EFTA00141368 ## Deloitte Current State Assessment of Staffing Data, Processes, and Calculations Bureau of Prisons Human Resources Management Division March 2022 1 EFTA00141369 ##
Table of Contents
# Executive Summary ... 4 ## Background Information ... 5 - Project Background ... 5 - Corrections Landscape ... 6 - BOP Values ... 7 ## Methodology ... 7 - Field Research Design ... 7 - Focus Group Design ... 8 - Field Research Analysis ... 9 - Field Research Assumptions ... 10 ## Data Analysis Methodology ... 10 - Data Limitations ... 11 ## Hire: Acquire BOP Staff ... 12 - Introduction to the Hiring Process ... 12 - Promotions and Succession Planning ... 14 - Strengths of Current Hiring and Succession Planning ... 15 - Scope of Challenges and Associated Risks of Current Hiring and Succession Planning ... 16 ## Train: Acclimate BOP Staff ... 18 - Introduction to Correctional (ICT) Training ... 18 - BOP Mentorship Program ... **Error! Bookmark not defined.** - Strengths of Current Acclimation Programs ... 19 - Scope of Challenges and Associated Risk of Current Acclimation Programs ... 19 ## Manage: Allocation of BOP Staff ... 21 - Key Metrics of Current Staff ... 21 - History of BOP’s Current Staffing Formula ... 21 - Strengths of Staffing Formula ... 22 - Risks of Staffing Formula ... 22 - Staffing Guidelines for CPD, HSD, and RSD ... 23 - Risks and Challenges for Staffing Guidelines ... 26 - Rosters and Scheduling at BOP ... 27 - Union Considerations ... 28 - Strengths of Scheduling ... 28 2 EFTA00141370
Page Number
Risks and Challenges of Scheduling28
Overtime and Augmentation Usage29
Retain: Minimize Staff Attrition32
Retention Incentives32
Exit Survey Data32
Strengths of Retention33
Risks and Challenges of Retention33
Recommendations37
Recommendations Overview37
Recommendation #1: Develop Automated Staffing Tool to Establish a Reliable Source for Determining Staffing Levels37
Recommendation #2: Invest in Workforce Planning Capabilities to Improve Succession Planning39
Recommendation #3: Conduct Cost Benefit Analysis of 8-Hour vs. 12-Hour Shifts to Optimize Staff Allocation40
Other Recommendations41
Conclusion42
Appendix42
Appendix A: Field Research Themes42
Appendix B: Focus Group Questions42
Appendix C: Competitive Job Landscape43
Appendix D: Key Definitions45
Appendix E: Time-On-Post (TOP) Formula46
Appendix F: Document Review47
3 EFTA00141371 ## Executive Summary Since July 2021, the Deloitte team has conducted nine focus groups at five institutions (FDC Philadelphia, FCC Allenwood, FCI Edgefield, FCC Butner, and FCI Three Rivers) and 30 interviews with Executive Staff, resulting in over 750 datapoints across five regions (North Central, South Central, Southeast, Mid-Atlantic, and Northeast). Findings from the field research, in conjunction with additional data analysis and stakeholder engagement, helped formulate and solidify recommendations to address the Bureau of Prisons (BOP)'s most pressing staffing challenges. Tasked with both protecting society by confining inmates in a humane and secure way, and with assisting offenders to become law-abiding citizens, BOP has a vital mission. The ability of the Bureau to achieve its mission is predicated upon attracting and retaining employees with interpersonal skills, empathy, and the ability to operate successfully in a corrections environment. Data was collected and synthesized to be relevant to, and reflective of, BOP’s vision for providing the most efficient, safe, and humane correctional services and programs in America. This report uncovers several key challenges the Bureau faces today: - Current hiring practices are falling behind projected retirements - Current recruitment strategies make it difficult to hire clinical and mental health professionals (e.g., MDs, MLPs, psychologists, RNs) $ ^{1} $ - ICT training needs continued investment and accountability to provide the exposure and practice needed for staff to feel ready their first day on the job - The supplemental onboarding programs appear to be inconsistently executed - BOP’s staffing formula requires additional scheduling variables (e.g., accrued personal time off, military deployments, or expanded training requirements) to properly estimate staffing needs and maximize its ability to allocate resources across its 122 federal institutions - Overtime and augmentation has increased over the years, but a deeper quantitative analysis is required to understand associated risks - Current staffing guidelines are developed for each discipline independently rather than using a standard process across the Bureau - More shift transitions are required using the standard 8-hour shift schedule, which may result in increased mandatory OT and a reduction of days off for staff - BOP’s compensation and retention incentives require additional analysis to understand effectiveness compared to market standards - Negative media has affected officers’ sense of pride, both internally and externally - Prioritized recommendations below and highlighted throughout this report aim to mitigate these challenges: - Develop an Automated Staffing Tool to establish a reliable source for determining staffing levels - Invest in workforce planning capabilities to improve succession planning - Conduct cost benefit analysis of 8-Hour vs. 12-hour shifts to optimize staff allocation 1 Hard-to-fill positions can vary by position and location. For example, one BOP institution may strive to fill medical positions while another institution located in a rural area finds it more difficult to hire Correctional Officers. 4 EFTA00141372 The visual below illustrates an overview of the current state assemement of the staffing lifecycle at BOP. ## Staffing at BOP ## Background Information ## Project Background The Bureau of Prisons has faced significant challenges related to staffing, recruiting, and retaining employees, which has impacted the employee experience. The COVID-19 pandemic further exacerbated these challenges as facilities became a focal point of the public health crisis. In response to staffing issues and a declining employee experience, the Government Accountability Office (GAO) published a report in February 2021 outlining shortfalls across the 122 federal correctional institutions titled, Opportunities Exist to Better Analyze Staffing Data and Improve Employee Wellness Programs. Following the release of the report and to respond to its findings, BOP hired Deloitte/NTT Data team, which will be referred to as the ‘Deloitte team’, as an objective third-party to examine and recommend solutions to the Bureau’s challenges. Since July 2021, the Deloitte team has evaluated BOP’s staffing challenges, employee experience, and staff safety and support offerings to develop this Current State Assessment, with the goal of improving staffing processes, job satisfaction and retention. The team addressed six of the seven GAO recommendations, utilizing the following three to specifically shape our focus group design: $ ^{2} $ - (GAO Recommendation 1) The Director of BOP should develop and implement a reliable method, or ² United States Government Accountability Report No. GAO-21-123. 2021. 5 EFTA00141373 amend existing methods, for calculating staffing levels at BOP institutions. - (GAO Recommendation 2) The Director of BOP should develop and implement a plan for analyzing data to help identify and address the causes and potential impacts of staffing challenges on staff and inmates. - (GAO Recommendation 6) The Director of BOP should develop and implement a method to routinely collect and evaluate employee feedback on its Employee Assistance Program such as leveraging existing tools or creating new ones, as applicable. As of January 2022, the Deloitte team completed an assessment of BOP’s current workforce landscape through intensive research including interviews with BOP leadership, institution site visits, and focus groups with BOP staff. Data collected was used to develop recommendations in alignment with BOP's mission and core values. ## Corrections Landscape Almost 2 million individuals in the United States are incarcerated, 153,000 of which fall into the Bureau of Prisons’ population. $ ^{3} $ Despite the decline in inmate population from its 2013 peak of 220,000, $ ^{4} $ inadequate staffing levels continue to produce a strain on staff and inmates. Due to its critical mission and complex operating environment, Correctional Officers require interpersonal skills and ability to be successful in a correctional environment; however, an ongoing challenge for federal institutions has been recruiting and retaining these employees. As of May 2021, nearly one-third of federal Correctional Officer positions were vacant across the United States. $ ^{5} $ Various factors can curb potential hires from entering or remaining in the workforce: work with dangerous individuals leading to risk of injury, both physical and emotional; staff safety and support stressors such as exposure to crisis situations and trauma; a negative public perception of the work; and mandatory overtime and augmentation. The high rates of turnover—whether from burnout, retirement, or local job competition—often leads to a less safe environment for officers and inmates and, in turn, can create a cycle of forcing institutions to implement mandatory overtime and augmentation to ensure critical needs are met. To address these challenges, the Bureau announced a National Hiring Initiative in February 2021 to search for qualified external candidates with diverse skills and experiences, even after hiring 3,800 staff in 2020. $ ^{6,7} $ In April 2021, Director Carvajal testified before the Senate Judiciary Committee about these efforts, adding that a 5% retention incentive was offered to staff eligible to retire in 2019 in hopes that they would continue working at BOP. $ ^{8} $ The Bureau has also advocated for closing older facilities and reallocating their staff—following best practices from state prisons such as South Carolina which closed six prisons and saved $491 million in averted spending and reduced operating costs – and are considering closings elsewhere. Along with increased public scrutiny and rapidly evolving mission mandates, the operating environment of the Bureau is very complex. $ ^{9} $ Today’s staffing crisis is affecting more than just federal corrections; the strain of understaffing has been felt across state level institutions and other industries as well. The COVID-19 pandemic has triggered a “Great 3 Federal Bureau of Prisons: Population Statistics. https://www.bop.gov/about/statistics/population_statistics.jsp. $^4$ Federal Bureau of Prisons: Past Inmate Population Totals. https://www.bop.gov/about/statistics/population_statistics.jsp#old_pops. 5 Cooks, Nurses Guard Inmates with US Prisons down 6K Officers. https://appnews.com/article/business-health-coronavirus-pandemic-prisons-government-and-politics-88fff925b1901a36a10581c28d826916. ⁶ Federal Bureau of Prisons: National Hiring Initiative. https://www.bop.gov/resources/news/pdfs/20210210_press_release_hiring.pdf. 7 Federal Bureau of Prisons: BOP Hiring Frenzy. https://www.bop.gov/resources/news/20210210_hiring_frenzy.jsp. 8 Federal Bureau of Prisons: Statement. https://www.bop.gov/resources/news/pdfs/statement_20210415.pdf. 9 The Pew Trusts: Data Trends- South Carolina criminal justice reform. https://www.pewtrusts.org/en/research-and-analysis/fact-sheets/2017/09/data-trends-south-carolina-criminal-justice-reform 6 EFTA00141374 Reassessment” of work in America—people are reassessing what they want to do and how they want to work. $ ^{10,11} $ Particularly in a strong labor market, it is imperative that BOP understands how organizations are competing to recruit and retain employees. ## BOP Values BOP's core values, mission, and vision were used to frame recommendations in this report to support the long-term staff safety and support of the BOP workforce $ ^{12} $ : Mission: It is the mission of the Federal Bureau of Prisons to protect society by confining offenders in the controlled environments of prisons and community-based facilities that are safe, humane, cost-efficient, and appropriately secure, and that provide work and other self-improvement opportunities to assist offenders in becoming law-abiding citizens. Vision: The Federal Bureau of Prisons, judged by any standard, is widely and consistently regarded as a model of outstanding public administration, and as the best value provider of efficient, safe, and humane correctional services and programs in America. ## Core Values: - Courage, we forge new paths, challenging the status quo, and make difficult decisions to rise above adversity. - Respect, we embrace diversity and recognize the value and dignity of staff, inmates, and the general public. - *Integrity*, we demonstrate uncompromising ethical conduct in all our actions. - Correctional Excellence, we are correctional workers first, committed to the highest level of performance. Recommendations outlined in this Current State Assessment focus on tangible actions for BOP staff and reflect BOP’s vision for providing the most efficient, safe, and humane correctional services and programs in America. ## Methodology A combination of qualitative and quantitative data was used to support findings. The data analysis conducted for this report was based on the data made available to the Deloitte team. ## Field Research Design The team conducted five site visits comprised of nine focus groups as well as 30 interviews with leaders across BOP. Interviewees were selected based on gender, location, and position to provide a diverse representation of BOP staff. $ ^{13} $ Additionally, with the advice of Central Office and the National Union, questions covered topics most applicable to the GAO recommendations: staffing, leadership, recruiting, retention, employee experience, Employee Assistance Program, Crisis Support Team, mental health, wellness, and staff crisis prevention and response. The interview questions were tailored based on the participant’s division and leadership title. $ ^{14,15} $ 10 The Washington Post: Why America has 8.4 million unemployed when there are 10 million job openings. https://www.washingtonpost.com/business/2021/09/04/ten-million-job-openings-labor-shortage/. 11 The Washington Post: It’s not a ‘labor shortage.’ It’s a great reassessment of work in America. https://www.washingtonpost.com/business/2021/05/07/jobs-report-labor-shortage-analysis/. 12 Federal Bureau of Prisons: About Our Agency. https://www.bop.gov/about/agency/agency_pillars.jsp 13 All interviews were with a Leadership member (see Leadership in “Definitions” section for a more accurate description). 14 The interview topics depended on the interviewee’s position. For example, a CST Leader’s questions would focus predominantly on CST, but every CST Leader received the same standardized questions. 15 Each interview lasted roughly 60 minutes. The ten virtual interviews were conducted either over the phone, over Zoom, or through Microsoft Teams. 