BOP Could Further Enhance its COVID-19 Response by Capturing and Incorporating Lessons Learned (GAO-21-502)
Summary
A GAO report to congressional addressees, GAO-21-502, dated July 2021, on the Federal Bureau of Prisons (BOP) and COVID-19. It notes that BOP was responsible for about 129,000 federal inmates in BOP-managed facilities and employed more than 37,000 staff as of May 2021. GAO reports that BOP developed COVID-19 guidance, with input in part from the Centers for Disease Control and Prevention, and periodically updates it, but some BOP staff reported confusion in how to implement it. It also cites a Department of Justice Office of Inspector General survey of BOP staff. Its title states that BOP could further enhance its response by capturing and incorporating lessons learned.
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United States Government Accountability Office
Report to Congressional Addressees
BUREAU OF
July 2021
PRISONS
BOP Could Further
Enhance its COVID-
19 Response by
Capturing and
Incorporating Lessons
Learned
GAO-21-502
July 2021
BUREAU OF PRISONS
BOP Could Further Enhance its COVID-19 Response
by Capturing and Incorporating Lessons Learned
Highlights of GAO-21-502, a report to
congressional addressees
Why GAO Did This Study What GAO Found
BOP was responsible for the custody The Federal Bureau of Prisons (BOP) has developed COVID-19 guidance, with
and care of about 129,000 federal input in part from the Centers for Disease Control and Prevention, and
inmates in BOP-managed facilities, periodically updates this guidance, but some BOP staff reported to GAO
and employed more than 37,000 staff confusion in how to implement BOP’s guidance. In addition, the Department of
as of May 2021. Because of confined Justice’s Office of Inspector General surveyed BOP staff and reported that of the
spaces, the prison population is 28 percent of employees who responded, 59 percent of respondents thought
particularly vulnerable during infectious BOP’s guidance was not clear. Routinely evaluating how it communicates its
disease outbreaks, such as COVID-19. COVID-19 guidance to staff, and modifying its approach as needed based on
About $620 million has been
staff feedback, would help BOP ensure that staff can understand and effectively
appropriated to or designated by BOP
implement the protocols for COVID-19 and any future public health emergency.
for COVID-19- related efforts.
GAO was asked to review BOP’s
As of May 2021, BOP’s data showed that:
approach to responding to COVID-19. • BOP obligated nearly $63 million for personal protective equipment (PPE)—
This report addresses, among other such as masks, hand sanitizers, gloves and COVID-19 testing kits—for staff
objectives: (1) BOP’s development and and inmates.
updates of COVID-19 guidance; (2)
• 45,660 inmates had tested positive, and 237 inmates had died from the virus.
BOP’s provision of PPE, COVID-19
In addition, 6,972 staff members tested positive, with four deaths.
tests and vaccines, and infection and
fatality rates for inmates and staff; and • BOP fully vaccinated about 56 percent of all inmates in BOP-managed
(3) the impact of COVID-19 on inmates facilities (73,050 inmates) and about 50 percent of all staff (19,000 staff)
and staff, and the extent to which BOP COVID-19 has affected inmates and staff. For example, inmates faced reduced
has incorporated lessons learned into access to certain programs, services, visitors and facility spaces. For staff,
its response. quarantining procedures have resulted in reduced staff availability and increased
GAO reviewed BOP policies, data, and the use of overtime. BOP has processes, such as teleconferences among BOP
other documentation related to the officials and facilities inspections, to identify best practices and lessons learned
impact of COVID-19 and how BOP related to its COVID-19 response. However, BOP does not capture or share,
addressed it. GAO also conducted bureau-wide, the lessons and practices discussed at its teleconferences, or have
non-generalizable interviews of officials an approach for ensuring facilities apply them, as appropriate. Implementing
from five BOP facilities and one private approaches for such actions would help BOP ensure that the lessons and
facility operating under contract with practices it identifies reach all facilities that could benefit from them, and that
BOP, selected based on inmate facilities actively improve their COVID-19 response efforts.
infection rates and other factors.
A BOP Facility’s Housing Tents for Inmates in Quarantine and Isolation
What GAO Recommends
GAO is making three
recommendations that BOP evaluate
communication of COVID-19 guidance,
develop an approach to capture and
share best practices and lessons
learned; and develop an approach to
ensure facilities apply these practices
as appropriate. BOP concurred with all
three recommendations.
View GAO-21-502. For more information,
contact Gretta L. Goodwin at (202) 512-8777
or goodwing@gao.gov.
United States Government Accountability Office
Contents
Letter 1
Background 5
BOP Updated Guidance to Coordinate Its COVID-19 Response,
but Some Staff Reported Confusion about How to Implement It 10
Despite Some Challenges, BOP Has Distributed PPE,
Implemented Testing and Vaccine Policies, and Tracked
COVID-19 Outcomes 18
COVID-19 Has Impacted Conditions for Inmates and Staff, but
BOP Lacks an Approach to Ensure Facilities Capture and
Implement Lessons Learned 33
Conclusions 57
Recommendations for Executive Action 58
Agency Comments and Our Evaluation 58
Appendix I Objectives, Scope, and Methodology 64
Appendix II Release Timeline for Federal Bureau of Prisons’ (BOP)
COVID-19 Phased Action Plans, January-August 2020 70
Appendix III Impacts of the Suspension of Inmate Transfers
During the COVID-19 Pandemic 71
Appendix IV Additional Data on Infection Trends for Federal
Bureau of Prisons (BOP) Inmates 73
Appendix V Comparison of COVID-19 Positive Cases at Selected
Facilities to Cases in Surrounding Counties 82
Appendix VI Overview of Selected Facilities’ Response to COVID-19 84
Page i GAO-21-502 BOP Response to COVID-19
Appendix VII Comments from Federal Bureau of Prisons 92
Appendix VIII GAO Contact and Staff Acknowledgments 97
Related GAO Products 98
Table
Table 1: Federal Bureau of Prisons’ (BOP) COVID-19 Compliance
Review Team’s Most-Cited Areas of Concern during
September 2020 55
Figures
Figure 1: Map of Federal Bureau of Prisons’ (BOP) Six Regions 7
Figure 2: Examples of Federal Bureau of Prisons’ (BOP) COVID-
19 Response Partners 14
Figure 3: A National Guard Unit’s Hospital Space within a Federal
Bureau of Prisons Facility Established to Treat Inmates
with Advanced COVID-19 Cases 17
Figure 4: Monthly Types, Amounts, and Distribution Rates of
Personal Protective Equipment (PPE) the Federal Bureau
of Prisons (BOP) Provided to Facilities, (March 2020-
February 2021) 21
Figure 5: Federal Bureau of Prisons’ COVID-19 Enhanced
Screening Tool for Staff and Visitors 25
Figure 6: Federal Bureau of Prisons’ (BOP) Processes for COVID-
19 Data Collection and Dissemination by Facility Type 27
Figure 7: Total New COVID-19 Infection, Recovery, and Fatality
Rates for Inmates in Federal Bureau of Prisons-Managed
Facilities (March 2020-February 2021) 29
Figure 8: Total New COVID-19 Infections, Recoveries, and
Fatalities for Federal Bureau of Prisons Staff, March 2020
through February 2021 31
Figure 9: Examples of Federal Bureau of Prisons’ (BOP) Reported
Changes to Program Operations During COVID-19 35
Figure 10: A Federal Bureau of Prisons’ Telephone Booth with
Sanitization Instructions 37
Page ii GAO-21-502 BOP Response to COVID-19
Figure 11: A Federal Bureau of Prisons Facility’s Visitation Room
with Plexiglas Separation 38
Figure 12: Federal Bureau of Prisons’ (BOP) Quarantine and
Isolation Rates per 1,000 Inmates in BOP Custody,
March 2020—February 2021 39
Figure 13: A Federal Bureau of Prisons’ Facility’s Recreation Area
Repurposed for Medical Isolation 41
Figure 14: A Federal Bureau of Prisons Facility’s Installation of
Temporary Showers in Alternate Housing Areas for
Inmates in Quarantine and Isolation 42
Figure 15: Trends in the Bureau of Prisons’ (BOP) Transfer of
Inmates to Home Confinement Before and During the
COVID-19 Pandemic (March 2019 through February
2021) 44
Figure 16: Trends in the Bureau of Prisons’ (BOP) Transfer of
Inmates to Home Confinement under Different Authorities
(March 2020-February 2021) 47
Figure 17: Ethnic and Racial Comparison of inmates Transferred
to Home Confinement with Overall Federal Bureau of
Prisons (BOP) Population (February 2019-February
2021) 50
Figure 18: Steps for an Agency to Implement a Lessons Learned
Process 57
Figure 19: COVID-19 Infection Rates among Inmates Confined in
Federal Bureau of Prisons-Managed Facilities 73
Figure 20: COVID-19 Infection Rates among Inmates Confined in
Federal Bureau of Prisons-Managed Facilities by Race
(March 2020-February 2021) 74
Figure 21: COVID-19 Infection Rates among Inmates Confined in
Federal Bureau of Prisons-Managed Facilities by
Ethnicity (March 2020-February 2021) 75
Figure 22: COVID-19 Infection Rates among Inmates Confined in
Federal Bureau of Prisons-Managed Facilities by Age
(March 2020-February 2021) 76
Figure 23: Total New COVID-19 Infection, Recovery, and Fatality
Rates for Inmates in Private Prison Facilities Operating
Under Contract with the Federal Bureau of Prisons
(March 2020-February 2021) 77
Figure 24: Inmate COVID-19 Infection Rates at Private Prison
Facilities Operating Under Contract with the Federal
Bureau of Prisons (March 2020 – February 2021) 78
Page iii GAO-21-502 BOP Response to COVID-19
Figure 25: Inmate COVID-19 Infection Rates at Private Prison
Facilities Operating Under Contract with the Federal
Bureau of Prisons by Race (March 2020-February 2021) 79
Figure 26: Inmate COVID-19 Infection Rates at Private Prison
Facilities Operating Under Contract with Federal Bureau
of Prisons by Ethnicity (March 2020-February 2021) 80
Figure 27: Inmate COVID-19 Infection Rates at Private Prison
Facilities Operating Under Contract with Federal Bureau
of Prisons by Age (March 2020-February 2021) 81
Figure 28: Map of Federal Bureau of Prisons’ Facilities and
Surrounding Counties Selected for Virtual Site Visits 85
Abbreviations
BOP Federal Bureau of Prisons
CDC Centers for Disease Control and Prevention
COVID-19 Coronavirus Disease 2019
DHS Department of Homeland Security
DOJ Department of Justice
FCC Federal Correctional Complex
FCI Federal Correctional Institution
FEMA Federal Emergency Management Agency
FMC Federal Medical Center
HHS Department of Health and Human Services
OIG Office of the Inspector General
OPM Office of Personnel Management
PPE personal protective equipment
USMS United States Marshals Service
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Page iv GAO-21-502 BOP Response to COVID-19
Letter
441 G St. N.W.
Washington, DC 20548
July 29, 2021
Congressional Addressees
The Federal Bureau of Prisons (BOP), a component within the
Department of Justice (DOJ), was responsible for the custody and care of
approximately 129,000 inmates in BOP-managed facilities as of May
2021. The Bureau employs more than 37,000 staff to assist with this
effort. 1 Because inmates and the staff working in prison facilities function
in confined spaces and in close proximity to each other, the prison
population has been particularly vulnerable during infectious disease
outbreaks, such as the H1N1 (Swine Flu) pandemic that occurred in 2009
and the current Coronavirus Disease 2019 (COVID-19) pandemic.
Further, many inmates have underlying health conditions such as
diabetes and chronic heart disease—factors that further increase the risk
for severe illness from the virus that causes COVID-19.
As of May 2021, about $620 million from a combination of sources has
been either appropriated to or designated by BOP for COVID-19
response efforts. According to the National Academies of Sciences,
Engineering and Medicine as of August 2020 COVID-19 cumulative case
rates among incarcerated people were five times higher than in the
general population, and the rates among correctional staff were three
times higher. Additionally, the COVID-19-related death rate in the prison
population was three times higher than in the U.S. population, adjusting
for age and sex. 2
Questions have been raised about BOP’s COVID-19 response related to
the consistency of BOP’s policies; coordination with relevant agencies
1Other federal agencies are involved in the monitoring and safety of inmates, such as the
United States Marshals Service (USMS), which has custody of inmates before sentencing
and transports them after sentencing, and U.S. Probation and Pretrial Services, which
ensures home confinement locations are suitable and monitors inmates during home
confinement. BOP’s home confinement program allows eligible inmates serving a term of
imprisonment in federal prison and nearing release to transfer to a home or residence to
serve the remainder of their sentence. USMS is another component of DOJ. U.S.
Probation and Pretrial Services is housed within the Administrative Office of the U.S.
Courts, which is part of the Judicial Branch.
2National Academies of Sciences, Engineering and Medicine, Decarcerating Correctional
Facilities during COVID-19: Advancing Health, Equity, and Safety ; Washington, D.C.:
National Academies Press, 2020).
Page 1 GAO-21-502 BOP Response to COVID-19
during inmate transfers; COVID-19 testing for staff and inmates; provision
of personal protective equipment (PPE); and other topics. 3 We were
asked to assess how BOP protects inmates during the federal response
to the COVID-19 pandemic as well as other disasters and emergencies.
In addition, two pieces of legislation enacted in 2020 have included
provisions for us to assess the effect of the COVID-19 pandemic and
examine BOP’s disaster response, which includes its response to COVID-
19. 4 This report addresses: (1) the extent to which BOP developed and
updated guidance in response to COVID-19, and coordinated with
stakeholder agencies; (2) the status of BOP’s provision of PPE, tests, and
vaccines, and the COVID-19 infection and fatality rates for inmates and
staff; and (3) the overall impact of COVID-19 on inmates and staff, and
the extent to which BOP has incorporated lessons learned into its
ongoing response.
To address all three of our objectives we selected a non-generalizable
sample of five facilities from BOP’s total of 122, and one facility from the
total of 12 that BOP operated under contract with private providers. 5 We
then met with staff and officials at each location virtually from November
2020 through January 2021. We selected these facilities using criteria
3PPE refers to equipment worn to minimize hazards that cause serious workplace injuries
and illnesses.
4The source of the two mandates are S. Rept. No. 116–127 (2019) which accompanies
the Consolidated Appropriations Act, 2020, Pub. L. No. 116-93, 133 Stat. 2317; as well as
the CARES Act, Pub. L. No. 116–136, § 19010, 134 Stat. 281, 579-81 (2020). The
Congressional requesters for this work are Senator Tammy Duckworth, Senator Margaret
Hassan, and Representative Fred Keller. We are conducting related work (to be issued in
the fall of 2021), that will address BOP’s response to natural and manmade disasters
other than COVID-19, such as hurricanes and tornados. We regularly issue government-
wide reports on the federal response to COVID-19. For the latest report, see GAO,
COVID-19: Continued Attention Needed to Improve Federal Preparedness, Response,
and Service Delivery and Enhance Program Integrity, GAO-21-551 (Washington, D.C.:
July 15, 2021). Our next government-wide report will be issued in October 2021 and will
be available on GAO’s website at https://www.gao.gov/coronavirus. For a list of our
previous work in this area, see the Related GAO Products page at the end of this report.
5The six facilities we selected were: Lexington Federal Medical Center; Florence Federal
Correctional Complex; Seagoville Federal Correctional Institution; Elkton Federal
Correctional Institution; Yazoo City Federal Correctional Complex; and Great Plains
Correctional Institution (which operated under contract with BOP). About 4 months after
our interview with Great Plains Correctional Institution, BOP’s contract with the facility
expired on May 31, 2021. Pursuant to Executive Order 14006, 86 Fed. Reg. 7483 (Jan.
26, 2021), the Attorney General was directed not to renew DOJ contracts with privately
operated criminal detention facilities, as consistent with applicable law. As a result, BOP
did not renew its contract and federal inmates are no longer being housed at that facility.
Page 2 GAO-21-502 BOP Response to COVID-19
including geographic dispersion, a mix of facility COVID-19 infection
rates, a mix of facility security levels, and the presence of a medical
center or Federal Prison Industries factory at the facility. 6 We also
requested and analyzed documents, such as facility-specific plans and
memoranda on BOP’s COVID-19 response, as well as photographs
representing various aspects of each facility’s response to the pandemic.
While results from our interviews with officials from these facilities cannot
be generalized to all BOP facilities or all private facilities, they provide
insight into BOP’s planning and response to the pandemic.
In addition to the above, we interviewed BOP headquarters officials from
several divisions, including Correctional Programs, Health Services,
Program Review, Reentry Services, and Administration about each of our
objectives. Further, we interviewed four advocacy groups representing
inmates and former inmates, to obtain their perspectives on BOP’s
COVID-19 response, as well as the impact of the pandemic on inmates
and staff. 7
To address our first objective, we reviewed BOP policies and guidance for
pandemic response, including BOP’s COVID-19 Pandemic Plan, Phased
Action Plans, and facility-specific memoranda for pandemic response. We
reviewed these plans and interviewed officials to understand how BOP
modified its pandemic response based on leading guidance on COVID-19
response that others such as the Centers for Disease Control and
Prevention (CDC) have issued. In addition, we assessed BOP’s guidance
against internal control standards related to internal communication. 8 We
also reviewed agreements BOP has with stakeholder agencies, such as
the United States Marshals Service (USMS), on responding to the
COVID-19 pandemic. We interviewed officials from our six selected
6Federal Prison Industries is a government corporation authorized by law. See 18 U.S.C.
§ 4121. It operates under the trade name UNICOR and provides employment and training
for inmates through production and sales of its products using factories at BOP facilities.
For more information, see GAO, Federal Prison Industries: Actions Needed to Evaluate
Program Effectiveness, GAO-20-505, (Washington, D.C.: July 29, 2020).
7The four advocacy groups were JustLeadershipUSA, the University of California, Los
Angeles Behind Bars Data Project, Justice Roundtable, and the American Civil Liberties
Union. We selected these groups because of their advocacy for inmate safety and well-
being concerns and the COVID-19 data analysis and research they conducted.
8GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept 10, 2014).
Page 3 GAO-21-502 BOP Response to COVID-19
facilities, as well as officials from these stakeholder agencies, to
determine how they coordinate on COVID-19 response.
