among the
inmate population. However, we also found that some BOP staff use formal religious titles when referring
to inmates who lead services, thereby reinforcing and elevating the inmate’s status. We agree that allowing
inmates to lead services and referring to inmates as religious leaders presents a risk that inmate religious
leaders could misuse services to encourage violent behavior, radicalize other inmates, or engage in
otherwise prohibited activity. 10
Given the agreement about the risks posed by inmate-led services, we asked the CSB Administrator why
there is not a clear policy that would prohibit certain inmates, especially those considered high-risk, from
leading religious services. The CSB Administrator agreed that certain inmates should not lead religious
services, but added that it is difficult to change BOP policy on this point because of the Religious Freedom
The BOP defines radicalization as the process by which individuals come to believe that their engagement in, or
facilitation of, non-state violence to achieve social and political change is necessary and justified.

10

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Restoration Act (RFRA). 11 The CSB Administrator added that in the absence of specific policy, chaplains
should rely on training, guidance memos, and support from the BOP’s Chaplaincy Services Coordinators
(CSCs) when determining whether certain inmates at their institutions should be permitted to lead religious
services.
Many CSB officials agreed with the Branch Administrator and told us that high-risk inmates, including
terrorist inmates, should not be allowed to lead religious services; however, in the absence of a clear BOP
policy, they recognized it is difficult for chaplains to enforce. In fact, despite the consistent belief that highrisk inmates should not lead services among CSB staff, we found only one instance where a chaplain
reportedly took preemptive action to prevent a known terrorist from leading religious services. Chaplains
may have a multitude of individual reasons why they might hesitate to proactively prevent a particular
inmate from leading services. However, regardless of those individual reasons, we believe hesitancy is
understandable because chaplains do not have the weight of clear BOP policy to support such sensitive
decision-making.
In addition to not stating clearly whether chaplains may exclude certain inmates from leading religious
services, we also found that the BOP policy is silent on acceptable processes for the selection of inmates to
lead services. Many chaplains currently allow faith groups to select their own leaders. When we inquired
about the rationale for this selection process, some chaplains explained that they allowed inmates to select
their own leaders to avoid complaints, lawsuits, or the rejection of leaders that would otherwise be selected
by BOP staff. While these are legitimate concerns, the absence of a clear selection process in BOP policy
results in the potential for the selection of inmates designated as high-risk by the BOP, including terrorist
inmates, to lead religious services.
At the 12 facilities we visited we sought to determine whether any inmates identified as terrorist inmates by
the BOP were permitted to lead religious services. Overall, we found that terrorist inmates were permitted
to lead or regularly led religious services at 4 of these 12 facilities. For example, at one facility, terrorist
inmates led religious services even though the BOP hired a contract faith provider, as we discuss in greater
detail below. At another one of these facilities we found that an al-Qaeda affiliated inmate, who was
convicted on terrorism charges, was permitted to lead services on a frequent basis. The facility’s chaplain
explained that the inmate was selected to lead services by the other inmate faith group members due to his
extensive faith knowledge and Arabic fluency. At two other facilities we learned that inmates with ties to
two prominent terrorist groups, the Islamic State of Iraq and Syria (ISIS) and Al-Shabaab were permitted to
lead services, with at least one doing so on a regular basis at this facility.
In addition, we identified two instances in two different institutions, where inmates disagreed with the
ideology of a contract faith provider secured by the BOP. 12 At one of these institutions, we identified two
convicted terrorists who were currently leading religious services for their faith group in place of the
contract faith provider. At the other institution, institution staff believed allowing the contract faith provider

11

Religious Freedom Restoration Act, 42 USC § 2000-bb (1993).

In addition to the four locations visited during this audit that allowed terrorist inmate-led services, we also observed a
terrorist inmate leading services at one of the locations we visited during our Audit of the Federal Bureau of Prisons’
Monitoring of Inmate Communications to Prevent Radicalization, Audit Report 20-042 (March 2020),
https://oig.justice.gov/sites/default/files/reports/a20042.pdf.
12

8

to conduct services for the objecting inmates would jeopardize the provider’s safety. As a result, the
contract faith provider stopped conducting services to the inmate faith group, allowing the inmates to lead
their own services.
In the absence of adequately staffed chaplaincy services departments and a clear policy further limiting or
prohibiting the practice, many chaplains have consistently and regularly permitted high-risk inmate-led
religious services. Although we recognize the challenges and sensitivities in developing such policies, we
recommend that the BOP strengthen existing policy to include clear guidance about when inmates may be
permitted to lead religious services, which inmates should be prohibited from leading services, and
minimum monitoring requirements for religious programs or services led by inmates.

Monitoring of Chaplaincy Services Spaces and Activities
Chaplaincy services spaces include chapels, chapel libraries, and inmate lockers as well as other controlled
areas used for faith-based programming. Generally, inmates can enter or exit these spaces during
controlled movement periods within scheduled inmate programming hours. 13 BOP policy requires
chaplains or other BOP staff to frequently monitor the chaplaincy services space for inmate misconduct,
including circulating contraband, fighting, advocating extremism or violence, or other BOP inmate policy
violations. Depending upon the resources available at an institution, including its chaplaincy services
staffing levels, a single chaplain may be solely responsible for simultaneously monitoring multiple chapels,
classrooms, hallways, restrooms, offices, and storage areas for improper inmate activities. To better assist
chaplaincy staff with monitoring, these spaces are typically equipped with audio and visual monitoring
equipment. However, we found that two institutions we visited did not have any monitoring equipment in
spaces where religious services were conducted.
At one facility, we observed the chaplain monitoring services that were being led by a detainee charged with
terrorism-related crimes by leaving his office door ajar to hear the service in the adjacent chapel. During
our observation of the service, we had difficulty hearing and distinguishing individual words. Further,
because the chaplain’s office did not have a direct, unobstructed line of sight into the chapel, we could not
see what activities were occurring inside the chapel. We also found that some religious services were
permitted to be conducted in housing unit spaces that were not outfitted with audio or visual monitoring
equipment and were monitored by correctional officers rather than chaplains. At another facility, we
learned that the chaplain conducted services in the housing units on a rotational basis. 14 On the weeks that
the chaplain was not present, inmates were able to lead services. Similarly, the chapel areas in the housing
units at this location did not have audio or visual monitoring equipment and were visually monitored by
correctional officers.

With the exception of federal prison camps, inmate movement throughout the BOP’s institutions are regulated by
controlled movement. The purpose of controlled movement is to ensure that the movement of inmates is orderly.
During a controlled move, inmates are allowed a specific amount of time (e.g., 10 minutes) to move from one point to
another within the institution without a pass or staff escort.

13

We observed this instance during our Audit of the Federal Bureau of Prisons’ Monitoring of Inmate Communications
to Prevent Radicalization, Audit Report 20-042 (March 2020),

14

https://oig.justice.gov/sites/default/files/reports/a20042.pdf.

9

We find the lack of monitoring equipment at these institutions concerning because these two institutions
frequently house detainees being held on terrorism-related charges. Further, when monitoring duties are
performed by non-chaplaincy staff, they likely do not possess the same level of religious training as
chaplaincy staff. Therefore, they may not be able to recognize questionable language or behaviors among
inmates during these services, or, alternatively, inadequately trained staff may identify certain language or
behaviors as questionable when they are not and attempt to restrict them. Additionally, many housing units
are staffed by only one correctional officer who must often monitor hundreds of inmates in the unit,
facilitate inmate movements to other areas, and perform various necessary administrative duties. We
recommend that the BOP determine the institutions without remote audio and video monitoring equipment
in spaces where religious services are conducted and determine the feasibility of installing such equipment,
or if the BOP is unable to install monitoring equipment at these facilities, it should take steps to ensure
adequate monitoring is performed.
We observed real-time religious services at six of the institutions that we visited to determine the quality of
the BOP’s video monitoring systems within its Chaplaincy Services departments. Based on our
observations, we found that the video monitoring equipment was inadequate at five out of the six
institutions we visited. Specifically, the quality of some of the visual feeds was poor and we had difficulty
clearly distinguishing personal characteristics and facial features among inmates. We also found that the
placement of some cameras created blind spots because the camera placement was stationary and could
not be adjusted by the chaplains. One chaplain pointed out that inmates had identified these “blind spots”
and have used them to engage in prohibited behavior. For example, the chaplain noted that he caught
multiple inmates smoking when he saw smoke rising from a blind spot while monitoring the camera feed.
To supplement visual monitoring, the BOP has installed microphones in most chapel spaces that allow them
to switch between audio transmissions from different locations. However, staff at some of the locations we
visited indicated that it is difficult to hear inmates when they talk in low voices or when they turn up the
volume of the television or radio. Further, the audio monitoring equipment is separate from the video
monitoring equipment, and in some locations was not installed in a readily accessible or convenient area for
the chaplains. At one institution, a chaplain had to cross the room or reach well above head level, turning
their attention away from ongoing activities, just to switch to another audio feed. Also, several of the
institutions’ SIS departments did not have access to the chapel and chapel classroom audio transmissions.
Instead, the SIS staff had to rely on chaplains to report and refer any concerns or policy violations that
occurred in the chaplaincy services department.
According to the CSB Administrator, to preserve the sacredness of the chapel space, audio and visual feeds
from chaplaincy services spaces should not be recorded. Therefore, chaplains or others utilizing this
monitoring equipment can only do so in real-time, creating a significant risk that prohibited behavior could
be frequently missed. Given the fact that religious services are already subject to real-time video
monitoring, we do not believe recording services from the video transmission would be any more of an
intrusion on the service. In view of its legitimate institutional security interests, we recommend that the
BOP reexamine its practice of prohibiting recording audio and video feeds from chaplaincy services spaces
alongside relevant federal law and regulations to help ensure that religious services are monitored to the
greatest extent possible and are not misused by some inmates to engage in prohibited conduct.

10

Oversight of Faith Group Lockers
Faith groups at some institutions are provided with an individual, dedicated space within the Chapel spaces
to store various items necessary for the practice, ceremonies, and religious rituals and rites associated with
each faith. The BOP considers these individual storage spaces, commonly referred to as “faith group
lockers” and the contents within them to be BOP property. Property obtained or owned by inmates is not
permitted to be stored in these lockers. Chaplains are required to maintain access to the lockers which are
generally located in the chapel or classrooms. Further, chaplains are required by policy to conduct frequent
searches of storage areas, including faith group lockers, to ensure that contraband is not introduced.
To ascertain the effectiveness of the BOP’s controls over faith group lockers, we inspected the faith group
lockers in 10 of the 12 institutions we visited. 15 While most of the lockers we reviewed contained only
permissible items, such as altar cloths, small statues, candles, and sacred texts specific to that faith, a total
of four lockers among three different institutions contained prohibited or questionable items. In these
instances, the materials we found were either prohibited in chapel libraries, advocated violence and
extremist beliefs, or property personally owned by inmates. For example, at one facility we found a faith
group locker that contained documents and images advocating white supremacy. At the same institution
another faith group locker contained copies of emails sent to individual inmates and a photo album of
inmates in that faith group as well as several copies of a previously prohibited book marked as chapel
property with a checkout list. At another facility, we found that one faith group locker contained a SENTRY
roster of inmates identifying as part of the faith group along with a handout containing hate speech. When
we presented the results of this review to CSB, those officials agreed that these items were inappropriate
and in violation of BOP policy. As it relates to the multiple copies of the prohibited book, CSB officials
believed it was likely due to miscommunication or misunderstanding on the guidance related to it.
While BOP policy provides inmates with access to items needed for their religious practice that may be
stored in faith group lockers, it also requires that chaplains conduct searches of faith group lockers and to
remain in control of the lockers. At some locations we visited, we found that chaplains unlocked faith group
lockers at the start of services and then locked them after services were complete, without consistently
conducting a locker search before and after the service. By allowing inmates unsupervised access to the
lockers during their allotted worship time, chaplains at these locations temporarily relinquished control of
the faith group lockers but did not consistently search the lockers after the service to ensure that no
prohibited items were introduced.
We believe that the BOP should better ensure that chaplains and Chaplaincy Services staff monitor faith
group lockers as required and have a complete understanding of prohibited items such as restricted texts
and inmate personal property. Without proper monitoring implemented, faith group lockers can be used as
a method for inmates to share or distribute radical, violent, and other prohibited materials. We recommend
that the BOP ensure that established security procedures regarding faith group lockers are followed and
that the BOP policy includes clear procedures for inmate access.