7 EFTA00141375 The interviews were structured around previously mentioned topics and utilized open-ended questions to allow interviewees to provide sufficient details on each topic and adequately capture perspectives. Interview responses were documented verbatim and grouped according to similar themes (Appendix A). Additionally, responses were anonymously itemized and did not include any identifying information, to protect interviewee data. Key takeaways from the interviews were placed by theme into a quantitative research database (Figure 1) to assess data from interviews and institution visits. $ ^{16} $ The database was organized by the following: Interview Number, Date, Office, Position, Comment, Theme, Sub-theme, and Categorized Responses and were used to add a deeper level of understanding during the analysis of responses. $ ^{17} $ Furthermore, a categorized response was used to label and sort responses. For example, if a comment notes that, “Career advancement relies upon movement between institutions,” then the categorized response would be “relocate for career.” Using this framework of grouping together alike sentiments created a practical analysis that quantifies categorized responses, themes, and subthemes, which led to clear and concise insights. Figure 1: Quantitative research database used by the team to analyze interview responses. ## Focus Group Design Focus group participants were identified based on gender, position, and tenure with the Bureau to gain a diverse group of attendees. $ ^{18} $ All participants volunteered their time to partake in the focus group. Additionally, with the approval of HRMD and the National Union, an agenda of activities and questions was developed (Appendix B) to prompt BOP staff members to speak openly and honestly about their employee experience related to staffing, well-being, leadership, and culture. The same questions were used for every focus group to ensure questions were standardized and insights were clear and accurate. $ ^{19} $ The team conducting the interviews consisted of two facilitators and two notetakers. Participants were asked to keep focus group conversations confidential and were notified that all responses would remain anonymous. Facilitators worked together to make sure that all responses were recorded correctly. $ ^{20} $ The team analyzed the focus groups using a method similar to the interview data analysis (Focus Group Number, Date, Office, Position, Comment, Theme, Sub-theme, and Categorized Responses). The team standardized the focus group questions across institutions and tagged the question with the response, which allowed for an accurate cross-sectional 16 The team made the research database through Microsoft Excel. The team analyzed the data by using the pivot table function. 17 The model is for internal third-party use only, therefore none of the information within the database will be attributed to a specific individual. Additionally, themes and sub-themes are explained within “Definitions.” 18 The focus groups consisted of only Bureau of Prisons’ staff members and supervisors. The team did not allow high level institutional leaders (such as the Captain and Lieutenant) to participate in the focus groups. 19 Each focus group lasted roughly 90 minutes. Some focus group questions changed over time, dependent on additional information learned during prior institutions. 20 Notetakers cross checked each other’s notes before implementation into the research database. 8 EFTA00141376 analysis of data covering all focus groups (Figure 2). $ ^{21} $ For this report it is important to note that focus group participants did not answer every question and sometimes had more than one response per question. For example, the question, “What do you love about working at the Bureau of Prisons,” resulted in 222 total responses from 90 focus group participants. Therefore, the focus group responses are not mutually exclusive. For example, during the question, “What are the bugs of the job,” 40 participants mentioned “training” or “training needs improvement” as a “bug.” This does not mean that 50 out of the 90 participants believe the opposite is true. Just like the interviews, focus groups were a free-flowing conversation meant to lead to insights and uncover underlying root causes. The data can be sorted by any focus group question to find trends through the themes, sub-themes, and categorized responses. Additionally, the 'quantity' was labelled within the database, reflecting the number of focus group participants that agreed on a response. The database is a conglomerate of all the different themed responses from every stage of field research. This research database was used to gain collective insights across institutions to inform recommendations to BOP. Figure 2: Quantitative research database used by the team to analyze focus group responses. ## Field Research Analysis After inputting the focus group and interview responses into the research database, a cross-sectional analysis was applied that proved to be beneficial during the research process. For example, instead of looking at responses as a whole, the interview data could be used to segment out and compare responses from Wardens to responses from Lieutenants. Moreover, the same logic could be used for focus group data; responses were compared across different institutions and regions nationwide. This comparison technique uncovered the major themes identified within the field research and underlying root causes for BOP to address. The team used Carl Jung’s word association test which is based on the idea that asking for one-word responses from participants can reveal subconscious ideas. $ ^{22} $ One-word associations were used during focus groups and participants were asked, “What is the first word you think of when you hear EAP?” Responses were sorted by labelling each either positive or negative. A positive response exemplifies a sentiment that views EAP as a beneficial program, while a negative response is a sentiment that criticizes EAP. Additionally, “I don’t know” responses were categorized as a negative since it represented unawareness of the program. Using this technique to classify responses, in conjunction with additional data points, provided clear insights into the awareness and perception of EAP at BOP. 21 The team reflected changes made with focus group questions into the research database. 22 Carl Jung’s Word Association Test. https://exploringyourmind.com/carl-jung-word-association-test/. 9 EFTA00141377 Once the themes, sub-themes, and categorized responses were finalized, outside sources were used to aid in problem solving and ensure best practiced were utilized. Subject matter experts in mental health within law enforcement agencies were brought in to discuss both staffing and EAP related issues. In addition, organizations with similar problems were researched to identify what worked and what did not work in these similar circumstances. Connecting both quantitative and qualitative data, recommendations—supported by key insights—were compiled to address BOP’s needs. $ ^{23} $ ## Field Research Assumptions Findings of the field research consider several assumptions outlined below: 1. The participants responded to all questions asked with honesty and to the best of their knowledge. 2. The institutions visited were representative of Bureau of Prisons as a whole, even though five out of 122 institutions and five out of six regions were visited. 3. The participants for virtual interviews selected were representative of their discipline or department. 4. The focus group participants selected consisted of a representative sampling amongst the majority of disciplines. 5. COVID-19 had a large impact from the beginning of the pandemic (March 2019) to present day. 6. While the team used a consistent approach across all divisions, disciplines, regions, and locations, categorizing data into themes involves a level of subjectivity. ## Data Analysis Methodology In addition to the field research, the team collected a combination of qualitative and quantitative data to provide a holistic analysis. The data analysis conducted for this report was reliant on the availability of BOP's data. Data that was provided included: - Retention incentives - Recruitment incentives - Relocation incentives - Overtime and augmentation hours - Leave hours - Eligible and mandatory retirements - Exit survey results - Current staffing levels The documents reviewed included Staffing Guidelines for CPD, HSD, and RSD to better understand current staffing at BOP. Additionally, the team reviewed BOP's Human Capital Plan to understand how they plan for critical and future staffing needs. $ ^{24} $ The analyses were primarily focused on institutional staff rather than Central and Regional staff members, given the scope of this report. The team conducted analyses using both external and internal data. The analysis of external data included using publicly available data from Bureau of Labor Statistics (BLS) and OPM's Fedscope tool to compare entry level 23 It is important to note, the team did not quantify all themes found within the field research. The team used some of the themes for qualitative purposes, such as using impactful quotes and unpacking specific sentiments. 24 BOP Human Capital Operating Plan_FY21_Q4 10-2021 – BOP Internal Document. 2021. 10 EFTA00141378 Correctional Officer wages. To depict the high-level overview of the current BOP workforce, the team analyzed staffing level data from 2021, calculating the representation of Correctional Officers in BOP’s workforce. To understand overtime and augmentation hours recorded by BOP, the team took the total overtime and augmentation hours and divided this number by the total staff, resulting in the average overtime and augmentation hours per staff member. This process was then replicated, and trends were tracked for the past 5 years—which showed an increase over time. Data for staff incentives were similarly trended for the past 5 years by depicting the number of retention incentives offered to staff, broken out by region. Additionally, the team identified the top 10 positions receiving incentives. The retirement analysis was created based the current workforce’s retirement data to project the number of staff that will be eligible to retire and reach a mandatory retirement age in 5 years. To assess leave, usage hours were broken out by type of leave. Many of the analyses used 5-years’ worth of data to get a more accurate trend while accounting for external variables such as COVID-19. ## Data Limitations Due to limitations of availability of certain data elements, the team made several assumptions during the data analysis process. Given the limited non-public data available at the time of this report, GS 6 (the GS scale is the predominant pay scale within U.S. civil service) was assumed as the entry level BOP Correctional Officer. OPM’s Fedscope tool enables a comparison of publicly available wages, but it does not offer state and federal Correctional Officers salary data below GS 6. Additionally, for the wage analysis, federal Correctional Officers were assumed to be BOP Correctional Officers. For the exit survey data, the team assumed the reasons for staff resignations were representative of BOP staff as a whole. When analyzing the incentives data, positions deemed similar were grouped together and based on the team's understanding of job titles. 11 EFTA00141379 ## Hire: Acquire BOP Staff ## Introduction to the Hiring Process The first interaction that a new employee has with the Bureau is through the recruitment and hiring process. BOP is working to address the first goal in its HC Operating Plan—to replenish talent pipeline for mission critical occupations—through a new national marketing campaign. $ ^{25} $ The Bureau’s current workforce is rapidly approaching retirement—which makes it even more critical to refill the talent pipeline now than ever before. The Bureau faces the following challenges related to hiring staff: - Current hiring practices are falling behind projected retirements - Current recruitment strategies make it difficult to hire clinical and mental health professionals (e.g., MDs, MLPs, psychologists, RNs) $ ^{26} $ Like many other agencies, hiring at BOP follows federal government-wide personnel management laws. External candidates that are hired into the Bureau as Correctional Officers enjoy a steady career progression where they can be hired at any level from GS 5 to GS 7 depending on a candidate’s experience. Hiring candidates at GS 5 allows BOP to pull from a broader and more diverse pool of eligible candidates. The typical GS 5 hire has 3 years of managerial or supervisory experience or holds a bachelor’s degree. However, over the last two years during the COVID-19 pandemic, BOP has more commonly hired at the GS 7 level. One Warden stated that it is not uncommon to hire a Correctional Officer at the GS 7 level and have them apply for the GS 6 level within the year. Candidates at the GS 6 or 7 "They are promoting staff, but they do not have the staff to backfill positions." - Focus Group Participant level must have specialized experience. For example, specialized experience at the GS 6 level would include working as a police officer, while specialized experience at the GS 7 level would include experience time in the correctional field. Candidates can also substitute years of experience with a master’s degree in a related field of study. BOP is required by law and the federal hiring process known as competitive examining to notify the public about job vacancies; screen applications against minimum qualification standards; apply selection priorities such as veterans' preference; and assess applicants' relative competencies or knowledge, skills, and abilities against job-related criteria to identify the most qualified applicants. $ ^{27} $ BOP uses USAJOBS.gov as its primary site to post jobs, but also utilizes other recruitment platforms such as recruitmilitary.com and indeed.com. BOP is required by the Office of Personnel Management to hire new employees within 80 days. According to the GAO report in February 2021, “BOP’s time-to-hire has ranged from an average of 82 days (in fiscal year 2016) to an average of 96 days (in fiscal year 2017) from fiscal years 2015 through 2020. In fiscal year 2020, BOP’s average time-to-hire was 91 days.” $ ^{28} $ The hiring process involves a variety of stakeholders and many checks and balances (Figure 3). Employees familiar with the hiring process have attributed delays to a number of items including a lengthy background check/e-QIP process, required medical screenings, and credit check complications. 25 BOP Human Capital Operating Plan_FY21_Q4 10-2021 – BOP Internal Document. 2021 26 Hard-to-fill positions can vary by position and location. For example, one BOP institution may strive to fill medical positions while another institution located in a rural area finds it more difficult to hire Correctional Officers. 27 Office of Personnel Management. https://www.opm.gov/policy-data-oversight/hiring-information/competitive-hiring/#CompetitiveExamining. 28 United States Government Accountability Report No. GAO-21-123. 2021. 