Central Inmate Monitoring System and Separation Assignments (Program Statement 5180.05)

By Elizabeth Franklin-Best, Esq., and Christopher Zoukis, JD, MBA

Field	Value
Program Statement	5180.05
Subject	Central Inmate Monitoring System (PS only)
Effective / current edition	12-31-2007
Change notices	None. BOP’s published policy list carries 5180.05 with no change notice. The 12/31/2007 document is itself a reformatting: “This is an electronic re-issuance for technical reasons only. There are no substance or word changes to the document” — PS 5180.05 at p. 2.
Supersedes	The Directives Rescinded block lists PS 1436.08, Secret Service Liaison and Surveillance (12/02/88), and PS 5180.03, Central Inmate Monitoring System (09/14/90) — PS 5180.05 at p. 3. That block was carried forward unchanged from the earlier edition; the signature is Kathleen M. Hawk, Director, and the referenced directives are all 1987–1996 editions.
Governing statute	The Program Statement cites none for the CIM system itself. It lists 18 U.S.C. §§ 1961–1968 (RICO) and 21 U.S.C. § 848 (continuing criminal enterprise) among its referenced directives (p. 3). The Bureau’s underlying placement and transfer authority is 18 U.S.C. § 3621(b).
28 C.F.R. anchor	28 C.F.R. part 524, subpart F, §§ 524.70–524.76 — “Central Inmate Monitoring (CIM) System.” The Program Statement says so itself at p. 3: “Rules cited in this Program Statement are contained in 28 CFR 524.70-76.” Verified section by section.
Related BP forms	None published. The policy refers to a “notification form” that the person signs for and receives a copy of (p. 5), but assigns it no BP number and BOP does not post it. The challenge route uses BP-A0148 (Inmate Request to Staff) and then BP-9 / BP-10 / BP-11.
Official PDF	bop.gov/policy/progstat/5180_005.pdf

Checked against the BOP policy set · 2026-09-06.

The Central Inmate Monitoring System — everyone inside says “CIM” — is the Bureau of Prisons flag that says a particular person’s movements need a higher level of sign-off than usual. If you have a CIM assignment, a transfer, a court trip, a furlough or a halfway-house placement cannot be approved by the ordinary staff member who would normally approve it; it has to be cleared by the Warden, the Regional Office or Central Office first, depending on which assignment you carry.

A CIM assignment is not a punishment and it is not a security level. It says nothing about your custody classification, your prohibited-act record or your good conduct time. The most common one people encounter — and the one that generates the most confusion and the most blocked transfers — is a Separation assignment, which means the Bureau has identified specific other people you may not be housed with. Those people are called your separatees. If your immediate concern is safety on the compound rather than paperwork, start with Protective Custody; this page explains the monitoring system and how a CIM assignment is made, reviewed and challenged.

The rule itself: CIM assignments

Everything in this section is transcribed from the Bureau’s own text at bop.gov/policy/progstat/5180_005.pdf.

Read the brackets — the Program Statement tells you which words are law

PS 5180.05 uses a convention that most Bureau policies of its era share and that almost nobody outside the agency notices. At the bottom of p. 2 it states the key:

[Bracketed Bold – Rules] Regular Type – Implementing Information

Text inside square brackets is the regulation — the published rule in 28 C.F.R. that went through notice and comment and that binds the Bureau. Text outside the brackets is the Bureau’s internal instruction to its own staff. In the mirrored text and in the PDF, the bracketed sections carry their C.F.R. section number right in the heading: [PURPOSE AND SCOPE §524.70, [CIM ASSIGNMENT CATEGORIES §524.72, [APPEALS OF CIM CLASSIFICATION §524.76, and so on.

This matters practically. When you quote the bracketed language, you are quoting a regulation. When you quote the unbracketed language, you are quoting policy. Every quotation below is labeled.

What the system is for

PS 5180.05 at p. 2, bracketed — this is 28 C.F.R. § 524.70 verbatim:

1. [PURPOSE AND SCOPE §524.70. The Bureau of Prisons monitors and controls the transfer, temporary release (e.g., on writ), and community activities of certain inmates who present special needs for management. Such inmates, known as central inmate monitoring (CIM) cases, require a higher level of review which may include Central Office and/or Regional Office clearance for transfers, temporary releases, or community activities. This monitoring is not to preclude a CIM case from such activities, when the inmate is otherwise eligible, but rather is to provide protection to all concerned and to contribute to the safe and orderly operation of federal institutions.]

That last sentence is the one to hold onto: monitoring “is not to preclude a CIM case from such activities, when the inmate is otherwise eligible.” It is a clearance requirement, not a bar.

Immediately following it, in unbracketed staff-instruction type:

Detailed instructions and guidelines for implementation of the Central Inmate Monitoring System are contained in the CIM Operations Manual. The CIM manual is designated as “Limited Official Use Only” and shall be maintained in accordance with the Program Statement on Directives Management.

That is why this Program Statement carries “(PS only)” in its title. There is a second document — the CIM Operations Manual — and it is not public. The Bureau’s own policy index carries it separately as PS 5180.06, Central Inmate Monitoring System (Operations Manual Only). Do not expect to obtain it.

The seven CIM assignment categories

PS 5180.05 at pp. 4–5, bracketed throughout — this is 28 C.F.R. § 524.72, transcribed exactly. The regulation’s text was verified independently against eCFR and matches word for word.

7. [CIM ASSIGNMENT CATEGORIES §524.72. CIM cases are classified according to the following assignments:

a. Witness Security Cases. Individuals who agree to cooperate with law enforcement, judicial, or correctional authorities, frequently place their lives or safety in jeopardy by being a witness or intended witness against persons or groups involved in illegal activities. Accordingly, procedures have been developed to help ensure the safety of these individuals. There are two types of Witness Security cases: Department of Justice (authorized by the Attorney General under Title V of Public Law 91-452, 84 Stat. 933); and Bureau of Prisons Witness Security cases (authorized by the Assistant Director, Correctional Programs Division).

b. Threats to Government Officials. Inmates who have made threats to government officials or who have been identified, in writing, by the United States Secret Service as requiring special surveillance.

c. Broad Publicity. Inmates who have received widespread publicity as a result of their criminal activity or notoriety as public figures.

d. Disruptive Group. Inmates who belong to or are closely affiliated with groups (e.g., prison gangs), which have a history of disrupting operations and security in either state or federal penal (which includes correctional and detention facilities) institutions. This assignment also includes those persons who may require separation from a specific disruptive group.