Administrative Maximum Facility Florence does not provide faith group lockers as all services are conducted in
inmate cells. We did not review the contents of faith group lockers at Federal Detention Center Miami.

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Chapel Libraries, Foreign Language Materials and Chapel Library Database
Collectively, the BOP’s chapel libraries contain nearly 800,000 individual items including religious texts,
books with religious themes, and audio and video recordings. The contents of each library vary by location,
with many of the resources donated by religious organizations. While these libraries help to facilitate the
free exercise of religion by inmates, without appropriate oversight prohibited material could find its way to
the chapel library shelves.
In a 2004 report, the OIG found that several BOP institutions did not have inventories of the books available
to the inmates. In response to that report, the BOP stated it would complete an inventory of print and
audio-video materials in its libraries and review them for content that promotes violence, domestic or
foreign terrorism, or any discrimination based upon race, color, religion, gender or national origin. As a
result of this effort, CSB‘s Chapel Library Database (CLD) was established. The CLD is currently managed by
the CSB, and available to all chaplaincy staff. It is housed on the BOP’s intranet and is required to contain a
record of all publications and other religious media materials that have been obtained for chaplaincy
services’ use. Each institution-level chaplaincy services department is required to maintain an accurate and
up to date account of the library materials they possess. These records are searchable by CSB officials and
other chapel staff members. A potential benefit of this system is that chaplains can search CLD records for
book titles that have already been reviewed and accepted thus reducing the time required to review new
materials. However, we found that the CLD was inefficient due to the lack of consistency in its use and the
CSB’s ineffective control and maintenance of the database.
To prevent the introduction of prohibited materials, chaplains are required by policy to review all new
chapel library acquisitions prior to allowing the materials to be circulated among the inmate population. To
signify that the materials have been reviewed, new library materials should be entered into the CLD with
one of four status designations: accept, review, pending review, or reject. 16 Nearly all library items (780,732
or 98 percent) in the CLD are designated as accepted for circulation. Further, according to CSB officials and
CLD records, the BOP has never formally rejected any religious materials from inclusion in its chapel
libraries. CSB officials stated that library materials are not rejected because doing so might be considered a
violation of the constitutionally protected rights of inmates. However, as of March 2020, there were 12,593
library items designated as “review” and 200 are designated as “pending review.” The BOP could not
provide data regarding the length of time materials have been in a “pending review” status because the CLD
is not capable of tracking this information. Without timely action or a function to monitor an item’s status,
these designations effectively serve as rejections.
We also found that religious materials were inconsistently recorded in the CLD among the 12 institutions we
visited. For example, one book that had been removed from circulation within the chapel libraries at the
institutions we visited was marked as “review” in the CLD at two institutions, accepted at another, and not

According to the CSB, the four status designations are defined as: (1) “Accept” means the item has been reviewed and
is available for inmate use; (2) “Review” means an item has been removed or prevented from entering circulation and is
stored away from inmate access due to BOP staff concerns; (3) “Pending Review” means an item has been sent to the
CSB for further review; and (4) “Reject” means an item is not available for circulation and has been removed from
chapel libraries. For items marked as rejected, the CSB in consultation with the BOP’s legal and intelligence
departments assign this designation to materials that contain specific documented institution security threat and
terrorist links.

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included in the CLD for the remaining nine. We saw more than twelve other books also inconsistently
recorded in the CLD. To determine the accuracy of the CLD inventories, we judgmentally sampled a total of
110 books from the chapel libraries at 11 of the institutions we visited and checked them against their CLDs
for each BOP institution. We found that collectively 47 of the 110 books we sampled (43 percent) were not
recorded in the CLDs. Further, we found that at least one sampled item from each chapel library that was
not recorded in the respective CLD at each of the tested facilities.
Because of this inconsistent use, we concluded that the CLD has not been an effective tool for chaplains and
other Chaplaincy Services staff. We believe that because of the many inaccuracies we found in the CLD,
neither chaplains nor the CSB have adequate knowledge of the contents of the materials in the BOP’s chapel
libraries. When we asked CSB staff why the database does not accurately reflect the contents of the BOP’s
chapel libraries we were told that the chaplains have multiple responsibilities that consume their work
hours and can make mistakes. We heard similar concerns from chaplains regarding the demands on their
time and the impact that it has on their CLD responsibilities. One chaplain told us that he reviews library
materials at home and does not record it as hours worked. Other chaplains told us it is difficult to maintain
the CLD due to the lack of staffing resources that they need to realistically keep the database up to date with
additions and deletions. We believe that this is another example of the multiple duties assigned to
chaplains that cannot be reasonably completed as required.
The CLD should be a tool that prevents duplication of effort among the BOP’s chaplaincy services staff. If
working as intended, a chaplain should be able to determine if a book has already been reviewed and
accepted at another institution. If a book is accepted by one chaplain, the chaplains at other institutions
should not have to spend time reviewing the same book. Yet, because of the inconsistencies and
inaccuracies, the CLD cannot reliably serve this purpose.
Recognizing that many inmates are not native English speakers, chaplaincy services departments often
purchase library materials in other languages, including Arabic, French, Hebrew, Japanese, Korean, and
other languages. Library materials in non-English languages must also be reviewed before entering library
circulation. This presents significant challenges for chaplaincy services departments because chaplains do
not have easy access to translation services to review the foreign language materials.
Further, in some cases, according to an CSB official, chaplains cannot enter foreign language publications
and other library items into CLD without an English translation. Therefore, the BOP cannot confidently say
that all foreign language materials in its chapel libraries have been entered into the CLD or reviewed prior to
entering circulation. These conditions create serious risks that foreign language materials with hateful,
violent, or discriminatory language may be circulating within the BOP’s chapel libraries. For example, at one
institution we found ten foreign language books in circulation that were not entered into the CLD. Two of
the books were written by an author that both the BOP and FBI considered potentially dangerous. Because
the books were not recorded in CLD, the BOP or CSB may not be aware that these books are accessible to
inmates.

13

We recommend that the BOP perform a comprehensive review of the CLD at the CSB to strengthen existing
policy or develop new policy that ensures an accurate inventory and timely review of newly introduced
English and foreign language texts with suitability determinations that can more easily be shared among all
BOP institutions; provide resources to assist chaplains in evaluating existing library materials, including
foreign language media, that have not been previously reviewed and entered into the CLD; and ensure that
those titles are added to the CLD or its replacement if applicable.

Advisories Regarding Inappropriate Chapel Library Materials
At times, the BOP’s Counter Terrorism Unit (CTU), CSB, and other entities within the BOP, issue advisories
regarding publications that are identified as questionable, inappropriate, dangerous, or in conflict with BOP
policy. 17 However, we found that these advisories and other guidance related to religious materials were
not always followed or considered by chaplaincy or other BOP staff when adding or reviewing chapel library
materials. For example, we learned that in April 2019, two CSCs emailed chaplains in their regions and
recommended removing specific materials from their chapel libraries prior to our site visits. Several of the
publications referred to in the CSCs emails were already identified as inappropriate by CSB, CTU, or other
experts and should have been removed several years ago. The list also included a general warning about
books and videos by a high-level, well-known terrorist and other concerning authors that were designated
as “accepted” in the CLD listings at the time the emails were sent. During our fieldwork, we found books by
some of these authors that were in circulation but not listed in the CLD. We further determined that the
BOP did not disseminate information about, or limit access to, materials by some of these authors that FBI
terrorism experts had restricted inmates subject to Special Administrative Measures (SAMs) from obtaining
due to the risks of promoting terrorism and threatening the safety and security of the institution. 18
Additionally, two long standing advisories issued in 2004 and 2006, that were in circulation as recently as
2017 and 2019, warned chaplaincy staff of concerns regarding a specific religious publication that had the
potential to support radicalization. During our audit, we found evidence that the publication was accessible
to inmates in at least two locations and had been purchased by one of these institutions as recently as 2018.
In the 2004 advisory memo, it warned that the publication was not a faithful interpretation of the text on
which it was based and cited at least six instances where the translators had inserted inflammatory or
disrespectful comments. The advisory instructed chaplains to remove this publication from library
circulation and to no longer purchase it with BOP funds. Further, the advisory directed chaplains to refrain
from confiscating inmate owned copies as BOP policy did not prohibit inmates from personally owning it.
Then, in 2006, a separate advisory concerning the same publication was issued which stated that it
contained significant radical content that endorsed violence, threatened the safety and security of BOP
intuitions, and jeopardized public safety. This 2006 advisory concluded that the publication violated BOP

An “advisory” is an intelligence report summary published by the BOP and sent to BOP institutions to inform staff of
security issues such as identifying, intercepting, and preventing objectionable publications from entering the BOP’s
institutions. The CTU is an intelligence unit created to assist in identifying terrorist inmates and provide for the
coordination of translation services and analysis of terrorist inmate communications.

17

A Special Administrative Measure (SAM) directive is an order authorized by the Attorney General that requires 100percent live monitoring by the sponsoring law enforcement agency of an inmate’s communications and can impose
other restrictions on an inmate, such as limiting communications to immediate family. A SAM can be authorized by the
Attorney General for any inmate who is deemed to pose a current threat to national security or public safety.
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policy and could be rejected from entering BOP facilities. However, the 2006 advisory did not specifically
address the 2004 guidance asking chaplains to refrain from confiscating inmate owned copies.
At the institution that purchased copies of the publication in 2018, we found copies accessible to inmates
through the library and a faith group locker. Chaplaincy staff at this institution stated they were aware of
the 2004 and 2006 guidance regarding the publication; however, the chaplains could not sufficiently explain
why the publication was still accessible to inmates in the chapel or why they purchased copies with BOP
funds after the advisories were issued. 19 We also asked the CSB Administrator how it was possible that, as
recently as 2018, an institution could have purchased several copies of this restricted publication. The
Branch Administrator opined that the book was probably purchased due to a lack of consistency and
knowledge regarding the policy of the publication. In this instance, we agree that the inconsistent advisories
and the lack of a policy requiring centralized retention of such advisories probably created confusion among
the chaplaincy at this specific institution, and potentially other institutions throughout the BOP.
At the second institution we also found copies of the publication in its chapel library. This institution is part
of a complex that houses maximum and high security level inmates. At this location we asked a staff BOP
linguist, who was certified by the FBI, if the publication should have been accessible to inmates. The linguist
told us that in his opinion because the publication encourages violence against certain faith groups it should
not be allowed in the institution. The linguist also stated that he does not believe the BOP’s institutions
know the full extent of what is in their libraries, especially in terms of foreign language books.
Because of the lack of coordination between the CTU, CSB, and chaplains in the field, we also asked the CSB
Administrator how information about restricted texts is disseminated to field chaplains. We were told that,
since 2012, the CSB has offered chaplains religious extremism courses that cover such topics, including
instruction on concerning or otherwise restricted religious books and videos. However, we found that these
training materials lacked pertinent information regarding the authors and publications that have been
identified by CTU and CSB as security threats. The training also did not specifically mention the 2004 and
2006 advisories or highlight the BOP’s policies against purchasing certain publications with BOP funds.
We also identified risks associated with the lack of protocols for handling religious items that have been
removed from chapel libraries due to security concerns. Currently, there is no BOP protocol in place that
provides directions to institutions on how they are to dispose of items considered inappropriate. Several
chaplains we interviewed stated that they have not been instructed on what to do with materials after
removal from the libraries. This is particularly concerning if the item is considered a sacred text. At one
facility we found that a chaplain kept several copies of one of the previously referenced books that he had
removed from circulation in his desk drawer for several years because he did not know how to
appropriately dispose of the material. Without a standardized protocol for removing and properly handling
materials identified for removal from chapel libraries, there is a risk that these items may subsequently be
erroneously placed back into circulation and become accessible to inmates again. We recommend that the
BOP develop a centralized repository for BOP Chaplaincy Services related advisories to better ensure that

The CLD for this institution listed one copy of the publication in a “review” status and it should not have been in
circulation. Further, the multiple copies of the publication found in the faith group locker and purchased with BOP funds
were not recorded in the CLD.

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important guidance for chaplains is current and consistent and provide chaplains with clear instructions for
proper handling and disposal of religious texts deemed inappropriate for inmate use.