12 EFTA00141380 Figure 3: Normal hiring process flow for Institution Staff Under the normal hiring process, the need to fill a vacancy is first identified by the local institution, who submits vacancy posting materials to the Consolidated Staffing Unit (CSU). If the selection official for the position is the Regional Director (e.g., supervisory and managerial-level positions), however, the Regional Office will submit vacancy posting materials to CSU. The Consolidated Staffing Unit will post the job opening on USAJOBS and eventually present a list of qualified candidates to the local Human Resources (HR) staff, who then administer the Core Value Assessment, conduct interviews, and select candidates. The overall timeline can be expedited for positions that qualify for direct hire authority in accordance with OPM policy whereby “OPM is authorized to permit agencies to use direct hire authority for positions where OPM has determined that there is either a severe shortage of candidates or a critical hiring need for such positions.” $ ^{29} $ BOP can also submit a written request to OPM for specific positions. 29 United States Government Accountability Report No. GAO-21-123. 2021. 13 EFTA00141381 Figure 3.1: Process of obtaining Direct Hire Authority (DHA) approval and hiring Direct hire authority expedites the typical hiring process associated with the competitive examining hiring process by eliminating competitive rating and ranking procedures and veterans’ preference (Figure 3.1). To obtain Direct Hire Authority (DHA) for specific positions, the local institution submits justification for DHA to the Personnel Director’s Office within HRMD. The justification is reviewed and submitted to DOJ on behalf of BOP and submitted by DOJ to the Office of Program Management (OPM), who decides on DHA request approvals. If OPM approves the institution’s request for DHA, the approval is relayed back to the Personnel Director’s Office, who informs the Staffing and Employee Relations (SERS) office within HRMD. Then, SERS notifies CSU and the local HR. As with the normal hiring process, it is at this point that CSU posts the job on USAJOBS. The next step differs from the normal process in that the local institution is now authorized to accept and consider applications, evaluate candidate qualifications, determine a list of candidates to move forward, and complete the pre-employment process. Direct Hire Authority remains for one year from date of approval. As an agency, BOP has applied for direct hire authority twice (October 2019 and March 2020). If BOP is granted DHA, they can exercise that authority for two years. In one instance, OPM decided that there was a lack of sufficient evidence to show a critical hiring need and severe shortage of candidates. $ ^{30} $ However, requests for direct hire authority have been granted to specific institutions, such as USP Thomson, which received 25% retention bonuses and direct hire authority for staff in September 2021. $ ^{31} $ ## Promotions and Succession Planning The application and selection process for internal candidates follows the same process as external candidates, with a few exceptions. Merit-based promotions are not required to complete interviews or the pre-hiring questionnaire. Since these positions do fall under the competitive hiring process, a candidate must meet thresholds for time-in-grade and necessary experience, and they must apply to be considered for the position. The application packet that candidates submit includes: their resume; performance evaluation from the last 13 months; performance awards they have received over the last 5 years; and responses to an assessment regarding their skillsets. 30 United States Government Accountability Report No. GAO-21-123. 2021. Thompson Prison employee named AFGE 2021 Officer of the Year. https://qctimes.com/news/local/homson-prison-employee-named afge-2021-officer-of-the-year/article_4154e34a-e6d1-5f78-9a01-93fc0950f096.html 14 EFTA00141382 BOP provides an opportunity for staff to relocate to develop skills and learn best practices from other institutions. Some focus group participants appreciated that leaders were selected internally. However, others expressed frustration around the perception that promotion was predicated on a willingness to relocate and that the entire hiring process was centralized in Grand Prairie. Forty participants commented on the hiring process, stating it was too slow and that new hires are not prioritized based on quality. According to institution leadership and focus group respondents, relocation is often encouraged to achieve career progression at the supervisory level. Some field research participants noted that the positives of a culture of relocation enabled exposure to different institutions and an ability to share best practices across the Bureau. At institutions that were self-described as “homestead” institutions, participants described transitioning into positions such as teacher or social worker to progress their salary while staying local. In addition, they also cited the Grand Prairie HR specialists’ lack of functional knowledge about institutions as prohibiting their ability to qualify for desired positions (i.e., resumes were tossed out if they did not contain specific key words). Unlike other positions, which are posted when they are vacant, promotion to the Associate Warden and Warden positions follows a cyclical pattern. The announcements are posted twice a year and Executive Staff meet quarterly, and as needed, to review Associate Warden and Warden vacancies across the Bureau. Staff generally must serve as an Associate Warden at least twice to be eligible for promotion to Warden. Regional Directors make recommendations for Warden roles, however the BOP Director makes the ultimate selection. Succession planning at BOP to backfill positions is mostly focused on mandatory and confirmed eligible retirements. HRMD provides a report on the number of projected mandatory retirements to each new Assistant Director or Regional Director. Each Regional Office has access to see all eligible and mandatory retirements within their region coordinated by the Consolidated Benefits Unit (CBU), however availability to support individual institutions may vary. In addition, every individual institution has a monthly HR workforce utilization committee meeting to discuss budget, succession planning, and upcoming staff transfers with the Warden. This meeting serves as an important step to backfill positions at the local level. After an employee decides to retire upon becoming eligible for retirement, they are assigned a benefits counselor who walks them through their retirement options. If the staff member makes the decision to retire and submits their completed application for retirement packet, CBU then notifies the local HR office—enabling the institution to begin backfilling the position. When an employee is six months away from their mandatory retirement, CBU sends a notification to both the employee and their institution’s HR office. Given that the retirement is mandatory, the HR office can then begin backfilling the position. ## Strengths of Current Hiring and Succession Planning BOP offers a few unique long-term benefits such as student loan repayment, early retirement as a law enforcement agency, and family benefits (e.g., EAP counseling) that entice employees to remain at BOP after a few years of service. $ ^{32} $ Additionally, healthcare for BOP retirees is also transferrable to retirement and covers family members until they reach the age of 26. A few interviewees noted that BOP’s 2021 hiring initiative was successful at recruiting some candidates by offering financial waivers to pay off student loans. The National Recruitment Office has, in conjunction with a marketing partner, launched a new marketing campaign to promote a career in correctional services. The new marketing campaign, which began in October 2019, is focused on the overall BOP brand and features targeted ads for Correctional Officers, nurses, and social workers. According to BOP’s National Recruitment Office, this marketing campaign has gathered 1,100 clicks on advertisements and nearly 300 applications using Facebook, LinkedIn, and Google Search advertisements. In 32The term “early retirement” refers to the eligible retirement age for law enforcement personnel at age 50 rather than age 62 for other civil service workers. 15 EFTA00141383 addition to the marketing campaign, the National Recruitment Office has built up its team of recruiters, providing full-time dedicated recruitment support for most positions. BOP has made a concerted effort to focus on recruiting teachers to help fulfill First Step Act requirements around educational programming. Another strength of the hiring process is the Bureau’s proprietary Core Value Assessment (CVA). The CVA presents candidates with simulated, stressful security threats they are likely to encounter as a correctional worker. The objective of the assessment is to analyze their cultural fit with BOP by comparing their responses to hypothetical situations with BOP's core values. The CVA is a good attempt by BOP to attract quality candidates to serve as correctional workers. ## Scope of Challenges and Associated Risks of Current Hiring and Succession Planning Challenge: Current hiring practices are falling behind projected retirements As BOP is a law enforcement agency, most of its workforce is mandated to retire at the age of 57. The looming deadline to replenish its talent pipeline before it experiences a dramatic uptick in retirement (from 291 retirements in 2018 to 762 retirements in 2025 according to Figure 4) presents a hiring risk to BOP. $ ^{33} $ HRMD reports the number of upcoming eligible and mandatory retirements, however, workforce planning documentation at the enterprise-level does not consistently identify plans of action to backfill these predictable separations. $ ^{34} $ The prioritization of which positions to backfill first are often based on the individual Warden and Regional Directors’ discretion. To address this risk, it is recommended that the Bureau invest in more robust workforce planning capabilities to forecast rates of retirement for eligible employees in addition to mandatory retirements. An ability to better predict critical staffing shortages would enable the Bureau to present evidence-based applications for hiring exemptions or special salary rates to mitigate this threat. Number of BOP Staff Retirements by Year Figure 4: Based on average BOP retirements at age of 53 and over BOP Retirement Data CY 2021-2026. 34 HRMD Workforce Systems and Evaluation Section: BOP Workforce Planning Information. 2021. 16 EFTA00141384 ## Challenge: Current recruitment strategies make it difficult to hire clinical and mental health professionals (e.g., MDs, MLPs, psychologists, RNs) $ ^{35} $ The Bureau’s ability to hire specialized positions such as MDs, MLPs, psychologists, and RNs is another critical challenge that presents risk to the organization. Sentiments from field research indicated that Wardens may not have the specialized knowledge needed to best evaluate the technical skills of candidates applying for a specialized position. Furthermore, the National Recruitment Office does not currently have a full-time recruiter specifically dedicated to recruiting for medical positions. Subject Matter experts do provide input around the candidate selection process: they support the creation of position descriptions and the crediting plan-which rates the knowledge, skills, and abilities required for each job posting; and are included in panel interviews. However, HR has the primary responsibility of selecting candidates. Field research participants expressed the sentiment that local HR had selected candidates to interview that were unqualified for specialized positions, and excluded candidates known to contain the proper qualifications without explanation. Further involving SMEs during the selection process could be an area of exploration to improve recruitment efforts. The COVID-19 pandemic has further exacerbated the challenge of recruiting for highly sought-after HSD positions such as physicians, nurse practitioners, and physician’s assistants. In addition to a national shortage of nurses, BOP is competing against local hospitals that often offer higher salaries and incentives. Individuals who graduate from nursing school may not immediately think of BOP as a viable career option, particularly in comparison to nearby hospitals. "I didn’t know BOP was an option when I was in nursing school." – Focus Group Participant Current recruitment strategies at RSD would benefit from increased communication and coordination to ensure that BOP is consistently hiring quality candidates. Recruiters in Grand Prairie could benefit from trainings taught by subject matter experts that focus on how to identify necessary skills for psychologists. Although BOP’s new national recruitment initiative has dedicated recruiters for medical personnel, RSD does not have a recruiter in the National Recruitment Office (NRO) that is dedicated to hiring psychologists. RSD psychology internships have also been a successful recruitment tool in the past, with many interns seeking out full time opportunities at BOP post-internship. However, these internships fall short of other similar public sector psychology programs who offer more desirable student loan repayment benefits. Some BOP stakeholders reported that BOP’s student loan repayment program is simply not as generous as other similar psychology student loan repayment programs such as the Department of Veterans Affairs debt reduction program. In addition, BOP’s program could become more competitive by the offering post-doctoral positions that many candidates are looking for. It is recommended that BOP re-invest in student loan repayment programs that are market-competitive and ensure consistent technical Subject Matter Expert input throughout the entire hiring process. 35 Hard-to-fill positions can vary by position and location. For example, one BOP institution may strive to fill medical positions while another institution located in a rural area finds it more difficult to hire Correctional Officers. 