BOP Program Statement 3721.07 § 3

a. Each Warden will appoint a member of the institution’s Executive Staff who is not an officer

of the organization to hold the responsibility for monitoring the activities of employee

organizations. The staff member assigned must be no lower than the Associate Warden level.

The designated person must have the authority to recommend whatever administrative action is

necessary to achieve compliance with Bureau policy and audit findings. The action may range

from temporary to permanent suspension of employee organization activities on Bureau

property. The employee organization is to receive written notice of such recommendations and

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must have the opportunity to respond. Any sanction taken must be commensurate with the

violation(s) detected and the number of violations and must be approved by the Warden.

Continued noncompliance will be dealt with by increasing the severity of sanctions.

b. The designated person is responsible for providing written certification to the Warden, no

later than the 25th day of the first month of each quarter, certifying the following actions for the

previous quarter have been taken:

 All financial statements were submitted accurately and promptly.

 All financial reports were reviewed with the Business Administrator.

 An independent audit was conducted when required.

 The audit was reviewed with the Business Administrator (if the audit was performed

during the quarter); and

 All deficiencies noted in the last Bureau compliance audit were corrected, and if not, a

plan of action exists to correct and ensure compliance with Bureau policy. An update on

unresolved deficiencies is required each quarter.

c. The designated person is responsible for ensuring the following have been forwarded to the

Regional Comptroller by the last day of the first month of each quarter, except as noted:

 A current copy of the institution supplement (as applicable when changed).

 A current copy of constitution/by-laws (as applicable when changed).

 Quarterly and annual statements as required.

 A copy of the merchandise inventory.

 A copy of the bill and evidence of payment to Trust Fund for their percentage of vending

income, which is 15 percent of the profits received from Class 1 vending machine sales.

 Annual certification from the Warden on the status of organizations.

 Annual audit.

 A copy of the quarterly certification by the designated person responsible for

organization.

 Tax information - copies of all reports filed including 1099’s, as applicable.

d. Regional Oversight. Upon receipt of the required statements and certifications from each

institution having employee organizations, the Comptroller must ensure these documents are

reviewed and meet all financial requirements contained in this program statement.

 The Comptroller must ensure files are maintained at each institution and they include at a

minimum the following documentation:

 A copy of the institution supplement.

 A copy of the current constitution and by-laws.

 Warden’s annual certification on the status of the organization.

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 Quarterly certification by the designated person responsible for the organization.

 Quarterly and annual statements, as required.

 Annual audit report.

 Tax information - copies of all reports filed, including 1099’s.

 Documentation of Regional Office review to include evidence of proper payment to

Trust Fund of the rebate of vending machine income as required.

 Any documentation to show requests for the correction of deviations noted during a

review and the responses from the institution.

 After a review of the annual statements and certifications by the Warden, the Comptroller

must provide the Chief, Finance Branch, with a summary report on employee

organizations, including any deviations from these requirements as noted and identified

by the facility. The report must include the plans to correct these deviations. This

summary report is due no later than June 30th for the previous calendar year.