Volunteer Faith Providers - Inmate Contact
Chaplains are required to monitor the activities of external faith providers, including any worship services
and study groups they conduct. The level of required monitoring depends on the type of provider.
Institutions can supplement the BOP’s monitoring policy to define intermittent and constant supervision in
terms of time (e.g., every 20 minutes). However, the chaplains with whom we spoke generally agreed that
monitoring entails either constant or periodic visual observation of the service or other activity whether
conducted by volunteer faith providers or inmates while it occurs.
Further, with limited exceptions, BOP policy prohibits external service providers, including those for
Chaplaincy Services, from contacting inmates outside of the prison setting to reduce opportunities for
inappropriate relationships to develop. All contractors and volunteers with the BOP, including those for
Chaplaincy Services, receive training regarding this policy and certify that they are aware and understand it.
However, during our fieldwork, a BOP staff member shared concerns with us about volunteers potentially
developing personal relationships with inmates and being manipulated into engaging in prohibited
behaviors, such as transporting contraband or providing their personal contact information.
To determine if there were any indications of prohibited contact between volunteer faith providers and
inmates, we judgmentally selected a total of 79 volunteers from the files of the institutions we visited. For
each volunteer, we obtained telephone numbers that were provided to the institution on volunteer
applications or other documentation contained in the volunteer files. We then used this information to
query TRUVIEW, a link analysis application that can compare data across multiple BOP Trust Fund
applications, to search for activity between the volunteers’ information and individual inmate accounts.
Through our analysis, we initially found that 22 of the 79 volunteers had links to inmate accounts that could
have been an indication of prohibited contact. Upon further testing we determined that 18 of these 22
volunteers with links to inmate accounts either did not represent inappropriate conduct by the volunteer or
we were unable to assess the propriety of the link. 20 However, for the 4 remaining volunteers, we identified
266 instances of improper contact between the volunteers and inmates.
When an inmate attempts to contact someone outside of the institution by telephone or email, the recipient
must consent to receive the communication. Therefore, these 4 volunteers (or someone with access to their
We note that one of these 18 volunteers received a telephone call from an inmate at the same institution where they
volunteered just a few days before the individual applied to serve as a volunteer faith provider. According to the BOP
records, the volunteer disclosed his prior relationship with the inmate and the BOP did not object. When we inquired
about the telephone contact with SIS, we were informed that a subsequent investigation determined that the volunteer
had served as the inmate’s pastor prior to his incarceration. We were also told that, in March 2020, SIS counseled the
volunteer on the BOP’s policy prohibiting outside communication with inmates. Although the telephone communication
was not prohibited by BOP policy because the individual was not serving as a volunteer at that time, we note that
generally allowing individuals with current or prior associations with inmates to serve as volunteer faith providers may
create unnecessary security risks in some cases. For example, individuals with nefarious intent and existing inmate
relationships may see volunteer service as an opportunity to gain access to inmates under the guise of religious service.
Although we do not make a formal recommendation related to this situation, we urge the BOP to consider ways to
address this potential risk.

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email or telephone number), consented to receive the communication or took direct action to email, send
funds, or visit the inmate. These 4 volunteers performed their volunteer service at four of the facilities we
visited. We discussed these potentially prohibited contacts with SIS representatives at each location. The
results of these conversations are noted below.
Volunteer 1 received one email from an inmate at the same institution where they volunteered. This
individual had served as a volunteer with the BOP since 2006 and the communication occurred in 2014.
Although we alerted SIS to the communication in March 2020, as of December 2020, an investigation had not
yet been conducted. In December 2020, SIS stated an investigation would be forthcoming.
Volunteer 2 exchanged five emails from an inmate at another BOP facility. As a result of our analysis and
the identification of the email communications, the BOP suspended the volunteer in early 2019. However,
the volunteer was later reinstated by the Warden after “further scrutiny.” The BOP did not provide any
additional details regarding its decision to reinstate the volunteer.
Volunteer 3 received nine telephone calls from an inmate while housed at two different institutions between
January 2016 and November 2016. The volunteer also made a funds transfer to the same inmate in 2016.
When we discussed these events with SIS at this facility, they stated that because the inmate was housed at
facilities other than the one where Volunteer 3 was providing assistance, the communication was not
prohibited. We inquired whether CSB agreed with this SIS assessment and CSB told us that it did not agree
because BOP policy clearly states that volunteers must not have contact with inmates outside of volunteer
service and makes no exception for communicating with inmates at other institutions. SIS representatives
also stated that they had no record of a funds transfer; however, our link analysis found clear evidence of a
transfer. When we followed up with the BOP in March 2021, we were told that Volunteer 3 was terminated
in February 2021 due to the unauthorized contact we identified.
Volunteer 4 exchanged 250 emails with an inmate at another institution between November 2016 to July
2019. Initially, SIS representatives stated that Volunteer 4 was part of the BOP’s Mentoring and Transitional
Program, and that because BOP policy allows volunteers in the program to communicate with inmates, the
communications we identified were authorized. 21 However, when we asked the BOP to provide evidence to
support the volunteer’s participation in the program, SIS told us that the volunteer was not part of the
program and was not authorized to communicate with any inmates outside of volunteer service. Based on
the BOP’s subsequent response, the 250 instances of email communication violated BOP policy. In March
2021, the BOP informed us that remedial action against Volunteer 4 was forthcoming.
We also found that Volunteer 4 provided letters of endorsement for several volunteer applicants despite a
previous suspension for policy violations. As noted above, the BOP requires its Chaplaincy Services
volunteer applicants to provide one letter of endorsement. Additionally, the sponsor of the endorsement
must not have been in an unfavorable standing with any BOP component. Because a single endorsement
letter will satisfy this important application requirement for new volunteers, we believe that the BOP should

Volunteer participants in the BOP’s Mentoring and Transitional Program are permitted to engage in program-related
contact with inmates to whom they have been assigned. Nevertheless, BOP policy states that mentor volunteers must
submit a written request for approval for telephone or written communications with inmates in the program and to
document all instances of communication.
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adhere to its policies related to vetting volunteers and apply increased scrutiny to endorsements from
previously disciplined volunteers. The BOP should also ensure that those reviewing the volunteer
application are aware of the prior discipline when determining the weight given to the endorsement in their
decision-making. 22
Given the many instances of inappropriate contact and instances of apparent reliance on endorsements
from previously disciplined volunteers, we believe that the BOP can strengthen its volunteer vetting process
by conducting testing similar to ours to better identify volunteers that could pose a risk to BOP institutions.
Therefore, we recommend that the BOP conduct a periodic analysis of volunteer contact information
through its TRUVIEW system and clearly document any exception that was granted to specific volunteers,
such as those in mentoring and transitional programs. The BOP must also ensure its volunteers and
inmates are aware of its policy on prohibited contact and apply increased scrutiny to endorsements offered
by previously disciplined volunteers.

Volunteer Faith Provider Data Management
Currently, the BOP manages volunteer data in its National Automated Volunteer System (NAVS) database. 23
At the start of a volunteer’s service, BOP staff establish a profile for each volunteer that includes personal
information, including name, physical description, contact information, sponsor organization details,
volunteer location, and volunteer service status. If the volunteer has been terminated, the file should also
contain reasons for the termination and accompanying documentation.
During our fieldwork we found three volunteer faith providers from different institutions that were
terminated due to BOP policy violations, including attempting to provide an inmate with personal contact
information, communicating with an inmate outside of volunteer services, and attempting to provide
inmates with an unauthorized item. We reviewed NAVS volunteer profile information for each of the three
terminated volunteers and found that the NAVS profiles for two of the three volunteers listed their status as
“inactive” rather than “discontinuation”, which would have alerted other institutions that the services of
these volunteers were no longer permitted in any BOP institution. We also found that none of the three
profiles included the reason for termination or any other supporting documentation, such as a termination
letter.
Without complete information, such as the reason for termination, the BOP runs the risk of permitting
volunteers previously terminated for prohibited conduct from entering volunteer service at other BOP
institutions. Therefore, we recommend that the BOP ensure that NAVS volunteer data profiles are accurate,
complete, updated, and contain all necessary information so that BOP volunteers terminated for violating

Volunteer 4 provided the sole letters of endorsement to support at least seven volunteer applicants. Although we
cannot confirm how much weight the BOP gave to these particular letters of endorsement, the BOP appears to have
allowed them to at least satisfy this specific application requirement.

22

In October 2018, the BOP transitioned from the Volunteer and Contractor Information (VCI) system to the NAVS
database, and current and past volunteer data was migrated into NAVS. NAVS was reported to provide greater
functionality including Level 1 volunteer tracking and the ability to upload supporting documentation, functions that
were not possible with VCI.

23

18

BOP policy cannot seek volunteer roles at other BOP institutions.

Strategies to Improve Chaplaincy Shortages, Faith Diversity Imbalance, and Existing
Recruitment Methods
As of March 2020, the BOP’s inmate population consisted of over 160,000 inmates, of which approximately
70 percent officially identified with a faith group. During intake processing into the BOP’s custody, inmates
are asked to state their religious affiliation, if applicable. Those inmates who indicate a religious preference
are designated in the BOP’s SENTRY system as a member of one of the faith groups identified within the
system. 24

Chaplaincy Services Staffing Guidelines and Shortages
We found that the BOP’s chaplaincy services departments are not staffed according to BOP guidelines at
many institutions. The BOP’s current policy states that, at a minimum, each chaplaincy services department
should be staffed with at least one chaplain and one RSA. This standard translates to a minimum need for
122 chaplains and 122 RSAs throughout the BOP. 25 However, we found that as of March 2020, nearly half of
the BOP’s institutions had no RSA, three institutions had no chaplain at all, twenty-one institutions employed
a single chaplain, and two institutions had only recently filled their only chaplain position after long
vacancies. In addition to the minimum staffing level, BOP guidelines also suggest that institutions
supplement the minimum requirement with additional chaplains based on inmate population (1 chaplain
per 500 inmates) and specific characteristics of the institution, such as being a major medical center, having
2 or more satellite facilities, or the inclusion of a special unit, each of which should have one additional
chaplain. Therefore, the BOP’s chaplaincy services staffing and supplemental guidelines suggest that a fully
staffed chaplaincy would include 357 chaplains and 122 RSAs. As noted earlier, as of March 2020, the BOP’s
chaplaincy staff included only 236 chaplains and 64 RSAs, which is approximately 30 percent below what the
BOP’s guidelines consider to be a fully staffed chaplaincy for the inmate population.
Based on these minimum and supplemental guidelines, we reviewed the BOP’s chaplaincy population by
institution and found that as of February 2020, more than two-thirds of the BOP institutions did not meet
these guidelines. Table 2 below details the 10 BOP institutions where chaplaincy services departments are
most understaffed per BOP guidelines.

Inmates generally may choose to update or change their affiliation while incarcerated. Inmates who claim an
affiliation with a religious organization not in SENTRY are categorized as “other” while those who do not claim a
preference are tracked as “no preference” or “unknown.”

24

Although some institutions have administrative positions in addition to the RSA, such as mentor coordinator and Life
Connections Program assistant, those positions only service the programs to which they are assigned.

25

19

Table 2
BOP Institutions with Greatest Chaplain Disparity
As of February 2020
Institutions

Inmate
Population a

Number of
Chaplains b

Chaplains to
Inmate
Ratio*

Major
Medical
Facility,
Special Unit
or Other
Program c

Number of
Chaplains
Suggested
by BOP
Guidelines

1

Federal
Correctional
Institution
(FCI) Seagoville

1,993

1

1:1,993

√

5

2

FCI Jesup

1,567

1

1:1,567

√

5

3

Federal
Correctional
Complex (FCC)
Beaumont

4,865

4

1:1,216

10

4

FCI Forest City

3,203

3

1:1,068

7

5

FCI Lompoc

2,842

3

1:947

√

7

6

FCI Petersburg

2,781

3

1:927

√

7

7

FCC Victorville

4,139

5

1:828

9

8

FCC Yazoo City

3,985

5

1:797

8

9

FCC Coleman

6,141

9

1:682

13

10

FCC Terre
Haute

2,606

4

1:652

a

Inmate population of listed institution as of February 20, 2020.

b

Chaplain assignment as of March 28, 2020.