17 EFTA00141385 # Train: Acclimate BOP Staff ## Introduction to Correctional (ICT) Training After receiving an official offer letter and start date, a new hire’s next major milestone is onboarding to BOP. Given the unpredictable, and potentially dangerous environment that institution staff face (regardless of their position), it is imperative that new hires feel ready to work on day one. New Mexico, for example, is one of several states that has proposed starting new training academies to solve their staffing shortages. Between inconsistent training, a struggling staffing rate and low compensation, most new officers leave within three years. $ ^{36} $ BOP Correctional Officer turnover saw an 1% increase from 2019 to 2020, and 17% of new hires across all departments left the Bureau within one year. $ ^{37} $ The Bureau faces the following challenges related to staff onboarding: - ICT training needs continued investment and accountability to provide the exposure and practice needed for staff to feel ready their first day on the job - The supplemental onboarding programs appear to be inconsistently executed Introduction to Correctional Techniques (ICT) is a training all new correctional hires are required to complete when joining an institution. ICT is a five-week program for a total of 184 hours of instruction that is taught in two phases. However, day one is often a few months before starting ICT, which could create a challenge for new hires that then feel unprepared. Ideally, all Correctional Officers would complete ICT training before their first shift, but given scheduling constraints, this is not always the case. Phase I of ICT occurs in-person at an officer’s assigned institution and focuses on security issues, “Let’s get away from ‘I figured it out, you can figure it out too.’” - Focus Group Participant contraband, emergency situations, ethics, sexual abuse prevention and intervention, worker’s compensation limits and other location-specific issues. It also focuses on communication and de-escalation training to minimize assaults on staff or inmates. After new Correctional Officers learn policies in the classroom, they shadow an active Correctional Officer to go through day-to-day activities. Individual institution leadership also has the authority to determine necessary additional training on an individual basis. ICT Phase II is a 17-day training for all disciplines to attend at the BOP Staff Training Academy. The first week is comprised of in-class trainings while the second week is on-the-job trainings (OJT), including working side by side with a seasoned staff member depending on their discipline. This phase has four main components: firearms, self-defense, a written academic test on policies and procedures, and the Physical Abilities Test (PAT). The training covers an array of topics, such as correctional supervision principles, national policy guidelines, interpersonal communication, and diversity and inclusion. The PAT measures an employee’s ability to perform essential functions of a correctional worker. Completion of the program is required and must be completed within 120 days of entry-on-duty (EOD) under the discretion of the Staff Training Academy (STA) for continued employment of new law enforcement staff. ## Supplemental Onboarding Programs Some institutions have implemented onboarding programs to supplement ICT by pairing new staff with someone to mentor them through their initial year and beyond. The mentorship program is also available at all institutions for all Correctional Officers regardless of their tenure (i.e., it is not limited to new hires). In most cases, the level of 36 Many States Face Dire Shortage of Prison Guards. https://www.pewtrusts.org/en/research-and-analysis/blogs/stateline/2016/03/01/many-states-face-dire-shortage-of-prison-guards. 37 BOP Exit Survey and Turnover Data. CY 2021-2026. 18 EFTA00141386 investment in the program appears to vary depending on the level of involvement from the Warden and training department leaders. Each institution has been provided a curriculum for the mentoring program that includes policies and procedures, but the success of the program depends on how effectively the teaching materials are used. ## Annual Training Requirements After a Correctional Officer’s initial training and mentoring, all staff are required to complete 40 hours of training per year, focused on American Correction Association (ACA)-mandated topics and core annual topics determined by a BOP executive. After completing the core annual topics, the remaining training time is determined by the Warden and can be met through a variety of platforms including self-study, meetings, offsite training, experiential training, and/or computer modules. BOP utilizes an online learning management system known as the Bureau Learning University (BLU), to allow staff to complete some training requirements. Annual mandatory staff training includes firearms training, cardiopulmonary resuscitation (CPR) and automated external defibrillator (AED) and Information Security. The Bureau offers additional training for custody staff to grow more specific skillsets, such as a Marksman Observer and Witness Security training at the Staff Training Academy (STA), housed at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia. ## Strengths of Current Acclimation Programs BOP’s standardized ICT training results in a consistent introduction to the organization and information sharing for new hires, regardless of their geographic region or position. BOP will soon launch a Bureau-wide Correctional Training Officer (CTO) program. The program will be led by officers at each institution who are selected by the Regional Director and receive training on how to best aid future trainees in improving their skills. Participants in the program will include Correctional Officers that are referred by a supervisor and officers that indicate they would like to improve their correctional skills. In addition to the initial ICT training, some institutions have implemented supplemental onboarding programs such as mentoring for new hires as a best practice. The mentorship program presents an opportunity to supplement onboarding in a safe environment. ## Scope of Challenges and Associated Risk of Current Acclimation Programs ## Challenge: ICT training needs continued investment and accountability to provide the exposure and practice needed for staff to feel ready their first day on the job ## "A three-month person is training a three-week person." — Focus Group Participant Focus group participants indicated that on-the-job, real-time training would position them to be more successful than ICT. Current ICT relies on PowerPoint training, misses opportunities for cross-departmental training, and is often led by less experienced staff. Moreover, COVID-19 restrictions have exacerbated training backlogs, preventing staff from obtaining requisite skills and attending additional training opportunities. The current scheduling process does not account for all training requirements—which creates a risk for instructors being selected based on availability rather than expertise or training capability. Focus group participants recommended adding the role of Field Training Officer, to create a permanent training instructor to facilitate ICT and additional training opportunities across the Bureau. Shortfalls of ICT can lead to staff turnover—exit surveys from 2016 to 2020 show 30% of staff state lack of training as a contributing factor to their decision to separate from BOP. One focus group commented that they would add crisis management training to the current curriculum, while another felt that BOP should offer incentives and invest in staff that are interested in growing professionally. To mitigate this risk, it is recommended that the Bureau consider incorporating all training hours into its scheduling process and evaluate the effectiveness of 19 EFTA00141387 current training curriculum, considering innovative techniques to improve Correctional Officers’ preparation. BOP would also benefit from investing in external leadership training from OPM or external entities for the middle management positions (e.g., Lieutenants) that draw on industry best practices and support consistent learning across the Bureau. However, it is important to note that, much like other federal agencies, trainings are the first to get cut in funding due to budgetary constraints. ## Challenge: The supplemental onboarding programs appear to be inconsistently executed While staff will readily admit that the mentorship program is great in theory to supplement onboarding, they quickly cite challenges with how it is currently executed. Primarily, experienced staff who watch over new hires may not even be in the same discipline—limiting their ability to provide guidance and advice specific to the new hire’s role. Additionally, due to staffing constraints, some mentors may not be able to participate in the program to the extent needed. It is recommended that BOP assess the impact of the current supplemental onboarding programs and explore how standardization of the programs might drive an improved talent experience for new hires. 20 EFTA00141388 ## Manage: Allocation of BOP Staff Key Metrics of Current Staff Figure 5 Total number of staff at BOP as of December 2021 Figure 5.1: As of December 2021- CO represents Central Office (please see Appendix D) Following a period of acclimation, a new employee joins the Bureau’s workforce of approximately 37,000 staff members. $ ^{38} $ Given the large proportion of Correctional Officers to staff in other disciplines (around 15,000 out of 37,000), this section will focus primarily on current staffing processes for Correctional Officers and recommendations to resolve staffing challenges. Additionally, staffing for the Health Services Division (HSD) and Reentry Services Division (RSD) will be examined due to their specialized skillsets and critical mission impact. The Bureau faces the following challenges related to allocation of staff: - BOP’s staffing formula requires additional scheduling variables (e.g., accrued personal time off, military deployments, or expanded training requirements) to properly estimate staffing needs and maximize its ability to allocate resources across its 122 federal institutions - Overtime and augmentation has increased over the years, but a deeper quantitative analysis is required to understand associated risks - Current staffing guidelines are developed for each discipline independently rather than using a standard process across the Bureau - More shift transitions are required using the standard 8-hour shift schedule, which may result in increased mandatory OT and a reduction of days off for staff - Manual entry of changes to staff schedules in current roster system increases risk of human error ## History of BOP’s Current Staffing Formula The challenges BOP faces today have developed over a long thirty-year history. Since 1992, BOP has calculated its staffing needs by estimating the number of working days that Correctional Officers should be available to work by subtracting an average number of days for training, sick days, holidays, and annual leave. The formula does not account for Correctional Officers accruing more paid time off over the course of their career or variations in training requirements. In 1992, BOP set the number of available working days for Correctional Officers to be 216 $$\textcircled{38}$$ Federal Bureau of Prisons: About Our Agency. https://www.bop.gov/about/agency/. 21 EFTA00141389 days to calculate necessary staffing levels. In 2011, the Correctional Programs Division (CPD) recommended changing the available working days from 216 days to 210 days to better reflect the reality on the ground. However, this change was not implemented until 2016. In 2013 and again in 2016, the Bureau updated guidance to ensure greater safety in housing units at high security facilities: - In 2013, guidelines were updated to include an additional Correctional Officer in the housing unit during late shifts at high security facilities. - In 2016, Congress mandated that a second Correctional Officer is required on all shifts in each housing unit at high security institutions and detention centers. In 2019, the Warden’s Advisory Group (WAG) determined that 210 days did not accurately reflect the average number of days correctional services, human resources, and finance personnel were working, and was not a good foundation for calculating staffing needs. In 2020, the Correctional Services Branch (CSB) developed a new system to determine staffing levels by calculating how often a Correctional Officer is physically at their post, but the new system has not been approved. Today, staffing levels are still based on the assumption that Correctional Officers are available 210 days per year. Using this assumption, BOP calculates the required base number of in four steps as indicated below. Additional staff may be added to the calculation according to BOP’s staffing guidelines which are described later. $ ^{39} $ Below is a step-by-step process for how staffing levels at BOP are calculated today using the 210 number. The entire process is institution-specific. Sum 2 Multiply Sum the total number of 3-day, 5-day, and 7-day posts Multiply by the number of days each post is manned. The result is the total number of man days. 3Sum Sum the total number of man days across each type of posts 4 Divide
50 (Total Number of 7-day posts)x 364 = 18,200
20 (Total Number of 5-day posts)x 260 = 5,200
10 (Total Number of 3-day posts)X 156 = 1,560
To find the total number of needed positions, divide the total man days by 210. A remainder of 72 or more is one additional position. 18,200 + 5,200 + 1,560 = 24,960 24,960 / 210 = 118 positions Figure 6 ## Strengths of Staffing Formula Calculating the required number of Correctional Officers is straightforward with the simple formula above. The single formula has been standardized across the Bureau of Prisons for all Correctional Officers. The standardization of this approach provides a sense of clarity for all institutions to gauge their vacancy levels by finding the difference between authorized positions and their current staffing numbers. ## Risks of Staffing Formula Challenge: BOP’s staffing formula requires additional scheduling variables (e.g., accrued personal time off, military deployments, or expanded training requirements) to properly estimate staffing needs and maximize its ability to allocate resources across its 122 federal institutions 39 Correctional Services Staffing Solutions PowerPoint – BOP Internal Document. 