Ca Ig, Review of Correctional Facility Mail Processing, 2002
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O FFICE OF THE I NSPECTOR G ENERAL · PROMOTING INTEGRITY · STEVE WHITE, INSPECTOR GENERAL REVIEW OF CORRECTIONAL FACILITY MAIL PROCESSING CALIFORNIA DEPARTMENT OF CORRECTIONS JULY 2002 GRAY DAVIS, GOVERNOR OFFICE OF THE INSPECTOR GENERAL STEVE WHITE INSPECTOR GENERAL REVIEW OF CORRECTIONAL FACILITY MAIL PROCESSING CALIFORNIA DEPARTMENT OF CORRECTIONS REPORT JULY 2002 • PROMOTING INTEGRITY● STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 1 CONTENTS EXECUTIVE SUMMARY............................................................................................. 3 BACKGROUND................................................................................................................ 5 OBJECTIVES, SCOPE, AND METHODOLOGY .............................................. 5 FINDINGS AND RECOMMENDATIONS ............................................................... 7 FINDING 1 .................................................................................................................. FINDING 2 .................................................................................................................. FINDING 3 .................................................................................................................. FINDING 4 .................................................................................................................. FINDING 5 .................................................................................................................. FINDING 6 .................................................................................................................. FINDING 7 .................................................................................................................. FINDING 8 .................................................................................................................. FINDING 9 .................................................................................................................. FINDING 10 ............................................................................................................... APPENDIX ......................................................................................................................... 7 8 9 11 12 14 15 17 19 21 22 ATTACHMENT VIEWS OF THE CALIFORNIA DEPARTMENT OF CORRECTIONS ......................... STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL 23 GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 2 EXECUTIVE SUMMARY This report presents the results of a review by the Office of the Inspector General of the correctional facility mail processing operations of the California Department of Corrections. The review was performed to determine whether mail handling procedures and processes could be changed to improve efficiency and reduce costs while maintaining mandated service levels and institution security. In conducting the review, the Office of the Inspector General reviewed the searching, processing, delivery, and sending of inmate mail. Mailroom activities were evaluated to also determine whether they comply with California Code of Regulations, Title 15, and with plans of operation set up by wardens, superintendents, and other heads of correctional facilities for sending and receiving inmate mail. The Office of the Inspector General found a number of opportunities to improve mailroom efficiency and reduce costs without degrading essential services or violating mandates. The review revealed excessive and duplicative practices that increase mail processing costs and delay mail delivery, with institutions depending heavily on labor-intensive manual processing in handling mail. The review also found that Department of Corrections headquarters does not adequately review and monitor the mail operations of the institutions and that the mail processing operation plans of some institutions do not fully comply with California Code of Regulations, Title 15. Because of lack of documentation and recording of mailroom activities, the department may be unable to prove it is complying with the code in several key areas. The Office of the Inspector General recommends that the Department of Corrections institute procedures specified in the report to reduce manual processing, streamline processes, and take advantage of automation. Implementing the recommendations at all of the department’s 33 institutions could generate an estimated $1.3 million in operational savings and provide timelier mail delivery. The table shown on the following page summarizes potential cost savings estimated from implementation of each recommendation presented in this report. In each case, the estimate is based on the premise that the mail processing practices at the selected institutions are representative of the remaining institutions. Potential savings were calculated by multiplying the number of staff hours saved by the average mailroom staff salary rate and annualizing the savings per day. To help the Department of Corrections fulfill its California Code of Regulations, Title 15 and local mail handling mandates, the Office of the Inspector General has made recommendations for documenting and recording the department’s mailroom operations. Carrying out these recommendations at all correctional facilities will increase mailroom accountability and reduce the department’s vulnerability to mail-related complaints. The recommended changes also would provide evidence of compliance with California Code of Regulations, Title 15 and with local procedures for management oversight, as well as helping to satisfy external reviews. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 3 Estimated Cost Savings Resulting from Implementation of Changes Recommended by the Office of the Inspector General in Inmate Mail Processing California Department of Corrections Estimated Annual Savings (statewide) Recommendation Increase the use of services provided by the U.S. Postal Service $ 230,000 Increase the use of correctional officers in mail processing operations. $ 300,000 Standardize the procedures for handling cash, checks, and money orders contained in inmate mail. $ 596,000 Use accounting personnel to monitor inmate trust accounts for sufficient funds to pay postage on outgoing mail and provide pre-stamped envelopes to indigent inmates. $ 54,000 Establish standard procedures for processing legal mail. $ 110,000 $ 1,290,000 Total Estimated Annual Cost Savings (statewide) STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 4 BACKGROUND Department of Corrections inmates and staff send and receive millions of pieces of mail through the U.S. Postal Service each year. At each of the department’s 33 institutions, mail is processed through the mailroom before it is sent to the postal service or after it comes from the postal service for delivery to inmates and staff. Inmates consider mail a vital link to family, friends, and the outside world, as well as a vehicle for communicating with legal advisers, government officials, and clergy. Recognizing the important role that mail plays in inmate attitude and behavior, California Code of Regulations, Title 15, Division 3, Sections 3130-3147 and 3165, mandate how the department handles and processes mail. Wardens, superintendents, and other heads of correctional facilities are also required to establish plans of operation for mail processing at each facility. Sections 3006, 3130-3147 and 3165 of the California Code of Regulations, Title 15, Division 3, include the following provisions: • • • • • • An indigent inmate may send up to five letters a week without