Secure Mental Health Units

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

Program Statement	5335.02
Subject	Secure Mental Health Units
Current edition	March 19, 2026
Change notices	None
Supersedes	PS 5335.01, Secure Mental Health Units (1/23/2023) — rescinded
Governing regulation	None cited as this policy’s authority. The Program Statement adopts one definition from 28 C.F.R. § 549.46(b)(1)(ii)(C).
Governing statute	18 U.S.C. § 4245, listed under “Federal Statutes” in the policy’s references
Related BP forms	BP-A1185, Notice of Referral to the Secure Administrative Unit; BP-A1186, Secure Administrative Unit Referral Report (both new in this edition). Also used: BP-A0292, Special Housing Unit Record; BP329, Request–Authorization to Mail Inmate Package
Official PDF	https://www.bop.gov/policy/progstat/5335_002-1.pdf

Checked against the BOP policy set · 2026-09-07 · How we verify

A Secure Mental Health Unit is a locked housing unit inside a federal prison or medical center where people with serious mental illness are held apart from general population and are secured in their cells for part of each day — and Program Statement 5335.02, issued 19 March 2026, sets the minimum standards those units must meet, including a floor of 15 hours out of the cell per week. It is not a disciplinary status and it is not the Special Housing Unit, though the two can look similar from the outside. For what mental health treatment in the federal system looks like generally, start at mental health programs for inmates.

This edition is new — it replaced the January 2023 edition less than six months before this page was written — and it changed a great deal. It cut some requirements, added others, created two new forms, and for the first time put a numeric floor on out-of-cell time. Nothing written about these units before March 2026 reflects the policy that governs them now.

The rule itself: secure mental health units

The Program Statement gathers its own numeric requirements into a single closing section. This is the one paragraph a reader or a family member actually needs, reproduced verbatim.

15. TOTAL OUT-OF-CELL PROGRAMMING HOURS

In summary, this program statement requires a minimum amount of out-of-cell time be offered weekly as follows:

– Six hours facilitated by Recreation weekly – Two hours for PTUs and four hours for PTPs facilitated by Psychology Services weekly – Three hours facilitated by Chaplaincy Services weekly – Three hours facilitated by Education weekly – Socialization will be offered depending on recommendation from the Secure Treatment Team – Time for hygiene such as removing for showers three times a week, if applicable, and haircuts offered monthly – Time for appointments in Health Services (medical and psychiatric)

Any inmate housed in an SMHU will be offered a minimum of 15 hours out of their cell per week.

Reproduced from Program Statement 5335.02 at p. 24.

Reading that list accurately

Three things about this section are easy to get wrong, and getting them wrong is how a request gets denied.

The word is “offered,” not “provided.” The section says a minimum amount of out-of-cell time must “be offered weekly,” and the closing sentence says a person “will be offered a minimum of 15 hours out of their cell per week.” A refused hour still counts as an offered hour. Elsewhere the policy directs staff to document refusals — Correctional Services staff “document completed and refused showers,” “completed and refused meals,” and “completed and refused recreation” using a BP-A0292, Special Housing Unit Record (at pp. 20–21), and mental health providers document refusals in the electronic health record (at p. 16). That documentation is the evidence of whether an hour was offered at all.

The Chaplaincy and Education figures are the out-of-cell remainder of a larger number. Section 13.c requires Chaplaincy Services to offer five hours of religious programming weekly to the unit, of which “[n]o more than two hours of weekly programming may be offered as in-cell programming” (at p. 23). Section 14.d imposes the same five-hour/two-hour structure on Education (at p. 23). Five minus two is the three hours that appear in the summary. The numbers reconcile; they are not a contradiction.

Those hours belong to the unit, not to each person. This is the single most consequential sentence in the whole document for someone counting their own hours. The policy’s own Summary of Changes states that “Chaplaincy Services and Education will provide five hours of programming to the unit but not every person” (at p. 2), and both sections add that “[t]o ensure inmates are provided access to programming, they should be rotated into the available programming hours” (at pp. 23–24). An individual’s share of those hours therefore depends on rotation.

The arithmetic is worth doing once. Six hours of recreation, plus two (Secure PTU) or four (Secure PTP) hours of psychology programming, plus three of chaplaincy and three of education, comes to 14 hours in a Secure PTU and 16 in a Secure PTP. The 15-hour floor in the last sentence is therefore a separate, freestanding minimum — in a Secure PTU it is reached only by adding the socialization, hygiene and health-services time listed above it.