√

8

The BOP’s Chaplaincy Services staffing guidelines suggest an additional chaplain for institutions that are (a) major
medical facilities; (b) have two or more satellite programs, such as a camp, SMU, and CMU; or (c) operates a special
initiative or program, such as the Life Connections Program.
c

Source: OIG Analysis

We were particularly concerned to find that some BOP institutions were without any chaplaincy staff.
During our audit, we saw a peak of at least three institutions that were without a chaplain. When we asked
how institutions handle the absence of a chaplain, BOP officials told us that religious services were
conducted by external faith providers, or in most cases, inmates themselves. We also were told that the
required monitoring of these non-chaplaincy led services was generally conducted by other BOP staff

20

members, such as correctional officers. Further, according to the BOP, when an inmate required pastoral
care or guidance, chaplains from other institutions or the CSB might be temporarily assigned to the
institution to assist. However, even with these ad hoc adjustments, we believe that critical tasks may not be
accomplished, including purchasing and reviewing library materials and conducting certain faith-based
programing. Moreover, in the absence of a chaplain, other BOP staff do not have the same faith-specific
training that chaplains receive and may not be able to identify risks when monitoring religious services, and
some staff members told us that a void may be created and filled by inmates who seek power and influence
as faith group leaders. Finally, the absence of a consistent trained religious official deprives inmates and
staff of the expertise and guidance for spiritual matters in times of individual crisis, such as the illness or
death of family members.
When we inquired as to why the BOP was not meeting its own guidelines for chaplaincy staffing, we were
given various explanations. First, according to BOP officials, the BOP in 2017 required all departments to
reduce positions through attrition. As a result, BOP chaplaincy positions were reduced from 257 (in
September 2016) to 212 (in September 2018). According to some officials, the chaplaincy services is still
recovering from the reduction of positions. We were also told that because chaplains are not considered
“custody” staff, chaplaincy positions may continue to go unfilled in favor of custody staff positions to
maximize operational security. 26 Although the BOP continues to operate its chaplaincy services
departments at a severe deficit in chaplaincy staff based on its own guidelines, since 2018, some progress
has been made as CSB reported 236 chaplains in March 2020.

Faith Representation Disparities
The BOP chaplaincy staffing guidelines are based on factors such as the size of the institution and any
special operations that exist at a specific location, such as a major medical center. However, one factor that
is not considered within the staffing guidelines is the hiring or placement of chaplains based on the religious
needs of a particular institution or even BOP-wide. We believe this hiring approach has contributed, at least
in part, to the significant imbalance between inmate faith groups and those who are qualified and available
to provide religious services.
As of March 2020, 199 of the BOP’s 236 chaplains (84 percent) represented a Protestant Christian faith
(which includes Adventist). However, inmates who identify with the Protestant Christian faith make up
approximately 34 percent of the total inmates that claim a faith preference. Among the remaining 37
chaplains, only 7 additional faith groups are represented, leaving at least 16 groups without any chaplains
who share their faith. While the BOP expects its chaplains to be pluralistic and to meet the religious needs
of all inmates regardless of faith, it is not always possible for them to do so. There are many instances in
which a practitioner of a particular faith is needed to perform a specific service, ceremony, or religious rite.
For example, only a Catholic priest can perform mass, administer last rites, or provide confession for
Catholic inmates.

Custody staff is comprised of sworn law officers who provide supervision, care, and correctional treatment of inmates
by enforcing rules and regulations governing facility security, inmate accountability and inmate conduct to ensure
judicial sanctions are carried out and inmates remain in custody.

26

21

When factoring in the external providers that are intended to fill the gaps, nearly half of all faith providers
(chaplains, contractors, and volunteers) are adherents to a Protestant Christian faith. By comparison, the
Catholic faith, which is the second largest affiliation among inmates, making up approximately 25 percent of
inmates with religious affiliations, is represented by just 7 percent of the BOP’s chaplains and 16 percent of
its total faith providers. Exacerbating this problem is the fact that, similar to chaplains, when the BOP
retains the services of external faith providers, it does not place them in proportion to the needs of a
particular institution. As Table 3 shows, in some instances this approach can lead to the number of faith
providers available outnumbering the number of inmates they are retained to serve. Although these
volunteers are not necessarily at the same location and likely not providing volunteer services
simultaneously, we believe it is indicative of the BOP’s need to assess its strategy for recruiting and retaining
volunteers based on need.

22

Table 3
Inmate Population and Chaplaincy Services Resources by Faith Group at the BOP*
Faith Group

American Indian
Atheist a
Baha’i

Inmate Population by
Faith Group

Type of Chaplaincy Services Resource

5,743

0

6

27

Inmate to
Resource
Ratio
174:1

182

0

0

0

1:1

Chaplains

Contractors

Volunteers

0

0

0

0

0:0

Buddhist

1,592

2

1

69

22:1

Catholic

29,553

15

46

550

48:1

1

0

0

14

1:14

2,149

0

0

52

41:1

322

0

0

15

21:1

72

0

0

0

72:0

Christian Science
Church of Christ
Hindu
Humanist
Jehovah Witness

982

0

1

457

2:1

Jewish

3,298

4

32

87

27:1

Messianic

2,452

1

1

17

129:1

Moorish Science Temple

2,061

0

1

2

687:1

606

0

0

160

4:1

Mormon
Muslim

11,073

13

12

38

176:1

Nation of Islam

2,313

0

7

6

178:1

Non-Trinitarian

428

0

0

42

10:1

457

2

3

22

17:1

4,463

0

0

3

1,488:1

Orthodox Christian
Pagan
Pentecostal
Protestant Christian
including Adventist a
Rastafarian
Santeria
Sikh
Other Faiths b
Total:

26

0

0

171

1:7

40,797

199

5

1,852

22:1

3,387

0

0

2

1694:1

3,455

0

0

2

1728:1

48

0

0

0

48:0

2,870

0

2

110

26:1

118,330

236

117

3,698

29:1

* The data used in this table was compiled by the BOP at different periods of time. Specifically, inmate population faith
affiliation data is current as of February 2020, while chaplaincy data is current as of April 2020. The most recent
available data for contract and volunteer faith providers was from the FY 2019 Annual Chaplaincy Services Branch
Report because the BOP does not maintain this information on a continuous basis. Further, the data above reflects the
overall representation of faith service providers in the BOP. It does not reflect actual faith group representation based
on individual institution populations, or the availability of resources for religious services.
SENTRY includes individual designations for Adventist and Atheist faith groups. However, the BOP considers the
Adventist faith group to be represented by Protestant Christian chaplains and Atheists to be represented by all
chaplains.

a

b

The “other faiths” category includes inmates who identify with a faith not specifically listed in SENTRY.

Source: BOP

23

The BOP officials at CSB and institution chaplains have recognized that the disparity among faith groups is a
problem which has been highlighted in each of its annual reports submitted to the Regional Directors since
at least 2013. However, we believe the issue has remained largely unaddressed because the BOP has not
taken a strategic approach to its chaplaincy hiring efforts or its efforts to retain contract or volunteer faith
providers to fill the representation gaps.

Position Requirements that Hinder Chaplaincy Recruitment Efforts
BOP officials told us that several factors have impacted their efforts to recruit a more representative
chaplaincy. Two of the most significant limiting factors appear to be the BOP’s educational requirements
and age restrictions that must be satisfied to qualify for a Chaplain position.
The BOP has long considered a formal education in world religion and ministry to be essential to the
pluralistic environment of correctional settings and requires Chaplains to have a Master of Divinity degree,
or equivalent. Figure 1 shows the technical qualifications that the BOP requires for prospective chaplains.

Figure 1
Technical Requirements for Prospective BOP Chaplains

Endorsement
Affirmation
from religious
organization
or faith group

Credential
Ordination or
recognition as
a leader in
faith group

Education
Master of
Divinity, or
equivalent

Experience
Two years of
pastoral
leadership
experience

Source: BOP

However, many faith groups recognized by the BOP do not have formal educational pathways to attain
leadership positions in their faith. Graduate level programs are often found in seminary schools and are
commonly obtained prior to ordination in many Protestant Christian denominations. While other faith
traditions may have graduate programs directed to their faith, they may not be as prevalent and may not be
required to become a religious authority within their faith. We believe the BOP’s formal educational
requirement may exclude otherwise qualified practitioners from applying and serving as chaplains because

24

they may belong to faith groups without a wider organizational or educational structure, or because they
have fewer practitioners in the United States that can meet these requirements.
In addition to the educational requirements noted above, chaplains must also be under the age of 37 when
their BOP employment begins. In certain instances, this age requirement can be waived for an applicant
with prior law enforcement or military service. 27 This age requirement, which is typically applied to law
enforcement positions, is applied to chaplains because they may be called upon to assist correctional staff
in certain circumstances. However, since 1976, the BOP has, at times, waived the age requirement for
chaplain applicants of specific faith groups. Specifically, we learned that pursuant to DOJ Order 1200.0,
part 1, chapter 1-6, B.3, the BOP may waive the age restriction for applicants who have been endorsed by
the Catholic, Islamic, or Jewish faiths. When we asked the BOP why the age restriction waivers were limited
to only these three faith groups, the BOP stated that only the Department of Justice could waive age
requirements for other faiths and it had not sought the Department’s assistance to expand age requirement
waivers to more applicants.
In view of the current staffing level of chaplains within the BOP and the difficulties in recruitment related to
the BOP’s education requirements and age restriction, we recommend that the BOP reassess the existing
education requirement for chaplaincy eligibility to enhance the prospect of attaining the BOP’s target
chaplain staffing level, or evaluate the benefits of implementing religion-specific educational requirements
to account for differing requirements among religions. Further, the BOP should coordinate with the
Department of Justice to determine if age waivers should be expanded to a broader group of chaplaincy
applicants.

Internal Conditions and Hiring Processes That Hinder Chaplaincy Recruitment Efforts
In addition to the educational requirements and age restriction, CSB and regional office staff also pointed to
several internal conditions that hinder the BOP’s recruitment efforts. First, because chaplains are generally
classified at higher pay grades than “custody staff”, more custody staff can be hired with the same funding. 28
Therefore, chaplaincy vacancies may remain unfilled or unaddressed if Wardens prioritize less expensive
custody positions over higher salaried chaplaincy positions. Further, when chaplain positions are
advertised, they are often announced for multiple institutions at the same time. As a result, chaplain
candidates may apply for multiple vacancies and subsequently qualify for positions at several BOP
institutions, resulting in BOP institutions competing for the same candidates. Timeliness is also a factor that
is impacted by competing offers because hiring certification lists with qualified candidates are only valid for
up to 90 days and often expire before a backup selection can be made. According to one BOP human
resources staff member, their region could only fill approximately 40 percent of the chaplain vacancies posted
in that region due, in part, to the expiration of certification lists that may have qualified candidates beyond
the first candidate selected from a particular list. When we reviewed chaplain hiring decisions for the period

Pursuant to 5 U.S.C. § 3307, the Department of Justice may determine and fix the maximum age limit for an original
appointment to a position as a law enforcement officer. The Attorney General has determined that the law
enforcement age restriction also applies to initial appointments into BOP law enforcement positions. BOP policy further
applies this restriction to chaplains along with other correctional staff.

27

According to the BOP, Chaplains are typically hired at a GS-12/13 on the federal pay scale; whereas custody staff are
typically hired at the GS-5/7 pay grade.

28

25

of January 2019 through December 2019, we found that of the 34 positions announced, only half resulted in
the selection of a candidate.
Individual wardens are responsible for initiating the hiring process for chaplain positions at the BOP’s 122
institutions. The institution’s human resources staff coordinates with regional office staff to make the
vacancy announcement available to the public and coordinates interviews with the CSC, supervisory
chaplain, and other institution staff. The final hiring decision for a chaplain is made by the Regional
Director, with input from the CSC and individual warden. Figure 2 depicts the multiple steps in the
chaplaincy hiring process.

Figure 2
Overview of the Chaplaincy Hiring Process

Identification

Institution warden
determines need for
chaplain

Application

Candidates apply to
vacancy
announcement

Certification
List

Regional Office
human resources
staff receive list of
qualified applicants

Interview

Institution staff,
supervisory chaplain,
and CSC conduct
interviews

Selection

Warden and CSC
submit hiring
recommendations to
Regional Director

BOP creates vacancy
announcement

Regional Office sends
certification list to
institution

Regional Director
determines successful
candidate

Source: BOP

Because of the complex challenges the BOP faces in recruiting a complete and diverse chaplaincy, we
believe that the BOP should reassess its chaplaincy recruitment efforts and take a more strategic approach
that continues to focus on the chaplaincy services’ mission, but also accounts for the unique attributes of
individual BOP institutions. We believe shifting to this type of recruitment strategy along with other
innovative solutions could result in a more robust and diverse chaplaincy that better reflects the diversity of
the inmate population. Further, as discussed in previous sections, reducing chaplaincy shortages will also

26

improve religious services monitoring coverage and reduce the risks posed by inmate led services and
minimally vetted volunteers.