To address our second objective, we reviewed BOP policies and
analyzed BOP data on the provision of PPE, COVID-19 tests, and
vaccines from March 2020 through February 2021. We selected this
period because it marks the beginning of COVID-19 infection in BOP
prisons and an appropriate cutoff time that allowed us to fully analyze the
data to include in our issued report. Specifically, we reviewed BOP data
on PPE spending and distribution. Additionally, we analyzed BOP data on
inmate and staff COVID-19 infection, recovery, and deaths for the same
period. To assess the reliability of these data, we checked them for
obvious errors, omissions, and outliers and interviewed BOP officials
responsible for collecting and maintaining the data. We determined that
the data were sufficiently reliable for determining inmate infection,
recovery, and death rates in BOP-managed and private prisons. We
determined that the data were not reliable for determining infection,
recovery, and death rates for BOP staff predominantly because BOP
does not test its staff for COVID-19. As such, we do not report the rates of
staff infection, recovery, and deaths in this report and instead report the
counts as recorded by BOP.
To address our third objective, we reviewed the results of COVID-19
compliance inspections conducted by the DOJ Office of Inspector
General (OIG) throughout 2020. 9 We also interviewed officials from two of
the facilities the OIG inspected, as well as officials from several BOP
divisions, including Health Services and Correctional Programs.
To determine the extent to which BOP has incorporated lessons learned
into its ongoing response, we analyzed BOP’s mechanisms for capturing
lessons learned, such as the Program Review Division’s COVID-19
Compliance Team inspections of BOP facilities. These inspections took
9In response to COVID-19, DOJ OIG initiated a series of remote inspections of BOP
facilities, including BOP-managed institutions, contract prisons, and Residential Reentry
Centers. These inspections sought to determine whether these institutions were
complying with guidance related to the pandemic, including CDC guidelines, DOJ policy
and guidance, and BOP policy. These inspection reports can be viewed at
https://oig.justice.gov/reports/component/bop.
Page 4 GAO-21-502 BOP Response to COVID-19
place from August through September 2020. 10 Further, we compared
BOP’s mechanisms to the steps we have previously identified for
agencies to consider in implementing a lessons learned process. 11 For
the six facilities in our non-generalizable sample, we solicited
management’s views on the impact of the pandemic on inmates and staff,
including challenges officials at these facilities faced in their response to
the pandemic and any lessons learned that were identified and applied.
Additionally, to provide context for BOP’s approach, we interviewed
representatives of the Correctional Leaders Association—the organizing
body of state departments of corrections—to obtain perspectives on state
prisons’ response to COVID-19 and the organization’s practices for
capturing and sharing lessons learned.
For further information on our objectives, scope, and methodology, see
appendix I.
We conducted this performance audit from April 2020 to July 2021 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe the
evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Background
Roles and Responsibilities BOP Central Office serves as BOP’s headquarters and provides oversight
of BOP operations and program areas. Within the Central Office are
several divisions that develop national programs and provide functional
support to the entire bureau. The Program Review Division is responsible
for assessing BOP programs to ensure they are managed and operated
effectively. BOP’s Correctional Programs Division provides policy
direction and daily operational oversight of facility correctional services.
The Health Services Division is responsible for health care delivery,
10BOP’s Program Review Division COVID Compliance Review Team periodically
conducts unannounced inspections of its facilities to monitor response and develop further
mitigation strategies to the COVID pandemic.
11GAO, Federal Real Property Security: Interagency Security Committee Should
Implement a Lessons-Learned Process, GAO-12-901 (Washington, D.C.: September 10,
2012).
Page 5 GAO-21-502 BOP Response to COVID-19
infectious disease management, and medical designations of inmates in
BOP facilities.
Within the Correctional Programs Division, the Office of Emergency
Preparedness coordinates BOP’s national emergency response
capability. The Office of Emergency Preparedness houses the bureau’s
Command Center, which is part of a broader Incident Command System
to coordinate with other agencies during emergency or disaster response
events. BOP implemented the Incident Command System at the start of
the COVID-19 pandemic as the mechanism for coordinating its response
to the pandemic. The Incident Command System is to provide a
standardized approach to the command, control, and coordination of
emergency response as well as a common chain-of-command within
which responders from multiple entities can operate. As this was a public
health emergency, BOP’s Health Services Division and the BOP Medical
Director played a principle role in leading the response. The Command
Center, within the Office of Emergency Preparedness, oversees the
Command Centers at BOP’s regional offices, which in turn oversee the
Command Centers at the correctional facilities. Each of the Command
Centers are staffed by section chiefs and incident commanders who
provide oversight at the applicable level. The primary role of an Incident
Command System is to establish planning and management functions for
responding partners to work in a coordinated and systematic approach. In
the case of the response to the COVID Pandemic, it includes consulting
with the CDC on a variety of topics such as developing guidance, and
coordinating with other external entities, such as departments of public
health who are assisting with response efforts.
BOP also has six regional offices covering the Mid-Atlantic, North Central,
Northeast, South Central, Southeast, and Western regions of the United
States (see figure 1). These offices oversee the operations of the 122
federal facilities within their respective geographic regions of the country.
BOP facilities are managed by a warden and other officials, including an
associate warden and health services administrator, who provide overall
direction and, in part, administer the facility’s planning and policies,
including policies on health and safety.
Page 6 GAO-21-502 BOP Response to COVID-19
Figure 1: Map of Federal Bureau of Prisons’ (BOP) Six Regions
While BOP manages 122 federal facilities, federal inmates may also be
held in private prisons or in Residential Reentry Centers. BOP houses
about 84 percent of federal inmates in facilities it operates. Another 9
percent of these inmates are finishing their sentences in Residential
Reentry Centers or on home confinement. 12 In Residential Reentry
Centers, inmates are housed outside of a prison environment and are
required to work or be actively seeking a job. The remaining 7 percent of
12Inmates placed in home confinement are to be monitored and are required to remain at
home when not working or participating in programming and other approved activities.
Page 7 GAO-21-502 BOP Response to COVID-19
inmates who are not in BOP-managed facilities or Residential Reentry
Centers are held in privately-operated prisons. Privately-operated secure
contract facilities are low security, and primarily house non-U.S. citizens
convicted of crimes while in this country.
Other agencies also work closely with BOP as stakeholders for inmate
and detainee care. This includes USMS, which is responsible for the
custody of individuals from the time of their arrest by a marshal or their
remand to a marshal by a court, until conviction and commitment to
BOP’s custody. USMS is also responsible for coordinating inmate
transportation anytime movement is required post-incarceration, such as
for inmate transfers among BOP facilities. 13 Additionally, officials told us
that through an interagency, reimbursable agreement with BOP, U.S.
Probation and Pretrial Services provides pre-release investigation
services. This includes inspecting the homes of inmates who plan to
reside outside of the sentencing jurisdiction, to ensure they provide a
suitable environment for home confinement. It also provides supervision
and services such as drug testing to BOP inmates already placed on
home confinement.
Further, BOP works closely with the CDC, a component of the U.S.
Department of Health and Human Services (HHS). As the nation’s health
protection agency, the CDC is responsible for providing health information
and guidance aimed at protecting the nation from public health threats
such as the COVID-19 pandemic. BOP and the CDC have coordinated in
various ways, as discussed later in this report.
Home Confinement BOP’s home confinement program allows eligible inmates in federal
prison and nearing release to transfer to a home or residence to serve the
remainder of their sentence. BOP has statutory authority to place inmates
in home confinement for the concluding portion of their sentence,
amounting to either 10 percent of their prison term or 6 months,
whichever is shorter. 14 In response to the COVID-19 pandemic, the
CARES Act also authorized the BOP Director to lengthen the maximum
13See 28 C.F.R. § 0.111(k).
1418 U.S.C. § 3624(c)(2).
Page 8 GAO-21-502 BOP Response to COVID-19
amount of time to place federal inmates on home confinement. 15 This
authorization was granted only if the Attorney General finds that
emergency conditions will materially affect the functioning of the bureau
during the covered emergency period. 16 The First Step Act of 2018
reauthorized and expanded a pilot program—the Elderly Offender Home
Detention Program—that originated in the Second Chance Act to place
elderly and terminally ill inmates in home confinement. 17
CDC Guidelines As the federal government’s public health agency, CDC creates guidance
for the public and various groups, such as businesses, with information
on public health threats and what actions should be taken to mitigate
these threats. In the case of COVID-19, the CDC has promulgated and
updated science-based guidance throughout the pandemic on infection
control practices including mask wearing and social distancing, as well as
on testing protocols, quarantine duration, and vaccinations. This guidance
is used by agencies such as BOP to inform their agency-specific
guidance on mitigating the spread of COVID-19 in BOP facilities.
15Pub. L. No. 116-136, § 12003, 134 Stat. 281, 515-17. In addition, on January 15, 2021,
DOJ Office of Legal Counsel issued an opinion indicating that the CARES Act authorizes
the Director of BOP to place prisoners in home confinement only during the Act’s covered
emergency period and when the Attorney General finds that the emergency conditions are
materially affecting BOP’s functioning. However, should that period end, or should the
Attorney General revoke the finding, the bureau would be required to recall the prisoners
to correctional facilities unless they have completed their sentences or they are otherwise
eligible for home confinement under 18 U.S.C. § 3624(c)(2), which provides the authority
to place a prisoner in home confinement for the shorter of 10 percent of the prisoner’s
term of imprisonment, or 6 months.
16Pub. L. No. 116-136, § 12003, 134 Stat. 281, 515-17. (The “covered emergency period”
means the period beginning on the date on which the President declared a national
emergency under the National Emergencies Act (50 U.S.C. 1601 et seq.) with respect to
COVID-19 and ending on the date that is 30 days after the date on which the national
emergency declaration terminates).
17Pub. L. No. 115-391, §§ 602, 603 132 Stat. 5194, 5238, 5238-41. See 34 U.S.C. §
60541(g) (related to the elderly and family reunification for certain nonviolent offenders
pilot program). See 18 U.S.C. § 3582(d) (related to the compassionate release of an
inmate diagnosed with a terminal illness).
Page 9 GAO-21-502 BOP Response to COVID-19
In responding to COVID-19, BOP developed and disseminated a number
BOP Updated of guidance documents, but some staff reported confusion about how to
Guidance to implement such guidance. In the following two sections, we discuss the
strengths and limitations to BOP’s overall approach to COVID-19 policy
Coordinate Its development and implementation as well as BOP’s coordination with
COVID-19 Response, stakeholders such as the CDC and local health departments.
but Some Staff
Reported Confusion
about How to
Implement It
BOP Developed and BOP has developed its guidance for responding to the pandemic in the
Periodically Updated form of Phased Action Plans as well as a Modified Operations Plan,
which it updates periodically to incorporate evolving guidance from the
Pandemic Response
CDC. In addition, BOP developed its COVID-19 Pandemic Plan, which
Guidance but Some Staff includes 11 modules on topics such as infection prevention and control
Reported Confusion on measures, PPE, and medical isolation and quarantine. However, some
How to Implement It BOP staff expressed confusion about how to implement it, and BOP has
not evaluated its communication of its pandemic-related guidance.
BOP had a Pandemic Influenza contingency plan in place before the
onset of COVID-19, which it used to help develop its response to the
pandemic, beginning January 31, 2020. Specifically, BOP supplemented
the existing Pandemic Influenza plan to address the unique challenges
the COVID-19 pandemic presented, such as the need for social
distancing and widespread use of face coverings, which made it more
difficult to manage than an influenza pandemic. BOP also supplemented
the plan with additional guidance from the BOP Medical Director
pertaining to the identification of and screening for COVID-19. 18
Additionally, on February 29, 2020, the Bureau issued its Phase One
Action Plan. This plan was the first in BOP’s multi-phased planning
approach for responding to the COVID-19 pandemic. The intent of the
approach was to modify operations to adapt to evolving guidance from
18Additionally, BOP officials told us they updated the Pandemic Influenza contingency
plan to include more detail on pandemic response topics. For example, the updated
COVID-19 Pandemic Plan has detailed vaccine guidance; isolation and quarantine
requirements specific to COVID-19; additional PPE guidance for staff for interacting with
isolated or quarantined inmates; and more information on COVID-19 testing procedures,
such as what test to use and when to consider a test.
Page 10 GAO-21-502 BOP Response to COVID-19
the CDC and others in direct response to the changing conditions of the
pandemic. As of May 2021, BOP has issued nine phases of its action
plan—see appendix II for a timeline of the phases’ issuance as well as a
summary of each phase. According to BOP officials, the BOP Office of
the Medical Director and the Health Services Division coordinate regularly
with the CDC to modify the action plans to incorporate the most current
guidance and to inform the CDC of the Bureau’s response to COVID-19.
In addition to the Phased Action Plans, the BOP Central Office provides
COVID-19 guidance to BOP regional offices through weekly
teleconference and regular memoranda, according to BOP officials. One
regional office official we spoke with stated that his office works to ensure
that it distributes the guidance it receives from the BOP Central Office to
institutions in his region. Additionally, officials from one facility stated the
BOP Central Office also provided daily updates to their facility on
implementing the Phased Action Plans. Further, according to BOP
officials, the BOP Director also emphasized this guidance and the
updates through Director’s messages and national video messages. Staff
were alerted to these updates through broadcast emails to their individual
mailboxes.
BOP facilities are responsible for disseminating the COVID-19 guidance
they receive from their regional office and from the BOP Central Office to
their facility staff and inmates. Officials from the six facilities we selected
said they disseminate guidance to staff and inmates in a variety of ways,
including using the internal inmate email system, town hall-style meetings
with appropriate social distancing, and regular day-to-day interactions. In
addition, wardens at each facility can issue procedural memoranda to
guide their facility-specific response to the pandemic and operationalize
BOP guidance and are generally granted broad discretion to respond to
emergencies. For example, the warden of one facility we selected shared
a list of COVID-19 prevention strategies his facility developed, which
includes general hygiene, face covering, and sanitation practices that the
inmates must sign to indicate they will follow. The warden of another
facility developed guidance specifically on quarantining and isolating
inmates who have been exposed to or tested positive for COVID-19.
While BOP has developed and updated its guidance for responding to the
pandemic, some BOP staff reported instances of confusion about how to
implement some of these updates. For example, early on in the
pandemic, the DOJ OIG surveyed all BOP employees in April 2020, in
part to gather anonymous staff perspectives on the adequacy of the
guidance they received from BOP about exposure to COVID-19. Of the
Page 11 GAO-21-502 BOP Response to COVID-19
28 percent of employees who responded, 59 percent of respondents
thought the guidance was not clear and 53 percent thought the guidance
was not timely. 19 Further, during our review some BOP union officials we
interviewed provided examples of areas where they believed BOP
guidance was confusing at certain points during the pandemic. These
areas included the use of PPE and whether some staff could access
overtime pay.
According to Standards for Internal Controls in the Federal Government,
management should select appropriate methods to communicate
internally. Additionally, management should consider a variety of factors
in selecting an appropriate method of communication such as audience,
nature of information, availability, cost, and legal or regulatory
requirements. In addition, based on consideration of the factors,
management should select appropriate methods of communication, and
periodically evaluate the entity’s methods for communication so the
organization has the appropriate tools to communicate quality information
throughout the entity on a timely basis.
BOP officials told us they believe they have been responsive to the
evolving situation with COVID-19 and have issued updated guidance, as
appropriate. Further, BOP officials told us that they have provided
opportunities to clarify BOP guidance with staff, such as by establishing a
COVID-19 questions email account and having regular ongoing meetings
with staff to communicate and clarify guidance and answer questions.
While these efforts provide opportunities for BOP to address staff
questions on the substance of its guidance, they do not constitute an
evaluation of how BOP is communicating its guidance. In addition,
particularly since there have been multiple updates to the guidance over
time, such evaluation efforts could include routinely checking with staff,
not only to clarify any questions on the guidance, which BOP is currently
doing, but also to understand if its communication methods have been
effective. Such efforts would enhance BOP’s ability to ensure it
communicates quality information in the most timely and effective way.
Further, the value of the staff feedback gained from such an evaluation is
not limited to COVID-19, as such information could be used to inform
19Specifically, the OIG invited 38,651 total employees to take the survey and received
10,735 responses, a 28 percent response rate. The scope and methodology of each
inspection, including a description of the survey, is located in each of the OIG’s individual
Pandemic Response Reports for remote inspections conducted with selected BOP
facilities (https://oig.justice.gov/reports/pandemic).Given the low response rate, the results
of this survey are not generalizable to the entire BOP staff population.
Page 12 GAO-21-502 BOP Response to COVID-19
BOP’s future approaches to communicating fast-evolving guidance in
future public health emergencies.
BOP Coordinated with BOP has coordinated with federal, state, and local partners by leveraging
Partners in Guidance their expertise to develop guidance to support BOP’s ongoing response to
the COVID-19 pandemic. For example, BOP facilities may enter into a
Development and
memorandum of agreement, and forge working relationships, with local
Pandemic Response partners, and, for some facilities, with federal partners. See figure 2 for
examples of federal, state, and local entities BOP coordinates with in
response to the pandemic.
Page 13 GAO-21-502 BOP Response to COVID-19
Figure 2: Examples of Federal Bureau of Prisons’ (BOP) COVID-19 Response Partners
To aid in the development of its guidance, BOP officials said it consults
with federal, state, and local partners. For example, BOP officials from
one regional office said institutions are constantly working with local,
Page 14 GAO-21-502 BOP Response to COVID-19
state, and federal health authorities to ensure guidance is implemented in
facilities. Some local BOP facilities and regional offices consult subject
matter experts, such as Regional Infection Prevention and Control
Officers, who participate in reviewing the COVID-19 Pandemic Plan and
guiding the individual facilities in implementing it.
Coordination in developing guidance. BOP coordinates with other
federal agencies, such as the CDC and Office of Personnel Management
(OPM), primarily to incorporate guidance, directives, and best practices
for responding to the pandemic. 20 Specifically, BOP coordinates with the
CDC to assist with developing guidance specific to the unique nature of
correctional environments. For example, BOP’s COVID-19 Phase Two
Action Plan states that a bureau task force was working in conjunction
with subject matter experts in the CDC. The plan also states that BOP
implemented this phase of its action plan after coordinating with DOJ and
the White House. Further, according to BOP officials, some CDC and
U.S. Public Health Service personnel were temporarily assigned to BOP
to assist with coordination. 21 BOP also collaborated with the HHS–
Department of Defense (DOD) COVID-19 Countermeasures Acceleration
Group to prepare the Bureau for administering the COVID-19 vaccine. 22
Further, according to officials, BOP entered into an agreement with CDC
to receive a direct allocation of vaccines. Additionally, BOP institutions
have collaborated directly with, and received guidance from, the CDC
regarding best practices to mitigate the spread of COVID-19 within
correctional institutions.