e. State Prisoners. Inmates, other than Witness Security cases, who have been accepted into the Bureau of Prisons for service of their state sentences. This assignment includes cooperating state witnesses and regular state boarders.

f. Separation. Inmates who may not be confined in the same institution (unless the institution has the ability to prevent any physical contact between the separatees) with other specified individuals who are presently housed in federal custody or who may come into federal custody in the future. Factors to consider in classifying an individual to this assignment include, but are not limited to, testimony provided by or about an individual (in open court, to a grand jury, etc.), and whether the inmate has exhibited aggressive or intimidating behavior towards other specific individuals, either in the community or within the institution. This assignment also includes those inmates who have provided authorities with information concerning the unauthorized or illegal activities of others. This assignment may also include inmates from whom there is no identifiable threat, but who are to be separated from others at the request of the Federal Judiciary or U.S. Attorneys.

g. Special Supervision. Inmates who require special management attention, but who do not ordinarily warrant assignment in paragraphs (a) through (f) of this section. For example, this assignment may include an inmate with a background in law enforcement or an inmate who has been involved in a hostage situation. Others may include those who are members of a terrorist group with a potential for violence.]

One unbracketed gloss follows the Witness Security paragraph, PS 5180.05 at p. 4:

The vast majority of witness security (WITSEC) cases are those authorized by the Attorney General. Both types of WITSECs are treated similarly while in Bureau custody.

Reading paragraph (f) closely. The Separation category is the broadest of the seven and the one most people encounter, so it is worth slowing down on. Four different things are inside it, and they are not the same thing:

• People who testified, or about whom testimony was given, “in open court, to a grand jury, etc.”
• People who “exhibited aggressive or intimidating behavior towards other specific individuals,” in the community or in the institution.
• People who “provided authorities with information concerning the unauthorized or illegal activities of others.”
• People “from whom there is no identifiable threat, but who are to be separated from others at the request of the Federal Judiciary or U.S. Attorneys.”

That last clause is the one nobody expects. A separation assignment can exist with no allegation of any kind against the person carrying it, simply because a judge or a prosecutor asked for it. The most common real-world source is a multi-defendant case: co-defendants are routinely separated from one another regardless of who did what.

Note also what paragraph (f) does not say. It does not say separatees can never be at the same institution. It says they may not be confined together “unless the institution has the ability to prevent any physical contact between the separatees.” That carve-out is why the answer to “can we be at the same prison” is sometimes yes and sometimes no depending on the facility’s layout.

How the assignment is made

PS 5180.05 at p. 5, bracketed — 28 C.F.R. § 524.73(a):

8. [CLASSIFICATION PROCEDURES §524.73

a. Initial assignment. Except as provided for in paragraphs (a)(1) through (4) of this section, an inmate (including pretrial inmates) may be classified as a CIM case at any time by a Community Corrections Manager or by appropriate staff at the Central Office, Regional Office, or institution. This initial classification is effective upon documentation in the inmate’s record.

Four categories are carved out of that general rule, PS 5180.05 at pp. 5–6:

Carve-out	Who may make the initial assignment, in the regulation’s words	Pin-cite
Witness Security Cases	“Witness Security cases are designated by the Central Office only. An inmate’s participation in the Department of Justice Witness Security Program is voluntary. A commitment interview and an admission and orientation interview are to be conducted with the Witness Security inmate to ensure that the inmate understands the conditions of confinement within the Bureau of Prisons. Central Office classification of an individual as a witness security case, under either the Department of Justice or Bureau of Prisons, does not require additional review, and overrides any other CIM assignment.”	PS 5180.05 at p. 5
State Prisoners	“Appropriate staff in the Central Office or Regional Office designate state prisoners accepted into the Bureau of Prisons from state or territorial jurisdictions. All state prisoners while solely in service of the state sentence are automatically included in the CIM system to facilitate designations, transfers, court appearances, and other movements.”	PS 5180.05 at pp. 5–6
Special Supervision	“Placement in this assignment may be made only upon the authorization of a Regional Director or the Assistant Director, Correctional Programs Division.”	PS 5180.05 at p. 6
Recommitted Offenders	“An inmate who is recommitted to federal custody, who at the time of release was classified as a CIM case, retains this classification pending a review of the CIM status in accordance with paragraph (c) of this section.”	PS 5180.05 at p. 6

Two consequences worth naming. A State Prisoner CIM assignment is automatic and carries no implication of anything — it is a records-management flag so the Bureau can move people whose sentences it did not impose. And a CIM assignment follows you back in after a release and a new commitment, until it is reviewed.

Notification — what you are entitled to be told, and what you are not

PS 5180.05 at p. 6, bracketed — 28 C.F.R. § 524.73(b). This is the passage that answers most family questions:

b. Notification. The case manager shall ensure that the affected inmate is notified in writing as promptly as possible of the classification and the basis for it. Witness Security cases will be notified through a commitment interview. The notice of the basis may be limited in the interest of security or safety. For example, in separation cases under §524.72, notice will not include the names of those from whom the inmate must be separated. The inmate shall sign for and receive a copy of the notification form. If the inmate refuses to sign the notification form, staff witnessing the refusal shall indicate this fact on the notification form and then sign the form. Notification is not required for pretrial inmates. Any subsequent modification of a CIM assignment or removal from the CIM system requires separate notification to the inmate.]

Then, immediately below it and outside the brackets — this is Bureau instruction, not regulation, and it is the single most useful sentence on this page:

28 CFR 524.72 refers to Section 7 of this Program Statement. For purposes of this Program Statement, “prompt” has been defined as within 30 days of classification.

The regulation says “as promptly as possible” and stops. The 30-day definition exists only in the Program Statement. That is a genuine distinction with a practical consequence: a person who is notified on day 45 can point to the Bureau’s own internal standard, but is not pointing to a rule with the force of a regulation. Say “the Bureau’s own policy defines prompt as within 30 days,” not “the regulation requires notice within 30 days.”

Four other points from that paragraph:

• You get a copy. The notification form is signed for and a copy is provided. Ask for it if you did not receive one.
• Refusing to sign changes nothing. Staff note the refusal and sign it themselves; the assignment stands.
• You will not be told the names. In separation cases, “notice will not include the names of those from whom the inmate must be separated.” This is written into the regulation itself, not invented by staff.
• Every change gets its own notice. A modification or a removal “requires separate notification to the inmate.”

