MEMORANDUM FOR	RAYMOND J. BEAUDET ASSISTANT INSPECTOR GENERAL FOR AUDIT OFFICE OF THE INSPECTOR GENERAL
FROM:	Harley G. Lappin, Director Federal Bureau of Prisons
SUBJECT:	Response to the Office of Inspector General’s (OIG) Draft Audit Report: Department of Justice Key Indicators

The Bureau of Prisons (BOP) appreciates the opportunity to comment on and respond to the recommendations from the OIG’s draft audit report entitled Department of Justice Key Indicators.

The Bureau’s responses to the recommendations are provided below.

Recommendation #8: Disclose within the data limitations section of the PAR, the states that do not participate in the FBI's III, and that the results reported in the PAR do not include all federal and state crimes committed and arrests in these states and Washington, D.C.; in the alternative, revise the key indicator "Comparative Recidivism Rates for FPI Inmates versus Non-FPI Inmates" to address this data limitation.

Response: This recommendation is not relevant to the BOP, as we are not using FBI III data. The BOP will resubmit the following FY 2007 update to the "Data Collection and Storage" section of the MD&A to the DOJ, and request it be included in the FY 2008 data: "Data is gathered from the BOP's operational computer system (SENTRY), and is analyzed by the BOP's Office of Research and Evaluation."

The BOP will also request the following substitution be made to the "Data Definition" section: "Data Definition: Recidivism means a tendency to relapse into a previous mode of behavior, such as criminal activity resulting in arrest and incarceration. The definition of recidivism employed for this performance measure is return to BOP custody due to conviction for a new offense." Since it is the DOJ's responsibility for ensuring this information is updated appropriately, we request this recommendation be closed.

Recommendation #9: Disclose within the data limitations section of the PAR the data lag between the time an inmate is arrested and when the information is entered into the state's record management system or into SENTRY for the key indicator "Comparative Recidivism Rates for FPI Inmates versus Non-FPI Inmates."

Response: Same as Recommendation #8. We request this recommendation be closed.

Recommendation #10: Evaluate the cause of the FY 2006 overstatement and implement procedures to ensure the rate of assaults in federal prisons per 5,000 inmates is accurately reported in the future for the key indicator "Rate of Assaults in Federal Prisons (Assaults per 5,000 Inmates)."

Response: Based on information provided to OIG during the exit conference on February 15, 2008, OIG notified the BOP (via attached E-mail) that Recommendation #10 would be included in the final report, however, in the last appendix "Analysis and Summary of the Status Necessary to Close the Report," the status of the recommendation will be shown as closed. Therefore, no additional information is required. We consider this recommendation closed.

Recommendation #11: Examine the accuracy of their MD&A narratives covering the key indicators and verify supporting information necessary to ensure the accuracy of the key indicator performance data. Additionally, component management should notify staff of the significant need for accuracy of the key indicator information presented in the MD&A for the PAR.

Response: The agency has a review process to ensure MD&A performance measures and the narratives which describe them are accurate. Furthermore, all of the measures used in the computation of the Bureau’s key indicator performance measures are a by-product of the agency’s operational data needs. The PAR performance measures are computed from data extracted directly from the agency’s operational data systems for the express purpose of computing these performance measures. The use of operational data increases the accuracy of the performance data as they are scrutinized on a daily basis during routine operational practice. This ensures these performance data have operational validity and accuracy. We request this recommendation be closed.

If you have any questions regarding this response, please contact VaNessa P. Adams, Senior Deputy Assistant Director, Program Review Division, at (202) 616-2099.

Attachment