Coordination with state and local agencies. BOP facilities coordinated
with first responders and local law enforcement agencies to provide
guidance on how BOP is to coordinate with emergency response
agencies at the local and state level for COVID-19 response. For
20OPM serves as the chief human resources agency and personnel policy manager for
the federal government. OPM provides human resources leadership and support to
federal agencies. BOP followed OPM guidance in establishing its staff leave protocols
during the pandemic. According to BOP, the CDC published the Guidance on
Management of Coronavirus Disease 2019 (COVID-19) in Correctional and Detention
Facilities on March 23, 2020 as a result of the collaborative efforts between the two
agencies. The CDC also published a subsequent update on July 14, 2020 with BOP input.
21The U.S. Public Health Service is an agency under HHS that provides public health
services to underserved and vulnerable populations.
22Efforts to support vaccine development, manufacturing, and distribution to states and
other jurisdictions have been led at the federal level by a partnership between the DOD
and HHS. This partnership was formerly known as Operation Warp Speed, but as of May
2021 is called the HHS-DOD COVID-19 Countermeasures Acceleration Group.
Page 15 GAO-21-502 BOP Response to COVID-19
example, officials from BOP’s Health Services Division stated that BOP
coordinates with local health departments in areas highly impacted by
COVID-19 to ensure safe release of inmates into the community. Officials
from a BOP regional office explained that infectious disease coordinators
in each of the region’s institutions have preexisting relationships with their
respective local county health offices because of long-standing
requirements for facilities to report incidences of infectious diseases, such
as tuberculosis, scabies, and sexually transmitted diseases to the county
health department. This preexisting relationship facilitated coordination
with the county health offices when the COVID-19 pandemic occurred.
Coordination to identify community resources. Officials from one of
the six facilities we selected stated that they also coordinated with the
Federal Emergency Management Agency (FEMA), the National Guard,
and the Army Corps of Engineers to identify available community
resources for responding to the pandemic. For example, officials from the
BOP facility stated that their local health department established a 12-
hospital dispatch line for the facility to obtain information about available
hospital bed space. Additionally, the state’s National Guard unit set up a
center at this same facility to treat inmates with advanced COVID-19
cases, as illustrated in figure 3.
Page 16 GAO-21-502 BOP Response to COVID-19
Figure 3: A National Guard Unit’s Hospital Space within a Federal Bureau of Prisons Facility Established to Treat Inmates with
Advanced COVID-19 Cases
Coordination with local hospitals. According to officials, facilities
routinely coordinate with local hospitals on inmate care. This coordination
is critical for BOP facilities that do not have medical centers or run out of
space to accommodate inmates who become ill and must therefore
transfer the sick inmates to local hospitals. Prior to the pandemic, BOP
Page 17 GAO-21-502 BOP Response to COVID-19
reported that it transferred approximately 7,100 inmates monthly to local
hospitals located outside of its facilities in May 2019 and slightly fewer in
the remaining months of 2019. Similarly, BOP relied on these local
hospitals when the pandemic started in March 2020 to care for inmates
who contracted the virus and who could not be treated within BOP’s
medical centers or infirmaries. In 2020, even after COVID-19-related
hospitalizations were included, total hospital trips decreased due to the
COVID-19 precautions in place in the community, such as elective
medical procedures being postponed. Further, according to BOP union
officials, BOP staffing limitations during the pandemic put additional
burdens on staff in transporting inmates to local hospitals. This may be a
reason why BOP reduced transfers of inmates to hospitals because of the
number of staff needed to transfer an inmate to a local hospital.
Coordination on inmate transfers. BOP coordinated with USMS during
the pandemic to minimize any possible transmission of COVID-19 that
could take place during inmate transfers to and from BOP facilities. For
example, USMS officials told us that the USMS Prisoner Operations
Division Medical Director had numerous calls, email exchanges, and at
least one in-person meeting with BOP’s Medical Director, among other
BOP senior leadership, early in the pandemic. According to USMS
officials, during these interactions, BOP shared its inmate intake,
quarantine, testing, and transfer protocols with USMS. To further
minimize the spread of COVID-19, on March 13, 2020, BOP suspended
inmate transfers until the suspension was lifted in July 2020. 23 For more
information on the impacts of the suspension of inmate transfers, see
appendix III.
In responding to COVID-19, BOP has distributed PPE to its facilities,
Despite Some supplementing the individual facilities’ own PPE sources. In addition, BOP
Challenges, BOP Has developed policies for testing inmates and making testing available for
staff, and for distributing the vaccine to BOP inmates and staff. BOP has
Distributed PPE, also tracked and reported the numbers of COVID-19 infections,
Implemented Testing recoveries, and fatalities among inmates in BOP-managed and private
facilities, and among staff in BOP-managed facilities. In the following five
and Vaccine Policies, sections, we discuss the challenges BOP has faced and the approaches
and Tracked COVID- BOP has used to distribute PPE, collect and report COVID-19 data, and
test and vaccinate inmates and staff.
19 Outcomes
23During the suspension of transfers, some transfers still occurred, but on a limited basis.
Page 18 GAO-21-502 BOP Response to COVID-19
Despite Nationwide PPE According to Health Services Division officials, BOP experienced
Shortages Early in the challenges with PPE distribution in the first months of the pandemic,
including reduced availability of certain PPE items and equipment due to
Pandemic, BOP
national shortages. CDC’s guidance for correctional facilities
Developed a System to recommends that all staff use PPE when they have contact with people
Distribute PPE to Facilities with confirmed COVID-19 or with infectious materials. 24
Federal Bureau of Prisons (BOP) Union officials representing three out of the five selected BOP-managed
Personal Protective Equipment (PPE) facilities told us that their facilities did not have sufficient access to a
Categories
proper amount or quality of PPE early in the pandemic. For example, one
PPE includes garments or equipment
designed to protect the wearer’s body from
union representative said that there was limited access to PPE, hand
injury or infection. BOP breaks down PPE wipes, and other sanitary supplies in the beginning of the pandemic, and
into specific categories in its record keeping. that masks that BOP initially provided were of poor quality. The union
These categories include:
representative noted that access to these items had improved. The
• COVID-19 test kits
• Disinfectant
challenges in acquiring PPE that BOP experienced in the early months of
• Disposable coverall or body suit
the pandemic were similar to those that other health care providers and
• Eye protection
institutions experienced at that time, as PPE was generally in short
• Gloves
supply. We previously reported on PPE shortages across federal
• Gowns and other outer PPE
agencies and in the health care industry. 25
• Hand sanitizer
• Masks, including cloth face masks, Despite the challenges Health Services Division and BOP union officials
medical-grade surgical masks, and N95 told us about in obtaining PPE early in the pandemic, officials from three
respirators
of the six facilities we interviewed told us their facilities had not
• Medications
experienced significant shortages of PPE items. 26 According to BOP
• Thermometers
officials, BOP worked with HHS to secure weekly allotments of testing
• Ventilators
supplies and ventilators. BOP also sought new avenues through which to
Pictured below is a ready-made PPE pack
that one facility we selected provides to staff purchase PPE supplies and equipment in order to help address PPE
for medical escort trips, such as to a shortages. In March 2020, BOP began ordering and distributing PPE to
hospital. It includes a surgical mask, an N95
respirator, gloves, a gown, and a face shield.
facilities while facilities continued to procure PPE locally.
BOP has a process for distributing PPE to staff and inmates that is
coordinated through its Incident Command System, through which it has
distributed over 10 million units of PPE. This process included providing
24The CDC does not consider cloth masks to be PPE, but says cloth masks are worn to
protect others in the surrounding area from respiratory droplets generated by the wearer.
However, BOP guidance states that staff and inmates in public areas must wear face
coverings, which could be PPE or cloth masks, at all times in public areas when less than
six feet apart.
25See GAO, COVID-19: Federal Efforts Could Be Strengthened by Timely and Concerted
Source: BOP. | GAO-21-502
Actions, GAO-20-701 (Washington, D.C.: September 21, 2020)
26The other three selected facilities did not mention whether or not they had experienced
PPE shortages in our interviews.
Page 19 GAO-21-502 BOP Response to COVID-19
an equal amount of PPE to the six logistics sites BOP’s Emergency
Operations Center created in each BOP region to assist in distributing all
large PPE orders. The six logistics sites were then responsible for
distributing the PPE to individual facilities in their respective regions.
Individual facilities are to make determinations regarding distribution
between staff and inmates depending on the needs of the facility.
According to officials from BOP’s Health Services Division, each facility
had some PPE on hand prior to the pandemic, and in March 2020, BOP
began to help replenish that supply or to support facilities’ response and
mitigation efforts. The Incident Command System used electronic
reporting to monitor facility PPE usage and to help ensure that adequate
levels of PPE for staff and inmates are present at all times. Once the
logistics sites had received a few weeks of reporting, BOP calculated the
typical rate of usage for each PPE category (e.g., masks, outerwear,
etc.). The logistics sites can then use the typical rate of usage and the
facility’s current inventory to estimate the number of days of PPE the
facility has on hand. BOP’s goal was for every facility to have 100 days of
inventoried PPE. According to BOP officials, some facilities had less than
a 90 day supply of certain PPE at certain points, but officials were not
aware of any facilities running out of or having to reuse PPE.
According to BOP, from March 2020 through May 2021, BOP had
obligated nearly $63 million for acquiring PPE to distribute to facilities,
and had expended about $59 million of that. 27 As shown in figure 4 below,
from March 2020 through February 2021, BOP distributed the highest
volume of PPE to facilities in April 2020. According to BOP officials, this
was because it took time for BOP to receive and then distribute the large
orders placed with vendors in March. The April 2020 distribution included
over 2 million pairs of gloves and over 2 million cloth face masks. 28 From
27As of May 2021, about $620 million from a combination of three sources has been either
appropriated to or designated by BOP for COVID-19 response efforts. The Coronavirus
Aid, Relief, and Economic Security (CARES) Act, Pub. L. No. 116-136, 134 Stat. 281, 513
(2020), appropriated $100 million to BOP for preventing, preparing for, and responding to
the COVID-19 pandemic. Additionally, the Consolidated Appropriations Act, 2021, Pub. L.
No. 116-260, § 543, 134 Stat. 1182, 1285 (2020), appropriated $300 million to BOP for
preventing, preparing for, and responding to COVID-19, domestically or internationally.
Further, according to BOP officials, BOP obligated about $220 million from its fiscal year
2020 Salaries and Expenses appropriation for COVID-19 expenses. Officials explained
that funds from all three sources are to be used for, among other things, personal
protective equipment, cleaning supplies, and contracts for medical care provided outside
BOP facilities. Of this approximately $620 million, all of the funds have been obligated as
of May 2021, or will be by the end of fiscal year 2021, according to BOP officials.
28In April 2020, BOP-managed facilities had a total of 142,287 inmates and 36,291 staff.
Page 20 GAO-21-502 BOP Response to COVID-19
May through July 2020, the majority of PPE that BOP distributed included
masks and outerwear such as gloves and gowns.
Figure 4: Monthly Types, Amounts, and Distribution Rates of Personal Protective Equipment (PPE) the Federal Bureau of
Prisons (BOP) Provided to Facilities, (March 2020-February 2021)
Note: The shading indicates the percentage of each personal protective equipment type that was
distributed that month as compared to other months. For example, 26 to 50 percent of all masks
distributed by BOP were distributed in July 2020, and 1 to 5 percent were distributed in August 2020.
In addition to the PPE that BOP distributed to facilities, facilities may have also acquired their own
PPE which would not be reflected in this figure.
Page 21 GAO-21-502 BOP Response to COVID-19
BOP Has Faced Three Officials we interviewed collectively identified three key challenges with
Key Challenges COVID-19 testing and reporting. These challenges have involved (1)
obtaining testing supplies and deploying an adequate testing strategy; (2)
Implementing Its COVID-
ensuring symptomatic inmates report their symptoms so they can be
19 Testing and Reporting tested; and (3) mitigating the risk that staff bring COVID-19 into the
Policies facility.
Obtaining testing supplies and deploying an adequate testing
strategy. BOP’s COVID-19 testing strategy is contained in its COVID-19
Phased Action Plans and COVID-19 Pandemic Plan. BOP officials said
the strategy has changed multiple times since the pandemic began, to
adapt to updated CDC guidance, as BOP officials better understood how
to respond, and as BOP addressed challenges in obtaining testing
supplies.
An official from BOP Health Services Division reported that, much like
other health care sector entities at the start of the pandemic, the bureau
had difficulty deploying an adequate testing strategy. For example, the
market for testing supplies was burdened early in the pandemic with
supply that could not keep up with demand, so BOP and other healthcare
providers had difficulty getting testing supplies. 29 To address this, BOP
worked with HHS to secure weekly allotments of testing supplies for
inmates through the end of 2020, according to BOP officials. At the end of
2020, BOP procured and distributed its own tests for inmates through a
contract with a laboratory. In addition, in July 2020, BOP awarded a 5-
year contract to a different laboratory for processing staff COVID-19 tests
at BOP-managed facilities, according to BOP officials. BOP policy
allowed facilities to have test kits available for staff at the facility, where
staff submitted completed tests to an off-site testing provider for results.
According to BOP officials, BOP’s Health Services Division allows
facilities to receive these test kits when community testing is not available
near that facility. According to BOP officials, less than 300 of the tests
have been used nationally as of early July 2021.
While BOP has explored implementing a mandatory staff testing policy,
officials said there would be limited benefits but high costs to doing so,
and noted that CDC guidance did not indicate they should mass test.
They added that a negative COVID-19 test result would only show that
the individual was negative at the time of taking the test. If the individual
29We have previously reported on COVID-19 testing shortages and the reasons why they
exist. See GAO, COVID-19: Opportunities to Improve Federal Response and Recovery
Efforts, GAO-20-625 (Washington, D.C.: June 25, 2020).
Page 22 GAO-21-502 BOP Response to COVID-19
were exposed between taking the test and receiving the result potentially
days later, that would not be reflected in the test results. Even a rapid test
would only show whether an individual is negative on that day, but they
could be exposed shortly after taking the test.
In addition, BOP officials told us that regularly testing staff would be time
and resource intensive. BOP officials explained that putting other
protective measures in place was the more feasible route to mitigating the
threat of the virus—for example, BOP controlling staff entry to facilities by
conducting symptom screening of all staff and making testing options
available to staff. BOP guidance also encouraged facilities to establish
relationships with local health department testing sites, and BOP created
a form letter for staff to provide to local testing sites asking that they be
prioritized as essential workers.
Ensuring symptomatic inmates are tested when facilities rely on
inmate self-reporting of symptoms. BOP has developed a COVID-19
screening and testing strategy, and has updated it as the pandemic has
evolved. BOP’s strategy is to test inmates if they become symptomatic or
have been exposed to COVID-19, and also before they are transferred in
or out of a BOP institution. BOP generally relies on inmates to self-report
their COVID-19 symptoms in order to be tested. However, officials at
three of the six selected facilities we spoke with reported that they were
aware of instances where inmates did not report their symptoms for fear
of being quarantined or isolated. According to BOP officials, BOP’s
strategy also allows for facilities to consider, when cases are rising,
conducting targeted surveillance testing by testing all inmates in areas
experiencing rising COVID-19 cases.
BOP officials told us that BOP has discussed internally, and with CDC,
the feasibility of mass testing across all BOP facilities. Mass testing would
entail regularly testing all inmates every 3–7 days regardless of COVID-
19 vaccination status until testing identifies no new cases for 14 days.
This is in contrast to BOP’s policy of testing inmates who are symptomatic
or who may have been exposed to a positive case, or of considering
conducting targeted surveillance testing of certain areas, units, or facilities
where positive cases have increased. Officials explained that mass
testing would require a tremendous increase in testing resources, given
the need to repeatedly test for the virus. Additionally, officials told us they
are uncertain that the benefits of mass testing would outweigh the
financial costs.
Page 23 GAO-21-502 BOP Response to COVID-19
Mitigating the risk of staff bringing COVID-19 into the facility. BOP
uses an enhanced screening tool to query all staff for symptoms before
they could enter the facility—see figure 5.
Page 24 GAO-21-502 BOP Response to COVID-19
Figure 5: Federal Bureau of Prisons’ COVID-19 Enhanced Screening Tool for Staff
and Visitors
Note: BOP provided this COVID-19 Enhanced Screening Tool to facilities with instructions to screen
all staff upon their arrival to a BOP facility by conducting a temperature check, as well as obtaining
their responses to questions about COVID-related symptoms and risk. BOP does not require written
Page 25 GAO-21-502 BOP Response to COVID-19
documentation unless the person responds “Yes” to any of the screening questions, or has a
temperature deemed unacceptable as described in the screening form.
When staff fail the symptom screening, they are denied access to the
facility and referred to their doctor or local health department for testing or
evaluation. Following the failed screening, BOP does not require proof of
a negative test as a condition for staff to return to work, but rather that
employees follow the advice of their health department or physician. For
staff who do test positive, but are not hospitalized, BOP’s guidance allows
them to return to work once all of three criteria are met: (1) 10 days have
passed since their first symptoms appeared, (2) their symptoms have
improved, and (3) they have not had a fever in 24 hours, without the
assistance of fever-reducing medications.
BOP Gathers Inmate BOP’s Emergency Operations Center gathers COVID-19 data, such as
COVID-19 Data, and the infection, recovery, and fatality rates of inmates at BOP-managed and
private facilities, from multiple sources. The center then consolidates the
Inmate Infections Peaked
data, and the Information Policy and Public Affairs Branch posts them
in December 2020 daily on BOP’s website. Figure 6 shows BOP’s process for tracking and
reporting these data.
Page 26 GAO-21-502 BOP Response to COVID-19
Figure 6: Federal Bureau of Prisons’ (BOP) Processes for COVID-19 Data Collection and Dissemination by Facility Type
Note: While BOP manages 122 federal facilities, federal inmates may also be held in private prisons
operating under contract with BOP, or in Residential Reentry Centers. Private prisons are privately
operated secure contract facilities and are low security. Toward the end of an inmate’s incarceration,
BOP may place the inmate in a Residential Reentry Center, also known as a halfway house. In
Residential Reentry Centers, inmates are housed outside of a prison environment and are required to
work or be actively seeking a job.