External Factors That Hinder Chaplaincy Recruitment Efforts
Finally, BOP officials told us that recruitment has been affected by the declining number of people entering
faith professions. For example, Georgetown University’s Center for Applied Research in the Apostolate
reported that the Roman Catholic faith has experienced declining numbers of men entering the priesthood
for several years. Specifically, in the United States, the number of Catholic priests has declined from
approximately 59,000 in 1970 to just under 37,000 in 2018, although the United States’ self-identified
Catholic population has increased from 54.1 million to 76.3 million in the same span of time. 29 Some of the
BOP’s Catholic chaplains we spoke with were likewise not surprised by the difficulty of staffing positions
within the corrections environment because of the broader challenge of staffing Catholic parishes in the
United States.
Similarly, in the United States, the Islamic faith is experiencing an apparent decline in the number of
individuals entering faith leadership and a shortage of imams. According to a 2013 study conducted by the
Pew Research Center, nearly 60 percent of U.S. mosques were without a full-time paid imam and relied on
volunteers to fill the role. Currently, 6 percent of the BOP’s chaplains are Muslim, while 9.4 percent of
inmates identified as Muslim. According to the CSB Administrator, the challenges in recruiting chaplains for
the Islamic faith have persisted within the BOP for years. In fact, the BOP had no more than 13 Muslim
chaplains in the past 6 years even though the number of inmates who affiliate with the Islamic faith has
grown during that same timeframe. 30

Potential Improvements to the BOP’s Existing Chaplaincy Recruitment Efforts
Although the CSB does not have the authority to make local hiring decisions, we believe that it should be
involved in the development and implementation of policies that can expand and diversify chaplain
candidate pools and more effectively use contract and volunteer faith providers to fill the chaplaincy staff
gaps. At present, the CSB provides only limited assistance to chaplaincy field operations and staff. 31

Center for Applied Research in the Apostolate (CARA), “Frequently Requested Church Statistics,”
http://cara.georgetown.edu/frequently-requested-church-statistics/.

29

In a previous review of Muslim Services in the BOP, the OIG found the BOP had an inadequate number of chaplains
and other religious service providers to meet the needs of its inmates who identified as being of Islamic faith. At the
time, 6 percent of the inmate population identified as Muslim and the OIG recommended that the BOP develop a
strategy to recruit more Muslim service providers within its chaplaincy and chaplaincy services departments. In the
nearly 16 years that have passed since that OIG recommendation, the number of inmates identifying with the Muslim
faith has more than doubled. U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), A Review of the
Bureau of Prisons' Selection of Muslim Religious Services Providers. Oversight and Review Division (April 2004),
https://oig.justice.gov/sites/default/files/legacy/special/0404/final.pdf .
30

The services provided by the CSB are primarily performed by its three Chaplaincy Services Coordinators (CSC) who
are based at institutions within their regions of responsibility. These CSCs serve a large constituency as each CSC is
responsible for 2 regional territories that are each comprised of approximately 20 institutions and any other collocated
31

Continued

27

In the 1990s, the BOP established its Chaplain Trainee Program (CTP), which is an on-site training program
that allows current BOP employees to acquire the necessary skills and experience to become a chaplain.
Since its inception, approximately 27 chaplain candidates have participated in the program. In response to
a 2004 OIG report that highlighted a significant shortage in chaplains of Islamic faith, the BOP incorporated
the CTP into its effort to attract a greater number of Muslim chaplains. In addition, because the BOP
recognized that the educational requirements were barriers for potential candidates that do not necessarily
have educational pathways to religious leadership, the BOP hoped to also recruit external trainee chaplains
of Islamic faith through the CTP. However, the BOP’s efforts to increase Muslim chaplaincy using the CTP
were unsuccessful, resulting in only one Muslim chaplain trained through the CTP since 2006. During our
audit, we learned that the BOP was no longer placing emphasis on underrepresented faith groups when
selecting candidates for the CTP and institutions were not seeking CTP candidates outside of current BOP
employees, further limiting the potential applicant pool. We believe that the BOP should reassess this
decision as part of a more strategic recruitment effort. Since 2000, 22 chaplains have participated in the
CTP, although only 4 were of members of non-Protestant Christian faith groups. 32 In addition, we were
made aware of one trainee in the program at the time of our review who is scheduled to complete the
program in December 2021.
According to BOP chaplaincy staff, one of the major challenges with the current CTP is that positions are
limited and difficult to secure even if there are high levels of interest at specific institutions. For example,
one Supervisory Chaplain stated that several BOP staff members at his institution would be interested and
qualified to join the CTP if positions were available; however, each time he had tried to obtain a CTP position
the request was denied by CSB officials. When we inquired with CSB as to why such requests were denied
we were told that CSB no longer controls the placement of CTP positions because the available positions
were lost due to the BOP’s budget reductions. We recommend that the BOP review the current CTP model
to expand opportunities for current BOP staff and qualified external applicants with flexibilities that would
avoid disqualifying otherwise suitable candidates due to restrictive educational barriers or pastoral
experience requirements. We believe reasonable flexibilities can be particularly effective in recruiting
existing BOP staff who presumably have experience within and understand the organization along with a
desire to provide the pastoral needs of the inmate population.

Recruitment Strategies for Contract and Volunteer Faith Providers
Contract faith providers are trained clergy or spiritual advisors who help the BOP fill some of the voids in
their chaplaincy ranks. However, we found that the use of contract faith providers has generally declined
over the past several years as illustrated in Figure 3. In fiscal year (FY) 2015, the BOP employed 201 contract
faith providers. By FY 2020, the BOP had only 117 contract faith providers available. Contract faith
providers undergo a screening process that includes a moderate background investigation conducted by
the Office of Personnel Management.

facilities. CSCs serve as liaisons between CSB, regional offices, and the individual institutions regarding chaplaincy
services’ needs and they work closely with supervisory chaplains. They also provide training to chaplaincy services staff
and work with regional offices to secure additional funding allocation for religious needs and help institutions prepare
for Program Reviews, which are part of the BOP’s quality assurance process.
32 The CSB’s records did not contain information for all CTP participants’ faith traditions or whether the individuals
completed the program.

28

Figure 3
BOP Contract Faith Providers from 2015 to 2020

171
142

201

134

2015

2016

2017

117

2018

2019

Source: BOP Data

We found that the primary reasons for the declining use of contract faith providers are costs and local
resource availability. In most cases, the costs of these contract faith providers come directly from institution
level budgets which often do not have the resources to pay for contractors. Chaplaincy services department
budgets vary from institution to institution and for FY 2019 allotments ranged from $8,400 for an institution
with a projected inmate population of 1,400 to $30,500 for a pretrial facility with 1,400 inmates. According
to BOP officials, the budgets for each chaplaincy services department are determined by the BOP Central
Office based on the facility’s inmate population, special programs, and the type of institution. Once
established, chaplains at the institutions are responsible for ensuring that their allotted budget covers all
necessary religious expenses. As a result, for many institutions the cost of contractors, although relatively
low, is still cost prohibitive. Additionally, as with chaplains, many institutions have found it difficult to find
qualified and available local contract faith providers due to the demographics in their geographic locations.
In addition to contract faith providers, the BOP deploys volunteers to support its religious needs.
Volunteers are designated as either “Level 1” or “Level 2” volunteers. 33 Level 2 volunteers are only required
to be monitored intermittently, while in contrast, Level 1 volunteers are subject to constant supervision.
Volunteer faith providers typically are not ordained or professional religious figures within their faith and
unlike contract faith providers, who are subjected to more rigorous vetting, volunteers must only provide
faith endorsements and letters of recommendation and undergo an NCIC criminal record check. 34

Level 1 Volunteers are authorized to perform a service four days or less per year for an institution. These volunteers
will receive general training; however, they are escorted and monitored continuously during their visit. Level 2
volunteers are authorized to perform a service more than 4 days per year for an institution. These volunteers are
monitored intermittently during their visit and required to attend volunteer and/or mentor training.

33

An NCIC check entails a search of the NCIC database, that includes records of local, state, and other federal law
enforcement agencies nationwide.

34

29

Volunteers do not need religious credentials, training, or prior experience to serve BOP institutions;
however, as with chaplains and contract faith providers, it can be difficult for the BOP to recruit volunteers
for each recognized faith group. This is particularly true in more remote and less diverse geographical
locations. Figure 4 below indicates the decline of volunteer faith providers from 2015 to 2020.

Figure 4
BOP Volunteer Faith Providers from 2015 to 2020*

2015

2016

2017

2018

2019

* In 2016, the CSB started tracking mentoring volunteers as a separate category from
volunteer faith providers. The data in this chart includes both groups of volunteers.
Source: BOP Data, CSB Annual Reports

In addition to developing a strategy to bolster and diversify its chaplaincy staff, the BOP should likewise take
a centralized, strategic approach to its recruitment of contract and volunteer faith providers. Depending on
resources and needs of each institution, the CSB requires chaplains to search their immediate areas for
qualified individuals who are interested in and appropriately suited to provide services within a correctional
environment. For example, chaplains may reach out to local seminaries, colleges and other schools, religious
orders, churches, local or national faith organizations for external religious services resources. One chaplain
explained that his institution had developed a long-standing relationship with the local Catholic Archdiocese
to obtain continuous contracted faith representation for the facility. These types of relationships with the
local faith community help the chaplaincy services departments reduce interruptions in services. Although
not part of the chaplaincy services department, Reentry Affairs Coordinators (RAC) at institutions also assist
chaplaincy with recruiting, training, and onboarding of external faith providers. 35 However, there is no
guidance provided by the CSB or elsewhere in the BOP that can assist chaplains with best practices and
strategies for developing the types of relationships like the one created with the Catholic Archdiocese.
As discussed throughout this report, chaplains have significant, time-consuming responsibilities that are
critical to the safety and security of their institutions. We believe the CSB is better situated to establish

RACs are part of Reentry Affairs, a department at BOP institutions that assists inmates in preparing for adjustment to
life outside of prison.

35

30

relationships with contract service providers and national faith group organizations that can encourage local
members to work with BOP institutions in their area and, in turn, help expand the ranks of credible contract
and volunteer providers. Therefore, we recommend the BOP require the CSB to develop a strategy to
strengthen its viable volunteer ranks by establishing relationships with local, regional, and national-level
religious organizations that can assist in providing guidance and information to their members on
volunteering at BOP institutions at the community level.

Extended Periods of Absence
During our review we found that chaplaincy services departments throughout the BOP may experience
extended periods of absence among its chaplaincy staff. When extended absences are coupled with
vacancies and understaffing, many chaplaincy services departments have experienced significant hardships
in providing religious services as a result. Yet, the BOP lacks a strategy that would best prepare it for
extended absences, particularly due to military leave, which are likely to continue.
The BOP utilizes available veteran’s preference hiring authorities to hire current or former military members
when filling chaplain vacancies and, as a result, a significant portion of the BOP’s 236 chaplains are also
military reservists. Military reservists must meet monthly and annual military obligations and are also
subject to deployment or mobilization. We determined that, as of March 2020, 12 of the BOP’s 100 military
reservist chaplains were on military leave, and 5 of these 12 chaplains were assigned to institutions with the
greatest need for chaplains. For example, at one institution, two of its four chaplains were on military leave
for over a year and a half and at another institution, one chaplain had been on leave for over 3 years.
Additionally, two of the five chaplains at one BOP correctional complex with three institutions had been on
military leave for more than 3 months as of March 2020.
The impact of a reduction in chaplaincy services staff due to extended absences is felt by chaplains and
inmates alike. Generally, the duties of chaplains on extended leave are dispersed among other chaplains at
their institution whenever possible. However, for departments that are already short staffed, requiring staff
to absorb additional duties creates a ripple effect. While most periods of military leave are short, longer
periods are not uncommon. For example, we learned that at one federal prison camp the chaplaincy
services department operated without a chaplain for over a year when the chaplain was deployed for
military service. Because federal prison camps are generally only allotted a single chaplain, the BOP was
unable to hire a temporary chaplain for the duration of his service. During this time, the institution severely
reduced its religious services. Specifically, religious study group sessions were canceled, pastoral care needs
were unmet, pastoral visits to restricted housing units were reduced, and the inmates’ choir program was
eliminated. We believe the BOP should improve its ability to plan for extended absences and establish
procedures that ensure continuity of chaplaincy services operations without overburdening staff or relying
on inmate-led services. Therefore, we recommend that the BOP develop a sustainable strategy to mitigate
staffing shortages caused by chaplaincy absences due to anticipatable periods of extended leave, such as
military leave.