The other numbers in the policy

Requirement	What the policy says	Pin-cite
Out-of-cell time, floor	“a minimum of 15 hours out of their cell per week”	p. 24
Recreation	“at least six hours per week. Ordinarily this occurs over at least five days per week unless inmate behavior poses a security risk”	pp. 13, 21
Psychology out-of-cell programming	“at least twice a week in Secure PTUs and at least four days a week in Secure PTPs”	p. 15
In-cell programming	“[a]t least once each weekday mental health providers offer each inmate on the SMHU in-cell resources or exercises”	p. 15
Showers	“at least three times a week”	p. 20
Shaving	“a minimum of three times per week,” unless a shaving instrument presents a safety concern	p. 20
Haircuts	“once per month at a minimum”	p. 20
Cell rotations	“at least every 90 days”	p. 21
Length of stay, Secure PTU	“ordinarily, inmates placed in a Secure PTU will not remain there longer than 90 days”; past that, consultation with the Psychology Services Branch and the Chief Psychiatrist	p. 14
Length of stay, Secure PTP	consultation required “if the person has exceeded 18 months and is still in an SMHU”	p. 14
Psychiatric evaluation after referral	“within 14 days of referral”	p. 17
Psychiatric review once prescribed	“at least monthly”	p. 17
Medication-adherence trigger	“three consecutive doses, 50% of doses within one week, or when an otherwise clinically significant pattern of missed doses is present”	p. 18
Physical space	“at least three therapeutic enclosures in a private room and/or a small group space”; indoor and outdoor recreation space; clocks and calendars “such that each inmate can see the correct date and time”	p. 6
Staff activation training	“four hours of initial training with Psychology Services,” offered yearly thereafter	p. 25
Quality improvement	“a minimum of one quality improvement study quarterly” by the Psychology Services Branch	p. 15

All values reproduced from PS 5335.02 at the pages shown.

The three kinds of secure mental health unit

“SMHU” is a category, not a place. The policy defines it as “[a]ny housing unit, to include those at MRCs, dedicated to the treatment of inmates with a mental illness that offers mental health programming in the context of removal from the general inmate population, whether voluntary or involuntary. Inmates are secured in their cells for periods of time each day in support of safety” (at p. 3). Three types exist, and which one a person is in determines almost everything else.

Secure Psychology Treatment Programs (Secure PTPs) are “intensive residential treatment programs designed around a specific mental health need in which all program participants have volunteered to participate in mental health treatment activities” (at p. 3). The policy names three: Secure STAGES, which “targets inmates who engage in chronic self-directed violence”; the Secure Mental Health Step-Down Program, “for inmates who have an SMI diagnosis”; and Secure Skills, “for inmates who have intellectual deficits or social adjustment concerns” (at p. 3). All Secure PTPs are voluntary, “with the exception of inmates who are committed via court order for treatment.”

Secure Psychology Treatment Units (Secure PTUs) are “residential treatment units where intensive treatment services are offered but not required. Inmates have been assigned to the unit, regardless of their interest, and may or may not volunteer to participate in mental health treatment activities” (at pp. 3–4). This is the involuntary category. Secure PTUs at Medical Referral Centers house people “who require inpatient psychiatric treatment in a secure setting,” where “inmates are secured in cells for the majority of the day and do not have access to departments who do not routinely work on the unit” (at p. 4). See federal medical centers.

The Secure Administrative Unit (SAU) is a type of Secure PTU “designed to house inmates who have an SMI or history of SMI diagnosis and require a secure setting due to significant security concerns and/or are awaiting placement in a secure Psychology Treatment Program” (at p. 4). It is the only SMHU type with its own hearing process, described below.

The policy also draws a hard boundary around the category: “No other secure mental health units are authorized without a policy waiver approved by the RSD,” and any institution that cannot meet the minimum requirements must request a waiver under the Directives Management Manual (at p. 3).