As of May 2021, 45,660 inmates in BOP-managed and community-based
facilities have tested positive for COVID-19, according to BOP data. In
Page 27 GAO-21-502 BOP Response to COVID-19
addition, as of May 2021, 45,367 inmates have recovered and 237
inmates have died of the virus. 30 BOP used its Bureau Electronic Medical
Records system for BOP-managed inmate data. In addition, BOP used
spreadsheets to track data for its staff and for private prisons.
As shown in figure 7 below, the numbers of new cases, recoveries, and
fatalities for inmates at BOP-managed facilities have varied month to
month since COVID-19 was first introduced into BOP facilities in March
2020. For example, in March 2020, there were 105 new cases, six
recoveries, and one fatality; in August 2020 there were 2,084 new cases,
2,807 recoveries, and 13 fatalities; and in December there were 15,447
new cases, 13,004 recoveries, and 32 fatalities. Further, the figure shows
that the number of positive inmate cases in BOP-managed facilities
peaked in December 2020, and the number of inmate fatalities was
highest in April 2020. The peaks in positive inmate cases in December
and January were also similar across BOP inmate demographic groups
and among inmates at contracted facilities. Nationwide, the number of
COVID-19 cases also peaked in December 2020 and January 2021.
Additional information on inmate infection rates, including demographic
information and rates at BOP’s contracted facilities, can be found in
appendix IV.
30Inmate infection and recovery data as of May 2021 was collected from BOP’s website,
which includes inmates currently in custody and not inmates who have since been
released from custody. In addition, cases and their outcomes are both counted in BOP’s
data. For example, an inmate who tested positive for COVID-19 in April 2020 and
recovered in May 2020 would be counted both as a new positive case in April 2020 and as
a recovery in May 2020.
Page 28 GAO-21-502 BOP Response to COVID-19
Figure 7: Total New COVID-19 Infection, Recovery, and Fatality Rates for Inmates in Federal Bureau of Prisons-Managed
Facilities (March 2020-February 2021)
Note: Positive cases and their outcomes are each counted in this figure. For example, an inmate who
tested positive for COVID-19 in April 2020 and recovered in May 2020 would be counted both as a
new positive case in April 2020 and as a recovery in May 2020. The number of inmate recoveries and
Page 29 GAO-21-502 BOP Response to COVID-19
fatalities do not add up to the total number of inmates that have tested positive for COVID-19. This
can be due to inmates who are still sick at the time of data collection, or inmates who were released
from the BOP system before an outcome was recorded.
Trends in Infection Rates We did not detect a consistent relationship between the infection rates of
in BOP Facilities and inmates in BOP facilities and the infection rates in surrounding
communities. Specifically, we compared COVID-19 positive cases at
Those in Surrounding
each of the five BOP-managed facilities and one privately managed
Communities Were Not facility to the percent increase in cases reported in counties within a 15-
Consistent mile radius of each facility (see appendix V). For some of the facilities we
analyzed, the trends in inmate cases followed a similar pattern to the
cases in the surrounding community, while for other facilities, the inmate
and community cases did not follow similar trends. For at least one
facility, there were too few cases in the facility to be able to make any
conclusions. For more information on these facilities’ response to COVID-
19, see appendix VI.
BOP Gathers Staff According to BOP officials, BOP Office of Occupational Safety and Health
COVID-19 Data, and Staff is responsible for tracking staff COVID-19 data. Staff members are
required to report positive COVID-19 test results to their employing
Infections Peaked in
facilities. The facilities then are to submit the information to BOP’s
December 2020 regional offices. As with COVID-19 data involving inmates, BOP posts the
data on its public website each business day. However, while BOP’s
January 2021 revised COVID-19 Pandemic Plan required staff to report
positive tests to their facility, data about staff infection and recovery rates
may be underestimated since staff are tested outside of the facility and
there is no way of ensuring all test results are reported. Additionally,
some staff may have been positive but were unaware of it if they did not
get tested.
As of May 2021, BOP reported that 6,972 of its staff had tested positive
for COVID-19. In addition, as of May 2021, 6,837 staff had recovered,
and four died of the virus. 31 As shown in figure 8, the number of cases of
31In February 2021, there were 37,163 staff in BOP-managed facilities. Cases and their
outcomes are both counted in BOP’s data. For example, a staff member who tested
positive for COVID-19 in April 2020 and recovered in May 2020 would be counted both as
a new positive case in April 2020 and as a recovery in May 2020.
A study of COVID-19 infections in BOP staff found that occupational category was not
associated with the staff member’s likelihood to receive a positive COVID-19 test that is
reported to BOP, which, according to the study, could reflect the interconnected
operations within correctional environments. See Robin L. Toblin, Sylvie I. Cohen, and
Liesl M. Hagan, “SARS-CoV-2 Infection Among Correctional Staff in the Federal Bureau of
Prisons,” American Journal of Public Health (2021): p. 1-4.
Page 30 GAO-21-502 BOP Response to COVID-19
staff COVID-19 infections peaked in December 2020, with over 1,500
reported cases.
Figure 8: Total New COVID-19 Infections, Recoveries, and Fatalities for Federal Bureau of Prisons Staff, March 2020 through
February 2021
Page 31 GAO-21-502 BOP Response to COVID-19
Note: Positive cases and their outcomes are each counted in this figure. For example, a staff member
who tested positive for COVID-19 in April 2020 and recovered in May 2020 would be counted both as
a new positive case in April 2020 and as a recovery in May 2020.
BOP Developed an BOP, in consultation with the CDC, issued a COVID-19 Immunization
Approach to Prioritize Plan on November 2, 2020, for BOP-managed institutions. The plan
prioritized administering the vaccine to staff first, then to inmates in
Vaccinations for Staff and
certain housing units, such as nursing care units or open bay housing,
Inmates and finally to all other inmates. 32 Within these priority groups were sub-
priorities. For example, staff who were health care providers were the
highest priority group, while inmates with certain characteristics, such as
those 65 years old or older, those with cancer, and those with heart
conditions, among others, were prioritized before other inmates.
According to BOP guidance, the Central Office is responsible for
coordinating all vaccine orders, and the CDC distributor ships the vaccine
directly to individual facilities. Officials at the private prison we selected
said they worked with their state health department to develop the
facility’s vaccination plan in advance of vaccine distribution. As of May
2021, 5,095 inmates in private facilities had been fully vaccinated.
As of March 2021, BOP was receiving weekly shipments of both the
Pfizer and Moderna vaccines. Since the Pfizer vaccines are shipped in
large quantities in ultra-cold storage, CDC ships them to centralized BOP
locations, according to BOP officials. BOP facilities are to pick up an
assigned number of doses from the centralized location, transporting
them in refrigerated shipping boxes. Since the Moderna vaccine is
shipped frozen in batches of 100 doses, they are shipped directly to
facilities. Officials said that due to manufacturer storage requirements and
the lack of ultra-low temperature freezer capacity at BOP, the Pfizer
vaccine must be used within 5 days, and the Moderna vaccine must be
used within 30 days. BOP directs facilities to administer all doses within 5
days, except for some extenuating circumstances where BOP may direct
the facility to store the vaccine. For example, if a facility’s health care staff
are quarantined or sick, the facility could keep the Moderna vaccine for up
to 30 days, or use dry ice to extend the life of the Pfizer vaccine, until
there are staff available to administer the vaccine.
In March 2021, BOP began distributing doses of the Johnson & Johnson
vaccine. Unlike the Pfizer and Moderna vaccines which are two-dose
32Open bay housing is a term used to describe inmate housing where many inmates sleep
in one large room, potentially with cubicle-style partial walls, as opposed to fully enclosed
cells housing smaller numbers of inmates.
Page 32 GAO-21-502 BOP Response to COVID-19
vaccines, the Johnson & Johnson vaccine is one dose. BOP mainly used
this vaccine in holdover and detention centers where inmates have
shorter stays, and therefore would be more difficult to schedule for follow-
up second doses.
According to BOP officials, all BOP staff had been offered at least one
dose of vaccine by the end of February 2021. According to BOP officials,
BOP offered the vaccine to more than 90 percent of all inmates at BOP-
managed facilities before June 1, 2021. Of the remaining inmates, about
3,000 are new entrants to BOP facilities. According to BOP officials, BOP
continues to offer the vaccine to new entrants, as well as those who had
previously declined the vaccine. BOP anticipates having offered the
vaccine to all inmates by July 1, 2021, and will continue to offer the
vaccine to new staff and inmates thereafter.
As of May 31, 2021, 73,050 (56 percent) inmates in BOP-managed
facilities were fully vaccinated. In addition, 19,000 BOP staff (50 percent)
were fully vaccinated. 33 According to BOP officials, BOP does not
provide vaccines to private facilities nor reimburse them for vaccine costs.
Instead, officials said BOP directed these facilities to use state resources
to acquire vaccines.
COVID-19 has impacted inmates and staff in various ways. In its
COVID-19 Has response to the pandemic, BOP issued multiple guidance documents that
Impacted Conditions made changes to inmates’ living conditions, as well as to inmates’ access
to services and programs. In addition, BOP leveraged home confinement
for Inmates and Staff, authorities in an attempt to prevent the spread of COVID-19 among
but BOP Lacks an inmates. COVID-19 exacerbated existing staffing challenges at BOP
facilities that we identified in prior reviews by, for example, necessitating
Approach to Ensure staff be placed on quarantine if they were exposed to COVID-19 over the
Facilities Capture and course of the pandemic. BOP has some mechanisms for sharing lessons
learned and best practices from its response to the pandemic, but does
Implement Lessons not have an approach for ensuring that facilities capture and implement
Learned applicable lessons learned or best practices. In the following four
sections, we discuss how BOP’s response to the pandemic changed
inmates’ living conditions, how BOP leveraged its home confinement
program in response to COVID-19, how its response impacted new and
existing staffing challenges at its facilities, and the strengths and
33“Fully vaccinated” means that inmates had received their final dose of the vaccine.
These numbers measure the number of BOP administrations of vaccines to inmates and
staff. Because of this, staff vaccinations may be undercounted as staff can seek
vaccinations outside of BOP’s vaccine distribution structure.
Page 33 GAO-21-502 BOP Response to COVID-19
limitations of BOP’s approach to capture and apply best practices and
lessons learned from its pandemic response.
BOP’s Pandemic BOP’s efforts to safeguard its inmates during the pandemic has changed
Response Efforts Have inmates’ living conditions. Specifically, BOP has limited access to
programs, services, visitors, and facility spaces. Such changes have been
Changed Inmate Living
outlined in various guidance documents that BOP issued over the course
Conditions of the pandemic, such as BOP’s Phased Action Plans and its COVID-19
Pandemic Plan.
Access to programs and services. BOP changed inmates’ access to
various programs and services during the pandemic. Capacity for some
programs, such as vocational training and General Educational
Development (GED) testing, was reduced to allow for social distancing. 34
Routine medical care services, such as requests for doctor visits and
medication distribution, also have been changed to accommodate social
distancing guidelines. For example, instead of obtaining their medications
from a health care worker amongst multiple other prisoners, inmates are
required to access medications one housing unit at a time. In addition,
some activities, such as recreation, are conducted per housing unit in
order to reduce interactions between inmates assigned to different
housing units throughout the facilities. Figure 9 summarizes common
impacts on four BOP programs and services available to inmates.
34BOP facilities offer education and vocational training services to inmates, such as
literacy classes, adult continuing education, and occupational training. According to BOP,
in most cases, inmates who do not have a high school diploma or a GED certificate must
participate in the literacy program for a minimum of 240 hours or until they obtain the
GED.
Page 34 GAO-21-502 BOP Response to COVID-19
Figure 9: Examples of Federal Bureau of Prisons’ (BOP) Reported Changes to Program Operations During COVID-19
Page 35 GAO-21-502 BOP Response to COVID-19
Access to visitors. According to BOP’s COVID-19 Phase Two Action
Plan, issued in March 2020, BOP suspended inmates’ in-person legal and
social visits. During suspension, BOP facilities granted access to legal
counsel via teleconference, or in some cases video conference, based
upon request and the availability of space to allow for adequate social
distancing at local facilities. Additionally, over the course of the pandemic,
individual wardens have had discretion to suspend or lift suspension of in-
person legal and social visitation based on the facility’s COVID-19
outbreak status, which led to some facilities allowing in-person visitations
through appointments, while others did not.
To ensure that inmates maintain community ties, BOP’s Phase Two
Action Plan increased inmate telephone minutes to 500 from 300 per
calendar month bureau-wide. In addition, BOP officials said that they
made these calls free, pursuant to the CARES Act. 35 Officials at each of
the six BOP and private facilities we selected said that inmates had
access to legal counsel through telephone or email at a minimum. Three
facilities we selected said they were also able to set up video
conferencing for legal visits for some inmates. According to BOP’s
COVID-19 Pandemic Plan, BOP instructed facilities to institute a
continuous cleaning and disinfection schedule for all “high traffic” touch
areas, including telephones (see figure 10). In addition, facilities granted
in-person social visits to inmates if the facility was not under lockdown
due to a COVID-19 outbreak at the facility.
35Pub. L. No. 116-136, § 12003, 134 Stat. 281, 515-17. Pursuant to section 12003 of the
CARES Act, during the covered emergency period, if the Attorney General finds that
emergency conditions will materially affect the functioning of the Bureau, the Director of
BOP is required to promulgate rules regarding the ability of inmates to conduct visitation
through video teleconferencing and telephonically, free of charge to inmates, during the
covered emergency period.
Page 36 GAO-21-502 BOP Response to COVID-19
Figure 10: A Federal Bureau of Prisons’ Telephone Booth with Sanitization
Instructions
Page 37 GAO-21-502 BOP Response to COVID-19
Facilities resumed in-person social visits in October 2020. However,
BOP’s Phase Nine Action Plan directed visitors to adhere to CDC
guidance for social distancing and PPE use. For example, to comply with
BOP guidance, one facility we selected installed a Plexiglas wall in its
visitation room, as illustrated in figure 11.
Figure 11: A Federal Bureau of Prisons Facility’s Visitation Room with Plexiglas
Separation
Access to facility spaces. According to BOP’s COVID-19 Phase Two
Action Plan, in March 2020, BOP suspended inmates’ movement within
their assigned facilities. However, BOP granted some exceptions to the
suspension in cases of inmate transfer, such as for judicial proceedings
or for transfer to Residential Reentry Centers. In addition, BOP placed all
facilities on a 2-week lockdown on April 1, 2020, to minimize movement
within the prisons for staff and inmates.
Page 38 GAO-21-502 BOP Response to COVID-19
BOP’s COVID-19 Phase Four Action Plan, issued late March 2020,
mandated facilities to incorporate inmate quarantine and isolation
procedures (see figure 12 for monthly rates of inmate quarantine and
isolation). BOP required facilities to designate areas for medical
quarantine and isolation, isolate and test symptomatic inmates, and
quarantine asymptomatic inmates and inmates who may have been
exposed to a COVID-positive inmate. Furthermore, BOP required facilities
to quarantine all inmates transferring in or out of a facility for 14 days and
to isolate symptomatic inmates.
Figure 12: Federal Bureau of Prisons’ (BOP) Quarantine and Isolation Rates per 1,000 Inmates in BOP Custody, March 2020—
February 2021
Note: According to BOP’s COVID-19 Pandemic Plan, medical isolation refers to confining individuals
with suspected or confirmed COVID-19 infection, either to single rooms or by grouping them with
other viral infection patients. Quarantine, in the context of COVID-19, refers to separating, in an
individual room or grouping into a unit, asymptomatic persons who may have been exposed to the
virus to (1) observe them for symptoms and signs of the illness during the incubation period, and (2)
keep them apart from other incarcerated individuals.
The highest monthly total of quarantined inmates was in April 2020 when
more than 27,100 inmates were quarantined (almost 200 per 1,000
Page 39 GAO-21-502 BOP Response to COVID-19
inmates, compared to 23 in 1,000 inmates in March 2020). 36 BOP
quarantined more than 18,000 inmates each month from July through
December 2020, which corresponds with higher reported inmate COVID
cases and recoveries during those same months. In December 2020,
almost 182 per 1,000 inmates were in quarantine, which corresponds with
the highest monthly rate of new COVID cases for inmates in BOP-
managed facilities.
From March through April 2020, the number of inmates in isolation
increased significantly, from fewer than 400 in March (two per 1,000
inmates) to more than 2,600 in April (18 per 1,000 inmates)—the month
after BOP issued guidance mandating quarantine and isolation
procedures as referenced above—and almost 3,500 in May. In May 2020,
almost 26 per 1,000 inmates were in isolation. In November and
December of 2020, the number of inmates in isolation increased again; in
December, almost 126 in 1,000 inmates were in isolation. This is the only
month where more than one in 100 inmates were in isolation, which
corresponds with the highest monthly rate of new COVID cases in
December 2020, for inmates in BOP-managed facilities. This is similar to
COVID-19 cases peaking nationwide in December 2020 and January
2021.
BOP also modified its facility spaces in response to the pandemic. For the
purposes of identifying spaces for isolation and quarantine, BOP’s
COVID-19 Pandemic Plan directed facilities to consider spaces not being
utilized such as those used for education, religious services, visiting, or
recreation. In addition, facilities were directed to obtain tents, shower
stations, and mobile hand hygiene stations to create separate spaces and
encourage social distancing at some facilities. As such, some BOP
facilities converted facility space—or, in some instances, constructed new
space around the facility—to allow for more quarantine and isolation
units. Officials from each of the six BOP and private facilities we selected
stated that they isolated or quarantined inmates in various areas of their
prisons—for example, housing units, gymnasiums, visiting rooms, or
tents, as illustrated by figure 13. Specifically, officials from one facility we
spoke with said their facility chapel was converted into a COVID-19
isolation room.
36April 2020 was the month after BOP issued guidance mandating facilities to incorporate
inmate quarantine and isolation procedures.
Page 40 GAO-21-502 BOP Response to COVID-19
Figure 13: A Federal Bureau of Prisons’ Facility’s Recreation Area Repurposed for
Medical Isolation
In addition, officials we spoke with from three of the five BOP-managed
facilities stated they had installed temporary, portable showers in
alternative housing units for inmate quarantine and isolation (see figure
14). Inmates had controlled access to showers on a per-unit basis,
according to these officials.