22 EFTA00141390 The availability of Officers to man their posts fluctuate from year-to-year making it difficult to accurately calculate how many positions an institution will need to remain secure. While the formula does provide an easy, standardized approach to determine staffing levels, it is not agile enough to adjust to an individual institution’s needs. For example, the current formula does not account for Correctional Officers accruing more paid time off over their career or variations in training requirements. Field research indicated that institutions could have a low staff vacancy rate, but still struggle to staff while some Correctional Officers are on military deployment. Data analysis illustrates that overtime and augmentation have been increasing over the years and indicate the staffing formula struggles to provide BOP the estimates needed to accurately staff its institutions. "I feel like trainings are scheduled without thinking about staff scheduling." - Focus Group Participant New staffing guidelines were proposed and developed in February 2021. However, implementation of the new guidelines has been postponed until BOP responds and addresses GAO recommendations. The new 2021 staffing guidelines provide a manual formula that Captains can use to calculate maximum number of staff that could be on scheduled leave, but the process is labor intensive and optional. Additionally, the staffing formula cannot respond to emergent staffing requests such as border patrol, riots, or natural disasters and does not account for projected staff turnover or promotions. Therefore, the new formula does not improve estimation of staffing needs or full address BOP’s staffing challenges. ## Staffing Guidelines for CPD, HSD, and RSD Building off the available 210 working days formula to determine the required number of staff, each division in BOP Central Office has developed guidelines on how to best allocate that number in each institution. The guidelines are written independently and provide guidance to Wardens when deciding the composition of their institution’s workforce. Institutions are permitted to hire additional positions beyond the staffing guidelines if they submit a waiver to their Regional Office and receive approval. ## Correctional Programs Division Staffing Guidelines The CPD staffing guidelines use type of post, security level and shift type to determine composition and volume of Full Time Employee (FTE)’s for Correctional Officers. There is a standard structure for staff posts and a supplemental guide which adjusts for an institution’s mission, physical layout, and other unique characteristics. The standard scheme includes a variety of positions and teams which include Captain, Lieutenant, Secretary, Correctional Officers and SIS Technician. Additional Correctional Officers may be afforded if an institution has more 7-day posts relative to 3-day posts. Each institution is also afforded supervisory Correctional Systems Officers (CSO) to help manage other officers. In February 2009, the Executive Staff approved a staff-to-inmate ratio of 1:225 for Correctional Systems Officers (CSOs) for stand-alone facilities, to include high, medium, low, minimum, and administrative security levels, regardless of population numbers. This ratio also applies to Care Level 3 and 4 facilities, complexes, medical centers, and those facilities with Residential Drug Abuse Programs (RDAPs). Institutions over 50 years old also require additional facility staff such as electricians, plumbers, and general maintenance to ensure the facility is functional. Correctional Officers comprise 35% of the workforce at Penitentiaries while low security institutions only require 30% of the workforce be Correctional Officers. The CPD guidelines assume that more dangerous inmates require more Correctional Officer attention. 23 EFTA00141391 Figure 7 Currently, BOP uses the above guidelines that were approved in 2016. However, CPD developed updated staffing guidelines in 2021 that have not been officially approved. The new guidelines define posts that are deemed critical to all institutions’ safety and security and should only be left vacant if there is an emergency or inmate programming is modified to alleviate the staffing need. Differing from the current guidelines, the 2021 guidelines incorporate more variables including physical layout of the institution, in addition to security level, care level, and special institution missions. Additionally, it includes guidance on how to calculate annual leave schedules to help Captains develop their rosters and daily schedules. Captains can use the formula as needed on a weekly or quarterly basis, but calculating the formula is a manual, labor-intensive process rather than automatic. While these new guidelines take a step in the right direction, they still do not account for fluctuating factors such as accrued personal time off, military deployments, or even training requirements. ## Health Services Division Staffing Guidelines Aside from keeping institutions safe, BOP HSD provides healthcare to inmates. HSD staffing at BOP consists of clinical, administrative, and allied health personnel that are determined by an institution’s security level, care level, and the number of inmates that are served. While higher security institutions always require more Correctional Officers, additional nurses are also required for care level 4 inmates who require a higher level of medical care such as oncology services. The type of institution also affects nurse staffing. For example, staffing is determined by admissions, discharges, and population for detention and transfer centers who operate 16 hours per day. Nurse staffing also depends on the number of inmates and whether the population is male or female. Internal BOP data affords female institutions additional health services staff due to higher service utilization rates and more psychosocial and preventive health needs. The standard composition and volume guidelines of FTEs for an institution’s ambulatory care is designed to serve 1,500 care-level 2 inmates. For institutions with alternative medical missions, there are 3 supplemental staffing models which require additional staff above the base staffing model. 24 EFTA00141392 ## Reentry Services Division Staffing Guidelines While HSD is required to provide healthcare to inmates, RSD is required to prepare inmates for reentry to society. RSD staffing guidelines include the psychology department and all other reentry services departments such as education, chaplaincy, and recreation. The Psychology department generally follows the same criteria as HSD to determine its staffing requirements. Base level staffing includes a Drug Abuse Program Coordinator, Drug Abuse Treatment Specialist, MAT Psychologist, and at least one Staff Psychologist, Psychology Services Secretary, or Psychology Services Technician. Outside of these positions, additional staff psychologists are determined by inmate-to-staff ratios that are based on an institution’s security level. Outside of psychology, all other departments in RSD use inmate population numbers to determine the required number of staff with additional staff for various incremental increases in inmates. Figure 9 25 EFTA00141393 ## Risks and Challenges for Staffing Guidelines ## Challenge: Current staffing guidelines are developed for each discipline independently rather than using a standard process across the Bureau The biggest challenge with staffing guidelines for CPD, HSD and RSD is that they are currently created in siloes and do not provide a standard approach to developing staffing requirements across mission critical disciplines. Each institution requires adequate staffing in food services, maintenance, chaplaincy, and other departments to remain operational and in compliance regardless of an institution’s inmate population. Initial staffing needs are determined at the Central Office level, but Wardens have the ultimate decision with input from Regional Directors. However, Wardens may have a misunderstanding of how to properly staff for other departments. This may result in an overemphasis of staffing roles in Correctional Services, and underemphasis of staffing roles in other mission critical divisions. The guidelines are also reliant on a different set of metrics than what is conveyed externally, resulting in disjointed messaging. Congress has a bottom-line inmate to staff ratio of 15:1, however staffing at BOP is a lot more complex and nuanced. To function, institutions need plumbers, chaplains, and teachers outside of Correctional Officers regardless of whether there is a single inmate, or an institution is at full capacity. Congress also does not take into account implications of the 2017 hiring freeze into BOP’s current staffing challenges. According to GAO, BOP eliminated any positions that were vacant at the time of the hiring freeze, establishing a new maximum of authorized positions they could employ. $ ^{40} $ In fiscal year 2018, BOP eliminated 5,100 authorized positions per DOJ’s budget office recommendation. $ ^{41} $ BOP officials stated that the elimination of these positions in 2018 has had negative long-lasting effects on staffing that is not fully understood by external stakeholders. $ ^{42} $ Below is a graphic to describe the complexity of how staffing is measured and communicated, internally and externally. Figure 10 40 United States Government Accountability Report No. GAO-21-123. 2021. 41 United States Government Accountability Report No. GAO-21-123. 2021. 42 United States Government Accountability Report No. GAO-21-123. 2021. 26 EFTA00141394 To mitigate this risk, BOP would benefit from a staffing methodology that better communicates the complexities and nuances of staffing federal institutions to external entities. ## Rosters and Scheduling at BOP After reviewing the staffing guidelines to determine the correct number of Correctional Officers needed, an institution ensures that all posts (spaces that require COs) have coverage through the roster process. Rosters are created once a quarter and must account for posts that require 24-hour coverage, generally within the constraints of 8-hour shift schedules. While BOP has taken steps to standardize and automate this arduous process, it still requires manual updates which can result in human error. Compressed scheduling is common in other non-stop settings. Hospitals require 24/7 staffing like BOP institutions and successfully use 12-hour shifts to optimize their scheduling. The development of a roster (with associated timelines) can be seen below. Figure 11 The roster development process spans seven weeks. A blank roster is posted to show available shifts, days off, and assignments available. Correctional Officers have one week to submit their post preferences to the Captain tasked with creating it. Seniority determines which preferences are honored first. If Correctional Officers want to dispute the schedule, they have one week to submit complaints. The final roster is sent to the Warden to be approved and posted three weeks prior to its implementation. This new software automates previous manual tasks and improves efficiencies in several ways. First, the system enables Correctional Officers to sign up for their quarterly preferences and generates a ‘best guess’ of their schedule. Second, the system improves on the current system by validating whether a Correctional Officer is qualified for the post they are assigned to. Third, it automates the form that needs to be completed each time a staff member is assigned an overtime shift by pre-filling the form and enabling someone to save it before completion. While the system offers improvements over previous versions, it still has several limitations. Since personnel data is pulled from payroll data, new hires and transfers do not automatically appear on the daily roster until their first paycheck. The system does not currently incorporate upcoming staff trainings when developing daily rosters. Finally, the software is not integrated with WebTA, requiring a Time and Attendance clerk to manually track the time each Correctional Officer works and then enter it into their Time and Attendance system. 27 EFTA00141395 Union Considerations The roster system is limited according to the Master Agreement which articulates a standard workweek consisting of 5 consecutive workdays with 8-hour shifts and an additional 30-minute, non-paid duty-free lunch break. $ ^{43} $ Requests for telework or compressed work schedules such as a 12-hour or 10-hour shift may be negotiated at the local level. Some local unions also have contractual limitations on augmentation while others do not, which can create an inconsistent employee experience and may have implications on mandatory overtime usage. Some local unions have utilized a compressed schedule. It would be beneficial to do a cost-benefit analysis to uncover the most favorable schedule while considering the Master Agreement. ## Strengths of Scheduling The current roster and scheduling process provides ample time for Correctional Officers to input preferences and file complaints before the roster is finalized. The roster is posted three weeks before it is implemented, providing transparency and predictability around Correctional Officer’s work schedules. The new roster system will allow for more automation than the current system and house roster data in a centralized location, enabling easier reporting and oversight. The system also shows the certificates and skillsets of each staff member, validating their qualifications for specific shifts. While the new system has taken steps towards easier and more accurate scheduling, there are risks that come alongside it. ## Risks and Challenges of Scheduling Challenge: More shift transitions are required using the standard 8-hour shift schedule, which may result in increased mandatory OT and a reduction of days off for staff One participant stated that the mindset of some staff on 12-hour shifts is: “We do them for an emergency. If it works for that, why not always do it?” Rosters also utilize an 8-hour shift schedule that results not only in a greater number of shift transitions, but a reduced number of available days off for Correctional Officers. Frequent shift changes create a risk of delayed or missed communication between staff and departments. A compressed shift schedule might free up days during the week that would allow Correctional Officers to take care of their responsibilities outside of work and as a result reduce the amount of sick time they take. 43 Master Agreement Between Federal Bureau of Prisons and Council of Prison Locals. https://www.afge.org/globalassets/documents/cbas/bop2014_new_master_agreement-with_revisions_06-23-2014.pdf. 28 EFTA00141396 Figure 12 illustrates the various types of leave used per year. Sick leave has increased from 2020 to 2021—while it is important to note that the recent increase could be a result of COVID-19, sick leave has made up a significant portion of the total leave taken in the last 3 years, second only to annual leave. ## Challenge: Manual entry of changes to staff schedules in current roster system increases risk of human error The new web-based roster system attempts to alleviate the issues with the existing roster system, yet it does not incorporate all relevant staffing constraints. The system set to deploy does not show transfers until their first pay period, which may cause a delay in their ability to sign up for shifts and be accurately included in the roster. In these situations, local HR staff can manually enter the information, but must be aware of the risks of duplicate entries or inaccurate personnel data. The new system does not incorporate upcoming constraints like scheduled trainings or alleviate the need for a manual time and attendance process. It also is not fully integrated with other systems and processes such as time and attendance, and the staffing guidelines. Overtime and Augmentation Usage 29 EFTA00141397 The daily availability of existing staff is subject to staff call outs, training, and military duties. To mitigate staff shortages related to these issues, BOP uses overtime and augmentation. $ ^{44} $ Augmentation is the temporary reassignment of a non-custody staff member (i.e., teacher) to a custody post. As previously stated, BOP requires all staff members to go through Correctional training, as all institutional staff are required to perform Correctional duties on a regular and reoccurring basis, including assuming Correctional Officer posts when necessary. Overtime is time worked beyond one's scheduled working hours. The usage of these methods has been increasing over time while the staff levels have only fluctuated by +/- 5%. An institution’s vacancy level is not a perfect indication of their staffing need. For example, institutions could be staffed at near zero vacancy but report increasing overtime and augmentation because the current staffing formula struggles to provide BOP ample staffing for their needs. While these methods can be used short-term to cover staffing shortages, more research is recommended to understand the impacts of extended use on staff burn out, increased budgetary risk, and employee performance. Figure 13 shows the trend of average amount of augmentation and overtime hours per staff over 4 years. Figure 13: The average augmentation hours per staff may be underrepresented to inconsistent use of the augmentation tracking (T&A) code The figures above illustrate that overtime and augmentation has increased exponentially over the last 4-years in relation to the total number of staff on board. Figure 14 shows a similar trend as Figure 7 broken out by region. All regions have increased their augmentation usage since 2017 with North Central, South East, and Western regions experiencing the highest increase. Similarly, all regions have seen an increase in overtime usage with South Central (SCR), South East (SER), and Western (WXR) regions requiring the most overtime. 