Initial review, and who reviews what

PS 5180.05 at pp. 6–7, bracketed — 28 C.F.R. § 524.73(c):

c. Initial Review. A classification may be made at any level to achieve the immediate effect of requiring prior clearance for an inmate’s transfer, temporary release, or participation in community activities. Except for Central Office or Regional Office classification of an individual as a state prisoner in sole service of the state sentence or for classification of pretrial inmates made by designated staff at the institution, a review by designated staff (ordinarily within 60 days of notification to the inmate) is required to determine whether a sound basis exists for the classification. Staff making the initial classification shall forward to the reviewing authority complete information regarding the inmate’s classification. An inmate not notified of a change in the classification by the reviewing authority within 60 days from the date of the initial notification may consider the CIM classification final.

The reviewing authorities, transcribed from the same passage:

Reviewing authority	What it reviews, verbatim	Pin-cite
Central Office Inmate Monitoring Section	“reviews classification decisions for all future separation assignments (including recommitments) for Witness Security cases and for any combination of assignments involving Witness Security cases.”	PS 5180.05 at p. 6
Regional Office	“reviews CIM classification decisions for Disruptive Group, Broad Publicity, Threat to Government Officials, Special Supervision, State Prisoners not in sole service of state sentence and initial multiple assignments except Witness Security cases.”	PS 5180.05 at p. 7
Warden, or Designee	“reviews CIM classification decisions for all separation assignments.”	PS 5180.05 at p. 7

One unbracketed clarification follows, PS 5180.05 at p. 7: “Warden refers to Chief Executive Officer and includes Community Corrections Managers.”

The sentence that does the most work here is the last one in the regulation: “An inmate not notified of a change in the classification by the reviewing authority within 60 days from the date of the initial notification may consider the CIM classification final.” Sixty days of silence is the point at which the assignment is settled — and, practically, the point at which the administrative-remedy clock is no longer waiting on anything.

Removal

PS 5180.05 at p. 7, bracketed — 28 C.F.R. § 524.73(d):

d. Removal

(1) Because participation in the Department of Justice Witness Security Program is voluntary, such participants may request removal from this assignment at any time. Such request shall be forwarded to the Central Office Inmate Monitoring Section. Actual removal of the CIM assignment will not occur until after approval from the Department of Justice is received.

(2) The reviewing authority is responsible for determining if removal or modification of any CIM classification other than a Department of Justice Witness Security case is appropriate. The inmate retains the CIM classification pending a decision by the reviewing authority.

(3) When an inmate is removed for any reason from a CIM classification (for example, because the reviewing authority either disapproves the CIM classification or approves removal of a CIM classification based on new information), the appropriate staff member shall ensure that the relevant portions of the inmate central file are either removed or, when part of a larger document, are amended to clearly reflect removal of the CIM assignment. Staff shall notify the inmate of the decision and document any change in the inmate’s record, and supportive documentation and the written basis for removal are to be retained in the inmate privacy file.]

Paragraph (3) is a records provision that people miss. Removal is not just an entry in SENTRY — the regulation directs that the central file itself be cleaned up or amended, with the supporting documentation moved to the privacy file. If an assignment was removed and old paperwork is still driving decisions, that paragraph is the one to cite.

Who clears a trip, a transfer or a furlough

PS 5180.05 at p. 7, bracketed — 28 C.F.R. § 524.74:

9. [ACTIVITIES CLEARANCE §524.74

a. Except as provided for in paragraph (b) of this section, the Warden is the clearance authority on all transfers, temporary releases, community activities, and escorted trips.

b. Witness Security Cases. Central Office Inmate Monitoring Section staff shall be the clearance authority on all transfers, temporary releases, community activities, and escorted trips for Witness Security cases, except in a medical emergency. In a medical emergency, the Warden may transfer a Witness Security case to a local hospital for emergency medical care without prior clearance.]

Unbracketed staff instruction follows at p. 8:

The Inmate Monitoring Section, Central Office (or during non-business hours, the Central Office Duty Officer) is to be notified immediately when a WITSEC inmate receives an emergency escorted medical trip. Central Office clearance must be obtained prior to any extended period of hospitalization.

Institution authorization to proceed will be entered into SENTRY. A permanent record of the authorization is to be maintained in the inmate’s central file, privacy folder.

Periodic review and the right to appeal

PS 5180.05 at p. 8, bracketed — 28 C.F.R. § 524.75:

10. [PERIODIC REVIEW §524.75. The Warden shall ensure that the status of an inmate’s CIM assignment is considered at each program review. When staff believe that removal or modification of the CIM classification is appropriate, the institution’s CMC and the appropriate reviewing authority must be notified. Only the reviewing authority shall determine if removal or modification of the CIM classification is appropriate.]

And PS 5180.05 at p. 8, bracketed — 28 C.F.R. § 524.76, the whole of it:

11. [APPEALS OF CIM CLASSIFICATION §524.76. An inmate may at any time appeal (through the Administrative Remedy Program) the inmate’s classification as a CIM case. Inmates identified as Witness Security cases may choose to address their concerns directly to the Inmate Monitoring Section, Central Office, rather than use the Administrative Remedy Program.]

Two sentences, and both are regulation. “At any time” — there is no window that closes on the right to challenge the assignment itself, and § 524.75 puts the status in front of the Warden at every program review. That is the strongest procedural language on this page, and it is the reason a CIM problem should never be treated as too old to raise.

The local rules you cannot see

PS 5180.05 at p. 8, unbracketed:

13. INSTITUTION SUPPLEMENT. Each Warden shall develop an Institution Supplement that includes local procedures and identifies staff responsible for an institution’s CIM program. A copy of the Institution Supplement shall be forwarded to the respective Regional Office for approval within 120 days from the issuance of this Program Statement. The Institution Supplement shall be marked as “Limited Official Use Only.”

Every institution has local CIM procedures, and they are marked Limited Official Use Only. So is the balance of the document: PS 5180.05 at p. 9 carries a full-page notice that “THE REMAINDER OF THIS PROGRAM STATEMENT HAS BEEN DESIGNATED AS LIMITED OFFICIAL USE ONLY AND CANNOT BE REPRODUCED OR DISTRIBUTED WITHOUT THE CONSENT OF THE CENTRAL INMATE MONITORING SYSTEM ADMINISTRATOR.” What is published is what appears above. Anyone offering you the rest of it is not quoting bop.gov.

What binds and what does not in PS 5180.05

A Program Statement is the Bureau’s internal instruction to its own staff. It is not a regulation. The Supreme Court described the difference in Reno v. Koray, 515 U.S. 50 (1995), noting that a Bureau interpretation appearing “only in a ‘Program Statement]’ — an internal agency guideline — rather than in ‘published regulations subject to the rigors of the Administrative Procedure] Act, including public notice and comment'” is “akin to an ‘interpretive rule’ that ‘do[es] not require notice and comment,'” though “still entitled to some deference.”