Two definitions carry weight in practice. Serious mental illness (SMI) is “a mental illness other than a substance use disorder that results in serious functional impairment substantially limiting or interfering with major life activities,” with classification requiring “consideration of diagnosis(es), the severity and duration of symptoms, the degree of functional impairment associated with the illness, treatment history, and current treatment needs” (at p. 4). And gravely disabled is defined as “[c]onsistent with 28 CFR § 549.46(b)(1)(ii)(C), a grave disability is an extreme deterioration in personal functioning due to a mental illness or disorder” (at p. 4). Grave disability appears in both the admission criteria and the discharge criteria, so it is a term worth knowing by its definition rather than by impression. The underlying regulation, 28 C.F.R. § 549.46, is the Bureau’s rule on involuntary administration of psychiatric medication, and the cited clause defines one of three circumstances constituting a psychiatric emergency.

Who can be admitted, and who cannot

The admission criteria at a Medical Referral Center

For Secure PTPs and Secure PTUs generally, “[c]riteria for admission … are specific to the mission of each program and are determined when the unit is established,” through an activation memo published by the Reentry Services Division and the Correctional Programs Division (at p. 9). At a Medical Referral Center the policy states the criteria itself. Reproduced verbatim:

MRCs. Inmates may be admitted to an SMHU if the inmate has an SMI or is deemed to be at heightened risk for suicide and under one or more of the following circumstances:

– The inmate poses an imminent threat to the safety of others; – The inmate poses an imminent threat to the security of the institution; – The inmate poses an imminent threat to the safety of themself (i.e., requires suicide watch); – The inmate requests secure housing because of safety concerns (i.e., is requesting protective custody); – The inmate requests secure housing as a temporary means of self-management; – The inmate is gravely disabled and requires assistance with activities of daily living; or, – The inmate has been designated to an SMHU by the DSCC or Office of Medical Designations and Transfers (OMDT) through consultation with PSB.

Reproduced from PS 5335.02 at p. 9.

Two of those seven are requests by the person themselves — protective custody, and secure housing “as a temporary means of self-management.” That is unusual in Bureau policy and worth knowing about. Meeting a criterion is not the same as being admitted: admission is a clinical decision, and this page cannot tell you whether any particular person will be placed anywhere.

Who makes the call differs by unit type. For Secure PTPs and PTUs, “[t]he PSB, in collaboration with the Specialty Program Coordinator, determines designation/admission,” with the Assistant Director of the Reentry Services Division holding final authority in a disagreement (at p. 8). At an MRC, “only psychologists and psychiatrists may admit inmates with an SMI to SMHUs”; where psychology and psychiatry disagree, the institution consults the Reentry Services Division and the Health Services Division, and “[t]he Warden will have the final decision-making authority” (at p. 8). This edition newly gave psychiatrists admission authority.

Who is precluded

Admission is restricted in two situations the policy names. First, medical: “SMHUs do not house inmates whose current medical condition(s) cannot be managed in the proposed SMHU,” as determined by the Clinical Director or designee — and where that happens, “the services needed to meet their mental health needs will adhere to requirements outlined in this program statement except as their medical condition prohibits” (at p. 9). See medical designations and care levels.

Second, pregnancy: “If an inmate is pregnant or up to 12 weeks postpartum (i.e., live birth, miscarriage, or pregnancy termination) and is admitted to an SMHU, the Warden will reference the Program Statement Female Offender Manual and will notify the PSB Administrator and the Women and Special Populations Branch Administrator for further guidance and continuation of care” (at p. 9). Separately, in the Secure Treatment Team’s escort decisions, “[t]he use of restraints on pregnant and postpartum individuals is prohibited except in rare instances” (at p. 13). Those restrictions have a statutory floor beneath them; see pregnancy and child placement and the Female Offender Manual.

Someone facing discipline is not automatically excluded. Where a person “is accused of violating an institutional rule in the 100- or 200-series and is pending a disciplinary hearing or … has been sanctioned to Disciplinary Segregation (DS), a psychologist or psychiatrist will determine if placement in the SMHU is appropriate” (at p. 9). See the inmate discipline program.

The SAU hearing — and the two new forms

This edition added a hearing step that did not exist before. “Prior to admission to a Secure Administrative Unit (SAU), inmates must be provided the opportunity to engage in an SAU hearing with a hearing officer who will be a PSB psychologist. Forms utilized in this process include the BP-A1185, Notice of Referral to the Secure Administrative Unit and BP-A1186, Secure Administrative Unit Referral Report” (at p. 10). The policy places the current hearing procedures on the Bureau’s internal intranet rather than in the Program Statement itself, so the procedural detail is not publicly published.