Utilization of Existing Programs and Technologies
In 2015 the CSB developed the Subject Matter Resource (SMR) program. This program is an effort to bridge
the gaps in religious diversity by establishing internal chaplaincy expertise and points of contact for field
chaplains who need assistance in providing pastoral care to inmates outside of their own faith traditions.
Under the SMR program, field chaplains volunteer for the role as a collateral duty and act as a resource to

31

field questions from other chaplains that are funneled to them through CSCs and CSB. If an SMR cannot
answer a question through personal knowledge, the SMR is expected to assist with conducting research and
other outreach to provide an adequate response to the requestor.
Like the CTP, we believe the SMR program has not met its full potential. We found that the program is
largely ineffective because it places an additional burden on short-staffed field chaplains who cannot
reasonably respond to requests in a timely manner. Further, SMR chaplains we spoke with stated that they
received no additional training or resources to perform this extra duty and several other chaplains stated
that they did not use the SMR program because it was faster and easier to draw on their own relationships
with other BOP contacts or within their own community. In fact, SMRs are allocated 180 days to respond to
SMR requests so they can perform research and consultation with experts outside of the BOP, in addition to
their own primary chaplain responsibilities. As a result, the program’s own timeliness guidelines contribute
to its ineffectiveness.
We believe the CSB is in the best position to maximize the effectiveness of the SMR program. By shifting
responsibilities entirely to CSB, the BOP can ensure that chaplains who rely on the program receive timely,
consistent responses to inquiries and that information obtained through SMR requests can be disseminated
to benefit chaplains across the BOP’s 122 institutions. Accordingly, we recommend removing responsibility
for SMR program duties from field chaplains and centralizing it within the CSB to include the primary
responsibility for researching and answering field chaplaincy inquires and to gain greater awareness of
issues facing field chaplains. Centralization of this program will also ensure consistency and timeliness of
responses and allow field chaplains to more effectively manage their institution’s religious services program
by focusing on mission critical responsibilities like monitoring religious services and controlling chaplaincy
services spaces.
Further, while contract and volunteer faith providers can partially assist the BOP in meeting religious needs
when chaplains are not available, the practice is a stopgap and does not address the conditions that have
created the chronic staff shortages within the BOP’s chaplaincy services departments. This increases the
likelihood that institutions will rely on undesirable alternatives, such as inmate-led services, with the
accompanying risks associated with them. We believe the BOP can leverage existing technologies which
present little or no risk as better alternatives to these current undesirable practices. In so doing, the BOP
can encourage institutions to better coordinate and share religious resources throughout the BOP. For
example, the BOP has piloted video calls as an alternative to in-person visits and traditional phone calls. We
believe the BOP could consider using this technology as a method for streaming live services to institutions
experiencing chaplaincy shortages. A BOP-wide calendar of services coupled with relatively inexpensive
technological advances in videoconferencing could significantly fill voids that result from chaplaincy
shortages and diversity challenges.
During our audit, we asked BOP staff members about potential alternatives to allowing inmate to lead
services, and some chaplains agreed that live video streaming of weekly religious services and religious
programming is a viable alternative to in-person services that has not been deployed. Further, although
field work for this audit was completed before the onset of the COVID-19 pandemic, we note here that
utilizing these kinds of technologies may help the BOP minimize large gatherings and provide an alternative
choice to inmates who may wish to avoid larger gatherings for health and other reasons. We recommend
that the BOP leverage existing resources and explore potential enhancements and additional technological
solutions for providing religious services, such as live streams, as an alternative to riskier options such as

32

inmate-led services, which require stricter monitoring, and to enable greater diversity in the denomination
for which services can be provided to a broader population of inmate.

33

Conclusion and Recommendations
We believe the BOP must take immediate steps to address its persistent chaplaincy shortages and lack of
diversity among the religious affiliations represented within its chaplaincy services program. The BOP’s lack
of adequate chaplaincy resources and religious diversity among its existing chaplain staff has led to a
reliance on inmates and contract and minimally screened volunteer faith providers to lead or otherwise
provide religious services. We believe over reliance on individuals outside of the chaplaincy, including
inmates, likely creates an unacceptable level of risk, especially when individuals incarcerated for terrorismrelated crimes and other high-risk inmates lead religious services. Several BOP staff members expressed
significant concern that these inmates could use religious leadership as a platform to radicalize other
inmates or to elevate their status and power among the broader inmate population. As a result, it is
essential that the BOP aggressively seek alternatives to the practice of inmate-led services while making
additional efforts to strategically expand the diversity of its chaplaincy and fill staffing shortages. These
staffing shortages exacerbate the risk of inmate-led services and reliance on external providers because
monitoring requirements performed by chaplaincy services staff cannot reasonably be met. In addition to
the risk of inmate-led services, the chaplaincy staff shortages and diversity challenges also effect the BOP’s
ability to adequately secure its chaplaincy services spaces, such as faith group lockers and chapel libraries.
To achieve more faith diversity among chaplaincy and to bolster it ranks, we believe the BOP should
strategically reassess its strict educational requirements, maximum age restrictions and better utilize
existing programs such as its Chaplain Trainee Program to address chaplaincy shortages nationwide.
Furthermore, the BOP can alleviate the burden placed on field chaplains by centralizing programs, like the
Subject Matter Resource program, by shifting responsibilities to CSB staff. Doing so will not only help
provide consistent guidance to field chaplains who need assistance in providing pastoral care to inmates
outside of their own faith traditions, but it will also allow field chaplains to focus more on mission critical
functions such as monitoring services, securing religious spaces, and overseeing the activities of external
providers. The BOP should also consider a more active role for the CSB in the establishment of working
relationships with national, regional, and local religious organizations which we believe can help expand the
ranks of credible external providers by encouraging their local membership to work with BOP institutions in
their geographic areas. Finally, we believe the BOP already has in place technological capabilities that could
be utilized to live stream religious services programming to institutions throughout the nation, which we
believe could serve as a viable alternative to riskier options currently being relied upon, such as inmate-led
services.
We recommend that the BOP:
1. Take steps to address its persistent chaplaincy shortages and lack of diversity of religious affiliations
represented within the BOP’s chaplaincy by:
a. Reassessing the existing education requirement for chaplaincy eligibility to enhance the
prospect of attaining the BOP’s target chaplain staffing level, or evaluate the benefits of
implementing religion-specific educational requirements to account for differing
requirements among religions;
b. Reconsidering its age restriction for chaplains and coordinate with the Department of Justice

34

to determine if age waivers should be expanded to a broader group of chaplaincy applicants;
and
c.

Reviewing the current Chaplain Trainee Program model to expand opportunities for current
BOP staff and qualified external applicants with flexibilities that would avoid disqualifying
otherwise suitable candidates due to restrictive educational barriers or pastoral experience
requirements.

2. Address the security weaknesses that result from its understaffed, overburdened, and diversitychallenged chaplaincy by:
a. Strengthening existing policy to include clear guidance about when inmates may be
permitted to lead religious services, which inmates should be prohibited from leading
services, and minimum monitoring requirements for religious programs or services led by
inmates;
b. Determining the institutions without remote audio and video monitoring equipment in
spaces where religious services are conducted and determine the feasibility of installing
such equipment, or if the BOP is unable to install monitoring equipment at these facilities, it
should take steps to ensure adequate monitoring is performed;
c.

Reexamine its practice of prohibiting recording audio and video feeds from chaplaincy
services spaces alongside relevant federal law and regulations to help ensure that religious
services are monitored to the greatest extent possible and are not misused by some inmates
to engage in prohibited conduct; and

d. Ensuring that established security procedures regarding faith group lockers are followed and
that the BOP policy includes clear procedures for inmate access.
3. Ensure safe and robust chapel libraries throughout the BOP by:
a. Performing a comprehensive review of the Chapel Library Database (CLD) at the CSB to
strengthen existing policy or develop new policy that ensures an accurate inventory and
timely review of newly introduced English and foreign language texts with suitability
determinations that can more easily be shared among all BOP institutions;
b. Providing resources to assist chaplains in evaluating existing library materials, including
foreign language media, that have not been previously reviewed and entered into the CLD to
better ensure that those titles are added to the CLD or its replacement (if applicable); and
c.

Developing a centralized repository for BOP Chaplaincy Services related advisories to better
ensure that important guidance for chaplains is current and consistent and provide
chaplains with clear instructions for proper handling and disposal of religious texts deemed
inappropriate for inmate use.

35

4. Improve its oversight of its minimally vetted chaplaincy services volunteers to better address the risk
of inappropriate contact with inmates and to prevent rehiring of volunteers who were previously
found to violate BOP policy by:
a. Conducting a periodic analysis of volunteer contact information through its TRUVIEW system
and clearly document any exception that was granted to specific volunteers, such as those in
mentoring and transitional programs;
b. Ensuring its volunteers and inmates are aware of its policy on prohibited contact and apply
increased scrutiny to endorsements offered by previously disciplined volunteers; and
c.

Ensuring that NAVS volunteer data profiles are accurate, complete, updated, and contain all
necessary information so that volunteers terminated for violating BOP policy cannot seek
volunteer roles at other BOP institutions.

5. Take steps to better support existing chaplaincy services staff and enable them to focus on their
primary function of providing spiritual guidance by:
a. Requiring the CSB to develop a strategy to strengthen its viable volunteer ranks by
establishing relationships with local, regional, and national religious organizations that can
assist in providing guidance and information to their members on volunteering at BOP
institutions at the community level;
b. Developing a sustainable strategy to mitigate staffing shortages caused by chaplaincy
absences due to anticipatable periods of extended leave, such as military leave;
c.

Removing responsibility for SMR program duties from field chaplains and centralizing it
within the CSB to include the primary responsibility for researching and answering field
chaplaincy inquires and to gain greater awareness of issues facing field chaplains; and

d. Leveraging existing resources and exploring potential enhancements and additional
technological solutions for providing religious services, such as live streams, as an alternative
to riskier options such as inmate-led services, which require stricter monitoring, and to
enable greater diversity in the denominations for which services can be provided to a
broader population of inmates.

36

APPENDIX 1: Objectives, Scope, and Methodology
Objectives
The objective of our audit was to assess the BOP’s management and oversight of its religious services
program to support faith-based activities and its effectiveness in preventing security risks and misuse of
program resources.

Scope and Methodology
To accomplish our objective, we performed audit work at branches of the BOP responsible for
implementation and oversight of the BOP’s chaplaincy and religious services programs, including the BOP’s
Central Office, Southeastern Regional Office, and federal correctional institutions. The scope of our audit
generally covers activities in the time period between October 2013 to March 2020 in the Chaplaincy
Services departments of the 122 BOP institutions, including chapel spaces, such as libraries, storage rooms,
and classrooms, as well as chaplains and contract and volunteer faith providers.
During the audit, we interviewed more than 70 BOP personnel, including officials from the BOP’s Central
Office Chaplaincy Services Branch (CSB), the Southeast Regional Office in Atlanta, Georgia, and 12 individual
facilities of varying security levels. While at these facilities we observed religious services and other religious
programming, as well as chaplaincy spaces, such as libraries, storage rooms, and assigned faith lockers. At
the institutions and CSB, we viewed the chaplaincy’s digital records of the Chapel Library Database, as well
as the TRUVIEW and NAVS databases. We also reviewed a sample of volunteer faith provider files to test
whether BOP guidelines were met along with applicable BOP program statements, and procedures. Lastly,
we utilized evidence related to the BOP’s chaplaincy services program gathered during the OIG’s recent
Audit of the BOP’s Monitoring of Inmate Communications to Prevent Radicalization. 36

Statement on Compliance with Generally Accepted Government Auditing Standards
We conducted this performance audit in accordance with generally accepted government auditing
standards (GAGAS). Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Internal Controls
In this audit, we performed testing of internal controls significant within the context of our audit objectives.
We did not evaluate the internal controls of the BOP to provide assurance on its internal control structure as
a whole. The BOP’s management is responsible for the establishment and maintenance of internal controls
in accordance with the BOP’s program statements and other procedural documentation. Because we do

U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), Audit of the Federal Bureau of Prisons’
Monitoring of Inmate Communications to Prevent Radicalization, Audit Report 20-042 (March 2020),

36

https://oig.justice.gov/sites/default/files/reports/a20042.pdf.