44 United States Government Accountability Report No. GAO-21-123. 2021. 30 EFTA00141398 Figure 14 One of the advantages of BOP using augmentation and overtime to address staffing shortages is that it can be done quickly by reallocating existing staff. Additionally, staff members who volunteer for overtime shifts receive supplemental income. It is important to evaluate the effects increased augmentation and overtime usage may have on staff performance and burnout. For instance, 33 focus group participants cited augmentation as a primary driver of staff burnout. Participants also mentioned that being augmented detracts from their ability to complete their primary responsibilities, negatively impacts program implementation, and makes them feel less safe. As cited in the GAO report, it is recommended that BOP create metrics to assess risks associated with the increase in overtime and augmentation. $ ^{45} $ In the next phase of work, the Deloitte team will dive deeper into analyzing such risks associated with the increase usage. The analysis will include finding correlations between the metrics such as the number of incidents, staff-to-inmate assaults, and inmate-to-staff assaults with increased usage of overtime. 45 United States Government Accountability Report No. GAO-21-123. 2021. 31 EFTA00141399 # Retain: Minimize Staff Attrition ## Retention Incentives The last stage in the employee lifecycle is retention. Forbes estimated in 2019 that employee turnover cost organizations 33% of an employee’s annual salary. $ ^{46} $ Exploring the main drivers of staff attrition, along with projected attrition rates, will provide a more holistic view of how BOP can address understaffing. The Bureau faces the following challenges related to retention of staff: - BOP’s compensation and retention incentives require additional analysis to understand effectiveness compared to market standards - Negative media has affected officers’ sense of pride, both internally and externally BOP’s challenges in retention have been noted frequently, such as in a 2016 OIG review that discovered retention obstacles in the medical field, “in large part because it competes with private employers that offer higher pay and benefits, and because the BOP does not identify or address its recruiting challenges in a strategic manner or take full advantage of staffing flexibilities such as those available through the U.S. Public Health Service.” $ ^{47} $ Focus group participants also reiterated the issue of low compensation, while the Bureau’s exit survey data provided additional reasons for the decreasing attrition rate. Exit Survey Data Staff are asked to complete an exit survey when they leave the Bureau to share why they are separating from the Bureau and what they feel can be improved. According to the GAO report, “BOP officials responsible for overseeing the survey told us that while they provide the exit survey data to institutions, they do not track or analyze how, if at all, institutions make use of this information.” $ ^{48} $ Between 2016 and 2020, the top three reasons for leaving BOP were voluntary retirement, transferring to another government agency, and mandatory retirement. As Figure 15 demonstrates, a third of exit survey respondents indicated their choice to leave was due to an unreasonable workload and lack of resources to properly do their job, while another third reported a lack of opportunities for advancement. Correctional Officer turnover saw an increase from 2019 to 2020 and 17% of new hires across all departments left the Bureau in 2020. 46 Forbes, The Cost of Turnover Can Kill Your Business and Make Things Less Fun. https://www.forbes.com/sites/johnhall/2019/05/09/the-cost-of-turnover-cankill-your-business-and-make-things-less-fun. 47 Department of Justice 2021 Financial Report. 2021. 48 United States Government Accountability Report No. GAO-21-123. 2021. *It is important to note that completing the exit survey is voluntary and responses do not represent the entire BOP population. 32 EFTA00141400 Figure 15: Exit Survey Data (2016-2020) Currently, responses received from exit surveys could be utilized better to compare to compensation offered to staff as well as the organization’s use of retention incentives and their effectiveness. Analyzing exit survey responses could also enable the Bureau to develop interventions that positively impact employee experience and retention. ## Strengths of Retention Focus group participants were asked to identify what they loved about working at BOP, and cited employment benefits, their teammates, and an opportunity to grow in their career. Benefits highlighted by participants include early retirement, pension and paid sick days. $ ^{49} $ According to field research, employees that realize the long-term benefits of BOP (e.g., early retirement eligibility) tend to stick around. Fulfilling the mission of BOP and the reward of helping inmates was also cited as an incentive to stay. ## Risks and Challenges of Retention Challenge: BOP’s compensation and retention incentives require additional analysis to understand effectiveness compared to market standards Challenges in retention at BOP have been expressed anecdotally through reasons such as: remote location, job-competition in more populated areas, an unpredictable schedule, and lower compensation. Field research indicated that federal institutions face competition in hiring and retention from state institutions and other region-specific work such as oil refineries in Texas-based institutions. The competition between jobs is highest in more populated areas, while the challenge of keeping employees in more remote areas was attributed by field research participants to a lack of access to outside entertainment, stores, good school systems, and ways staff can spend their free time. For example, a staff member that joined the institution as a young adult may want to relocate to an institution “One of the most rewarding parts of the job is the ability to help inmates get their lives on track.” - Focus Group Participant in a more populated area once they have started a family. However, there has been little analysis of organizational data to determine if these are the true reasons for difficulty in retaining staff. Field research participants also commented that state prisons offer better compensation and an easier schedule, as well as frustrations that BOP’s GS-levels were not compatible with fellow agencies. Non-custody roles also struggle with retention, being (e.g., medical staff who are offered higher pay at nearby hospitals). BOP can potentially combat hiring competition through data analysis to confirm their GS-levels and aligning wages are on par with similar positions at other law enforcement agencies. 49 The term "early retirement" is about the retirement age for law enforcement personnel at age 50 rather than age 62 for other civil service workers. 33 EFTA00141401 At present, the most utilized option for retaining staff has been in the form of incentives. Conducting an analysis of performance metrics to see where BOP falls will allow the organization to determine if this current method is making a difference and establish steps for effective retention strategies. Since 2017, over 20,000 staff have received retention incentives across BOP’s six regions that have institutions, as observed in Figure 16. Retention incentives have been utilized most consistently by institutions in BOP’s western region over that time span, with over 2,500 of the total 6,601 staff receiving retention incentives in 2021. This region covers more remote states, such as areas of California, who also face the challenge of salary competition with California Department of Corrections. BOP’s investigation into whether the retention incentives are working in this region to curb attrition will aid in understanding if remote location is a driver of employee turnover, and if the funds are being provided to the region most in need. Figure 16: Actual incentives are given at a local level rather than regional. According to Figure 17 and 18, the top positions that have received retention incentives include Correctional Officers and Registered Nurses. In 2020, over a third of Correctional Officers received retention incentives. Retention bonuses have been utilized to keep staff, especially if the employee has unique qualifications or the need for their services makes it essential to retain. In FY19, retention incentives cost BOP approximately $22 million. BOP is on track to assess the outcomes of the staffing incentives it utilizes by April 2022. 34 EFTA00141402 Figure 17: These are the reflection of the top positions receiving incentives across all institutions Top 10 Positions with Highest Retention Incentive Amount Figure 18: These are the reflection of the top positions receiving the most incentive amount across all institutions ## Challenge: Negative media has affected officers’ sense of pride, both internally and externally. Public perception of BOP contributes to the challenges of retention. More senior staff stated that a job in corrections is no longer seen as one of pride, but rather an organization surrounded by embarrassment. Focus groups discussed the often-negative press that comes out about the Bureau, how it impacts their morale, and contributes to understaffing. One group mentioned the way Hollywood portrays prison life and how it affects outsiders’ view of their work. This outsider's idea of what working corrections is like misrepresents the true day-to-day work the role entails. Additionally, recent press regarding correctional facilities does not capture all the difficulties caused by the pandemic. COVID-19 has had a major impact on overtime and augmentation and placed a strain on staff, as shown 35 EFTA00141403 through many responses from the focus group when asked their “bugs” about working at BOP. With the implementation of COVID-19 housing units, officers needing to deliver meals, and inmate tensions rising from missing out on programs and visitations, many participants felt that their workload has doubled since the pandemic began. It is recommended that BOP consider taking time to combat negative media with positive staff stories internally and externally, which will likely aid in the recruiting and retaining of quality hires. BOP made strides in 2020 by completing a rebrand of their website and social media pages; the next step is to consider using these platforms to share and boost positive news regarding local institutions through Bureau-wide successes. Focus groups at one site visit were immensely proud of their Residential Drug Abuse Program (RDAP). An RDAP participant returned to that focus group’s facility to speak on the program, how it helped him, and how it has affected his life. $ ^{50} $ With 20 years of RDAP, stories such as these "RDAP here is better than any substance abuse program anywhere in the country." - Focus Group Participant could be highlighted, in addition to instances where staff are recognized for their achievements. For example, a staff member at FCI Edgefield was awarded the Attorney General’s Award for Excellence. $ ^{51} $ When considering retention for hard-to-fill positions, particularly those in the medical department, it is important to highlight their successes. At FCC Butner, the comparison to their medical availability versus that of a civilian hospital was shared with pride. One interviewee explained, “The FCC Butner hospital is incredible high performing because the tumor board meetings are faster, and patients get a better level of care than they might in the outside world in which they might not be able to afford it and doctors are pressed to see more patients.” Sharing inmate and staff success stories shows the public that BOP has a desire to recruit while underscoring organizational values. It is recommended that BOP build upon the positive momentum of their newly revamped website and social media presence to amplify positive messaging internally and externally, highlight positive societal impact, and focus on reestablishing Correctional Officers’ pride in their profession. 50 Department of Justice. https://reentry.ojp.gov/testimonials/rdap-lessons-success. 51 Bureau of Prisons. https://www.bop.gov/resources/news/20201109_ag_awards.jsp. 36 EFTA00141404 ## Recommendations ## Recommendations Overview The following recommendations fall on a matrix in order of priority by impact and urgency to address BOP’s greatest risks to staffing (Figure 19). Impact is defined as defined as the magnitude of the recommendation’s benefit for BOP employees. Urgency is the extent of the need that the recommendation addresses or fills. Effort is defined as the amount of time and resources that achieving the recommendation will probably take (e.g., high = 1 year+, medium = 6 months to 1 year, low = less than 6 months). Recommendations include an automated staffing tool to address challenges of the current staffing formula and associated staffing guidelines, improved succession planning to better anticipate retirements and staff exits, and finally, exploring the cost-benefit analysis of a compressed schedule. Figure 19 ## Recommendation #1: Develop Automated Staffing Tool to Establish a Reliable ## Source for Determining Staffing Levels The Deloitte team’s most urgent and impactful (Figure 19) recommendation is developing an automated staffing tool to determine staffing levels, weigh security trade-offs, and accommodate future staffing needs. BOP’s current methodology for assessing staffing requirements has not kept pace with the complexity and nuances of staffing BOP’s institutions. As stated previously in the Manage section, staffing guidelines are developed independently rather than using a standard process across the Bureau and do not account for key drivers of staffing requirements such accrued personal time off, military deployments, or its mission. Additionally, the metrics used to discuss staffing internally differ significantly from how the agency reports on staffing externally, resulting in 37 EFTA00141405 disjointed communication between internal and external stakeholders such as Congress who ultimately decide on BOP staffing needs. Finally, as the GAO reported, the methods for assessing staffing levels are inconsistent in the methodology and documentation, which hinders the ability for BOP to address staffing shortfalls proactively and successfully. $ ^{52} $ To address these challenges, it is recommended that BOP develop and implement an Automated Staffing Tool. The development of this tool would take a phased approach (Figure 20), beginning with a prioritization of the criteria that are most likely to influence staffing needs. Once this set of criteria has been defined, institutions will be categorized or grouped based upon criteria similarities (i.e., all 122 institutions will be grouped into 1 of 6 categories). Figure 20 In the second phase, a prototype of the tool will be built with the capability to compute the optimal staffing levels broken out by discipline. Leaders in the Central and Regional Offices will be able to review the optimal staffing levels of each institution based upon which category that institution falls under. This will streamline staffing guidance and provide a more holistic view of staffing requirements (currently, guidelines are written by each individual division and not coordinated across all disciplines). This phase will also provide data-driven justification for staffing requirements that can be utilized in communication with Congress, OPM, and other external stakeholders. 