Page 41 GAO-21-502 BOP Response to COVID-19
Figure 14: A Federal Bureau of Prisons Facility’s Installation of Temporary Showers
in Alternate Housing Areas for Inmates in Quarantine and Isolation
Page 42 GAO-21-502 BOP Response to COVID-19
BOP Used Home BOP has leveraged its home confinement program to respond to the
Confinement as Part of Its pandemic by transferring nearly 27,000 inmates to the community
between March 2020 and February 2021 and by regularly reviewing all
COVID-19 Response
inmates for home confinement eligibility (see figure 15 for trends in home
confinement release before and during the pandemic). 37 BOP’s home
confinement program allows eligible inmates nearing release to serve the
remainder of their sentence at a home or residence.
As indicated in figure 15, BOP reported that it transferred more inmates to
home confinement in May and June 2020 than it did in the same months
in 2019. Thereafter, the number of inmates transferred to home
confinement each month in 2020 generally were slightly lower compared
to the same months in 2019.
According to BOP officials, the increased transfers in May and June 2020
were in direct response to two memoranda the Attorney General issued
directing the bureau’s use of the home confinement program during the
pandemic. According to BOP officials, BOP facilities sent a list of inmates
who were likely eligible for home confinement to BOP Central Office for
review and the transfers accelerated soon thereafter.
37Specifically, BOP reported the transfer of over 6,500 inmates to the community under
updated CARES Act eligibility criteria, close to 300 elderly offenders, and another
approximately 20,000 under preexisting authority between March 2020 and February
2021. We were unable to independently verify the accuracy of BOP’s reported home
confinement numbers. Additionally, we identified the following limitations of the home
confinement numbers provided by BOP for the purposes of our review: (1) BOP’s home
confinement data were provided as a snapshot and are limited to the inmate’s status on
the date the data were extracted; and (2) BOP was unable to provide a count of all
inmates eligible for home confinement at any given time, as an inmate’s eligibility status
can change regularly in relation to the eligibility criteria for home confinement. Given these
limitations and caveats, we concluded the data were sufficiently reliable for the purposes
of presenting estimates in this report rather than exact numbers.
Page 43 GAO-21-502 BOP Response to COVID-19
Figure 15: Trends in the Bureau of Prisons’ (BOP) Transfer of Inmates to Home Confinement Before and During the COVID-19
Pandemic (March 2019 through February 2021)
Note: BOP’s home confinement data were provided in monthly snapshots and are limited to the
inmate’s status on the date these data were extracted for each of the months included in this graph.
As such, these numbers may not fully align with numbers presented in other sources where the
extraction dates differ or for different time periods. We determined these data were sufficiently reliable
for presenting estimates in this report as opposed to exact numbers.
In its first memo, issued on March 26, 2020, the Attorney General
directed the BOP Director to prioritize home confinement as an
appropriate response to the COVID-19 pandemic. The memo also
suggested that BOP consider the totality of circumstances for each
individual inmate, the statutory requirements for home confinement—such
as how close inmates are to completing their sentences—and a non-
exhaustive list of discretionary factors when making home confinement
decisions. For example, one discretionary factor included assessing the
inmate’s score under BOP’s new risk assessment tool—the Prisoner
Assessment Tool Targeting Estimated Risk and Needs—with inmates
Page 44 GAO-21-502 BOP Response to COVID-19
who have anything above a minimum score not receiving prioritization for
home confinement. 38
A second memo the Attorney General issued on April 3, 2020, directed
BOP to “move with dispatch” in administering the home confinement
program, and immediately process eligible inmates for transfer and then
immediately transfer them, following appropriate quarantine protocols. To
comply with directions from the March 26, 2020 Attorney General memo
as well as existing criteria for its Elderly Offender Home Detention
program, the Acting Assistant Director for Correctional Programs Division
issued guidance on May 8, 2020 outlining the following factors that
facilities must consider when determining whether inmates are suitable
for home confinement:
• The inmate’s institutional discipline history for the prior 12 months; 39
• Whether or not the inmate has a verifiable plan for release into the
community;
• If the inmate’s primary offense is not violent, a sex offense, or
terrorism related;
• Whether or not the inmate has a current detainer; 40
• That inmates residing in low and minimum security facilities should be
given priority;
38The First Step Act of 2018, Pub. L, No, 115-391, § 101, 132 Stat. 5194, 5195-5208,
required the Attorney General to develop a risk and needs assessment system for inmates
in BOP prisons. See 18 U.S.C. § 3632. BOP’s Prisoner Assessment Tool Targeting
Estimated Risk and Needs is designed to predict whether an inmate is at high, medium,
low, or minimum risk for reoffending based on several characteristics, or “risk factors,”
among other things. A higher score indicates a higher risk of reoffending, while a lower
score indicates a lower risk of reoffending.
39The guidance noted that inmates who have received a 300 series (moderate severity
security risk) or 400 series (low severity security risk) incident report for an infraction in the
past 12 months may be referred for placement on home confinement, if in the Warden’s
judgment, such placement does not create an undue risk to the community.
40A detainer is a hold placed on the inmate pending charges from another jurisdiction.
Page 45 GAO-21-502 BOP Response to COVID-19
• That inmates who have anything above a minimum risk score for
reoffending on the Prisoner Assessment Tool Targeting Estimated
Risk and Needs should not be given priority for release; 41 and
• The inmate’s age and vulnerability to COVID-19.
In addition to the criteria listed above, the guidance also stated that the
bureau should prioritize inmates for home confinement consideration if
inmates either (1) have served 50 percent or more of their sentence, or
(2) have 18 months or less remaining on their sentence and have served
25 percent or more of their sentence. As of February 2021, BOP had
transferred approximately 6,500 more inmates to home confinement than
they would have if the criteria had not been updated on May 8, 2020.
As described earlier, BOP generally transferred a slightly lower number of
inmates from July through December 2020, compared to the same period
in 2019. BOP officials told us this was because BOP developed a list that
included a large portion of the inmates who were eligible for home
confinement at the start of the pandemic. As a result, the transfer process
was front-loaded in the initial stages of the pandemic in May and June
2020, resulting in a decrease in home confinement transfers after July
2020.
See figure 16 for inmate placement in home confinement under BOP’s
various authorities. As indicated in the figure, BOP reported that it
transferred nearly 27,000 inmates to community programs from March
2020 through February 2021 under various authorities granted to BOP,
such as under the First Step Act of 2018 or the Second Chance Act. Of
these transfers, approximately 1 in 4 transfers were a direct result of
CARES Act authority. The Bureau reported that it transferred the highest
number of inmates under CARES Act authority from April through July
2020, accounting for nearly two thirds of all transfers under CARES Act
authorities that took place between March 2020 and February 2021.
According to BOP officials, this was a result of actions taken by BOP after
the Attorney General issued memoranda directing the bureau to leverage
the home confinement program in response to the pandemic.
41On April 13, 2021, BOP issued a memo updating the criteria for home confinement
further, including by expanding the criteria on the Prisoner Assessment Tool Targeting
Estimated Risk and Needs to include inmates with a “low” risk score. Pursuant to the First
Step Act, this assessment tool is used to determine the recidivism risk of each prisoner as
part of the intake process and classify each prisoner as having minimum, low, medium or
high risk for recidivism.
Page 46 GAO-21-502 BOP Response to COVID-19
Figure 16: Trends in the Bureau of Prisons’ (BOP) Transfer of Inmates to Home Confinement under Different Authorities
(March 2020-February 2021)
Note: “CARES Act” represents inmates who were transferred to home confinement under CARES Act
authority, “Elderly Offender” represents transfers under the Elderly Offender Home Detention
Program authority. “Other” represents inmates who were transferred to home confinement under
authorities BOP already had.
Page 47 GAO-21-502 BOP Response to COVID-19
Officials from the five BOP-managed facilities we selected said they are
taking certain actions in response to the updated guidance and criteria for
home confinement transfer. For example, officials from all five facilities
said they review their inmate population for home confinement eligibility
on a regular basis. These officials stated that they track inmates who are
eligible for home confinement using an internal spreadsheet they share
with the regional office for review and approval. Further, BOP’s Health
Services Division also determines if eligible inmates are vulnerable to
COVID-19, as required in the updated criteria.
Representatives of two advocacy groups we interviewed expressed
concerns that BOP has not fully leveraged the home confinement
program to transfer inmates during the pandemic. Representatives of one
of the advocacy groups told us BOP has not been transparent about the
updated criteria. For example, the representatives stated that they
learned of additional, unpublicized criteria—such as criteria related to an
inmate completing 50 percent of a sentence before being considered for
home confinement—that BOP is using to determine home confinement
eligibility only during the course of litigation against the bureau. They
pointed out that since BOP initially established the 50 percent standard, it
has been rescinded, and then reestablished, leading to confusion.
Additionally, the group stated that BOP applies the home confinement
criteria in a manner that works against a finding of eligibility by treating
the criteria as a “gauntlet” or a series of hoops that inmates must jump
through rather than applying the criteria holistically. BOP officials said
they endeavor to balance the health and safety of an inmate with the
safety and security of the community when making home confinement
transfer decisions.
Representatives of another advocacy group questioned the relevance of
using BOP’s Prisoner Assessment Tool Targeting Estimated Risk and
Needs in making home confinement transfer decisions during a
pandemic, considering the tool does not incorporate risk factors for
infectious disease. However, the updated criteria BOP uses to assess
home confinement eligibility includes an inmate’s risk factors for
contracting COVID-19. Additionally, they questioned equity in
compassionate release decisions, noting that inmates who are minorities
are less likely than their counterparts to be granted compassionate
Page 48 GAO-21-502 BOP Response to COVID-19
release. 42 However, BOP data on compassionate release show that the
number of inmates to whom BOP granted compassionate release
increased nearly twenty-fold between the year prior to the pandemic
(March 2019-February 2020) during which BOP released over 150
inmates, and the year after the pandemic was declared (March 2020-
Feburary 2021) during which BOP released over 3,000 inmates. 43
We also compared—by ethnicity and race—the percentage of inmates
BOP reported that it transferred to home confinement from February 2019
through February 2021, to the overall prison population during the period,
as illustrated in figure 17. We found that BOP released proportionally
more inmates of non-Hispanic than of Hispanic ethnicity compared to the
prison population make-up. In addition, by race, it consistently released a
higher proportion of Black inmates than make up the general prison
population from February 2019 through February 2021.
42BOP grants inmates compassionate release under certain legal authorities. For certain
inmates, under 18 U.S.C. § 4205(g), a sentencing court, on motion of the Bureau of
Prisons, may make an inmate with a minimum term sentence immediately eligible for
parole by reducing the minimum term of the sentence to time served. Under 18 U.S.C. §
3582(c)(1)(A), a sentencing court, on motion of the Director of the Bureau of Prisons, may
reduce the term of imprisonment of an inmate sentenced. BOP uses these authorities in
particularly extraordinary or compelling circumstances which could not reasonably have
been foreseen by the court at the time of sentencing.
43The BOP data we examined on compassionate release comprised the total number of
compassionate release approvals for the year prior to the pandemic (March 2019-
February 2020) in comparison to the total number of approvals for the year since the
pandemic was declared (March 2020-February 2021). This total includes both
compassionate release approvals originating from a motion from BOP as well as
approvals granted directly by the court.
Page 49 GAO-21-502 BOP Response to COVID-19
Figure 17: Ethnic and Racial Comparison of inmates Transferred to Home Confinement with Overall Federal Bureau of
Prisons (BOP) Population (February 2019-February 2021)
Data for 2019 represent transfers for 11 months, all except January.
a
Data for 2021 represent transfers for 2 months—January and February
b
As for the application process for transferring inmates to home
confinement, BOP currently tracks applications at the facility level.
Officials from three of the five facilities also said the process for placing
an inmate in the community usually takes 30 days, while one facility said
the process can take between 2 to 5 months. 44
44According to BOP, some of the time to complete the referrals to home confinement is
due to the time needed to review the inmate’s home environment to ensure its feasibility.
Further, the process requires concurrence from the U.S. Probation Office which assumes
supervision for the inmate under home confinement.
Page 50 GAO-21-502 BOP Response to COVID-19
BOP’s COVID-19 COVID-19 exacerbated existing staffing challenges at BOP facilities that
Response Efforts we identified in prior reviews, altered shifts and post assignments, and
increased overtime use.
Impacted BOP Staff
Exacerbated existing staffing challenges. While BOP continued its
hiring and recruitment efforts throughout the pandemic in an effort to
address staffing challenges, each of the five BOP facilities we selected
reported facing staffing challenges in their response to the pandemic.
These challenges include staffing shortages brought about or
exacerbated by staff quarantine procedures, staff placed on temporary
duty assignments, or staff placed on temporary job modifications. 45
According to BOP officials, they were able to supplement some medical
staff at facilities experiencing outbreaks with medical personnel from the
Public Health Service and partnered with contractors at select sites. In
February 2021 we reported that BOP has multiple methods for assessing
its staffing levels to determine shortfalls, but faces challenges with these
methods. 46 In addition, we found that BOP has implemented practices for
addressing the staffing shortfalls, such as use of overtime, but has not
assessed associated risks to staff and inmate safety, such as officer
fatigue and decreased observation skills. We recommended, among other
things, that BOP develop and implement a reliable method for calculating
staffing levels—whether by amending existing methods or developing a
new one—and conduct a risk assessment of its staff augmentation and
overtime use. 47 BOP agreed with our recommendations and is in the
process of developing plans to address them.
Altered shifts and post assignments. BOP union officials at four of the
five facilities and one of the six regional offices we interviewed stated that
the pandemic contributed to staff shortages at their facilities, which
altered shifts and post assignments. For example, the number of staff
who took administrative and sick leave for COVID-19-related reasons
caused management officials at one facility we spoke with to change staff
45According to BOP guidance, some prior emergency situations have required the
temporary assignment of bureau staff away from their home duty stations. Temporary duty
assignments are made on a voluntary basis, to the extent possible.
46For example, we found that these methods have limitations and do not yield reliable
information. We also found that BOP has multiple data sources available to help it identify
and address the causes and potential impacts of staffing challenges, but it is not
leveraging them and lacks a plan to do so. For more details see GAO-21-123.
47Augmentation is the assignment of a non-custody staff member, e.g., an individual
responsible for educational or vocational training, to a custody role, whereby the staff
member’s primary task becomes the custody and supervision of the inmate.
Page 51 GAO-21-502 BOP Response to COVID-19
shifts from 8-hour to 12-hour shifts, while management officials at three
facilities we spoke with mandated overtime shifts to maintain operations.
In addition, BOP reassigned staff to cover posts when staff were
unavailable, granted temporary job modifications to reduce their exposure
to the virus, or deployed staff to other BOP facilities for temporary duty,
according to these officials.
Further, BOP temporarily reassigned some staff to facilities across the
nation. According to BOP officials, this staff deployment approach is a
routine way that BOP reallocates resources when circumstances warrant
to ensure the bureau can sustain basic operations in emergencies. BOP
tracks staff moving to and from multiple facilities, but does not typically
monitor data on staff deployments specifically related to the COVID-19
pandemic. As such, officials told us it would be difficult for BOP to provide
an analysis on how staff deployments changed as a result of the
pandemic, but that it would be accurate to conclude that the number of
staff temporarily reassigned to other facilities increased due to the
pandemic.
Increased overtime use. We previously reported that BOP’s overtime
costs had been increasing since 2015. 48 Officials from three of the six
BOP and private facilities we selected said they experienced increases in
overtime during the pandemic, which can contribute to increased costs
associated with the pandemic response and, according to one union
representative, contribute to staff fatigue. For example, a BOP union
representative we interviewed from one facility said staff worked 12-hour
shifts for 3 weeks straight while on temporary duty assignment. According
to another BOP union representative from a different facility, staff who
refused to work overtime were subject to disciplinary action, such as
placement on leave without pay, which further exacerbated staff
shortages. 49
BOP does not currently track or analyze instances of staff refusals of
mandated overtime. However, if BOP management at individual facilities
charge a staff member with refusal to work mandatory overtime, the
charge is referred to BOP’s Office of Internal Affairs for disciplinary
investigation. This office investigates the matter, and if the charge is
sustained, the matter is referred to the facility’s Human Resources
Department to take disciplinary action. If the Human Resources
48GAO-21-123.
49We did not independently verify these allegations.
Page 52 GAO-21-502 BOP Response to COVID-19
Department chooses to discipline staff, the case is to be documented in
BOP’s Office of General Counsel’s Employment Law Branch database.
According to the database, from February 2020 through February 2021,
there were 58 cases of refusal to work mandated overtime. Of the 58
cases, 22 resulted in disciplinary action that required leave between 1
and 5 days. BOP officials also clarified that some institutions have
entered into local union agreements to allow refusal of mandatory
overtime, such as one refusal annually.
BOP Has Some BOP has two main mechanisms for capturing and sharing lessons
Mechanisms for Sharing learned and best practices from the COVID-19 pandemic. However, BOP
does not document the lessons and practices identified through its regular
Best Practices, but Does
information sharing teleconferences—one of the two mechanisms for
Not Document Them or capturing and sharing lessons and practices. Further, BOP does not have
Have an Approach for an approach for ensuring facilities implement applicable lessons learned
Ensuring Implementation or best practices for responding to the pandemic.
BOP’s mechanisms for capturing and sharing lessons learned and best
practices include (1) regular information sharing teleconferences that rely
on facility wardens’ discretion to voluntarily implement and track lessons
learned and best practices; and (2) COVID Compliance Review Team
inspections, coordinated by BOP’s Program Review Division.
Regular information-sharing teleconferences. BOP’s Central Office
and regional offices held weekly calls with facilities during which they
shared best practices and lessons learned they identified. For example,
officials from four of the BOP regional offices we spoke with said they
held regular meetings with facilities to discuss COVID-19 response efforts
in local facilities. Officials from one of these regional offices said the
regional health services administrator has weekly meetings with its
facility’s health services administrators to discuss best practices for
managing COVID-19.
While BOP’s above actions to compile and share some best practices are
beneficial, BOP does not document the lessons and practices discussed
at the regular information-sharing teleconferences or share them more
broadly. Officials at BOP Central Office and regional offices told us they
do not document the practices and lessons discussed, and that wardens
can decide whether to document the information at their discretion.
Officials from one facility we spoke with said that they developed their
own best practices and sometimes, but not always, share them with other
facilities on an informal basis. For example, one of the wardens we spoke
with shared a list of best practices his facility had compiled with other
Page 53 GAO-21-502 BOP Response to COVID-19
facilities during the pandemic, which included suggestions for security of
inmates at local hospitals and for educating inmates on procedures for
COVID-19 prevention, among others.