37

not express an opinion on the BOP’s internal control structure as a whole, we offer this statement solely for
the information and use of the BOP. 37
As noted in the Audit Results section of this report, we identified deficiencies in the BOP’s internal controls
that are significant within the context of the audit objectives and based upon the audit work performed that
we believe adversely affect the BOP’s ability to satisfy the objectives of its religious services programs while
also protecting the safety and security of BOP institutions, staff, and the communities in which they are located.

Compliance with Laws and Regulations
In this audit we also tested, as appropriate given our audit objective and scope, select transactions, records,
procedures, and practices, to obtain reasonable assurance that the BOP complied with federal laws and
regulations for which noncompliance, in our judgment, could have a material effect on the results of our
audit. Our audit included examining, on a test basis, the BOP’s compliance with the following laws and
regulations that could have a material effect on the BOP’s operations:
•

28 C.F.R. § 548

•

28 C.F.R. § 540.71

•

Religious Freedom Restoration Act (42 USC § 2000-bb) (1993)

•

Second Chance Act, Pub. Law 110-199, sec. 214 (2007)

This testing included interviewing auditee personnel, observing processes, and assessing internal control
procedures. However, nothing came to our attention that caused us to believe that the BOP was not in
compliance with the aforementioned laws and regulations.

Sample-based Testing
To accomplish our audit objective, we performed sample-based testing regarding volunteer faith provider
profile information and the CSB’s Chapel Library Database. In this effort, we employed a judgmental
sampling design to obtain broad exposure to numerous facets of the areas we reviewed. This nonstatistical
sample design did not allow projection of the test results to the universe from which the samples were
selected.

Computer-Processed Data
During our audit, we obtained information from TRUFONE, TRULINCS, TRUFACS, the BOP’s Web Visiting
System, and the Volunteer and Contractor Information (VCI) and National Automated Volunteer System
(NAVS). We did not test the reliability of those systems as a whole, therefore any findings identified
involving information from those systems were verified with documentation from other sources.

37

This restriction is not intended to limit the distribution of this report, which is a matter of public record.

38

APPENDIX 2: BOP Correctional Facilities Reviewed or Visited
BOP Correctional Facilities Selected for Review
BOP Institution

Security Level

Federal Correctional Complex Coleman

Sumterville, FL

Federal Correctional Institution (FCI)
Coleman
FCI Coleman

Low
Medium

United States Penitentiary (UPS)
Coleman I

High

UPS Coleman II

High

Federal Correctional Complex Florence

Florence, CO

FCI Florence

Medium

USP Florence

High

USP Florence ADMAX

Location

Maximum

FCI Miami

Low

Miami, FL

Mixed

Miami, FL

Medium

Pekin, IL

FCI Talladega

Low

Talladega, AL

USP Marion

High

Marion, IL

Federal Detention Center Miami
FCI Pekin

BOP Correctional Facilities Visited During Prior Review 38
BOP Institution

Security Level

Federal Correctional Complex Terre
Haute

Location
Terre Haute, IN

FCI Terre Haute

Medium

USP Terre Haute

High

FCI Dublin

Low

Dublin, CA

These locations were visited during our prior audit of the BOP’s Monitoring of Inmate Communications to Prevent
Radicalization. U.S. Department of Justice (DOJ) Office of the Inspector General (OIG), Audit of the Federal Bureau of
Prisons’ Monitoring of Inmate Communications to Prevent Radicalization, Audit Report 20-042 (March 2020),
https://oig.justice.gov/sites/default/files/reports/a20042.pdf. Only sites from which we have utilized evidence to support
our audit findings related to this report are included.
38

39

Cont’d

Metropolitan Detention Center Brooklyn

Mixed

Brooklyn, NY

Metropolitan Corrections Center New
York

Mixed

New York City, NY

40

APPENDIX 3: The BOP’s Response to the Draft Audit Report
U.S. Department of Justice
Federal Bureau of Prisons

Oflia <f the /Jir('no1

\\'11.1/1111~1<111.

DC 21153-1

May 28, 2021
MEMORANDUM FOR JASON R. MALMSTROM
ASSISTANT INSPECTOR GENERAL
AUDIT

FROM:

SUBJECT:

~~.D 0~ ~

l)

Direc~~~

/

Response to the Office of Inspector General's (OIG)
Draft Report: Audit of the Federal Bureau of
Prisons' Management and Oversight of its Chaplaincy
Program

The Bureau of Prisons (BOP) appreciates the opportunity to provide
a formal response to the Office of the Inspector General's above
referenced report. The BOP has completed our review of the report
and agrees with all recommendations. We offer the following
comments regarding the recommendations.

Recommendation One: Take steps to address its persistent
chaplaincy shortages and lack of diversity of religious
affiliations represented within BOP's chaplaincy by:
a. Reassessing the existing education requirement for
chaplaincy eligibility to enhance the prospect of attaining
BOP's target chaplain staffing level, or evaluate the
benefits of implementing religion-specific educational
requirements to account for differing requirements among
religions;

BOP's Response: Because BOP chaplains lead out of their own
faith tradition and are responsible for ensuring religious
accommodations across all religious lines, agency
chaplains require a graduate level theological degree that
includes interfaith study as outlined in current policy.
The
agency will however revise its policy to address religious
diversity chaplaincy hiring needs and enhance the prospect of
attaining BOP's target chaplain staffing level.
The draft

41

policy will be presented to the National Union by the end of
FY21 .
b. Reconsidering its age restriction for and coordinate with
the Department of Justice to determine if age waivers
should be expanded to a wider group of chaplaincy
applicants; and
BOP's Response:
To improve the representation of non-Protestant
faith groups, the agency will coordinate with the DOJ on wider
age waivers for specific faith groups of chaplains to best meet
inmate diversity religious needs . The BOP will forward such a
request to DOJ for their review and determination by the end of
FY21.
c. Reviewing the current Chaplain Trainee Program model to
expand opportunities for current BOP staff and qualified
external applicants with flexibilities that would avoid
disqualifying otherwise suitable candidates due to
restrictive educational barriers or pastoral experience
requirements.
BOP's Response: BOP policy will be updated to allow for
chaplain trainee hiring flexibility . The draft policy will be
presented to the National Union by the end of FY21.

Recommendation Two: Address the security weaknesses that result
from its understaffed, overburdened, and diversity-challenged
chaplaincy by:
a . Strengthening existing policy to include clear guidance
about when inmates may be permitted to lead religious
services, which inmates should be prohibited from leading
services, and minimum monitoring requirements for religious
programs or services led by inmates;
BOP's Response: The BOP will revise the policy guidance
regarding inmate-led religious services, chapel monitoring
branch procedures, and national chaplaincy training content.
The draft policy will be presented to the National Union by the
end of FY21 .
b . Determining the institutions without remote audio and video
monitoring equipment in spaces where religious services are
conducted and determine the feasibility of installing such
equipment, or if BOP is unable to install monitoring

42

equipment at these facilities, it should take steps to
ensure adequate monitoring is performed;
BOP's Response: As a result of the 2016 OIG Contraband
Interdiction Audit (OIG 16-05), the BOP conducted a survey of
all field site camera systems and developed a plan to address
gaps in surveillance systems. The BOP subsequently developed an
acquisition plan to replace and/or update systems where blind
spots and additional cameras were needed. Seventy-two camera
systems were identified and funded for replacement/upgrade. The
BOP will review the survey to identify sites which specified
gaps in the areas of religious services and modify the upgrade
plan were necessary to address this recommendation. The review
and update of the survey will be completed by the end of 1QFY22
(December 31, 2021). Note, this recommendation also relates to
the recommendation below requiring legal analysis of the BOP's
visual/auditory monitoring of religious services.
c. Reexamining its practice of prohibiting recording audio and
video feeds from chaplaincy services spaces alongside
relevant laws and regulations to ensure that religious
services are monitored to the greatest extent possible and
are not misused by some inmates to engage in prohibited
conduct; and
BOP's Response: The BOP's Office of General Counsel will
reexamine recording audio and video feeds in chapel services
spaces in light of relevant laws and regulations with the
anticipated completion of this review by the end of FY21.
If
additional surveillance is determined permissible and
appropriate, the BOP will prioritize and work towards resolving
needed chaplaincy and support staff positions to monitor
existing chapel programming and chapel monitoring equipment by
incorporating additional staff into the FSA spend plan.
d. Ensuring that established security procedures regarding
faith group lockers are followed and that BOP policy
includes clear procedures for inmate access.
BOP's Response:
The BOP will provide updated guidance and
remind field sites on the security procedures relating to faith
group lockers and inmate access by the end of FY21.

Recommendation Three:
throughout BOP by:

Ensure safe and robust chapel libraries

43

a. Performing a comprehensive review of the Chapel Library
Database (CLD) at the CSB to strengthen existing policy or
develop new policy that ensures an accurate inventory and
timely review of newly introduced English and foreign
language texts with suitability determinations that can
more easily be shared among all BOP institutions;
BOP's Response: The BOP will perform a comprehensive review of
the CLD to affirm compliance with policy as it relates to the
timely review of chapel materials in English and other languages
by the end of FY21.
If additional changes to the CLD or
refresher training is required, BOP will implement such training
and/or changes by the end of 2QFY22 (March 31, 2022).

b. Providing resources to assist chaplains in evaluating
existing library materials, including foreign language
media, that have not been previously reviewed and entered
into the CLD to better ensure that those titles are added
to the CLD or its replacement (if applicable); and
BOP's Response: As part of its review of the CLD, BOP will
identify those foreign language materials requiring translation
and make them available to the CTU for translation and
affirmance as to content and to identify any potential security
threats.
This review will be completed by the end of 1QFY22
(December 31, 2021) and the translation is expected to be
completed by the end of March in FY22.

c. Developing a centralized repository for BOP Chaplaincy
Services related advisories to better ensure that important
guidance for chaplains is current and consistent and
provide chaplains with clear instructions for proper
handling and disposal of religious texts deemed
inappropriate for inmate use.
BOP's Response:
The BOP will develop a centralized repository
for BOP Chaplaincy Services related advisories by the end of
FY21 to better ensure that important guidance for chaplains is
current and consistent and provide chaplains with clear
instructions for proper handling and disposal of religious texts
deemed inappropriate for inmate use.

Recommendation Four:
Improve its oversight of its minimally
vetted chaplaincy services volunteers to better address the risk
of inappropriate contact with inmates and to prevent rehiring of
volunteers who were previously found to violate BOP policy by:

44

a. Conducting a periodic analysis of volunteer contact
information through its TRUVIEW system and clearly document
any exception that was granted to specific volunteers, such
as those in mentoring and transitional programs;
BOP's Response:
The BOP is developing an improved volunteer
database that will allow us to better review and analyze
volunteer information. This new database includes volunteer
identifiers including those in mentoring and transitional
programs and unauthorized volunteers. The first phase of the
new system is anticipated for roll-out by the end of FY21. We
anticipate this system will be fully deployed by the end of
FY22.

b. Ensuring its volunteers and inmates are aware of its policy
on prohibited contact and apply increased scrutiny to
endorsements offered by previously disciplined volunteers;
and
BOP's Response:
Prohibited contact with inmates and procedures
for volunteers to be discontinued from volunteering is covered
in the existing BOP Volunteer Services policy. This policy
guidance will be reinforced in divisional/branch communication,
staff and volunteer training materials, and on the public
website by the end of FY21.

c. Ensuring that NAVS volunteer data profiles are accurate,
complete, updated, and contain all necessary information so
that volunteers terminated for violating BOP policy cannot
seek volunteer roles at other BOP institutions.
BOP's Response:
The agency is developing an improved volunteer
database, with the first phase anticipated roll out by the end
of FY21. This database will ensure volunteer data profiles are
accurate, complete, updated, and contain all necessary
information so that volunteers terminated for violating BOP
policy cannot seek volunteer roles in other BOP institutions.
In the interim, an analysis of volunteer profiles will be
conducted to verify that volunteers terminated for violating BOP
policy are prohibited. This review will be completed by the end
of 1QFY22 (December 31, 2021).