PS 5180.05 is the cleanest illustration of that line in the entire policy set, because the Bureau marked the boundary itself. Here is where each side falls.

Binding regulation — 28 C.F.R. §§ 524.70–524.76, every bracketed passage above: the seven assignment categories and their definitions; who may make an initial assignment and the four carve-outs; the written-notice provision and the rule that separatee names are withheld; the 60-day initial review and the three reviewing authorities; the removal and central-file amendment provisions; the clearance authorities; periodic review at each program review; and the right to appeal a CIM classification “at any time” through the Administrative Remedy Program.

Policy only, not regulation — the unbracketed text: the definition of “prompt” as within 30 days; the existence and confidentiality of the CIM Operations Manual; the SENTRY entry and central-file/privacy-folder recordkeeping instructions; the WITSEC emergency-trip notification procedure; the note that “Warden” includes Community Corrections Managers; and the Institution Supplement requirement.

What courts have said about the assignment itself. The leading appellate decision is Pugliese v. Nelson, 617 F.2d 916 (2d Cir. 1980), which held that “a prisoner’s interest in avoiding CMC classification does not entitle him to due process protections.” The court reasoned that the Bureau’s policy “does not limit in any way the Attorney General’s discretion to grant or to deny the benefits of furloughs, transfers, work releases and participation in community programs,” and that “a prisoner’s mere expectation of benefits associated with non-CMC status does not amount to a statutory or constitutional entitlement sufficient to trigger due process protections.” Pugliese construed the 1970s-era policy under the then-governing statutes, but its core point has held: a CIM assignment is a management classification, and there is no constitutional hearing right attached to it.

That is not the same as saying nothing can be done. It means the leverage is procedural and administrative — the notice provision, the 60-day review, the periodic review at every program review, and the appeal right that never closes — rather than constitutional.

The Privacy Act question, because it always comes up. A CIM assignment lives in the Inmate Central File, and the natural instinct is to demand that a wrong entry be corrected under the Privacy Act. That route is largely closed. Under 28 C.F.R. § 16.97(j), the “Inmate Central Records System (JUSTICE/BOP-005)” is exempt “pursuant to 5 U.S.C. 552a(j) and (k) from subsections (c)(3) and (4); (d); (e)(1), (2), (3), (4)(G), (H), and (I), (5), (8); (f); and (g)” — which includes both the amendment provision and the accuracy duty. The D.C. Circuit applied that exemption in Skinner v. U.S. Department of Justice, 584 F.3d 1093 (D.C. Cir. 2009), holding that the Bureau “exempted its Inmate Central Records System from § 552a(d)’s amendment provision,” and that “that exemption prevents us from ordering the amendment of an inmate’s records.”

Two openings survive. The regulation itself provides that “[w]here compliance would not appear to interfere with or adversely affect the law enforcement process, and/or where it may be appropriate to permit individuals to contest the accuracy of the information collected, the applicable exemption may be waived, either partially or totally, by the BOP” (§ 16.97). And § 16.97 separately records that “the BOP has initiated a procedure whereby federal inmates in custody may gain access and review their individual prison files maintained at the institution of incarceration,” limited where disclosure would jeopardize internal decision-making, the privacy rights of others, or “a legitimate correctional interest of security, custody, or rehabilitation.” In practice that means: ask to review the file, and challenge the assignment through the administrative remedy route the CIM regulation itself provides — not through a Privacy Act amendment demand. See FOIA and Privacy Act Requests.

Applied Insight — Christopher Zoukis, JD, MBA, Managing Director: The most common CIM problem is not a wrong assignment. It is a stale one. Separation assignments get entered when a case is active and then sit in the file long after the co-defendant has been released, deported, or died. Nothing purges them automatically. What the regulation gives you is 28 C.F.R. § 524.75 — the Warden “shall ensure that the status of an inmate’s CIM assignment is considered at each program review” — and § 524.76’s right to appeal “at any time.” Put the request on the program-review agenda in writing before the review, not after, and ask the Case Management Coordinator specifically whether the reviewing authority has been asked to consider removal. Under § 524.73(d)(2), the CMC and the unit team cannot remove it themselves; only the reviewing authority can. Knowing that is the difference between a request that goes somewhere and one that stops at the unit.

What a CIM assignment means for you

If you are the person inside: which assignment, and who reviews it

Find out which assignment you have and who reviews it. Those are two different facts and they determine everything else. Ask your case manager, in writing on a BP-A0148 Inmate Request to Staff — a “cop-out” — for a copy of your CIM notification form and for the CIM assignment currently reflected in SENTRY. Under § 524.73(b) you signed for that form and were entitled to a copy. Then match your assignment to the reviewing-authority table above: separation assignments are reviewed by the Warden or a designee; Disruptive Group, Broad Publicity, Threat to Government Officials, Special Supervision and non-sole-service State Prisoner assignments are reviewed by the Regional Office; anything involving Witness Security goes to the Central Office Inmate Monitoring Section.

Understand what it does and does not do. It does not raise your security level — that is a separate calculation under Security Designation and Custody Classification. It does not put you in the Special Housing Unit. It does not disqualify you from programs. What it does is add a clearance step to transfers, temporary releases, community activities and escorted trips, and § 524.70 says in terms that the monitoring “is not to preclude a CIM case from such activities, when the inmate is otherwise eligible.”

You will not get the names. Section 524.73(b) says notice “will not include the names of those from whom the inmate must be separated,” and that is regulation, not a staff choice. Do not spend a cop-out asking for them. Spend it asking whether the assignment has been reviewed, when, by whom, and whether removal has been submitted to the reviewing authority.

Raise it at every program review, and use the appeal right. Section 524.75 puts your CIM status in front of the Warden at each program review; § 524.76 lets you appeal the classification “at any time” through the Administrative Remedy Program. Together those are the two levers that actually exist. See Unit Team and Program Review and Administrative Remedy Program.

If you are the family member: why a transfer was blocked

Here is what you are probably seeing. A transfer that was approved at the institution has not happened. A halfway-house date slipped. A visit was denied for someone on the list. Nobody will explain why, and the explanation you do get is a sentence long.

Often the reason is a CIM assignment, and often nobody at the institution is being evasive — they genuinely cannot approve the thing themselves. Under § 524.74 the Warden is the clearance authority on transfers, temporary releases, community activities and escorted trips, and for Witness Security cases the Central Office holds that authority. A request sitting at a Regional Office or in Central Office review looks exactly like a request being ignored.