On admission to any SMHU, a psychologist writes an admission note recording the date and time, the reason for admission, “[l]ess restrictive alternatives considered or attempted prior to SMHU admission,” the person’s mental status at admission, “[c]riteria that must be met for discharge from the SMHU or completion of the Secure PTP,” and the interventions planned to support that discharge (at p. 10). That fourth and fifth item — the alternatives considered and the written discharge criteria — are the two entries most worth asking for, because they are the record of why the placement happened and what ends it.

How long a placement lasts, and how it ends

The policy sets no maximum, but it does set consultation triggers. “Except for Secure PTPs, ordinarily, inmates placed in a Secure PTU will not remain there longer than 90 days,” and past that point the Secure Treatment Team consults the Psychology Services Branch and the Chief Psychiatrist of the Health Services Division “to determine any appropriate changes to treatment.” In Secure PTPs, “this consultation occurs if the person has exceeded 18 months and is still in an SMHU,” and either a psychologist or a psychiatric provider documents the consultation in the electronic health record (at p. 14). The Secure Treatment Team is expressly “responsible for tracking how long each inmate has been housed in the SMHU.”

Discharge criteria at MRCs and Secure PTUs are stated as four conditions — that the person “demonstrates the ability to be safe around staff and other inmates,” “does not interfere with the safety and security of the institution,” “demonstrates the ability to keep themself safe,” and “is no longer considered gravely disabled” (at p. 10). Only psychologists and psychiatrists may discharge from an MRC or Secure PTU; disagreement between the two disciplines routes through the Reentry Services Division and Health Services Division to the Warden, who decides.

Because Secure PTPs are voluntary, they have their own exits. A voluntary withdrawal requires a documented formal request, then “at least three different clinical interventions spread throughout at least a 30-day period to increase motivation for treatment,” then documentation of the final decision in the electronic health record and a treatment summary before transfer (at p. 11). An expulsion for refusing to participate likewise requires at least three documented psychological interventions, and where behavior is “so egregious in nature (e.g., behavior equivalent to a prohibited act of greatest severity),” a consultation chain running through the Chief Psychologist, Captain, Warden, Consolidated Legal Center, Regional Psychology Administrator and Psychology Services Branch — and if expulsion is recommended or the team cannot reach consensus, the matter goes to the Difficult to Place Committee, a Central Office body that includes an attorney from the Office of General Counsel, for a final decision (at pp. 11–12, 5).

What a Secure Mental Health Unit means for you

If you are the person inside: ask which unit, by name

Ask which unit you are in, by name. “SMHU” covers three different things with different rules: a Secure PTP is voluntary and you can ask to withdraw; a Secure PTU is an assignment and you cannot; an SAU carries a hearing right before admission. What you can ask for, and how, depends on which one it is.

Ask for your SMHU Admission Note. It is supposed to record the less restrictive alternatives considered before you were placed, and the criteria you must meet to be discharged (at p. 10). If nobody has told you what would end the placement, that note is where the answer is supposed to be written down.

Know what is supposed to be offered, and know that refusals are recorded. The floor is 15 hours out of the cell weekly, recreation is at least six hours over ordinarily five days, showers and shaving at least three times a week, haircuts monthly, cell rotation every 90 days. Correctional Services documents completed and refused showers, meals and recreation on a BP-A0292. If the log shows offers you never received, that discrepancy is the point.

Two protections are worth knowing precisely. “Psychotropic medication will not be withheld from any inmate solely for disciplinary reasons,” and where a medication has been diverted, it is the psychiatric provider who decides whether discontinuing it is clinically warranted (at p. 18). And “[r]esiding on an SMHU does not prohibit an inmate from receiving incentive awards or time credits under the FSA,” with the policy directing that people on these units have opportunities to participate in recidivism-reduction programming (at p. 20). See First Step Act time credits.

You keep more property than in a Special Housing Unit. The minimum issue includes a uniform distinct from both general population and SHU uniforms, a mattress, linens, and hygiene items; previously purchased commissary hygiene items stay in the cell unless a mental health provider identifies a specific safety issue; radios with batteries and headphones are permitted; at least two books on admission on request; flexible pens or short pencils and lined paper on request (at pp. 6–7). Property is not ordinarily removed “unless this is the result of a formal disciplinary sanction, or the presence of the property causes a safety issue.”