Recommendation Five:
Take steps to better support existing
chaplaincy services staff and enable them to focus on their
primary function of providing spiritual guidance by:

45

a. Requiring the CSB to develop a strategy to strengthen its
viable volunteer ranks by establishing relationships with
local, regional, and national religious organizations that
can assist in providing guidance and information to their
members on volunteering at BOP institutions at the
community level;
BOP's Response:
The CSB will build upon existing partnerships
and establish new partnerships with local, regional, and
national religious organizations to strengthen current and
future chapel volunteering. An update of these new partnerships
will be provided at the end of FY21.

b. Developing a sustainable strategy to mitigate staffing
shortages caused by chaplaincy absences due to
anticipatable periods of extended leave, such as military
leave;
BOP's Response:
Within the FSA spending plan, the BOP will
prioritize needed chaplaincy and support staff positions to
monitor existing chapel programming and new programming to
counter-balance inmate radicalization.

c. Removing the SMR duties from field chaplains and
centralizing it within the CSB to include the primary
responsibili~y for researching and answering field
chaplaincy inquires and to gain greater awareness of issues
facing field chaplains; and
BOP's Response:
The SMR duties will be merged with the
centralized CSB Religious Issues Committee process by the end of
FY21.

d. Leveraging existing resources and exploring potential
enhancements and additional technological solutions for
providing religious services, such as live streams, as an
alternative to riskier options such as inmate-led services,
which require stricter monitoring, and to enable greater
diversity in the denominations for which services can be
provided to a broader population of inmates.
BOP's Response:
The Bureau plans to purchase 125 field chapel
VTCs to expand access to viable religious resources and

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programming in real-time and via web-conferencing recording.
The purchase is anticipated to be completed by the end of FY21.
The anticipated installation date for these chapel VTC endpoints
is the end of 2QFY22, assuming no infrastructure changes (new
conduit, etc.)is required.

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APPENDIX 4: Office of the Inspector General Analysis and
Summary of Actions Necessary to Close the Audit Report
The OIG provided a draft of this audit report to the BOP. The BOP’s response is incorporated in Appendix 3
of this final report. In response to our audit report, the BOP agreed with our recommendations and
discussed the actions it will implement in response to our findings. As a result, the status of the audit report
is resolved. The following provides the OIG analysis of the response and summary of actions necessary to
close the report.
Recommendations for the BOP:
1.

Take steps to address its persistent chaplaincy shortages and lack of diversity of religious affiliations
represented within the BOP’s chaplaincy by:
a. Reassessing the existing education requirement for chaplaincy eligibility to enhance the
prospect of attaining the BOP’s target chaplain staffing level, or evaluate the benefits of
implementing religion-specific educational requirements to account for differing
requirements among religions;
b. Reconsidering its age restriction for chaplains and coordinate with the Department of Justice
to determine if age waivers should be expanded to a broader group of chaplaincy
applicants; and
c.

Reviewing the current Chaplain Trainee Program model to expand opportunities for current
BOP staff and qualified external applicants with flexibilities that would avoid disqualifying
otherwise suitable candidates due to restrictive educational barriers or pastoral experience
requirements.

Resolved. The BOP agreed with our recommendation. The BOP stated in its response that it would
revise its policy to address religious diversity chaplaincy hiring needs and enhance the prospect of
attaining the BOP’s target chaplaincy staffing level and present the policy to the National Union by
the end of FY 2021. Further, the BOP also stated that it will coordinate with the DOJ on wider age
waivers for specific faith groups of chaplains to best meet inmate diversity religious needs and will
forward the request to the DOJ for their review and determination by the end of FY 2021.
Additionally, the BOP stated that it would also update policy to allow for chaplain trainee hiring
flexibility and will present the draft policy to the National Union by the end of FY 2021.
As a result, this recommendation is resolved. This recommendation can be closed when we receive
evidence that the BOP has reassessed existing educational requirements for chaplaincy or evaluated
the benefit of implementing religion-specific educational requirements to account for differing
requirements among religions, worked with the DOJ to coordinate the wider use of age waivers in
the hiring of chaplaincy for a greater number of faiths, and updated its Chaplaincy Trainee Program
policy to allow for greater hiring flexibility.

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2.

Address the security weaknesses that result from its understaffed, overburdened, and diversitychallenged chaplaincy by:
a. Strengthening existing policy to include clear guidance about when inmates may be
permitted to lead religious services, which inmates should be prohibited from leading
services, and minimum monitoring requirements for religious programs or services led by
inmates;
b. Determining the institutions without remote audio and video monitoring equipment in
spaces where religious services are conducted and determine the feasibility of installing
such equipment, or if the BOP is unable to install monitoring equipment at these facilities, it
should take steps to ensure adequate monitoring is performed;
c.

Reexamine its practice of prohibiting recording audio and video feeds from chaplaincy
services spaces alongside relevant federal law and regulations to help ensure that religious
services are monitored to the greatest extent possible and are not misused by some
inmates to engage in prohibited conduct; and

d. Ensuring that established security procedures regarding faith group lockers are followed
and that the BOP policy includes clear procedures for inmate access.
Resolved. The BOP agreed with our recommendation. The BOP stated in its response that it will
revise the policy guidance regarding inmate-led religious services, chapel monitoring branch
procedures, and national chaplaincy training content, and present a draft policy to the National
Union by the end of FY 2021. The BOP also stated it will review information previously obtained
through a survey of field site camera systems and an associated acquisition plan to identify sites
which specified gaps in the area of religious services and modify upgrade plans were necessary to
address the recommendation. The BOP expects the review to be completed by the end of FY 2021.
Furthermore, the BOP stated that the BOP’s Office of General Counsel will reexamine recording
audio and video feeds in chapel services spaces in light of relevant laws and regulations with the
anticipated completion of the review by the end of FY 2021. Further, the BOP stated that if
appropriate it will prioritize and work towards resolving needed chaplaincy and support staff
positions to monitor existing chapel programming and chapel monitoring equipment by
incorporating additional staff into the FSA spend plan. Finally, the BOP indicated that it would
provide updated guidance and remind field sites on security procedures relating to faith group
lockers are followed and that BOP policy includes clear procedures for inmate access.
As a result, this recommendation is resolved. This recommendation can be closed when we receive
evidence that the BOP has strengthened its existing policy to include clear guidance about when
inmates may be permitted to lead religious services, which inmates should be prohibited from
leading services, and minimum monitoring requirements for religious programs or services led by
inmates. We must also receive evidence that the BOP determined which institutions are without
remote audio and video monitoring equipment in spaces where religious services are conducted,
accessed the feasibility of installing such equipment, and taken steps to ensure adequate

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monitoring occurs in locations when monitoring equipment cannot be installed; and reexamined its
practice of prohibiting recording audio and video feeds from chaplaincy services spaces alongside
relevant federal law and regulations to help ensure that religious services are monitored to the
greatest extent possible and are not misused by some inmates to engage in prohibited conduct.
Finally, we must receive evidence that the BOP ensured that established security procedures
regarding faith group lockers are followed and that the BOP policy includes clear procedures for
inmate access.
3.

Ensure safe and robust chapel libraries throughout the BOP by:
a. Performing a comprehensive review of the Chapel Library Database (CLD) at the CSB to
strengthen existing policy or develop new policy that ensures an accurate inventory and
timely review of newly introduced English and foreign language texts with suitability
determinations that can more easily be shared among all BOP institutions;
b. Providing resources to assist chaplains in evaluating existing library materials, including
foreign language media, that have not been previously reviewed and entered into the CLD to
better ensure that those titles are added to the CLD or its replacement (if applicable); and
c.

Developing a centralized repository for BOP Chaplaincy Services related advisories to better
ensure that important guidance for chaplains is current and consistent and provide
chaplains with clear instructions for proper handling and disposal of religious texts deemed
inappropriate for inmate use.

Resolved. The BOP agreed with our recommendation. The BOP stated in its response that it will
perform a comprehensive review of the CLD and strengthen existing policy or develop new policy to
ensure accurate inventory and timely review of new texts for English and other languages with
suitability determinations that can be shared among all BOP institutions. The BOP also indicated
that it would identify foreign language materials in its inventory that require translation and submit
those materials to CTU for translation and affirmance as to their content by the end of March in
FY 2022. Additionally, the BOP stated that it would develop a centralized repository for advisories
related to BOP Chaplaincy Services and the policy will contain guidance for proper handling and
disposal of religious texts by the end of FY 2021.
As a result, this recommendation is resolved. This recommendation can be closed when we receive
evidence of a comprehensive review of the CLD, strengthened existing policy or new policy that
ensures accurate inventory and timely review of new texts with suitability determinations that can
be shared at all BOP institutions; documentation of a review of existing foreign language materials
requiring translation and evidence of their translation and affirmance of their content, and; evidence
of a centralized repository with advisories related to BOP Chaplaincy Services, including guidance
with clear instructions for proper handling and disposal of religious texts.

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4.

Improve its oversight of its minimally vetted chaplaincy services volunteers to better address the
risk of inappropriate contact with inmates and to prevent rehiring of volunteers who were
previously found to violate BOP policy by:
a. Conducting a periodic analysis of volunteer contact information through its TRUVIEW system
and clearly document any exception that was granted to specific volunteers, such as those in
mentoring and transitional programs;
b. Ensuring its volunteers and inmates are aware of its policy on prohibited contact and apply
increased scrutiny to endorsements offered by previously disciplined volunteers; and
c.

Ensuring that NAVS volunteer data profiles are accurate, complete, updated, and contain all
necessary information so that volunteers terminated for violating BOP policy cannot seek
volunteer roles at other BOP institutions.

Resolved. The BOP agreed with our recommendation. The BOP stated in its response that it will
conduct a periodic analysis of volunteer contact through its TRUVIEW system and clearly document
exceptions granted to volunteers. It will also reinforce is existing BOP Volunteer Services policy in
divisional/branch communication, staff and volunteer training materials, and on its public website by
the end of FY 2021. The BOP will also develop an improved volunteer database which will ensure
that volunteer data profiles are accurate, complete, updated, and contain all necessary information
to prevent terminated volunteers from volunteering in other BOP institutions. The new database
will be release in phases, with the first phase starting by the end of FY 2021. In the interim, the BOP
will conduct an analysis of volunteer profiled to verify that terminated volunteers are prohibited
from volunteering in BOP institutions.
As a result, this recommendation is resolved. This recommendation can be closed when we receive
documentation of the BOP’s periodic analysis of volunteer contact in the TRUVIEW system and
supporting documentation for any communications exceptions granted to volunteers; evidence or
documentation of the BOP’s reinforcement of its Volunteer Services policy through regional/branch
communication, staff and volunteer training materials, and on its public website, and; evidence that
the improved volunteer database includes accurate, complete, updated volunteer data profiles and
contain all necessary information to prevent terminated volunteers from volunteering in other BOP
institutions as well as evidence of an analysis of volunteer profiles conducted prior to the database’s
roll out.
5.

Take steps to better support existing chaplaincy services staff and enable them to focus on their
primary function of providing spiritual guidance by:
a. Requiring the CSB to develop a strategy to strengthen its viable volunteer ranks by
establishing relationships with local, regional, and national religious organizations that can
assist in providing guidance and information to their members on volunteering at BOP
institutions at the community level;

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b. Developing a sustainable strategy to mitigate staffing shortages caused by chaplaincy
absences due to anticipatable periods of extended leave, such as military leave;
c.

Removing responsibility for SMR program duties from field chaplains and centralizing it
within the CSB to include the primary responsibility for researching and answering field
chaplaincy inquires and to gain greater awareness of issues facing field chaplains; and

d. Leveraging existing resources and exploring potential enhancements and additional
technological solutions for providing religious services, such as live streams, as an
alternative to riskier options such as inmate-led services, which require stricter monitoring,
and to enable greater diversity in the denominations for which services can be provided to a
broader population of inmates.
Resolved. The BOP agreed with our recommendation. The BOP stated in its response that it will
require the CSB to develop a strategy to establish and strengthen relationships with local, regional,
and national religious organizations, by the end of FY 2021. The BOP will also develop a sustainable
strategy to mitigate staffing shortages caused by chaplaincy absences due to extended periods of
leave. The BOP also stated that it will merge SMR duties with the CSB Religious Issues Committee by
the end of FY 2021. Finally, the BOP states that it will purchase and install 125 field chapel Video
Telephone Conferencing to provide religious programming and resources, both in real-time and
recorded, by the end of the second quarter of FY 2022.
As a result, this recommendation is resolved. This recommendation can be closed when we receive
evidence that the BOP has developed a strategy to strengthen its viable volunteer ranks by
establishing relationships with local, regional, and national religious organizations to assist in
providing guidance and information to their members on volunteering at BOP institutions at the
community level; developed a sustainable strategy to mitigate staffing shortages caused by
chaplaincy absences due to extended leave; removed responsibility for SMR program duties from
field chaplains and centralized SMR duties to the CSB; and purchased and installed Video Telephone
Conferencing in field chapels to use for programming and resource access, as applicable.

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