52 United States Government Accountability Report No. GAO-21-123. 2021. 38 EFTA00141406 Figure 21: Sample Wireframe for Version 1 of AST Figure 21.1: Sample Wireframe of Version 2 of AST The next version of the tool will capture both optimal staffing levels and real-time staffing levels. In this phase, Wardens and Institutional Executive Staff will be able to view the most pressing staffing needs they are facing as an institution. Furthermore, this tool will enable Wardens to work with HR to consider changing variables (such as an increase in inmate population or the addition of Congressionally mandated tasks) to more frequently adjust staffing requirements. Finally, Wardens will be able to make risk-informed decisions to adjust for changing needs on the ground. The tool’s scenario planning capability will enable a user to prioritize filling positions that have the greatest impact on safety and the ability to achieve mission requirements by connecting minimum staffing requirements to associated risk levels. The flexibility of an Automated Staffing Tool will allow for future iterations to incorporate expanded capabilities (e.g., projected workforce vacancy and turnover rates). Additionally, it would provide visibility of staffing levels to leadership from Central Office to local institutions. Although there are many benefits of implementing the Automated Staffing Tool, it is important to consider some of the impediments. If there is limited data available, it could significantly delay the process of development. Additionally, gathering new data in form of interviews and surveys would require time to facilitate and analyze. Another challenge would be the learning curve of both understanding how to use the tool and how to implement it to all institutions. Mitigating this would require understanding data gaps early on and determining minimum data needed to define the criteria. It would also require developing a robust project plan to ensure timeliness in distribution of surveys, as well as developing a change management plan to confirm stakeholder are kept informed every step of the way. Additionally, each version of the tool would begin with targeted rollouts. The following next steps are recommended to develop the Automated Staffing Tool. First, meet with stakeholders to propose and define criteria. Second, obtain relevant data for criteria. Next, conduct surveys and/or interviews to further validate criteria. ## Recommendation #2: Invest in Workforce Planning Capabilities to Improve ## Succession Planning Predictive workforce planning is the second most urgent and impactful (Figure 19) recommendation to improve BOP’s staffing process and curb understaffing. As mentioned in the Hiring section, current recruitment strategies make it difficult to hire clinical and mental health professionals. The prioritization of mandatory retirements to backfill first are also often based on the individual Warden and Regional Directors’ discretion. BOP needs a Bureau-wide operating procedure to enable individual institutions to predict and address staff turnover. More can be done to improve and better prepare for the loss of staff members when they arrive at their eligible or mandatory retirement date. To address these challenges, it is recommended that BOP take a proactive role in predicting staff retirements, exits, and promotions using historical data to conduct attrition modeling and forecasting. Data will help compare 39 EFTA00141407 forecasted staffing estimates with projected needs by identifying Bureau-wide eligible and mandatory retirements occurring in the next 5 years. Historical data can be used to forecast how many staff will have to be replaced to sustain adequate staffing levels. Understanding the average timeline for promotion will allow BOP to project how many positions will need to be backfilled annually. Once the historical data has been analyzed, BOP should integrate succession plan performance metrics into its “BOP Workforce Planning Information” Strategy plan of action to address gaps and clearly define owners. $ ^{53} $ Other agencies such as the Federal Bureau of Investigation (FBI) use data to do attrition modeling and forecasting to outline patterns of retirement, separation, and promotions. BOP can benefit from similar research, form stronger connections, and leverage on-the-ground resources by reaching out to Regional Directors and local personnel to determine if the data is aligning with their experience. A best practice that can aid BOP in its succession planning is consistent and frequent communication with its potential new hires through recruitment coordinators and the utilization of an automated system, providing them with updates on where they are in the hiring process or their upcoming role, and ensuring they feel valued by the organization. Additionally, it is recommended BOP consider virtual platforms for interviews and introductory assessments, especially in the face of the COVID-19 pandemic. Good succession planning also involves knowledge transfer. Due to the mandatory retirement age of BOP, there is often a wave of outgoing employees at one time and, with them, a wealth of knowledge. Through succession planning, a part of an outgoing employee’s experience can be recording that knowledge, whether in the form of a Standard Operating Procedure (SOP) or providing a training. Those retiring are experienced veteran officers whose knowledge can be leveraged and collected to add to best practices not only for their home institution, but for the organization at large. Currently there is a larger focus placed on mandatory retirements than on eligible retirements, due to the uncertain nature of eligible retirements. Utilizing data collection and predictive planning, the Bureau can better understand the percentage of officers who will separate from BOP upon their eligible retirement date based on historical trends. The following next steps are recommended to improve succession planning at BOP. First, it is recommended that BOP review its turnover data and typical promotion timelines to understand trends around career progression—analyzing how succession planning unfolds and the causes behind it. Second, BOP could benefit from researching best practices from similar enforcement agencies on predictive retirement modeling. Third, the Bureau could consider developing a strategic roadmap, with clear ownership of actions, to mitigate forecasted workforce gaps. ## Recommendation #3: Conduct Cost Benefit Analysis of 8-Hour vs. 12-Hour Shifts to ## Optimize Staff Allocation Conduct Cost Benefit Analysis of 8-Hour vs. 12-Hour Shifts is the third most urgent and impactful (Figure 19) which will provide quick assessment of differing shift schedule to uncover the most optimal schedule. Due to its existing FY 21 $7.7M budget, it is difficult for BOP to justify additional staffing resources to Congress. $^{54}$ It is recommended that BOP evaluate if Correctional Officers are scheduled at near perfect efficiency to help mitigate understaffing issues. As mentioned in the Manage Section, the current standard 8-hour shift schedule requires more shift transitions to ensure post coverage, which may result in increased mandatory OT and a reduction of days off. Other correctional facilities, such as state facilities, have utilized 12-hour shifts as a mitigation tool for understaffing. Currently, almost all BOP institutions use an 8-hour shift schedule to staff their facilities. BOP could benefit from outlining the costs and benefits of a compressed shift schedule to ensure officers are optimally 53 BOP Human Capital Operating Plan_FY21_Q4 10-2021 – BOP Internal Document. 2021. 54 Justice.gov. https://www.justice.gov/doj/page/file/1246666/download. 40 EFTA00141408 allocated. The compressed schedule should then be tested in a real-world setting at BOP institutions to examine both intended and unintended consequences. There are multiple benefits to a compressed work schedule. First, longer shifts translate to fewer shift handovers and scheduling complexities. 12-hour shifts only require two shift changes per day—which presents fewer opportunities for knowledge transfer gaps and a potential misunderstanding of security threats. Second, Correctional Officers in 12-hour shifts have more consecutive days off work to take care of their family and handle responsibilities outside of work. Correctional Officers working in a 12-hour shift environment would also encounter less mandatory overtime—providing them with a more predictable schedule. Due to these benefits, Correctional Officers may already be receptive to 12-hour shifts: field research participants indicated that they are already mandated to work 12-hour shifts in emergencies. One respondent said, “with a 12-hour shift, you have a team and you’re only competing with your team for time off rather than all of custody.” Another respondent stated that they were depressed by the 8-hour shift schedule and craved the compressed 12-hour shift schedule of their prior employment at a state correctional facility. Furthermore, a compressed work schedule would allow graveyard shift Correctional Officers more exposure with leadership and administrative staff who typically work during the day. Given the nature of correctional work, there are valid concerns around the adverse effects that a compressed schedule may result in such as increased complacency and reduced alertness after 8 hours on the job. BOP should evaluate the costs, benefits, and unintended consequences of a compressed schedule to better allocate their current staff. Successful implementation of a compressed schedule should incorporate union considerations and more senior Correctional Officers’ scheduling preferences. First, many individual institutions have augmentation agreements with local unions that must be considered. However, BOP leadership should find confidence in the fact that the current Master Agreement already permits any individual institution to implement a 12-hour schedule. The only limitation is that with a 12-hour schedule, staff are only available for an additional 4 hours of overtime or augmentation. As a result, there will be fewer mandatory overtime shifts since Correctional Officers cannot be asked to work 24 hours straight. Successful implementation will also include a robust change management plan (particularly for more senior Correctional Officers) to acknowledge potential scheduling concerns or preferences. The following next steps are recommended to improve staff scheduling and optimize resources. First, it is important to define the goals and objectives of the two schedule options, 8-hour and 12-hour shifts. Second, it is recommended the Bureau analyze how a compressed schedule will affect the budget and required resources. Next, identify potential intended and unintended consequences of each option in a real-world setting. ## Other Recommendations Based on field research, data analysis, and stakeholder engagement, additional recommendations for BOP’s consideration are below: - Invest in more data analysis that highlights hiring needs regarding the availability and quality of candidates at the local level to create more successful direct hire applications. - It is recommended that BOP re-invest in student loan repayment programs that are market-competitive and ensure consistent technical Subject Matter Expert input throughout the entire hiring process - Assess the impact of current supplemental onboarding programs to explore how standardization of the programs might drive an improved talent experience for new hires. - BOP can potentially combat hiring competition through data analysis to confirm their GS-levels and aligning wages are on par with similar positions at other law enforcement agencies. - Build upon the positive momentum of the newly revamped website and social media presence to amplify positive messaging internally and externally, highlight positive societal impact, and re-establish Correctional Officers’ pride in their profession. 41 EFTA00141409 ## Conclusion The challenges around attracting and retaining employees with interpersonal skills, empathy, and the ability to operate successfully in a corrections environment are not unique to the Bureau of Prisons. The Bureau’s ability to achieve its mission, however, relies heavily on mitigating the current staffing risks it faces. BOP has an opportunity to build upon its efforts to date by enacting the recommendations outlined in this report. Beyond responding to the February 2021 GAO report, these recommendations are designed to be reflective of BOP's vision for providing the most efficient, safe, and humane correctional services and programs in America. ## Appendix ## Appendix A: Field Research Themes After collecting data from interviews and focus groups, the data was organized into the following thematic categories: Career Development, Communication, Culture, Leadership, Staffing and Well-Being. Data was then further categorized into sub-themes: Augmentation, Benefits, COVID, EAP, Morale, Recruitment, Retention, Safety, Scheduling, and Training. Each theme and subtheme are defined below. The other section is for ideas discussed in the Current State Assessment that are not a theme or sub-theme in the field research. ## Themes: Career Development: The professional trajectory and advancement of an employee. Examples include responses about promotions, relocation, and further education. Communication: The interactions between employees across the Bureau of Prisons both horizontally and hierarchically. Examples include responses about standardization of information-sharing and daily dialogue amongst staff and leadership. Culture: The overall staff morale, job satisfaction and sense of community regarding working at the Bureau of Prisons. Examples include responses about staff events, comradery, and strengthening the public perception of Bureau of Prisons. Leadership: The guidance, management, and accountability across and between multiple levels of employees and managers. Examples include responses about Supervisors, Lieutenants, Wardens and staff at Regional Office and Central Office. Staffing: The distribution of employees and allocation of resources to institution posts, positions, and associated rosters. Examples include responses about understaffing and augmentation. Well-Being: The mental and physical state of wellness and feeling of safety and security at the individual level. Examples include responses about burn out. ## Appendix B: Focus Group Questions 1. Introduced the facilitators, overviewed the objective of the project, and covered the ground rules. 