If you are the family: which of the three unit types

The most useful early question is which of the three unit types your family member is in, followed by who the Specialty Program Coordinator or Chief Psychologist is. Almost every decision on these units is made by an interdisciplinary Secure Treatment Team that meets each weekday at a Medical Referral Center and at least weekly in a Secure PTP or PTU (at pp. 5, 13). The team leader — the Chief Psychologist, Chief Psychiatrist, or the Specialty Program Coordinator, depending on the unit — “has final decision-making authority and responsibility for programming, therapeutic release, incentive awards, and any changes to authorized property,” while psychiatric providers keep final say on psychotropic medication and the Captain on security measures (at p. 13).

Visiting continues. “SMHU inmates will have the opportunity to maintain active visitor lists,” may receive visitors under the visiting policy, and may be provided non-contact visits “through the use of videoconferencing or other technology”; contact visits “may be recommended by the mental health provider and approved by the Captain” (at p. 19). The Correctional Counselor helps develop the visiting list and coordinates accommodations. See visiting regulations.

So do phone calls, in a specific way. “A monitored telephone will be available on the SMHU floor for inmates who have demonstrated the ability to safely enjoy leisure time on the unit outside of their cells. A portable, monitored landline telephone will be available to inmates who have not yet demonstrated the ability to safely participate in leisure time outside of their cells” (at p. 19). Being confined to a cell is not, under this policy, a reason for having no phone access at all.

Legal access continues too: unit staff “will facilitate easy access to legal resources to include making use of a law library, sending legal mail, and accommodating legal calls” (at p. 19). See inmate legal activities.

If you are counsel: secure mental health units

Start with the document trail, because this policy generates an unusual amount of it. The admission note and its record of less restrictive alternatives considered; the SMHU Discharge Note or Treatment Summary, which must state “[n]umber of days, weeks, or months the inmate was living in the SMHU,” how the person was included in discharge planning, how they meet the discharge criteria, and the continuity-of-care plan (at p. 12); the Secure Treatment Team meeting documentation recording date, attendance, which inmates were discussed and which topics (at p. 13); the 90-day and 18-month consultations; the BP-A0292 logs; and, for an SAU, the BP-A1185 and BP-A1186.

Be precise about what binds. PS 5335.02 cites no regulation as its own authority. It borrows a definition from 28 C.F.R. § 549.46(b)(1)(ii)(C) — a provision that, in its own setting, defines one of three circumstances constituting a psychiatric emergency for purposes of involuntary psychiatric medication. Using it as a housing-admission definition is the Bureau’s own drafting choice; it does not make § 549.46’s procedural protections applicable to an SMHU placement. Where involuntary medication is actually at issue, the applicable rule is § 549.46 itself, and the policy directs the SMHU psychiatric provider to participate in the due-process hearing (at p. 18).

The one statute the policy lists is 18 U.S.C. § 4245, and it is a live tool rather than a footnote. Where a sentenced person objects, in writing or through counsel, to being transferred to a suitable facility for care or treatment, the Government — at the request of the director of the facility where the person is imprisoned — may move for a hearing on their present mental condition in the district where the facility is located. Section 4245(a) provides that such a motion “shall stay the transfer of the person pending completion of procedures contained in this section,” the hearing runs under § 4247(d), and commitment follows only if the court finds “by a preponderance of the evidence” that the person presently suffers from a mental disease or defect for which they need custody for care or treatment. The policy itself warns staff that “[i]n no way should emergency medications be used to negate the need to potentially pursue commitment under 18 U.S.C. § 4245” (at p. 14).

Two Supreme Court decisions are named in the policy’s own training section. It requires at least annual training for psychiatric providers on emergency, involuntary and voluntary administration of psychiatric medication, “to include training on Sell v. United States and Washington v. Harper decisions and implications” (at p. 26). Harper, 494 U.S. 210 (1990), held that “given the requirements of the prison environment, the Due Process Clause permits the State to treat a prison inmate who has a serious mental illness with antipsychotic drugs against his will, if the inmate is dangerous to himself or others and the treatment is in the inmate’s medical interest,” while recognizing that an inmate “possesses a significant liberty interest in avoiding the unwanted administration of antipsychotic drugs.” It also held that an administrative hearing before non-treating medical professionals satisfies due process, rejecting a judicial-hearing requirement. Harper was a state case decided under the Fourteenth Amendment; the Bureau’s analogous administrative procedure is at 28 C.F.R. § 549.46.