Two things you can usefully do. First, stop asking why and start asking where: which CIM assignment is on the file, and which reviewing authority holds it. Your loved one can get that answer with a cop-out; you generally cannot get it by calling the institution, and staff will not discuss another person’s file with you. Second, keep dated notes of what you are told and by whom. When an administrative remedy is eventually filed, a specific chronology is what makes it answerable.

One thing to brace for: a separation assignment does not mean anyone has accused your loved one of anything. Under § 524.72(f) it can exist “from whom there is no identifiable threat,” at the request of a judge or a U.S. Attorney — which is the ordinary handling for co-defendants in a multi-defendant case. Our plain-language pages are Protective Custody, Inmate Visitation, and Federal Prison Problems.

If you are counsel: CIM and separation assignments

Three points.

Get the paper before you argue. The documents that exist are the CIM notification form the client signed under § 524.73(b); the SENTRY assignment record; the reviewing authority’s determination under § 524.73(c); and, on a removal, the “supportive documentation and the written basis for removal” that § 524.73(d)(3) directs be retained in the privacy file. The Operations Manual and the Institution Supplement are Limited Official Use Only and will not be produced. Route requests through the unit team first and through FOIA and the Privacy Act where staff will not produce; expect the Inmate Central Records System exemption at 28 C.F.R. § 16.97 to be asserted against any amendment demand, per Skinner.

Set expectations about the claim. Pugliese v. Nelson, 617 F.2d 916 (2d Cir. 1980), forecloses the intuitive due-process framing: a CIM assignment is not a liberty interest, and the Program Statement establishing procedures does not create one because it “simply does not disturb the Attorney General’s discretion.” Under Koray, a departure from PS 5180.05 is not itself a cause of action. The bracketed regulatory text is the stronger ground — a failure to provide the written notice § 524.73(b) directs, or a total failure to conduct the § 524.73(c) review, is a regulatory non-compliance argument rather than a policy complaint. Frame it accordingly, and exhaust first: under the Prison Litigation Reform Act, 42 U.S.C. § 1997e(a), no action may be brought about prison conditions until available administrative remedies are exhausted.

Watch for the sentencing-stage and cooperation overlaps. A separation assignment arising from cooperation is not the only record of that cooperation, and the practical consequences — designation, programming, halfway-house placement — begin at designation, not at arrival. Where a client’s exposure is foreseeable, the useful work happens before self-surrender. See Substantial assistance under § 5K1.1, Federal proffer agreements, and Preparing for Prison.

What changed with Program Statement 5180.05

Very little, and that is the finding.

PS 5180.05 is dated 12/31/2007, but it is not a 2007 policy. Its cover page at p. 1 is a memorandum from the Directives Manager explaining a formatting project: “Starting in May of 2006, the Office of National Policy Management began reformatting policies that contain change notices. With the rapid growth in word processing and electronic distribution via Sallyport and the internet, many of these WordPerfect 5.0 documents have become unstable. No word or substance changes have or will be made to any of these documents. To avoid confusion these documents will be re-issued electronically with a new number and new date.” The header at p. 2 repeats the point: “This is an electronic re-issuance for technical reasons only. There are no substance or word changes to the document.”

Three tells confirm it. The Directives Rescinded block at p. 3 lists PS 1436.08 (12/02/88) and PS 5180.03 (09/14/90) — a rescission list from the early 1990s, carried forward unchanged. The signature block at p. 8 is Kathleen M. Hawk, who served as Director from 1992 to 2003. And every referenced directive at p. 3 is a 1987–1996 edition. So the substantive text of this policy is roughly thirty years old, and the December 2007 date is a file-format date.

The regulation, by contrast, is current — and it matches. Each bracketed section of the Program Statement was checked against the live text of 28 C.F.R. part 524, subpart F. Sections 524.70, 524.72, 524.73, 524.74, 524.75 and 524.76 match the Program Statement’s bracketed language word for word. The eCFR shows an effective date of December 29, 2016 for each section in the subpart. Whatever that amendment did, the operative text a reader relies on today is the text the Program Statement carries.

What has drifted is everything the policy points at. The referenced directives at p. 3 have almost all been replaced. The current editions that matter to a CIM problem:

Named in PS 5180.05 at p. 3	Current edition on BOP’s policy list	Our explainer
PS 1330.13, Administrative Remedy System for Inmates (12/22/95)	PS 1330.18, Administrative Remedy Program	Administrative Remedy Program
PS 5100.06, Security Designation and Custody Classification Manual (06/07/96)	PS 5100.08, Inmate Security Designation and Custody Classification	Security Designation and Custody Classification
PS 5267.05, Visiting Regulations (07/21/93)	PS 5267.09, Visiting Regulations	Visiting Regulations
PS 5270.07, Inmate Discipline and Special Housing Units (12/29/87)	PS 5270.09 (discipline) and PS 5270.12 (SHU)	Inmate Discipline Program · Special Housing Units
PS 5280.07, Furloughs (06/23/95)	PS 5280.09, Furloughs	Furloughs
PS 5321.06, Unit Management Manual (07/31/96) and PS 5322.09, Classification and Program Review of Inmates (03/10/94)	PS 5321.09, Unit Management and Inmate Program Review	Unit Team and Program Review
PS 5800.09, Inmate Central File, Privacy Folder, and Parole Mini-Files (07/21/93)	PS 5800.17, Inmate Central File, Privacy Folder, and Parole Mini-Files	Inmate Central File, Privacy Folder, and Parole Mini-Files
PS 1315.05, Legal Activities, Inmate (06/13/94)	PS 1315.08, Inmate Legal Activities	Inmate Legal Activities

Two structural changes the 1990s text does not reflect. The Community Corrections Manager (CCM), who appears in § 524.73(a) as an official who may make an initial CIM classification and in the p. 7 gloss on “Warden,” no longer exists under that title: PS 5140.44 (2/16/2024) records in its Summary of Changes at p. 2 that “Community Corrections Manager changed to Residential Reentry Manager (RRM).” And most designation and redesignation work — the process a CIM clearance now sits inside — has moved to the Designation and Sentence Computation Center in Grand Prairie, Texas, as PS 5100.08 CN-3 records at p. 7. See BOP Grand Prairie.

