BOP Program Statement 1212.01 § 2

a. General. Reports generated by external auditing authorities have significant direct impact on

all levels of Bureau operations. The leadership of all Bureau components, including divisions,

regions, and facilities, must be thoroughly familiar with the Bureau’s external audit procedures

and maximize the Bureau’s responsiveness to external auditor requests and recommendations.

DCO is responsible for ensuring responses to external audit authorities are coordinated, timely,

and high quality.

Ordinarily, information provided by a Bureau component in response to an external auditor

request should first be sent to DCO, who will review and vet the information before providing it

to the requesting external auditors.

Prior to submission to DCO, draft responses to requests or recommendations from external audit

authorities shall be approved by the pertinent or responsible Assistant Director, Regional

Director, or Warden to ensure the information collected appropriately reflects the Bureau or

component’s position.

After the external audit authority issues its final audit report with recommendations for

corrective action, the pertinent Bureau components must take steps to implement applicable

corrective actions and provide detailed updates to DCO, including the implementation timeline

and supporting documentation. DCO will ensure the external auditing authority is provided

timely, informative updates on the actions taken to address the recommendations.

b. Entrance and Exit Conferences. To ensure consistency and maximize the Bureau’s

coordination and presentation for all external auditing engagements, the Bureau components

participating in an external audit must have appropriate subject matter expert (SME) and Senior

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Executive Leadership representation at entrance and exit conferences with auditors. Senior

Executive Leadership is defined as Assistant Director, Regional Directors, Wardens, Senior

Deputy Assistant Directors, Deputy Assistant Directors, and Deputy Regional Directors. Senior

Executive Leadership and SMEs must also be present at any scheduled preparation meetings for

the entrance and exit conferences to discuss proposed remarks prior to engaging with the external

auditors.

c. Submissions to External Auditors. The Bureau is required to submit information and

written responses to external auditors throughout the audit engagement. Those submissions

include the responses to data and document requests during the data gathering phase, technical

comments and a formal response signed by the Bureau Director in response to draft reports, and

status updates on open recommendations after the external auditor issues the final report. Data

requests may include interviews and site visits.

DCO coordinates the Bureau’s compliance with these submission requirements by requesting

responses from applicable Bureau components and finalizing any written response to the external

audit authority, including obtaining the appropriate signatures.

d. Audit Deadlines. It is essential to adhere to deadlines set by DCO, which are designed to

meet external audit deadlines while factoring in time to consolidate, review, and vet component

responses and supporting documentation.

Any request to extend an external audit deadline must be approved by the Assistant Director of

DCO. This authority may be delegated to the Senior Deputy Assistant Director of DCO. If a

component requires a deadline extension, the component must submit a written request to the

DCO Management Analyst assigned to the engagement as soon as possible, including a proposed

alternative deadline and an explanation for why the current deadline cannot be met.

e. Inspections. Ordinarily, the Bureau receives prior notification of an external auditor's intent

to or inspect a particular site, but on occasion, auditors may arrive unannounced. If this occurs,

the CEO of the facility being inspected must advise the DCO Senior Deputy Assistant Director

upon learning of the inspection for coordination purposes.

f. Federal Prison Oversight Act. On July 25, 2024, Congress passed the Federal Prison

Oversight Act (FPOA), P.L. 118-71. The FPOA establishes an inspections routine wherein OIG

conducts periodic inspections of all Bureau facilities, utilizing a risk score methodology to

review conditions of confinement and working conditions of staff. The FPOA also requires OIG

to submit a final report six months after its inspection. The Bureau has 60 days to issue a

response with its corrective actions plans.

Additionally, the FPOA requires the establishment of an independent Ombudsman whose

primary duty is to receive complaints from inmates, family advocates, representatives, staff, staff

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representatives, Congress, and judges regarding the health, safety, and welfare or rights of an

inmate and make determinations on the action to take regarding the complaint.

The Ombudsman will communicate any decisions to the complainant and the Bureau. The

Ombudsman is granted access to all Bureau facilities and, if they request, the Bureau must

respond to any inquiry or a request for information and inform any action(s) taken. The Bureau is

required to produce records to the Ombudsman within 30 days, and within 10 days if the record

pertains to the death of a staff member or inmate, threats of bodily harm (sexual or physical), or

the delay or denial of necessary medical care.