Finally, note what this edition removed. Institution Disciplinary Process Report requirements for SMHU inmates are gone, as are Verified Protective Custody and Central Inmate Monitoring assignment requirements and the emergency-equipment requirement (at pp. 1–2). If a prior filing, an older institution supplement, or a 2023-vintage source relies on any of those, it is describing a policy that no longer exists.

What changed from PS 5335.01 to 5335.02

PS 5335.02 rescinded PS 5335.01, Secure Mental Health Units (1/23/2023) (at p. 1), and its Summary of Changes runs to nearly two full pages — an unusually long list for a three-year-old policy. Grouped by what they actually do:

New numeric floors and reductions

• A stated minimum: “[s]pecifies a minimum of 15 hours out-of-cell time be offered to inmates in an SMHU” — the figure at the center of this page
• “Reduces and specifies out-of-cell programming requirements for mental health providers to twice a week in Secure PTUs and at least four days a week in Secure PTPs”
• “Chaplaincy Services and Education will provide five hours of programming to the unit but not every person”
• “Reduces requirements for initial activation training from eight hours to four hours and removes the specified hours for Correctional Services training”
• “Changes the quarterly Correctional Services training to a semi-annual requirement”
• “Reduces cable and satellite television requirements to providing when feasible”

New process

• “Creates BP-A1185, Notice of Referral to the Secure Administrative Unit and BP-A1186, Secure Administrative Unit Referral Report forms”
• “Adds information about Secure Administrative Unit (SAU) hearings”
• “Psychiatrists gain Secure Mental Health Unit (SMHU) admission authority”
• “Requires institutions consult with RSD or HSD in cases of disagreement on transitions to and from SMHUs with the Warden having final decision-making authority”
• “Includes Chief Psychiatrist as a Secure Treatment Team leader”
• “Specifies SMHU transition documentation is not needed when inmates move units in an SMHU if they do not change treatment providers”

Requirements removed

• “Removes Institution Disciplinary Process Report requirements for SMHU inmates”
• “Removes Verified Protective Custody and Central Inmate Monitoring Assignment requirements”
• “Removes emergency equipment requirement”
• “Removes the role of Nutrition from Health Services responsibilities to inmates”

Terminology and definitions

• “Changes the term Secure Care Coordination and Reentry (CCARE) Team to Secure Treatment Team”
• “Changes the term psychiatric medication prescriber to psychiatric provider and updates definition”
• “Adds psychology trainees, social workers, and Qualified Mental Health Professionals (QMPH) to the list of mental health providers”
• “Changes definition of inmate to exclude pretrial forensic study inmates”
• “Updates definition of emergency psychiatric medicine”
• “Provides examples of Secure Psychology Treatment Programs (PTP) and Psychology Treatment Units (PTUs)”

Other

• “Changes monitoring patient adherence with medication to a shared responsibility between psychiatric and mental health providers”
• “Adds specifications regarding restriction of water when clinically indicated”
• “Provides guidance regarding durable medical equipment”
• “Changes notification requirements regarding placement in Secure PTUs and Secure PTPs”
• “Changes the requirement of attendance to the Secure Treatment Team meetings for Correctional Counselors and Correctional Services staff assigned to the SMHU to attending as feasible”
• “Updates responsibility for Quality Improvement studies to the Psychology Services Branch (PSB)”

All quoted from the Summary of Changes, PS 5335.02 at pp. 1–2.

One change deserves flagging on its own. The exclusion of “pretrial forensic study inmates” from the definition of “inmate” means this Program Statement’s minimum standards do not, by their terms, reach people held for a court-ordered competency or criminal-responsibility study. That is a category of person frequently housed at the same facilities. For what governs those evaluations, see forensic mental health evaluations.

This edition is dated 19 March 2026, part of the wave of Bureau reissues that ran from February through May 2026. It was not among the twenty-three Program Statements reissued effective 22 June 2026, and it carries no Change Notice.