Finally, one thing that grew up beside CIM and is not part of it: the Communications Management Unit. CMUs postdate this policy entirely and have their own regulation — 28 C.F.R. § 540.200(a) states that “[t]his subpart defines the Federal Bureau of Prisons’ (Bureau) authority to operate, and designate inmates to, Communications Management Housing Units (CMUs) within Bureau facilities.” A CMU designation and a CIM assignment are different mechanisms with different rules and different appeal routes, and people conflate them constantly. See Communications Management Units (PS 5214.05).

Where people get stuck with CIM and separation assignments

Four problems recur. Each has a route, and the route matters more than the complaint.

“Every transfer request I file gets denied and nobody says why.” This is the signature CIM problem. The first step is not another transfer request; it is finding out which assignment is on the file and which authority must clear it. Ask on a BP-A0148 Inmate Request to Staff for your CIM assignment and a copy of the § 524.73(b) notification form. Then ask the Case Management Coordinator — the CMC is the staff member § 524.75 names — whether removal or modification has been submitted to the reviewing authority. Under § 524.73(d)(2), only the reviewing authority can act, so a unit team that agrees with you still has to send it up. See Request to Staff and Federal Inmate Transfer Process.

“The separation is from someone who left years ago.” Stale separation assignments are the single most common substantive CIM issue, and nothing removes them automatically. The regulation gives two hooks: § 524.75 puts the assignment in front of the Warden “at each program review,” and § 524.76 permits an appeal “at any time.” Put a written request on the program-review agenda in advance, stating the assignment, the approximate date it was entered, and the specific change in circumstances. If nothing moves, file the formal ladder: BP-9 to the Warden, BP-10 to the Regional Director, BP-11 to the Office of National Inmate Appeals, under 28 C.F.R. part 542, subpart B. The deadlines are short — 28 C.F.R. § 542.14(a) sets “20 calendar days following the date on which the basis for the Request occurred,” and § 542.15(a) allows 20 calendar days for the BP-10 and 30 for the BP-11, with extensions “[w]hen the inmate demonstrates a valid reason for delay.” Because § 524.76 permits an appeal of the classification at any time, the running of that 20-day clock is a question worth raising expressly in the BP-9 rather than assuming. BOP publishes BP-A0148 but does not publish the BP-9, BP-10 or BP-11 forms; you get those from your unit team. See Prison Grievances.

“I never got a notice, or I got it months late.” Under § 524.73(b) the notification is written, it is signed for, and a copy goes to the person classified — that is regulation. The 30-day definition of “prompt” is Program Statement language, so frame the complaint accordingly: the regulation directs written notice of the classification and the basis for it, and the Bureau’s own policy defines prompt as within 30 days of classification. Ask for the form. If none exists, say so in the BP-9 in exactly those words. Note the carve-out in the same paragraph: “Notification is not required for pretrial inmates.”

“They told me it was removed, but it is still blocking things.” Section 524.73(d)(3) is the provision for this: on removal, staff “shall ensure that the relevant portions of the inmate central file are either removed or, when part of a larger document, are amended to clearly reflect removal of the CIM assignment,” and shall “notify the inmate of the decision and document any change in the inmate’s record.” A removal that never reached the file is a documented regulatory failure, not a misunderstanding. Ask for the written removal decision and for confirmation that the central file was amended. See Inmate Central File, Privacy Folder, and Parole Mini-Files.

Where the underlying problem is designation, sentence computation, medical care or safety on the compound, the administrative-remedy path is necessary but rarely sufficient on its own. Those belong in a consult — see Federal Prison Consulting Services or contact us. Exhaustion also matters if court is ever a possibility: under the Prison Litigation Reform Act, 42 U.S.C. § 1997e(a), no action may be brought about prison conditions until available administrative remedies are exhausted. “Exhaustion” means completing every level of the internal ladder, on time, before filing.

Related BOP policy on monitoring and separation

The paired information page is Protective Custody. That page covers what happens when someone is not safe in general population and what asking for protection actually involves; this page covers the records-and-clearance system that sits behind separation decisions. They answer different halves of the same question and each links to the other.

Policies that meet this one directly: Security Designation and Custody Classification (PS 5100.08) — a CIM assignment is not a security level, and confusing the two is the most common error in this area. Unit Team and Program Review (PS 5321.09) — where § 524.75’s periodic review actually happens. Administrative Remedy Program (PS 1330.18) — the route § 524.76 names by regulation. FOIA and Privacy Act Requests (PS 1351.05) — the records route, and the place the Inmate Central Records System exemption is explained.

Policies a CIM assignment touches: Furloughs (PS 5280.09) and Temporary Release: Furlough Requests for temporary releases; Halfway House Placement Procedures (PS 7310.04) for community placement; Visiting Regulations (PS 5267.09) for visits; Special Housing Units (PS 5270.12) and Inmate Discipline Program (PS 5270.09) for the separate systems people confuse with CIM; Correctional Systems Manual (PS 5800.15) for state boarders and detainers; and Communications Management Units (PS 5214.05) for the mechanism people most often mistake for CIM.

Further reading on our site: Solitary Confinement and Special Housing Units, Violence and Sexual Assault in Prison, Securing the Right Transfer in the Federal Bureau of Prisons, and Special Administrative Measures (SAMs).

Frequently Asked Questions About Central Inmate Monitoring

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Program Statement 5180.05 — full text

What follows is the Bureau of Prisons’ own text, reproduced in full from the agency’s published PDF. Nothing has been summarized or condensed. Source: Program Statement 5180.05 (bop.gov).

Starting in May of 2006, the Office of National Policy Management began reformatting policies that contain change notices. With the rapid growth in word processing and electronic distribution via Sallyport and the internet, many of these WordPerfect 5.0 documents have become unstable. No word or substance changes have or will be made to any of these documents. To avoid confusion these documents will be re-issued electronically with a new number and new date. Thank you for your patience during this conversion process and please give me a call if you have any questions or concerns. Robin Gladden Directives Manager (202) 616-9150

U.S. Department of Justice Federal Bureau of Prisons &&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&& OPI: CPD NUMBER: 5180.05 DATE: 12/31/2007 SUBJECT: Central Inmate Monitoring System This is an electronic re-issuance for technical reasons only. There are no substance or word changes to the document . ))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))) 1. [PURPOSE AND SCOPE §524.70. The Bureau of Prisons monitors and controls the transfer, temporary release (e.g., on writ), and community activities of certain inmates who present special needs for management. Such inmates, known as central inmate monitoring (CIM) cases, require a higher level of review which may include Central Office and/or Regional Office clearance for transfers, temporary releases, or community activities. This monitoring is not to preclude a CIM case from such activities, when the inmate is otherwise eligible, but rather is to provide protection to all concerned and to contribute to the safe and orderly operation of federal institutions.] Detailed instructions and guidelines for implementation of the Central Inmate Monitoring System are contained in the CIM Operations Manual. The CIM manual is designated as “Limited Official Use Only” and shall be maintained in accordance with the Program Statement on Directives Management. 2. PROGRAM OBJECTIVES. The expected results of this program are:

a. Inmates who meet specified criteria will be given Central

Inmate Monitoring assignments so that critical decisions about their cases are carefully reviewed.

b. Inmates who have been sentenced and have been classified as

Central Inmate Monitoring cases will be notified of that fact, and the basis for it, in writing.

c. The status, identity, and location of Witness Security

cases will not be improperly disclosed.

d. The institution environment will be made safer by case

management decisions based on accurate information and sound correctional judgment.

e. The public will be protected from undue risk.