2. Asked the participants the icebreaker: “What is one thing you love about working at your institution, and what is one thing that bugs you?” 42 EFTA00141410 3. Instructed the group to take three voting dots and answer the question, “What are the biggest staffing challenges at your institution.” $ ^{55} $ The pre-populated answers are as follows: - Recruiting quality candidates - Lengthy hiring process - Ineffective onboarding and training - Competing with other jobs in the area - Inconsistent recognition for good work - Use of augmentation and/or mandatory overtime - Negative view of corrections - Leaders who don’t communicate well 4. Used one-word associations to quickly uncover recurring themes or outliers of EAP perception with the Bureau. 5. Prompted the group to write on three sticky notes the answer to the question, “If you were the Bureau of Prison’s Director for a year, and you had an unlimited budget, what would you do to improve these three topics: Culture, Staffing, and Well-Being?” 6. Thanked participants for their contributions. ## Appendix C: Competitive Job Landscape While the Bureau of Prisons has conducted analysis on how their Correctional Officers’ salaries compare to state-level averages, the analysis has not been sufficient to provide evidence that salary gaps are a key driver of recruitment challenges. $ ^{56} $ The graphics below illustrate the output of further analysis conducted using publicly available data from OPM’s FedScope tool and the Bureau of Labor Statistics occupational workforce datasets to compare federal Correctional Officer average salaries to Correctional Officers in other industries such as state and local. Figure 1 illustrates the average annual wage of federal and national entry level Correctional Officers by state. ## Initial Conclusion: Conclusions that can be drawn from this analysis are that if the lowest 10% earners are in comparison to the GS-6 level, then Federal employees on average have a higher starting salary. Alternatively, if the lowest 25% earners are in comparison to the GS-6 level, then high cost of living states such as California, New York. and Illinois have 55 Focus group participants could put more than one voting dot on an answer. 56 United States Government Accountability Report No. GAO-21-123. 2021. 43 EFTA00141411 on average a higher starting salary. Validation of either claim would require further analysis of detailed nonpublicly available salary data by state for Correctional Officers. Figure 1: $ _{2} $National wage is an aggregate of all industries that have Correctional Officers employed (state, local, federal, etc.). Graph is organized by BOP wage trend Figure 2 Data Source: Bureau of Labor Statistics (BLS) One Occupation by Multiple Industries (May 2020) Note: Health Care and Social Assistance: Includes psychiatric care and substance abuse hospitals; Other: includes Private Ownership and Administrative and Support (including Waste Management and Remediation Services. Figure 2 illustrates how federal (BOP) salaries on average compare to similar Correctional positions in alternate industries. The conclusions that can be drawn from the chart to the left is that on average Federal and Health Care Correctional Officers are the leading industries in terms of salary. What can be drawn from that chart to the right is that since state institutions on average have more employees, wages might reflect that. In the cases of high cost of living states, State Correctional Officers might get paid more than Federal Correctional Officers. ## Recommendation: Conduct Wage and GS-Level Analysis to Benchmark Compensation Given the scope of this report, it is recommended that BOP conduct further analysis to compare their Correctional Officers wages to similar occupations or its competitors. Analysis at this level could then be used as evidence that difficult to recruit locations should qualify for special salary rates. Additionally, it would be beneficial to assess current grade levels of positions to determine if it aligns appropriately. 44 EFTA00141412 ## Appendix D: Key Definitions BOP’s medical care includes four level classifications, to which each inmate and institution are assigned $^{57}$: Care Level 1 provides medical support for inmates younger than 70 years and in generally good health. The inmate may have limited medical needs that can be easily managed with annually or biannually evaluations. Examples of Care Level 1 inmate conditions include mild asthma and diet-controlled diabetes. Care Level 2 provides medical support to inmates requiring evaluations from monthly to biannually, whose medical and mental health conditions are manageable through regular appointments. Enhanced consultations may be required occasionally. Example conditions include medication-controlled diabetes and epilepsy. Care Level 3 provides medical support for inmate outpatients who have complex or chronic medical conditions. These inmates require frequent appointments to remain stable and prevent hospitalization. Inmates falling into this Care Level may need assistance with day-to-day activities, often provided by inmate companions. They may require periodic hospitalization. Example conditions include severe mental illness in remission on medication and end-stage liver disease. Care Level 4 includes inmates requiring services that can only be provided by a BOP Medical Referral Center (MRC), which can give enhanced care and services. The inmate may be severely impaired and required around the clock care or assistance. Examples of Care Level 4 inmate conditions include dialysis, stroke or head injury, and major surgical treatment. The Core Value Assessment is part of the Bureau’s pre-employment screening for potential new hires. The assessment is a measurement tool that encompasses BOP's core value competencies and behaviors. $ ^{58} $ Candidates are allotted 70 minutes to answer multiple choice and 2-part questions on either a tablet or on paper. The Human Resources Management Division (HRMD) coordinates personnel matters, including pay and leave administration, incentive awards, retirement, work life programs, background investigations, adverse and disciplinary actions, and performance evaluations. HRMD also manages employee development functions, directs recruitment efforts programs and administers the provisions of the collective bargaining agreement with representatives of the union at the national level. The Consolidated Staffing Unit (CSU) located in Grand Prairie, Texas, and National Recruitment Office (NRO) both fall within this Division. The Reentry Services Division (RSD) provides enhanced oversight and direction in the critical area of offender reentry, focusing on reentry programming and community resource transition. RSD is responsible for functions regarding contract residential reentry centers, residential reentry management field offices, federally sentenced juveniles, and both prison and community-based drug treatment. The divisions also work with other disciplines, agencies, and organizations to develop programs, resources, and activities designed to facilitate the successful reintegration of inmates into their communities upon release. The Correctional Programs Division (CPD) provides national policy direction and daily operational oversight of institution correctional services, as well as hold responsibility for inmate records, information gathering and case management. CPD coordinates the Victim and Witness Notification Program and the Inmate Financial Responsibility Program, manages inmates in the Federal Witness Security Program, coordinates the treaty transfer of inmates with other countries and manages the Bureau's contracts with private prisons. The Correctional Services Branch (CSB) falls under this division; CSB provides programs and services such as intake assessment, 57 Care Level Classification for Medical and Mental Health Conditions or Disabilities. https://www.bop.gov/resources/pdfs/care_level_classification_guide.pdf 58 Program Statement: Pre-employment. https://www.bop.gov/policy/progstat/3330.02.pdf 45 EFTA00141413 work-based education, and release planning. The National Institute of Corrections (NIC) provides training and technical assistance, information services, and policy and program development to correctional agencies. NIC awards funds to support program initiatives and provides guidance to correctional leaders and policymaking officials. Divisions work with regional offices, whose staff serve as liaisons to institutions in a designated region. Each region consists of a Regional Director. There are six regions within the organization: - MXR: Mid-Atlantic Region: Kentucky, Maryland, North Carolina, Tennessee, Virginia, West Virginia - **NCR:** North Central Region: Colorado, Illinois, Indiana, Kansas, Michigan, Minnesota, Missouri, South Dakota, Wisconsin - NER: Northeast Region: Connecticut, Massachusetts, New Hampshire, New Jersey, New York, Ohio, Pennsylvania - • SCR: South Central Region: Arkansas, Louisiana, Oklahoma, Texas - SER: Southeast Region: Alabama, Florida, Georgia, Mississippi, Puerto Rico, South Carolina - WXR: Western Region: Arizona, California, Hawaii, Oregon, Washington ## Central Office (CO) includes the following offices and divisions - Grand Prairie - Staff Training Academy - Management Specialty Training Center - Reentry Services Division - Program Review Division - Office of General Counsel - National Institute of Corrections - Information, Policy & Public Affairs Division - Health Services Division - Human Resource Management Division - Federal Prison Industries - Director's Office - Correctional Programs Division - Administration Division ## Appendix E: Time-On-Post (TOP) Formula The T.O.P. formula was created by BOP to replace the static number used in the past to understand how many days a Correctional Officer is available to work. T.O.P. annually calculates necessary staffing levels and determines how many days a staff member is available to work each year. The T.O.P. formula awaits approval until BOP responds and addresses GAO recommendations. 46 EFTA00141414 2 Calculate Review the daily assignments of each staff member for the past year. 3 Subtract Calculate the number of days each staff member was not assigned to their post (e.g., 165). Bureau-Wide Analysis Subtract that number from 364 days per year (e.g., 364-165 = 199). The final number is this staff member's available time to be on post. 4 Average Finally, average the T.O.P. for all employees of that specific institution for the review year (Average T.O.P. at HAX in 2019 was 179). Institution Specific Analysis Appendix F: Document Review
BOP Document Review
DocumentInsights
BOP Phase II Campaigns and AccomplishesReviewed BOP's marketing campaigns for recruitment and the successes behind it
BOP Year 1 Recruitment SummaryAssessed recruitment successes of various marketing efforts
Daily and Quarterly RostersReviewed the roster program to see how scheduling works at BOP institutions
BOP OT-Augmentation by locationTrended out overtime and augmentation usage by region for the past 5 years
Current Retention for Three Rivers, Edgefield, Butner, Allenwood, and PhiladelphiaAnalyzed list of employees receiving retention incentives based on institution
Recruitment or Relocation Incentive for Three Rivers, Edgefield, Butner, and PhiladelphiaAnalyzed list of incentives by amount and date being received broken out by employee. Data includes past 2 years
Staffing Levels for Three Rivers, Edgefield, Butner, Allenwood, and PhiladelphiaTrended out staffing levels by authorized, filled, and vacancies by pay period for both Correctional Officers and Medical staff. Used past 20 pay periods for this analysis.
Leave Hours for PhiladelphiaReviewed leave data broken out by sick, weather, annual, leave without pay, training, and accident for past 2 years
Turnover Rates 2020, 2019, 2018, 2017, 2016Reviewed average trend of turnover rates by location broken out by Correctional, non-Correctional, and all BOP staff
BOP Human Capital PlanReviewed BOPs strategic objectives to strengthen its workforce and efforts to date. Gives an overview of occupations deemed most mission critical
Hiring Process TimelineReviewed overview of the hiring process timeline including estimated length of time
Compensation PolicyReviewed various compensation for the appropriate position to retain and attract employees Including all the incentives offered and the different pay types such as Title 38 and student loan payment
BOP Staffing StudyStudy was conducted to analyze BOPs staffing methods. They found that custody staff all posts were appropriate to have, but concerns were about having a high inmate to staff ratio. While non-custody staff concerns were around high workloads
Staffing Guidelines – CPD, RSD, HSDReviewed BOP department's staffing requirements to increase understanding of overall staffing at BOP
Inmate-to-Co RatioReviewed inmate to Correctional Officer ratio broken out by institution
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Mandates 2021, 2021Reviewed list of assignments broken out by either employee accepted or mandated including shift and mandate type
BOP LV USAGE since 2019-01 thru 2021-20Reviewed leave trend for past 5 years to see what type of leave has increased
CST Manual Proposed CST PolicyReviewed the CST's new mission and objectives
BHS Insights and Utilization ReportProbed various datapoints around the EAP service providers' utilization and marketing efforts
Survey on the EAPExamined the strengths and weaknesses of EAP through the internal report
Semi-Annual Report on Staff Wellness 2021Analyzed EAP utilization and staff suicide data
BHS Trends and ObservationsExamined BHS trends in utilization and overall satisfaction
EAP PolicyStudied the purpose, scope, and program requirements for EAP
EAP Annual Training 2021Researched the challenges faced with correctional work and how to obtain EAP services
ICT Family Inclusion MemoOutlined family members involvement in ICT I.
EAP ICT Training 2021Examined EAP services and how the services can improve correctional work
Staff Safety and Support PolicyAddressed staff suicide and established a leadership driven model to support EAP and CST
Staff Suicides 1997 – PresentResearched all staff suicides since 1997
Suicide Prevention ProgramAnalyzed the purpose, scope, and objectives of the Suicide Prevention Program
Figure 3: Top 10 institutions with the highest usage of Absence without Leave (AWOL) 48