Where people get stuck counting offered but unused hours

Counting hours that were “offered” but never happened. The 15-hour floor is an offering requirement, and the Chaplaincy and Education hours belong to the unit rather than to each person. A family looking at a log showing full compliance and a person reporting they left the cell twice are often both describing the same week accurately. Route: ask, in writing, for the BP-A0292 Special Housing Unit Record entries and the weekly unit calendar the Specialty Program Coordinator is required to create, distribute to inmates and post “in a highly visible location,” along with “a record of whether activities were completed or canceled” (at pp. 14, 15). Cancellations are the number that matters. Then run the administrative remedy program: informal resolution (BP-8), BP-9 to the Warden, BP-10 to the Region, BP-11 to the Office of National Inmate Appeals.

A Secure PTU placement that has run past 90 days with no visible review. The policy does not cap the stay, but it does require the Secure Treatment Team to track duration and, past 90 days in a Secure PTU, to consult the Psychology Services Branch and the Chief Psychiatrist — a consultation that “will be documented by either a psychologist or a psychiatric provider in the EHR” (at p. 14). Route: a written request to Psychology Services asking whether the 90-day consultation occurred and on what date, followed by a BP-9. The comparable trigger in a Secure PTP is 18 months.

No written discharge criteria. The admission note is required to state “[c]riteria that must be met for discharge from the SMHU or completion of the Secure PTP” and the interventions planned to support it (at p. 10). When nobody can say what would end a placement, this is usually why. Route: ask the Secure Treatment Team, through a staff request, for the discharge criteria recorded in the admission note. If none were recorded, say so on the BP-9 — the absence of the entry is the defect, and it is provable.

Being treated as if the SMHU were a Special Housing Unit. These units share features with the SHU — cell confinement, escorts, restraints for movement — and staff unfamiliar with the policy sometimes apply SHU practice to them. They are different: the property minimums are higher, the programming minimums exist at all, the decisions belong to a clinical team rather than a lieutenant, and “[u]nless security concerns are present on the SMHU, out-of-cell programming and recreation are not ordinarily suspended for lockdowns” (at p. 14). Route: a BP-8 identifying the specific practice and asking which provision of PS 5335.02 authorizes it. Compare special housing units and solitary confinement and SHUs.

Applied Insight — Christopher Zoukis, JD, MBA, Managing Director: The reason we ask for the admission note first is that it is where the Bureau writes down its own theory of the case — why this person, why now, what was tried instead, and what has to change for it to end. Everything after that is measured against it. When the note is complete and the discharge criteria are specific, the file usually shows a clinical decision that a treatment team is actively working. When the note is thin, or the alternatives-considered line is blank, or nobody can produce the 90-day consultation, the placement starts to look like housing rather than treatment — and that is a difference a warden, a regional office, and eventually a court can see. We build these files out of the documents the policy itself requires, not out of impressions of what the unit is like.

Related BOP policy on secure mental health units

PS 5335.02 cross-references more than twenty Bureau directives at page 27. The ones that carry the most weight for a reader of this page:

• Mental health programs for inmates — the paired page: what treatment in the federal system looks like from the inside
• Treatment and Care of Inmates With Mental Illness — the general policy this one repeatedly defers to for care levels, provider duties and CCARE functions
• Psychiatric Services — the 14-day evaluation, monthly review and medication requirements
• Psychology Services — the department that staffs and leads these units
• Suicide Prevention Program — governs suicide-watch cells located inside an SMHU
• Forensic and other mental health evaluations — for the pretrial forensic study population this edition excludes
• Psychology treatment programs and RDAP — the residential treatment framework Secure PTPs sit within
• Federal medical centers — the Medical Referral Centers where most SMHUs are located
• Medical designations and care levels and medical care levels in federal prison — the medical-condition exclusion at p. 9
• Inmate discipline program — the DHO responsibilities at pp. 24–25
• Special housing units — the status an SMHU is most often confused with
• Use of force and restraints — governs any use of force under the emergency-medication provision
• Hunger strikes — a named topic in the semi-annual Correctional Services training for these units
• Pregnancy and child placement and the Female Offender Manual — the pregnancy and postpartum provisions at pp. 9 and 13
• Visiting regulations, inmate personal property and inmate legal activities — the access rules that continue on these units
• First Step Act time credits — SMHU placement does not bar earning them
• Security designation and custody classification — how DSCC designation interacts with SMHU placement
• Administrative Remedy Program — BP-8 through BP-11
• Federal prison consulting services — where the issue is designation, care level, or an administrative remedy that has stalled

Frequently Asked Questions About Secure Mental Health Units

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