[Bracketed Bold – Rules] Regular Type – Implementing Information

12/31/2007 Page 2

3. DIRECTIVES AFFECTED

a. Directives Rescinded

PS 1436.08 Secret Service Liaison and Surveillance (12/02/88) PS 5180.03 Central Inmate Monitoring System (09/14/90)

b. Directives Referenced

PS 1221.64 Directives Management Manual (08/20/96) PS 1315.05 Legal Activities, Inmate (06/13/94) PS 1330.13 Administrative Remedy System for Inmates (12/22/95) PS 1480.03 News Media Contacts (10/07/94) PS 5100.06 Security Designation and Custody Classification Manual (06/07/96) PS 5264.06 Telephone Regulations for Inmates (12/22/95) PS 5265.09 Correspondence (01/04/96) PS 5267.05 Visiting Regulations (07/21/93) PS 5270.07 Inmate Discipline and Special Housing Units (12/29/87) PS 5280.07 Furloughs (06/23/95) PS 5290.07 Intake Screening (07/20/92) PS 5290.08 Admission and Orientation Program (04/20/93) PS 5321.06 Unit Management Manual (07/31/96) PS 5322.09 Classification and Program Review of Inmates (03/10/94) PS 5360.06 Religious Beliefs and Practices of Committed Offenders (08/29/95) PS 5500.07 Correctional Services Manual (01/31/95) PS 5538.03 Escorted Trips (06/23/95) PS 5800.07 Inmate Systems Management Manual (12/24/91) PS 5800.09 Inmate Central File, Privacy Folder, and Parole Mini-Files (07/21/93) PS 5803.05 Progress Reports (02/11/94) PS 7331.03 Pretrial Inmates (11/22/94) TRM 005.01 SENTRY General Use Technical Reference Manual (06/01/94) 18 U.S.C. 1961-1968 21 U.S.C. 848

c. Rules cited in this Program Statement are contained in 28

CFR 524.70-76.

4. STANDARDS REFERENCED. None. 5. PRETRIAL/HOLDOVER PROCEDURES. Procedures required in this Program Statement are applicable to pretrial and holdover inmates.

12/31/2007 Page 3 6. [RESPONSIBILITY §524.71. Authority for actions relative to the CIM system is delegated to the Assistant Director, Correctional Programs Division, to Regional Directors, and to Wardens. The Assistant Director, Correctional Programs Division, and Regional Directors shall assign a person responsible for coordinating CIM activities. The Case Management Coordinator (CMC) shall provide oversight and coordination of CIM activities at the institutional level, and the Community Corrections Manager shall assume these responsibilities for contract facilities.] The Central Inmate Monitoring (CIM) Operations Manual identifies key staff who are to complete CIM certification procedures. 7. [CIM ASSIGNMENT CATEGORIES §524.72. CIM cases are classified according to the following assignments:

a. Witness Security Cases. Individuals who agree to cooperate

with law enforcement, judicial, or correctional authorities, frequently place their lives or safety in jeopardy by being a witness or intended witness against persons or groups involved in illegal activities. Accordingly, procedures have been developed to help ensure the safety of these individuals. There are two types of Witness Security cases: Department of Justice (authorized by the Attorney General under Title V of Public Law 91-452, 84 Stat. 933); and Bureau of Prisons Witness Security cases (authorized by the Assistant Director, Correctional Programs Division).] The vast majority of witness security (WITSEC) cases are those authorized by the Attorney General. Both types of WITSECs are treated similarly while in Bureau custody. [b. Threats to Government Officials. Inmates who have made threats to government officials or who have been identified, in writing, by the United States Secret Service as requiring special surveillance.

c. Broad Publicity. Inmates who have received widespread

publicity as a result of their criminal activity or notoriety as public figures.

d. Disruptive Group. Inmates who belong to or are closely

affiliated with groups (e.g., prison gangs), which have a history of disrupting operations and security in either state or federal penal (which includes correctional and detention facilities) institutions. This assignment also includes those persons who may require separation from a specific disruptive group.

e. State Prisoners. Inmates, other than Witness Security

cases, who have been accepted into the Bureau of Prisons for service of their state sentences. This assignment includes cooperating state witnesses and regular state boarders.

12/31/2007 Page 4

f. Separation. Inmates who may not be confined in the same

institution (unless the institution has the ability to prevent any physical contact between the separatees) with other specified individuals who are presently housed in federal custody or who may come into federal custody in the future. Factors to consider in classifying an individual to this assignment include, but are not limited to, testimony provided by or about an individual (in open court, to a grand jury, etc.), and whether the inmate has exhibited aggressive or intimidating behavior towards other specific individuals, either in the community or within the institution. This assignment also includes those inmates who have provided authorities with information concerning the unauthorized or illegal activities of others. This assignment may also include inmates from whom there is no identifiable threat, but who are to be separated from others at the request of the Federal Judiciary or U.S. Attorneys.

g. Special Supervision. Inmates who require special

management attention, but who do not ordinarily warrant assignment in paragraphs (a) through (f) of this section. For example, this assignment may include an inmate with a background in law enforcement or an inmate who has been involved in a hostage situation. Others may include those who are members of a terrorist group with a potential for violence.] 8. [CLASSIFICATION PROCEDURES §524.73

a. Initial assignment. Except as provided for in paragraphs

(a)(1) through (4) of this section, an inmate (including pretrial inmates) may be classified as a CIM case at any time by a Community Corrections Manager or by appropriate staff at the Central Office, Regional Office, or institution. This initial classification is effective upon documentation in the inmate’s record. (1) Witness Security Cases. Witness Security cases are designated by the Central Office only. An inmate’s participation in the Department of Justice Witness Security Program is voluntary. A commitment interview and an admission and orientation interview are to be conducted with the Witness Security inmate to ensure that the inmate understands the conditions of confinement within the Bureau of Prisons. Central Office classification of an individual as a witness security case, under either the Department of Justice or Bureau of Prisons, does not require additional review, and overrides any other CIM assignment. (2) State Prisoners. Appropriate staff in the Central Office or Regional Office designate state prisoners accepted into the Bureau of Prisons from state or territorial jurisdictions. All state prisoners while solely in service of the state sentence

