Open Recommendations

District leaders and the Antelope Valley Vet Center Director determine reasons for noncompliance with employees completing select trainings in the required time frame, ensure completion, and monitor compliance.

District leaders and the Antelope Valley, Phoenix, Santa Fe, and West Valley Vet Center Directors determine reasons for noncompliance with completion of an outreach plan with all required strategic components, ensure completion, and monitor compliance.

District leaders and the Santa Fe Vet Center Director determine reasons for noncompliance with having an annual risk and vulnerability assessment completed by VA police or local law enforcement, ensure completion, and monitor compliance.

District leaders and the Antelope Valley Vet Center Director determine reasons for noncompliance with monthly fire extinguisher inspections, ensure completion, and monitor compliance.

District leaders and the Antelope Valley and Santa Fe Vet Center Directors determine reasons for noncompliance with having an automated external defibrillator located on-site and ensure compliance with the requirement.

District leaders and the Phoenix and Santa Fe Vet Center Directors determine reasons for noncompliance with having an emergency and crisis plan that includes required components, ensure completion, and monitor compliance.

Establish formal controls that require documentation of the specific criteria used for initial STG
designations that include factors such as the severity and frequency of the group's criminal
activities, level of coordination, and affiliation rates at both an institution and national level. In
addition, the established controls should include requirements for periodic and well-documented
reassessments of designated STGs.

Establish formal criteria for activities that should trigger disruptive group consideration and
establish clear baseline information, data, and documentation requirements that consider practical
limitations such as housing limitations, for formal disruptive group proposals, initial certifications,
and [REDACTED.]

Establish formal controls that require the documentation of specific criteria used for initial
designations of management interest groups (MIGs) and subsequent [REDACTED] and
further ensure that the NGU considers these designated management interest groups with gang-affiliated
inmates as part of its routine intelligence assessments.

Implement a formal strategy for NGU oversight assignments to help ensure there are no gaps in
its coverage of the highest risk gangs and strengthen or establish protocols for information and
intelligence sharing between the NGU and other BOP entities that may be simultaneously
monitoring certain gangs and gang-affiliated inmates for other purposes.

Implement a well-documented, independent secondary review requirement for instances in
which a validation request is initiated by an NGU staff member instead of an SIS department.

Require the NGU to conduct an annual analysis that tracks population growth and other key
trends within its gang populations so that it can more effectively assign its resources to address the
most pressing threats. This recommendation can be implemented in concert with our earlier
recommendation that the BOP implement a formal strategy for NGU oversight assignments to
better ensure there are no gaps in its coverage of the highest risk gangs.

Implement and document within its policies, a quality control system for its validation process
that will ensure gang validations meet the validation criteria and are properly supported with
documentary evidence

Conduct an assessment of its internal controls in SENTRY and TRUINTEL to ensure that inmate
tags are applied consistently and purged when necessary, and that users of these important data
sources cannot alter inmate profiles without the proper permissions.

Ensure that existing disassociation files include all required information to support the actions
taken and implement mandatory, periodic quality control reviews for all disassociation files that
ensure all required information is obtained, analyzed, documented, and subjected to supervisory
review so that disassociation decisions are based on complete information and are made in a
consistent and objective manner, and that valuable gang-related intelligence is shared with partner
agencies.

Consider providing information about the disassociation process in inmate handbooks or
through other avenues available to all inmates without singling out any particular inmate or group
of inmates. The BOP should also consider whether it could improve the process for inmates to
make initial inquiries related to disassociation requests so that interested inmates could more safely
seek information.

Require the DSCC to consult with the NGU on all disassociated inmate housing assignments
made outside of the designated institutions with disassociated inmate housing and ensure the
consultations and justifications for the placements are well-documented.

Develop clear guidance for its gang-related intelligence gathering and information sharing
operations that include robust management oversight.

Develop a specialized, intelligence-focused training plan for its staff members who are tasked
with identifying and disseminating gang-related risks across BOP institutions and among external
law enforcement agencies.

Develop a formal work planning process that incorporatesthe selection criteria from the Handbook and requires thatACO teams clearly document the criteria used to selecteach agency in the inspection plans and reports.

Revise Standard Operating Procedure 2.2, section 12, toexplicitly require the inspection teams to document theanalyses they conduct to support their findings andrecommendations.

Develop a standard documentation template that ACOstaff can use to clearly document the deficienciesidentified during an inspection.

Migrate the existing program data from CARS to asupported in-house tool to better manage the data whilethe team completes the market research for a newprogram management information system.

Develop relevant internal controls (policies, procedures,and/or guidance) to ensure data entry is integrated intoACO’s daily workflow.

Complete the enterprise-wide data inventory.