Developing and implementing an approach for capturing the lessons and
practices discussed at BOP officials’ weekly teleconferences, and
formally sharing them across BOP would help ensure the information
reaches all facilities that could potentially benefit from it. The documented
information would also make it easier for facility officials to archive and
refer to the lessons and practices in carrying out their efforts to respond to
COVID-19 or other public health emergencies.
COVID Compliance Review Team inspections. Led by the Program
Review Division, BOP’s COVID Compliance Review Team conducted
unannounced inspections of 87 (of 98 total) BOP facilities to monitor their
COVID-19 response and develop further mitigation strategies to address
the pandemic. 50 The team completed its first round of inspections in
September 2020 and planned to complete a second by September 2021.
The 2020 inspections were focused on the facilities’ compliance with BOP
guidance on over 180 factors on a checklist, including compliance with
general hygiene practices, social distancing, proper use of PPE, and
screening of staff for COVID-19. According to our analysis, of the 87
facilities inspected, 83 did not comply with one or more factors on the
compliance checklist. In addition, 10 of the 87 facilities did not comply
with 20 or more factors on the compliance checklist. BOP’s Program
Review Division shared citations with the warden at each inspected
facility as well as with the Regional Director for the region that oversees
the facility. Wardens are responsible for taking corrective actions to
address the citations, and for reporting these actions to their respective
Regional Directors and BOP’s Program Review Division.
Table 1 describes the six most cited factors during the 2020 inspection, in
order of most cited, as well as examples of corrective actions facilities
took to address the noncompliance.
50The universe of BOP facilities for this review is 98 because some of BOP’s 122 facilities
are co-located and therefore some facilities were combined in BOP’s COVID Compliance
Review team’s inspections.
Page 54 GAO-21-502 BOP Response to COVID-19
Table 1: Federal Bureau of Prisons’ (BOP) COVID-19 Compliance Review Team’s Most-Cited Areas of Concern during
September 2020
Number of
noncompliance Example of corrective action taken to address
COVID-19 compliance review checklist factor citations noncompliance
Set up personal protective equipment (PPE) 33 One facility identified a separate entrance and exit at
donning/doffing stations outside every area where the isolation and quarantine unit so staff can properly
staff need to wear PPE. These stations should don PPE prior to entering the unit and doff their PPE
include posters depicting correct donning/doffing of when exiting the unit. Educational information was
relevant PPE categories. posted on either side so the process could be
completed without cross contamination.
Inmates do not move to commissary. Staff deliver 22 One facility coordinated scheduled movements to
commissary items directly to inmates in their housing ensure there was no mixing of inmates from different
locations/cells. housing units. Commissary staff enforced social
distancing, and markings were placed on the
sidewalk outside of the commissary at 6-foot
intervals. The procedures implemented adhere to the
guidance outlined in BOP’s Phase Nine Action Plan.
Appropriate universal wearing of face coverings by 22 One facility placed placards and laminated signage
staff and inmates when in public areas is mandatory directing staff to wear face coverings in all
and monitored by all staff. Face coverings are worn at appropriate locations throughout the institution.
all times when less than 6 feet apart. Face coverings Emails are disseminated to all staff on a recurring
should completely cover nose and mouth and not be basis directing staff to wear a face covering. Staff not
pulled down to speak. Staff and inmates should be adhering to this guidance face progressive
trained on appropriate wear, handling, and laundry disciplinary action.
care. Face coverings with vents should not be utilized
as they do not appropriately contain the respiratory or
oral droplets.
Staff disinfect and clean all shared equipment (e.g., 22 One facility made available sanitizing wipes and other
radios, keys, handcuffs, service weapons, perimeter cleaning supplies at housing unit officer stations,
vehicle driver compartment) several times throughout among other locations. Laminated instructions were
tour of duty and at beginning/end of tour of duty. placed at housing unit officer stations detailing
cleaning expectations. Additionally, weekly emails are
disseminated to all staff explaining the expectations
for cleaning shared equipment.
Inmates in medical isolation are evaluated for 20 Health Services staff were educated on completing
symptoms and temperature daily by a clinician. and documenting symptom checks with temperature
checks for inmates in medical isolation. An audit tool
was developed to oversee these efforts, and audits
are conducted and submitted weekly.
In open/barracks-style housing, bunks should be 20 A town hall was conducted by the Unit Managers in
separated as much as possible and sleeping all units informing the inmate population of the
orientation should alternate head to foot. requirement to alternate sleeping orientation. A poster
was created and hung up in all the units illustrating
the proper sleeping positions.
Source: GAO analysis of BOP data. | GAO-21-502
Following its first round of inspections, the inspection team also compiled
and shared recommendations and best practices for preventing or
reducing transmission of COVID-19 with all BOP facilities. Specifically,
Page 55 GAO-21-502 BOP Response to COVID-19
the team compiled a list of 75 best practices for various COVID-19
response and mitigation categories. For example, one best practice for
infection control practices included designating areas for physical
distancing with markings and assigning responsibility for controlling staff
movement to the front lobby officer. Another best practice, for staff
screening, included giving colored wrist bands to staff as their
temperature is checked.
While BOP has compiled the list of 75 best practices from its inspections,
it does not take steps to ensure these practices are applied, as
appropriate, across its facilities. According to BOP officials, they do not
oversee whether best practices are applied because individual wardens
have discretion on whether to adopt best practices identified from the
inspections. 51 Further, they view wardens as the best positioned to
determine which best practices and lessons learned are applicable and
should be implemented in their respective facilities.
While wardens may exercise judgment about each best practice or
lesson, BOP, at the Central Office level, has a role in overseeing the
efforts of its regional and facility-level operations and the extent that they
apply practices that would help them carry out BOP’s objectives of
ensuring safety of its staff and inmates. Without developing an approach
to ensure practices or lessons learned are applied as appropriate across
its facilities, BOP does not have reasonable assurance that its facilities
are improving their COVID-19 response as needed to effectively mitigate
the spread of the virus among staff and inmates.
In our prior work, we have identified eight practices that can be combined
as an overall eight-step, lessons learned process. 52 This process, as
illustrated in figure 18, is a systematic means for an agency to learn from
an event and make decisions about when and how to use that knowledge
to make a change in the behavior of the agency. These steps include
collecting and analyzing the lessons learned, as well as storing, archiving
and disseminating them, and determining whether to apply lessons.
51While BOP wardens have discretion on many aspects of their operations, such as
determining which best practices are applicable to their facility, BOP has established
requirements that are mandatory, such the screening of inmates and staff, and the use of
PPE and face coverings.
52GAO, Federal Real Property Security: Interagency Security Committee Should
Implement a Lessons-Learned Process, GAO-12-901 (Washington, D.C.: September 10,
2012).
Page 56 GAO-21-502 BOP Response to COVID-19
Figure 18: Steps for an Agency to Implement a Lessons Learned Process
Developing and implementing an approach for ensuring that lessons
learned and best practices—identified by the teleconferences as well as
the inspections—are applied at facilities, as appropriate, would help BOP
provide assurance that its facilities are actively improving COVID-19-
related response efforts when applicable. Further, BOP’s adoption of
such an approach could benefit the agency beyond its COVID-19
response, and could be used for other future public health emergencies.
Inmates and staff living and operating within the close confines of federal
Conclusions prisons are particularly vulnerable during infectious disease outbreaks.
With about 46,000 positive inmate cases and 237 inmate deaths related
to COVID-19 as of May 2021, and nearly 7,000 staff cases and four staff
deaths related to COVID-19 as of May 2021, COVID-19 has highlighted
key opportunities for BOP to better protect staff and inmates in response
to the current pandemic and any future public health emergencies.
Specifically, evaluating how BOP communicates its COVID-19 guidance
to facility staff, and modifying its approach as needed based on the
results, could help BOP ensure that BOP staff and inmates can clearly
understand the protocols and are able to follow them. The information
gained from such an evaluation would also position BOP to ensure a
more effective communication approach in future public health
emergencies as well. In addition, developing and implementing an
approach to capture and share best practices and lessons learned
discussed in regular information-sharing sessions could ensure facilities
are actively improving COVID-19 response efforts when applicable.
Further, developing and implementing an approach for ensuring lessons
learned and best practices are applied at facilities, as appropriate, could
Page 57 GAO-21-502 BOP Response to COVID-19
help BOP ensure facilities are sharing and receiving information to help
them respond effectively to a public health emergency.
We are making a total of three recommendations to BOP:
Recommendations for
Executive Action The Director of BOP should routinely evaluate how it communicates its
COVID-19 guidance to facility staff and modify its approach, as needed,
based on the results to ensure BOP protocols are clearly communicated
to staff. (Recommendation 1)
The Director of BOP should develop and implement an approach to
capture and share best practices and lessons learned for responding to
COVID-19 and future public health emergencies as discussed among
BOP officials at their regular teleconferences. (Recommendation 2)
The Director of BOP should develop and implement an approach for
ensuring its facilities are applying, as appropriate, best practices and
lessons learned related to COVID-19 and future public health emergency
response efforts. (Recommendation 3)
We provided a draft of this report to DOJ, BOP, HHS, and DHS for review
Agency Comments and comment. We also provided relevant excerpts of this report to the
and Our Evaluation Administrative Office of the United States Courts for review and comment.
DOJ, HHS, and the Administrative Office of the United States Courts
provided technical comments, which we incorporated as appropriate.
DHS had no technical comments. BOP provided written comments, which
are reproduced in appendix VII, as well as technical comments, which we
also incorporated as appropriate. In its comments, BOP concurred with all
three of our recommendations.
With respect to our first recommendation that BOP should routinely
evaluate how it communicates its COVID-19 guidance to staff and modify
its approach as needed, BOP agreed that continuous evaluation of its
efforts to communicate COVID-19 guidance is necessary to help ensure
BOP institutions are provided the most recent guidance in the most
effective manner. BOP also shared a number of steps it has taken to
disseminate guidance and clarify any aspects staff may have found
confusing. For example, BOP stated that it has established an email box
where staff can ask questions of BOP subject-matter experts. While these
and other actions BOP described are useful for clarifying understanding
about COVID-19 guidance, routinely evaluating how it communicates
such guidance to staff and modifying such approaches as needed, will
better position BOP to ensure it communicates the guidance as effectively
Page 58 GAO-21-502 BOP Response to COVID-19
as possible. For example, evaluating how BOP communicates guidance
could include such aspects as the timing of the guidance it provides, and
the mechanisms through which the guidance is communicated to staff.
With respect to our second and third recommendations that BOP develop
and implement an approach to (1) capture and share best practices and
lessons learned, and (2) ensure that facilities are applying them, as
appropriate, BOP agreed that capturing and sharing best practices is vital
to ensure continuous improvement in the current, and any future,
pandemic. BOP noted a number of efforts it has undertaken to identify
best practices and lessons learned, such as the COVID-19 Compliance
Review Teams and meetings with facility management staff, which we
described in our report. As we noted, these efforts have provided
important information for BOP to identify best practices and lessons
learned. In its letter, BOP also said it is planning an after-action
assessment of its pandemic response to help ensure preparedness for
any future public health emergencies. Such an assessment, once
complete, may help BOP further capture and share best practices and
lessons learned, and we will track BOP’s efforts to conduct this
assessment. By developing an approach for capturing and sharing best
practices and lessons learned, and ensuring they are applied as
appropriate, BOP could maximize the benefits of the knowledge and
experience gained bureau-wide while responding to the COVID-19
pandemic. Doing so will also help BOP ensure that facilities are actively
improving on their pandemic and other public health response efforts
based on the information provided.
Page 59 GAO-21-502 BOP Response to COVID-19
We are sending copies of this report to the appropriate congressional
requesters, the Attorney General, the BOP Director, the Secretary of the
Department of Health and Human Services, the Secretary of the
Department of Homeland Security, the Director of the Administrative
Office of the United States Courts, and other interested parties. In
addition, the report is available at no charge on GAO’s website at
https://www.gao.gov.
If you or your staff have any questions about this report, please contact
Gretta L. Goodwin at (202) 512-8777 or GoodwinG@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix VIII.
Gretta L. Goodwin
Director, Homeland Security and Justice
Page 60 GAO-21-502 BOP Response to COVID-19
List of Addressees
The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chair
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Jeanne Shaheen
Chair
The Honorable Jerry Moran
Ranking Member
Subcommittee on Commerce, Justice and Science, and Related
Agencies
Committee on Appropriations
United States Senate
Page 61 GAO-21-502 BOP Response to COVID-19
The Honorable Margaret Hassan
Chair
Subcommittee on Emerging Threats and Spending Oversight
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives
The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives
The Honorable Richard E. Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives
Page 62 GAO-21-502 BOP Response to COVID-19
The Honorable Matt Cartwright
Chairman
The Honorable Robert B. Aderholdt
Ranking Member
Subcommittee on Commerce, Justice, Science, and Related Agencies
Committee on Appropriations
House of Representatives
The Honorable Tammy Duckworth
United States Senate
The Honorable Fred Keller
House of Representatives
Page 63 GAO-21-502 BOP Response to COVID-19
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology
Methodology
Our objectives were to examine: (1) the extent to which the Federal
Bureau of Prisons (BOP) developed and updated guidance in response to
COVID-19, and coordinated with stakeholder agencies; (2) the status of
BOP’s provision of personal protective equipment (PPE), 1 tests, and
vaccines, and the COVID-19 infection and fatality rates for inmates and
staff; and (3) the overall impact of COVID-19 on inmates and staff, and
the extent to which BOP has incorporated lessons learned into its
ongoing response.
To address all three of our objectives we selected a non-generalizable
sample of five facilities from BOP’s total of 122, and one facility from the
total of 12 that BOP operated under contract with private providers in
2020. We then met with officials at each location, as well as union officials
representing each BOP-managed location, virtually from November 2020
through January 2021. We selected these facilities to achieve geographic
dispersion, a range of COVID-19 infection rates, a mix of facility security
levels, and variation in facility structures such as whether the facility had a
medical center or factory. 2
For each of the selected facilities, we held teleconferences with facility
management staff, including the facility warden, associate wardens, and
health services administrator, as well as with BOP union staff at the five
BOP-managed facilities. We also requested and reviewed documents,
such as facility-specific plans or memoranda for COVID-19 response, as
well as photographs representing various aspects of each facility’s
1PPE is protective garments or equipment designed to protect the wearer’s body from
injury or infection.
2We selected one facility to represent five of BOP’s six regions. We also interviewed
officials from a facility from the sixth region, but did not include it in our audit findings
because it was already covered under the scope of the Department of Justice Office of the
Inspector General audit. We also selected facilities to represent four BOP security levels—
low, medium, high, and administrative. We also selected facilities to include those with
high as well as low COVID-19 infection rates, with and without a medical center or factory,
and that were facing allegations related to their response to the pandemic. The six
facilities we selected were: Lexington Federal Medical Center; Florence Federal
Correctional Complex; Seagoville Federal Correctional Institution; Elkton Federal
Correctional Institution; Yazoo City Federal Correctional Complex; and Great Plains
Correctional Institution, which operated under contract with BOP. About four months after
our interview with Great Plains Correctional Institution, BOP’s contract with the facility
expired on May 31, 2021. Pursuant to Executive Order 14006, 86 Fed. Reg. 7483 (Jan.
26, 2021), the Attorney General was directed not to renew Department of Justice
contracts with privately operated criminal detention facilities, as consistent with applicable
law. As a result, BOP did not renew its contract and federal inmates are no longer being
housed at that facility.
Page 64 GAO-21-502 BOP Response to COVID-19
Appendix I: Objectives, Scope, and
Methodology
response to the pandemic. We excluded Residential Reentry Centers
because inmates living there, unlike those confined in prison, hold jobs in
the community, travel to and from their jobs, and engage with the
community beyond the confines of the facility. These inmates’ exposure
to COVID-19 is therefore well beyond the Residential Reentry Centers’
and BOP’s control. While results from our sample of facilities cannot be
generalized to all BOP facilities or all private facilities, they did provide
insight into BOP’s planning and response to the pandemic.
In addition to the interviews with BOP staff and officials described above
at each of our six selected facilities, we interviewed BOP officials from
several Central Office divisions, including Correctional Programs, Health
Services, Program Review, Reentry Services, and Administration. We
obtained information from these officials about issues such as BOP’s
policies for COVID-19 response, COVID-19 infection rates at various
BOP facilities, and the overall impact of the pandemic on inmates, staff,
and institutions. 3
Further, we interviewed four advocacy or research groups to obtain their
perspectives on topics such as BOP’s COVID-19 testing and home
confinement policies, as well as the impact of the COVID-19 pandemic on
inmates and staff. 4 We selected these groups because of their advocacy
for inmate safety and well-being, and the COVID-19 data analysis and
research they conducted. While information obtained from interviews with
these groups is not generalizable to all advocacy groups, it provides
useful insight into the overall impact of BOP’s response to the pandemic
on the inmate population. Finally, we interviewed officials from the
Federal Emergency Management Agency (FEMA), within the Department
of Homeland Security, and the Administrative Office of the United States
Courts to learn about their coordination with BOP in responding to the
pandemic.
3BOP’s Correctional Programs Division provides policy direction and daily operational
oversight of facility correctional services. The Health Services Division is responsible for
health care delivery, infectious disease management, and medical designations of
inmates in BOP facilities. The Program Review Division provides oversight of BOP
program performance and compliance, while Reentry Services prepares inmates for
reentry by providing oversight and direction of inmate reentry programming and
community resource transition. Lastly, BOP’s Administration Division is responsible for the
Bureau’s financial and facility management.
4The four advocacy groups were JustLeadershipUSA, the University of California, Los
Angeles Behind Bars Data Project, Justice Roundtable, and the American Civil Liberties
Union.
Page 65 GAO-21-502 BOP Response to COVID-19
Appendix I: Objectives, Scope, and
Methodology
To address the part of our first objective that relates to the extent to which
BOP has developed or updated guidance in response to COVID-19, we
reviewed BOP policies and guidance for pandemic response, including
policies and guidance in BOP’s COVID-19 Pandemic Plan, Phased Action
Plans, and Modified Operations Plan, as well as facility-specific
procedural memoranda for pandemic response. We reviewed these plans
and interviewed officials to understand how BOP modified its response to
the pandemic based on guidance from the Centers for Disease Control
and Prevention (CDC) and how it communicated its guidance to facilities.
In addition, we assessed how BOP communicates its guidance against
internal control standards related to internal communication, specifically
standards that agencies evaluate and select appropriate methods to
communicate internally. 5
To address the other parts of our first objective, which relate to BOP’s
coordination with its stakeholder agencies, we took a number of steps.