12/31/2007 Page 5 are automatically included in the CIM system to facilitate designations, transfers, court appearances, and other movements. (3) Special Supervision. Placement in this assignment may be made only upon the authorization of a Regional Director or the Assistant Director, Correctional Programs Division. (4) Recommitted Offenders. An inmate who is recommitted to federal custody, who at the time of release was classified as a CIM case, retains this classification pending a review of the CIM status in accordance with paragraph (c) of this section.

b. Notification. The case manager shall ensure that the

affected inmate is notified in writing as promptly as possible of the classification and the basis for it. Witness Security cases will be notified through a commitment interview. The notice of the basis may be limited in the interest of security or safety. For example, in separation cases under §524.72, notice will not include the names of those from whom the inmate must be separated. The inmate shall sign for and receive a copy of the notification form. If the inmate refuses to sign the notification form, staff witnessing the refusal shall indicate this fact on the notification form and then sign the form. Notification is not required for pretrial inmates. Any subsequent modification of a CIM assignment or removal from the CIM system requires separate notification to the inmate.] 28 CFR 524.72 refers to Section 7 of this Program Statement. For purposes of this Program Statement, “prompt” has been defined as within 30 days of classification. [c. Initial Review. A classification may be made at any level to achieve the immediate effect of requiring prior clearance for an inmate’s transfer, temporary release, or participation in community activities. Except for Central Office or Regional Office classification of an individual as a state prisoner in sole service of the state sentence or for classification of pretrial inmates made by designated staff at the institution, a review by designated staff (ordinarily within 60 days of notification to the inmate) is required to determine whether a sound basis exists for the classification. Staff making the initial classification shall forward to the reviewing authority complete information regarding the inmate’s classification. An inmate not notified of a change in the classification by the reviewing authority within 60 days from the date of the initial notification may consider the CIM classification final. Reviewing authorities for CIM classification are: (1) Central Office Inmate Monitoring Section – reviews classification decisions for all future separation assignments (including recommitments) for Witness Security cases and for any combination of assignments involving Witness Security cases.

12/31/2007 Page 6 (2) Regional Office – reviews CIM classification decisions for Disruptive Group, Broad Publicity, Threat to Government Officials, Special Supervision, State Prisoners not in sole service of state sentence and initial multiple assignments except Witness Security cases. (3) Warden, or Designee – reviews CIM classification decisions for all separation assignments.] Warden refers to Chief Executive Officer and includes Community Corrections Managers. [d. Removal (1) Because participation in the Department of Justice Witness Security Program is voluntary, such participants may request removal from this assignment at any time. Such request shall be forwarded to the Central Office Inmate Monitoring Section. Actual removal of the CIM assignment will not occur until after approval from the Department of Justice is received. (2) The reviewing authority is responsible for determining if removal or modification of any CIM classification other than a Department of Justice Witness Security case is appropriate. The inmate retains the CIM classification pending a decision by the reviewing authority. (3) When an inmate is removed for any reason from a CIM classification (for example, because the reviewing authority either disapproves the CIM classification or approves removal of a CIM classification based on new information), the appropriate staff member shall ensure that the relevant portions of the inmate central file are either removed or, when part of a larger document, are amended to clearly reflect removal of the CIM assignment. Staff shall notify the inmate of the decision and document any change in the inmate’s record, and supportive documentation and the written basis for removal are to be retained in the inmate privacy file.] 9. [ACTIVITIES CLEARANCE §524.74

a. Except as provided for in paragraph (b) of this section,

the Warden is the clearance authority on all transfers, temporary releases, community activities, and escorted trips.

b. Witness Security Cases. Central Office Inmate Monitoring

Section staff shall be the clearance authority on all transfers, temporary releases, community activities, and escorted trips for Witness Security cases, except in a medical emergency. In a medical emergency, the Warden may transfer a Witness Security case to a local hospital for emergency medical care without prior clearance.]

12/31/2007 Page 7 The Inmate Monitoring Section, Central Office (or during non-business hours, the Central Office Duty Officer) is to be notified immediately when a WITSEC inmate receives an emergency escorted medical trip. Central Office clearance must be obtained prior to any extended period of hospitalization. Institution authorization to proceed will be entered into SENTRY. A permanent record of the authorization is to be maintained in the inmate’s central file, privacy folder. 10. [PERIODIC REVIEW §524.75. The Warden shall ensure that the status of an inmate’s CIM assignment is considered at each program review. When staff believe that removal or modification of the CIM classification is appropriate, the institution’s CMC and the appropriate reviewing authority must be notified. Only the reviewing authority shall determine if removal or modification of the CIM classification is appropriate.] 11. [APPEALS OF CIM CLASSIFICATION §524.76. An inmate may at any time appeal (through the Administrative Remedy Program) the inmate’s classification as a CIM case. Inmates identified as Witness Security cases may choose to address their concerns directly to the Inmate Monitoring Section, Central Office, rather than use the Administrative Remedy Program.] 12. OPERATIONS MANUAL. Implementation procedures for CIM cases are contained in the CIM Operations Manual. 13. INSTITUTION SUPPLEMENT. Each Warden shall develop an Institution Supplement that includes local procedures and identifies staff responsible for an institution’s CIM program. A copy of the Institution Supplement shall be forwarded to the respective Regional Office for approval within 120 days from the issuance of this Program Statement. The Institution Supplement shall be marked as “Limited Official Use Only.” \s\ Kathleen M. Hawk Director

12/31/2007 Page 8

THE REMAINDER OF THIS PROGRAM STATEMENT HAS BEEN DESIGNATED AS

* * * LIMITED OFFICIAL USE ONLY * * *

AND CANNOT BE REPRODUCED OR DISTRIBUTED WITHOUT THE CONSENT OF

THE CENTRAL INMATE MONITORING SYSTEM ADMINISTRATOR

CENTRAL OFFICE

WASHINGTON, D.C.

SEE PS 1221.64, DIRECTIVES MANAGEMENT MANUAL FOR DETAILS

Reviewed for legal accuracy by Elizabeth Franklin-Best, Esq., Principal Attorney·September 2026