Specifically, we reviewed documentation on BOP’s response to the
COVID-19 pandemic that BOP has with stakeholder agencies. We also
interviewed officials from stakeholder agencies to determine how they
coordinate with BOP and also interviewed officials from BOP’s Central
Office about how BOP coordinates its COVID-19 response policies with
stakeholder agencies, such as with United States Marshals Service
(USMS) on inmate transfers. To do this, we analyzed data on the number
of inmate transfers between BOP and USMS during the pandemic (March
2020 – February 2021) and chose this period to illustrate the impact that
the pandemic had on inmate transfers, particularly during the suspension
of transfers that occurred from March through July 2020. We assessed
the reliability of these data by checking the data for outliers or anomalies
and interviewed BOP officials responsible for inputting the data. We
determined that these data were reliable for the purposes of illustrating
trends and the impacts of the pandemic on various aspects of BOP’s
operations.
To address the first part of our second objective, we reviewed BOP
policies and data on the provision of PPE and vaccines from March 2020
through February 2021. We selected this period because it marks the
beginning of COVID-19 infections occurring in BOP prisons and an
appropriate cutoff time that allowed us to fully analyze the data to include
in our issued report. Specifically, we reviewed BOP data on PPE
5GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept 10, 2014).
Page 66 GAO-21-502 BOP Response to COVID-19
Appendix I: Objectives, Scope, and
Methodology
spending and distribution and found the data to be sufficiently reliable for
our purposes.
We reviewed BOP’s policies for testing inmates and staff for COVID-19.
Additionally, we interviewed officials from BOP’s Health Services Division,
as well as officials who are knowledgeable about these policies from each
of the selected six facilities. We also interviewed BOP union
representatives from each of the five BOP-managed facilities we
selected, as well as the four aforementioned advocacy or research
groups to obtain their perspectives on BOP’s policies and procedures for
distributing PPE and COVID-19 testing.
To address the second part of our second objective, we analyzed BOP
data on inmate and staff COVID-19 infections, recovery, and deaths for
March 2020 through February 2021. We also compared the number of
cases in each selected facility to the percent increase in cases in the
community surrounding each facility, which we defined as counties within
a 15-mile radius of the facility, from March 2020 through February 2021.
To determine the reliability of the COVID-19 data we checked the data for
obvious errors, omissions, and outliers. We also interviewed BOP officials
responsible for maintaining and updating the data. Based on our analysis
and these interviews, we determined that the aggregate counts on inmate
COVID-19 infections, recovery, and deaths across all BOP facilities were
sufficiently reliable for determining BOP inmate infection, recovery, and
fatality rates in BOP-managed and private prisons. 6 We determined that
data on infections, recovery, and deaths among staff, on the other hand,
were not reliable for determining infection, recovery, and death rates for
BOP staff predominantly because BOP does not test its staff for COVID-
19. Rather, BOP relies on staff to test on their own and report testing
outcomes to the bureau. As such, we report BOP’s counts, as opposed to
the rates of infection, recovery, and fatality among staff in this report.
To address our third objective, we reviewed reports of inspections the
Department of Justice (DOJ) Office of Inspector General (OIG) conducted
of BOP-managed facilities and private prisons to identify reported impacts
of the pandemic on inmates and staff. Specifically, we reviewed the
COVID-19 compliance inspections that the DOJ OIG conducted
6Inmate infection, recovery, and fatality rates were derived by calculating the number of
inmates who were infected, recovered or died from COVID-19 as a proportion of the
inmate population at the respective facilities for the specified month and year.
Page 67 GAO-21-502 BOP Response to COVID-19
Appendix I: Objectives, Scope, and
Methodology
throughout 2020. 7 We also interviewed officials from two of the facilities
the OIG inspected, as well as officials from several BOP divisions,
including Health Services and Correctional Programs. For the six facilities
we selected, we solicited facility management views on the impact of the
pandemic on inmates, staff and the facilities, including challenges these
facilities faced in their response to the pandemic. Further, for the five
BOP-managed facilities we selected, we also obtained perspectives on
the same topics from the union leaders.
To assess the impact on inmates of BOP’s use of its home confinement
authorities, we reviewed BOP’s policies and procedures pertaining to the
release of inmates to home confinement, as well as BOP program
statements on home confinement, and memoranda the Attorney General
issued to the BOP Director on home confinement. We also requested and
analyzed data for the year prior and the first year of the pandemic (March
2019 – February 2021) on the number of inmate transfers to home
confinement, including by race and ethnicity, and the legal authorities
used to approve the home confinement. We also analyzed data on BOP
inmate hospitalization counts for COVID-19 and non-COVID-19-related
conditions during the same period. We chose this period for both the
home confinement and the hospitalization data to show how the trends
during the pandemic compare to the year prior to the pandemic. We also
interviewed officials from BOP’s Central Office about BOP’s data
collection and reporting processes for the home confinement program
during the COVID-19 pandemic.
To determine how BOP is overseeing the pandemic response and
implementation of COVID-19 guidance by its institutions, we analyzed
reports of BOP facility inspections that the Program Review Division’s
COVID-19 Compliance Team conducted from August through September
2020. We reviewed these inspection reports to understand the checklist
the Compliance Team used to inspect the facilities, to learn more about
the team’s findings, and any recommended remediation.
7In response to COVID-19, DOJ OIG initiated a series of remote inspections of BOP
facilities, including BOP-managed institutions, contract prisons, and Residential Reentry
Centers. These inspections sought to determine whether these institutions were
complying with guidance related to the pandemic, including CDC guidelines, DOJ policy
and guidance, and BOP policy. These inspection reports can be viewed at
https://oig.justice.gov/reports/component/bop.
Page 68 GAO-21-502 BOP Response to COVID-19
Appendix I: Objectives, Scope, and
Methodology
To determine how BOP ensures that lessons learned are incorporated
into its policies and facilities’ procedures for responding to the pandemic,
we interviewed officials from BOP’s Central Office as well as from the six
facilities we selected. We also compared BOP’s policies for capturing and
incorporating best practices for COVID-19 response against eight
individual practices that we have previously identified that agencies can
apply to learn from an event and make decisions about when and how to
use that knowledge to change behavior. 8 Additionally, to provide some
context for BOP’s approach, we interviewed representatives of the
Correctional Leaders Association—the organizing body of state
departments of corrections—to obtain perspectives on state prisons’
response to COVID-19 and the organization’s practices for capturing and
sharing best practices and lessons learned.
We conducted this performance audit from April 2020 to July 2021 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
8GAO, Federal Real Property Security: Interagency Security Committee Should
Implement a Lessons-Learned Process, GAO-12-901 (Washington, D.C.: September 10,
2012).
Page 69 GAO-21-502 BOP Response to COVID-19
Appendix II: Release Timeline for Federal
Appendix II: Release Timeline for Federal
Bureau of Prisons’ (BOP) COVID-19 Phased
Bureau of Prisons’ (BOP) COVID-19 Phased
Action Plans, January-August 2020
Action Plans, January-August 2020
Page 70 GAO-21-502 BOP Response to COVID-19
Appendix III: Impacts of the Suspension of
Appendix III: Impacts of the Suspension of
Inmate Transfers During the COVID-19
Inmate Transfers During the COVID-19
Pandemic
Pandemic
As previously discussed, United States Marshals Service (USMS) is
responsible for maintaining custody of Federal Bureau of Prisons (BOP)
inmates before sentencing and transporting them to BOP custody after
sentencing. USMS has experienced four key challenges related to these
responsibilities during the pandemic, all resulting from BOP’s suspension
of inmate transfers from March 13, 2020, through July 2020. In particular,
our interviews with USMS officials and review of related documentation
indicate that USMS experienced: (1) overcrowding of its detention
centers, (2) delays for detainees in accessing BOP mental health services
while in its custody, (3) increased cost to detain a larger population, and
(4) increased risk of COVID-19 spreading.
Overcrowding of USMS detention centers. At the start of the
pandemic, in March 2020, BOP suspended inmate transfers in an effort to
slow the spread of COVID-19. However, the suspension worsened a
backlog the USMS was already experiencing of sentenced individuals
awaiting transfer to the BOP facilities in which they would be confined. As
a result, these inmates continued to occupy USMS bed space that is
typically dedicated to the pretrial population, which caused overcrowding
in USMS’s detention centers. Specifically, USMS had a backlog of
approximately 3,800 inmates when the pandemic began, and this backlog
reached its peak of approximately 9,000 inmates shortly after BOP lifted
the suspension in July 2020. According to USMS officials, as of May
2021, they continued to experience a backlog of approximately 5,800
inmates because the volume of weekly inmate transfers—while steadily
rising since BOP lifted the suspension—is only about 80 percent of the
pre-pandemic level of approximately 850.
Delays in inmates’ access to BOP mental health services. According
to USMS officials, the backlogs that USMS experienced also delayed
access to mental health evaluations for individuals who had been
sentenced and committed to specific BOP facilities, but who were
detained in USMS facilities awaiting their transfer. This is because access
to BOP mental health evaluations and other services are only available to
those confined in a BOP facility. These individuals also could not be
considered for compassionate release since residence in a BOP facility is
one of several eligibility criteria that are considered.
Increased costs of detention for USMS. USMS officials cited an
increase in expenditures that the agency incurred related to detaining this
increased population. According to USMS, as of April 3, 2021, the agency
had spent over $213 million in additional detention housing costs since
the onset of the pandemic in March 2020.
Page 71 GAO-21-502 BOP Response to COVID-19
Appendix III: Impacts of the Suspension of
Inmate Transfers During the COVID-19
Pandemic
Increased risk of COVID-19 spreading. Prior to the COVID-19
pandemic, in September 2007, USMS and BOP had joint protocols in
place for handling and transporting inmates; however these protocols did
not address transporting individuals with an infectious disease. In
developing their respective COVID-19 guidance, both agencies further
collaborated. According to USMS officials, during these interactions, BOP
shared its inmate intake, quarantine, testing, and transfer protocols with
USMS. Further, BOP provided USMS with testing equipment.
Although helpful, USMS officials said that they could not replicate these
BOP protocols or implement a formal Memorandum of Understanding
between the two agencies. This was because, unlike BOP, USMS does
not operate the approximately 1,000 facilities it utilizes—most of the
facilities used by the USMS are operated by state and local governments.
Accordingly, while the USMS can request that the facility operate
consistent with its detention standards, the USMS cannot prescribe
specific actions. Furthermore, as USMS officials explained, the majority of
these facilities do not have the physical space, health care staffing, on-
site testing capabilities, and national laboratory contracts for outside
testing that BOP facilities have. Instead, USMS took other measures to
help curb the spread of the virus, such as implementing requirements for
pre-departure COVID-19 screening at its facilities which were
incorporated into its Medical Transfer Summary form, and updating
transport protocols as the CDC issued updated guidance. USMS officials
stated that there were instances when USMS detainees tested positive
for COVID-19 upon arriving at a BOP facility. However, these occurred
before BOP’s and USMS’s respective measures and protocols for transfer
were in place, and officials noted that implementing these measures was
intended to help minimize such instances going forward.
Page 72 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Trends for Federal Bureau of Prisons (BOP)
Inmates
Inmates
As shown in figure 19 below, the percentage of inmate infections in BOP-
managed facilities peaked in December 2020, when there were 125 new
infections per every 1,000 inmates. Recoveries also peaked in that
month, with 105 new recoveries per every 1,000 inmates. This is
consistent with trends nationwide of COVID-19 cases peaking in
December 2020 and January 2021.
Figure 19: COVID-19 Infection Rates among Inmates Confined in Federal Bureau of Prisons-Managed Facilities
As shown in figures 20-22 below, the proportion of positive cases within
all recorded inmate demographic groups (ethnicity, race, and age)
peaked in December 2020 within BOP-managed facilities. For example,
in December 2020, there were 190 new infections of American Indian
inmates for every 1,000 American Indian inmates in BOP-managed
facilities. In the same month, there were 145 new infections of inmates
over 59 years old for every 1,000 inmates over 59. There were 160 new
cases in Asian or Pacific Islander inmates per every 1,000 Asian or
Pacific Islander inmates. Further, in nearly every month, infection rates
among older inmates (60 and over) were higher than among younger
inmates (under 60).
Page 73 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
Figure 20: COVID-19 Infection Rates among Inmates Confined in Federal Bureau of Prisons-Managed Facilities by Race
(March 2020-February 2021)
Page 74 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
Figure 21: COVID-19 Infection Rates among Inmates Confined in Federal Bureau of Prisons-Managed Facilities by Ethnicity
(March 2020-February 2021)
Page 75 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
Figure 22: COVID-19 Infection Rates among Inmates Confined in Federal Bureau of Prisons-Managed Facilities by Age (March
2020-February 2021)
As shown in figure 23 below, the number of new cases, recoveries, and
fatalities for inmates at private facilities varied month-to-month since the
beginning of the pandemic in March 2020. For example, in April 2020,
there were 71 new cases, 29 recoveries, and no fatalities; in August 2020
there were 113 new cases, 156 new recoveries, and two new fatalities;
and in January 2021 there were 278 new cases, 85 new recoveries, and
one new fatality. New cases in inmates in private facilities peaked in
December 2020 (282 cases). Private facilities had the highest number of
inmate fatalities in May and December 2020 (three fatalities), and the
highest number of recovered cases in December 2020 (257 recoveries).
Page 76 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
Figure 23: Total New COVID-19 Infection, Recovery, and Fatality Rates for Inmates in Private Prison Facilities Operating Under
Contract with the Federal Bureau of Prisons (March 2020-February 2021)
Note: Positive cases and their outcomes are both counted in this figure. For example, an inmate who
tested positive for COVID-19 in April 2020 and recovered in May 2020 would be counted both as a
Page 77 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
new positive case in April 2020 and as a recovery in May 2020. These data do not include inmates in
Residential Reentry Centers.
The percentage of inmate infections in private facilities peaked in
December 2020, as shown in figure 24 below, where there were 20 new
infections that month per every 1,000 inmates. Recoveries also peaked in
that month, with 18 new recoveries per every 1,000 inmates.
Figure 24: Inmate COVID-19 Infection Rates at Private Prison Facilities Operating Under Contract with the Federal Bureau of
Prisons (March 2020 – February 2021)
As shown in figures 25-27 below, similar to what was seen among BOP-
managed facilities, the proportion of positive cases within all recorded
inmate demographic groups (race, ethnicity, and age) peaked in
December 2020 or January 2021 within private facilities. For example, in
December 2020, there were 41 new infections of Asian or Pacific Islander
inmates for every 1,000 Asian or Pacific Islander inmates in private
facilities. In the same month, there were 38 new infections of inmates
over 59 years old for every 1,000 inmates over 59. Also like what was
seen among BOP-managed facilities, in nearly every month infection
rates among older inmates (ages 60 and older) were higher than for
Page 78 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
younger inmates (under 60). Generally, the differences in the monthly
infection rates for older inmates compared, to younger inmates at the
privately-managed facilities, were greater than in BOP-managed facilities.
Figure 25: Inmate COVID-19 Infection Rates at Private Prison Facilities Operating Under Contract with the Federal Bureau of
Prisons by Race (March 2020-February 2021)
Page 79 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
Figure 26: Inmate COVID-19 Infection Rates at Private Prison Facilities Operating Under Contract with Federal Bureau of
Prisons by Ethnicity (March 2020-February 2021)
Page 80 GAO-21-502 BOP Response to COVID-19
Appendix IV: Additional Data on Infection
Trends for Federal Bureau of Prisons (BOP)
Inmates
Figure 27: Inmate COVID-19 Infection Rates at Private Prison Facilities Operating Under Contract with Federal Bureau of
Prisons by Age (March 2020-February 2021)
Page 81 GAO-21-502 BOP Response to COVID-19
Appendix V: Comparison of COVID-19
Appendix V: Comparison of COVID-19 Positive
Cases at Selected Facilities to Cases in
Positive Cases at Selected Facilities to
Surrounding Counties
Cases in Surrounding Counties
As discussed previously, we did not detect a consistent relationship
between the infection rates of selected Federal Bureau of Prisons’ (BOP)
facilities we visited and those in surrounding communities. We compared
COVID-19 positive cases at each of the six facilities to the percent
increase in cases reported in counties within a 15-mile radius of each
facility, from March 2020 to February 2021. For some of the facilities we
analyzed, the trends in inmate cases followed a similar pattern to the
cases in the surrounding community, while for other facilities, the inmate
and community cases did not follow similar trends.
Federal Correctional The pattern in new cases at FCI Elkton, located in Lisbon, Ohio, was
Institution (FCI) Elkton consistently different from that of the surrounding area. While the facility
had a large increase in the number of cases from April to May 2020 (84 to
291 new cases), the surrounding area had a relatively stable number of
cases from April to May. In the surrounding counties, the cases increased
from June to July by 128 percent (from about 29 to 65 new cases per
day), while the number of new cases in the facility declined (from 379 to
189 in the month). From July to August, cases declined in both the facility
and the surrounding area. From September to October, the number of
new cases in the surrounding area increased by more than 150 percent
and from October to November increased by more than 360 percent,
while the number of new cases in the facility remained stable (less than
five new cases a month).
Federal Correctional The number of new cases at FCC Florence, located in Florence,
Complex (FCC) Florence Colorado, was similar to that of the surrounding area for some but not all
the months. For example, new cases at the facility and the surrounding
area increased from June to July 2020 by 159 percent. However, while
the rate of increase slowed in the surrounding area in August and
September, the number of new cases in the facility continued to increase.
The overall numbers of cases in the facility were very low each month
through October (17 or fewer), so small changes may appear large. From
September to October, the new cases in the surrounding community
increased by nearly five times (479 percent, from nine to 54 new cases a
day) and from October to November increased by over four times (422
percent, from 54 to 283 new cases a day). Cases spiked in the facility
soon after, with 134 cases in November and 516 cases in December
compared to just 10 cases in October.
Correctional Institution Cases between Correctional Institution Great Plains, located in Hinton,
Great Plains Oklahoma, and the surrounding community also peaked at inconsistent
times. Correctional Institution Great Plains reported 83 cases in May 2020
but no cases were reported in the facility in June (only one inmate was
Page 82 GAO-21-502 BOP Response to COVID-19
Appendix V: Comparison of COVID-19 Positive
Cases at Selected Facilities to Cases in
Surrounding Counties
tested in the facility in June). The highest number of cases occurred in
November (22 cases) and there were no cases in January or February
(only 11 inmates were tested in the facility in January and February
combined). The largest increase in the community was from June to July
when cases nearly doubled (increased by almost 90%) from 38 to 72 new
cases per day.
Federal Medical Center The infection rate at FMC Lexington, located in Lexington, Kentucky,
(FMC) Lexington followed the same pattern as the infection rate of the surrounding
community for some but not all the months. Specifically, there was a large
increase in cases in May 2020 at both the facility and in the surrounding
counties. Cases in the facility increased from 18 in April to 260 in May
and cases in the surrounding area increased by over 130 percent from
April to May. However, while cases nearly doubled in October (compared
to September) in the surrounding counties, there was not a similar
increase in the facility. Cases in the facility peaked in December (375 new
cases) and cases in the surrounding community peaked in January 2021
with an average of about 349 new cases each day.
Federal Correctional In both FCI Seagoville, located in Seagoville, Texas, and the surrounding
Institution (FCI) Seagoville area, the largest increase in new cases was from June to July 2020.
However, the surrounding area also had large increases in November
and December, while cases in the facility remained stable (25 and 10,
respectively).
Federal Correctional Cases in FCC Yazoo City, located in Yazoo City, Mississippi, and the
Complex (FCC) Yazoo surrounding community peaked at inconsistent times. While cases in FCC
Yazoo City peaked in May then declined, cases in the community peaked
City
in July 2020. Cases in the community peaked again in December and
January (increasing by over 70 percent from November to December),
while cases in the facility peaked in November (133 new cases during the
month) and January (113) and dipped in December (50) and February
(14).
Page 83 GAO-21-502 BOP Response to COVID-19
Appendix VI: Overview of Selected Facilities’
Appendix VI: Overview of Selected Facilities’
Response to COVID-19
Response to COVID-19
We selected a non-generalizable sample of five Federal Bureau of
Prisons (BOP)-managed facilities and one private facility operating under
contract with BOP. Between November 2020 and January 2021, we met
with staff and officials at each location virtually to discuss each facility’s
response to COVID-19. For each of our selected facilities, we held
teleconferences with facility management staff, such as facility wardens,
associate wardens, and health services administrators, as well as BOP
union staff where applicable. We also requested and analyzed
documents, as well as photographs representing various aspects of each
facility’s response to the pandemic, such as facility-specific plans and
memoranda for COVID-19 response, and pictures representing various
aspects of the facilities’ compliance with COVID-19 guidance such as for
social distancing. While results from our sample of BOP-managed and
private facilities cannot be generalized to all prison facilities, they provide
insight into BOP’s planning and response to the pandemic. Figure 28
illustrates the geographic location of each of our selected facilities,
including counties within a 15-mile radius of each facility.
Page 84 GAO-21-502 BOP Response to COVID-19
Appendix VI: Overview of Selected Facilities’
Response to COVID-19
Figure 28: Map of Federal Bureau of Prisons’ Facilities and Surrounding Counties Selected for Virtual Site Visits
Note: Surrounding counties include counties within a 15-mile radius of the selected facility.
Page 85 GAO-21-502 BOP Response to COVID-19
FACILITY CHARACTERISTICS
• Low security Federal Correctional Institution (FCI) with
Federal Correctional an adjacent low security satellite prison
Institution, Elkton • Approximately 1,465 inmates at time of interview
• Total COVID-19 recoveries at time of interview: 901
Lisbon, Ohio inmates, 54 staff
UNIQUE CHALLENGES
Federal Correctional Institution, Elkton
Facility management and staff at FCI Elkton
said: Mahoning
County
• The open floor plan and dormitory-style Beaver
housing units made it more difficult to Columbiana County
County Pennsylvania
implement COVID-19 protocols, such as social
distancing. Carroll
County Lawrence
• The facility did not have adequate funds to Ohio County
Jefferson
cover inmate medical care, personal protective County
equipment (PPE), sanitation supplies, and Hancock
County
overtime.
• The population is comprised of inmates whose West
health conditions make them more susceptible Virginia
to COVID-19.
Source: GAO. | GAO-21-502
• FCI Elkton implemented its own guidance and
procedures before Federal Bureau of Prisons FCI Elkton Built Housing Tents to Quarantine and Isolate
(BOP) issued phased action plans. Inmates
• The facility has been experiencing a shortage
of staff since 2005, which caused additional
staff overtime and non-correctional staff to be
reassigned to perform the duties of correctional
officers when correctional officers were
unavailable.
• Staff were confused about whether they
qualified for state-based hazard pay for
correctional workers.
LESSONS OFFICIALS LEARNED
Facility management shared that it was
valuable to:
• Educate inmates on the importance of
FCI Elkton used unconventional areas to quarantine and medically
reporting symptoms. isolate inmates. For example, facility staff built housing tents to
• Identify potential areas within the facility for provide additional quarantine and isolation space for inmates.
medical isolation and quarantine. Facility staff also moved beds from the housing units to the
medical isolation and quarantine areas.
• Draw on local resources early in its response
to the pandemic, such as coordinating with the Source: BOP. | GAO-21-502
local health department to establish lines of
communication.
Page 86 GAO-21-502 BOP Response to COVID-19
FACILITY CHARACTERISTICS
• Administrative, medium, and high security Federal Correctional
Federal Correctional Complex (FCC) with an adjacent minimum security satellite camp
Complex, Florence • Approximately 2,291 inmates at time of interview
• Total COVID-19 recoveries at time of interview: 176 inmates,
Florence, Colorado seven staff
UNIQUE CHALLENGES
Federal Correctional Complex, Florence
Facility management and staff at FCC Florence
said:
• The layout of the complex made it more
difficult to implement quarantine and Colorado
isolation procedures based on each facility’s
configuration and space limitations.
Fremont County
• Staffing issues were exacerbated by the
pandemic because the facility changed Utah
scheduling flexibilities to accommodate staff
on sick leave or quarantining from exposure to Custer County
COVID-19. Pueblo County
• Staff overtime was incurred depending on how
short-staffed the facility was over the course
Source: GAO. | GAO-21-502
of the pandemic, and staff routinely stepped
in to fill in for each other when asked to do so.
FCC Florence Installed a UV Lighting System to Reduce the
Some staff faced disciplinary action for refusing Spread of Bacteria
to work overtime.
• After testing positive for COVID-19, some
staff returned to work before the minimum
quarantine time period was reached because
they were not exhibiting symptoms. The facility
allowed staff to return to work if they were not
symptomatic.
LESSONS OFFICIALS LEARNED
Facility management shared that it was
valuable to:
• Coordinate with stakeholders and follow
Centers for Disease Control and Prevention
(CDC) guidance to mitigate spread among
inmates.
• Activate the facility’s incident command center
early in the response to the pandemic, such
as by coordinating with other facilities that
have been hit by COVID-19 to learn of their
response efforts.
• Follow CDC and Federal Bureau of Prisons
(BOP) guidance as it was issued, such as
for posting signage for social distancing and
keeping units clean through service workers. At the entrance of the facility, FCC Florence installed a “cleanse
portal” that uses ultraviolet (UV) lighting intended to sanitize
facility staff and visitors. Staff and visitors are instructed to stand
and rotate within the portal for 20 seconds to reduce surface
microbes before entering the facility.
Source: BOP. | GAO-21-502
Page 87 GAO-21-502 BOP Response to COVID-19
FACILITY CHARACTERISTICS
• Administrative security Federal Medical Center (FMC)
Federal Medical Center, with an adjacent minimum security satellite camp
Lexington • Approximately 1,120 inmates at time of interview
• Total COVID-19 recoveries at time of interview: 204
Lexington, Kentucky inmates, 28 staff
Mahoning
County
UNIQUE CHALLENGES
Federal Medical Center, Lexington
Facility management and staff at FMC Lawrence
County
Lexington said:
Illinois Indiana Ohio
• FMC Lexington faced supply chain and shipping
delays for acquiring personal protective Scott County West
equipment (PPE) early in the pandemic. Virginia
Franklin Bourbon
• FMC Lexington was strained by a reduction County County
in outside medical trips due to local hospitals’ Woodford Fayette
County
low capacity during COVID-19 outbreaks in County
Jessamine
the community, and as a result its medical staff Kentucky County
members’ workloads increased greatly.
• The Health Services Department modified work
Tennessee
schedules for medical staff and to help deliver
appropriate medical care to inmates.
Source: GAO. | GAO-21-502
• The facility received inmates who tested positive
upon being transferred to the facility, but the
facility has done a good job with isolating FMC Lexington Staff Screening Site
inmates who test positive.
• Staff shortages became chaotic when the
pandemic started, and some staff resorted to
using personal leave when their additional 80
hours of administrative leave was used up.
LESSONS OFFICIALS LEARNED
Facility management shared that it was
valuable to:
• Control the movement of the virus by modifying
staff schedules, assigning staff to specific work
areas, and reducing the number of inmates
that participated in programs and work groups.
• Adjust the facility’s prison factory shift
schedules, and use smaller work groups to
FMC Lexington’s staff screening site incorporated Federal
maintain social distancing. Bureau of Prisons’ (BOP) COVID-19 Enhanced Screening Tool
and a temperature check. Colored wrist bands mark staff who
successfully complete the screening, BOP’s COVID Compliance
Review Team cites this as a best practice for COVID-19 mitigation.
Source: BOP. | GAO-21-502
Page 88 GAO-21-502 BOP Response to COVID-19
FACILITY CHARACTERISTICS
• Low security Federal Correctional Institution (FCI) with an adjacent
Federal Correctional minimum security satellite camp and detention center
Institution, Seagoville • Approximately 1,745 inmates at time of interview
• Total COVID-19 recoveries at time of interview: 1,273 inmates, 37
Seagoville, Texas staff
UNIQUE CHALLENGES
Federal Correctional Institution, Seagoville
Facility management and staff at FCI Seagoville
said:
• Additional COVID-19 precautions were needed
Dallas Rockwall
in the facility’s prison factory, which produces County County
clothing and textiles, such as creating morning
and night shifts to ensure social distancing
Kaufman
between workers. Texas County
Ellis
• The facility has a lot of inmates with preexisting County
conditions, but some inmates would not report
COVID-19 symptoms early in the pandemic Louisiana
because they did not want modifications to their
living arrangements.
• Officials installed fans in the housing units to
Source: GAO. | GAO-21-502
help address the lack of air conditioning in some
parts of the facility, but said it was possible the FCI Seagoville Converted Facility Space into Temporary
fans could blow air droplets around the open Housing Units
dorms.
• Staff felt their input into facility decisions was
limited because the facility was operating under
“emergency” status during the pandemic.
LESSONS OFFICIALS LEARNED
Facility management shared that it was
valuable to:
• Promote teamwork in responding to outbreaks,
such as when some staff put together personal
protective equipment (PPE) packets for all
facility staff to pick up before engaging with
inmates.
• Support inmate health and wellness during
the summer months when some areas in the FCI Seagoville converted existing facility space into temporary
facility did not have air conditioning, such as housing units to quarantine and medically isolate inmates. For
purchasing additional supplies like sports example, staff converted the facility’s auditorium into a temporary
drinks and snacks. housing unit with a maximum capacity of 26 inmates. Facility staff
also provided inmates with portable showers and toilets for these
areas.
Source: Federal Bureau of Prisons. | GAO-21-502
Page 89 GAO-21-502 BOP Response to COVID-19
FACILITY CHARACTERISTICS
• Low, medium, and high security Federal Correctional Complex
Federal Correctional (FCC) with an adjacent minimum security satellite camp
Complex, Yazoo City • Approximately 3,789 inmates at time of interview
• Total COVID-19 recoveries at time of interview: 181 inmates,
Yazoo City, Mississippi 31 staff
UNIQUE CHALLENGES
Federal Correctional Complex, Yazoo City
Facility management at FCC Yazoo City said:
• Although the facility had to purchase personal Missouri Georgia
protective equipment (PPE) early on in the Holmes
Humphreys
pandemic, as the pandemic continued the facility County
County
became a warehouse for BOP’s southeast
region logistics hub.
• Officials observed cases of inmates hiding Sharkey Yazoo
County County
their symptoms until they became severely ill,
because inmates perceived COVID-19 isolation
as punitive. Louisiana Mississippi
• The facility experienced a decrease in staff
who were available to work shifts because of
alternative work flexibilities granted for some
Source: GAO. | GAO-21-502
staff, such as to pregnant staff or staff with
medical conditions.
FCC Yazoo City Staff Sanitize Inmate Transport Vehicles
LESSONS OFFICIALS LEARNED
Facility management at FCC Yazoo City shared
that it was valuable to:
• Utilize good communication practices through
different platforms, such as telephone and
video conferencing, to regularly disseminate
information to staff and inmates.
• Hold informal monthly meetings to share
best practices and lessons learned with other
facilities.
• Ensure the facility’s command center
documents all relevant COVID-19 response
efforts to support compliance with relevant
guidance.
Federal Bureau of Prisons’ (BOP) COVID-19 Compliance Review
Team recommended that facilities incorporate procedures for
disinfecting transport vehicles for COVID-19 positive inmates. FCC
Yazoo City staff used “escort sanitation kits” to disinfect surfaces
in inmate transportation vehicles.
Source: BOP. | GAO-21-502
Page 90 GAO-21-502 BOP Response to COVID-19
FACILITY CHARACTERISTICS
• A federal contracted private prison, operated by GEO
Correctional Institution, Group, Inc.
Great Plains • Approximately 1,526 inmates at time of interview
• Total COVID-19 recoveries at time of interview: 166
Hinton, Oklahoma inmates, 72 staff
Fremont County
UNIQUE CHALLENGES
Correctional Institution, Great Plains
Facility management at Correctional Institution
Great Plains said:
• Facility management often would not wait for Blaine County
Federal Bureau of Prisons (BOP) to issue
technical direction for responding to the
pandemic, so the facility management had to Canadian
County
proceed with their own decisions so that their
facility could be more proactive in its response.
• The facility has not determined any inmates to Caddo County Oklahoma
be eligible for the home confinement program,
Missouri
because inmates in the facility are mostly on Texas
U.S. Immigration and Customs Enforcement
(ICE) immigration detainers and are therefore
not eligible for community-based release. An Source: GAO. | GAO-21-502
immigration detainer is a notice from ICE to a
Correctional Institution Great Plains Staff Follow BOP
federal, state, local, or tribal law enforcement
Policies on Staff Screening
agency articulating probable cause for
removability of an individual whom ICE requests
the agency to hold in order to potentially transfer
custody.
• The facility experienced some delays in
completing facility updates, repairs, and
inspections due to the pandemic.
LESSONS OFFICIALS LEARNED
Facility management shared that it was
valuable to:
• Educate staff and inmates about Centers
for Disease Control and Prevention (CDC)
COVID-19 guidance and prevention strategies,
including consistent enforcement of related
policies.
• Monitor personal protective equipment (PPE)
inventory and cleaning supplies so that facility
management could replenish the stockpile
quickly and prevent shortages.
• Assign staff to specific facility areas to perform BOP issued guidance to private facilities that direct these facilities
to follow similar COVID-19 response procedures, such as those for
work rather than multiple units in the facility, to staff screening. Correctional Institution Great Plains staff use the
reduce the risk of COVID-19 transmission. same COVID-19 Enhanced Screening Tool and temperature check
procedures as BOP-managed facilities.
Source: BOP. | GAO-21-502
About four months after our interview with Correctional Institution Great Plains, BOP’s contract with the facility expired on May 31, 2021. Pursuant to Executive Order
14006, which was signed on January 26, 2021, and directed the Attorney General to not renew Department of Justice contracts with privately operated criminal detention
facilities, BOP did not renew its contract and federal inmates are no longer being housed at that facility.
Page 91 GAO-21-502 BOP Response to COVID-19
Appendix VII: Comments from Federal
Appendix VII: Comments from Federal Bureau
of Prisons
Bureau of Prisons
Page 92 GAO-21-502 BOP Response to COVID-19
Appendix VII: Comments from Federal Bureau
of Prisons
Page 93 GAO-21-502 BOP Response to COVID-19
Appendix VII: Comments from Federal Bureau
of Prisons
Page 94 GAO-21-502 BOP Response to COVID-19
Appendix VII: Comments from Federal Bureau
of Prisons
Page 95 GAO-21-502 BOP Response to COVID-19
Appendix VII: Comments from Federal Bureau
of Prisons
Page 96 GAO-21-502 BOP Response to COVID-19
Appendix VIII: GAO Contact and Staff
Appendix VIII: GAO Contact and Staff
Acknowledgments
Acknowledgments
Gretta L. Goodwin at (202) 512-8777 or GoodwinG@gao.gov
GAO Contact
In addition to the contact named above, Joy Booth (Assistant Director),
Staff Edith Sohna (Analyst-in-Charge), Julia Vieweg (Analyst-in-Charge), Emily
Acknowledgments Flores, Kellen Wartnow, and Tamera Lockley made key contributions to
this report. In addition, key support was provided by Mariel Alper, Billy
Commons, Benjamin Crossley, Dominick Dale, Elizabeth Dretsch, Philip
Farah, Susan Hsu, Susan Irving, Taylor Matheson, Sara Ann
Moessbauer, and Leah Nash.
Page 97 GAO-21-502 BOP Response to COVID-19
Related GAO Products
Related GAO Products
Immigration Detention: ICE Efforts to Address COVID-19 in Detention
Facilities. GAO-21-414. Washington, D.C.: June 30, 2021.
COVID-19: Federal Air Marshal Service Should Document Its Response
to Cases and Facilitate Access to Testing. GAO-21-595. Washington,
D.C.: June 23, 2021.
Border Security: CBP’s Response to COVID-19. GAO-21-431. June 14,
2021.
COVID-19: TSA Could Better Monitor Its Efforts to Reduce Infections
Disease Spread at Checkpoints. GAO-21-364. Washington, D.C.: June
14, 2021.
COVID-19: Sustained Federal Action is Crucial as Pandemic Enters Its
Second Year. GAO-21-387. Washington, D.C.: March 31, 2021.
COVID-19: Key Insights from GAO’s Oversight of the Federal Public
Health Response. GAO-21-396T. Washington, D.C.: February 24, 2021.
COVID-19: Critical Vaccine Distribution, Supply Chain, Program Integrity,
and Other Challenges Require Focused Federal Attention. GAO-21-265.
Washington, D.C.: January 28, 2021.
COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal
Response. GAO-21-191. Washington, D.C.: November 30, 2020.
(104483)
Page 98 GAO-21-502 BOP Response to COVID-19
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