charge. [Section 3134]. All non-confidential mail is subject to being read by staff before it is mailed for or delivered to an inmate. [Section 3138 (a)]. All incoming inmate mail or packages must be opened and inspected before delivery. [Section 3138 (b)]. Contraband is defined to include such items as: 1) Coded messages, 2) Maps depicting areas within a 10-mile radius of the facility, and 3) Obscene materials. [Section 3006 (c)]. Inmates are prohibited from receiving cash in the mail. [Section 3138 (e)] Legal documents sent to courts and claims sent to the Board of Control will be sent out each working day. [Section 3165 (a)]. Through its plan of operations, each correctional facility establishes mail-processing procedures that must be approved by the Director of the Department of Corrections. Typically, these operational plans include such elements as establishing a seven-calendarday mail delivery standard, processing certified and registered mail on the day received, and recording legal and confidential mail in approved mailroom logs. OBJECTIVES, SCOPE AND METHODOLOGY The review by the Office of the Inspector General was conducted in conjunction with Sjoberg Evashenk Consulting, LLC. The objectives were to evaluate mailroom operations at selected institutions of the Department of Corrections to determine whether the mailrooms are being operated efficiently and in compliance with state regulations and institution guidelines. To accomplish these objectives, the Office of the Inspector General and its consultants: • Reviewed California Code of Regulations, Title 15 and local correctional facility plans of operations for mail handling. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 5 • Identified key efficiency and compliance elements to test at selected correctional facilities. • Conducted in-depth site visits to California State Prison, Solano, the California Institution for Men, and the California Institution for Women; and observed mailroom activities at California State Prison, Sacramento. [See the Appendix for a brief description of each of these facilities.] Observed, tested, documented, and analyzed mail handling at the selected facilities. • • • • • Sampled and reviewed inmate complaints (602s) about mail operations at selected facilities. Interviewed Department of Corrections executive, custodial, and mailroom staff at headquarters and each selected facility. Gathered information from U.S. Postal Service personnel about its processing of correctional facility mail. Reviewed plans of operations for nine institutions. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 6 FINDINGS AND RECOMMENDATIONS FINDING 1 The Office of the Inspector General found that the state prisons are not taking effective advantage of the services provided by the U.S. Postal Service. The review of the mail processing systems employed by the state prisons found that the institutions could save money by making more effective use of services offered by the U.S. Postal Service. Two prisons receive their mail unsorted. The Office of the Inspector General found that much of the mail delivered to California State Prison, Solano and the California Institution for Women—including regular inmate mail, legal mail, and administrative mail—is not sorted before it arrives. This occurs because each facility rents only one or two post office boxes or does not require the U.S. Postal Service to sort administrative mail into a post office box. As a result, the facilities spend significant staff time sorting incoming mail. Mailroom employees at California State Prison, Solano, spend two hours on a light day and approximately three and half hours on a heavy day sorting mail for more than 5,800 inmates. At the California Institute for Women employees average two hours a day sorting mail for more than 1,700 inmates. The California Institution for Men has a better system. The California Institution for Men rents a post office box for each of its four inmate housing units and two boxes for its administrative offices. When incoming mail arrives at the mailroom, the post office has already sorted the mail into trays and bins for the respective post office boxes. Mailroom employees assigned to a particular housing unit can simply pick up their assigned trays and bins. Since mailroom employees have worked mail for only a single housing unit that day, they can place all the mail in the unit’s mailbag for delivery. This system significantly reduces the time employees spend sorting mail and allows mailroom staff to work on other mail processing duties. Three prisons use employees to pick up and deliver mail to the post office. While California State Prison, Sacramento has the U.S. Postal Service pick up its mail daily, California State Prison, Solano, the California Institution for Men, and the California Institution for Women all send correctional officers and mailroom employees to the post office to deliver and pick up mail. California State Prison, Solano employees gave two reasons they do not have the U. S. Postal Service deliver and pick-up the mail: first, the location of the mailroom may cause a security problem, and second, the U.S. Postal Service in Vacaville does not have a truck large enough to carry the prison’s mail. California Institution for Women employees said they do not have the U.S. Postal Service deliver and pick up the mail because the mailroom is within its security perimeter. The California Institution for Men does not have the U.S. Postal Service deliver and pick up its mail because it wants the option of refusing packages that are damaged or torn open. California Institution for Men employees said they believes this helps limit the number of inmate complaints about damaged personal property items. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 7 These three prisons spend significant amounts of staff time transporting mail to and from the post offices. Two correctional officers at the California State Prison, Solano spend nearly two hours a day transporting mail. Two mailroom employees at the California Institution for Men and one at the California Institution for Women each spend one to two hours a day at the post office and transporting mail. RECOMMENDATIONS The Office of the Inspector General recommends that state correctional facilities take the following actions: • Rent post office boxes for each housing unit and at least one box for administrative mail. • Evaluate either having the Postal Service deliver and pick up mail at the sally port or having a correctional officer escort the mail truck from the entrance gate to the mailroom. Mailroom employees could reject damaged or torn packages when the U.S. Postal Service truck is unloaded. The Office of the Inspector General estimates that the Department of Corrections could save $230,000 a year by using these procedures. FINDING 2 The Office of the Inspector General found that some of the state prisons make inadequate use of correctional officers for mail processing duties. Mail processing procedures at each facility are largely manual and involve many steps. This is partly due to the need to perform specific procedures to comply with California Code of Regulations, Title 15 and because different types of mail require different handling. Correctional facilities need to sort, search, seal, bundle, transport, re-route, and log mail. The Office of the Inspector General found that facilities that assign correctional officers to do some of these tasks reduce the workload in the mailroom. Some prisons do not use correctional officers to search and seal mail. The California Institution for Women uses correctional officers during the graveyard shift to search and seal outgoing mail. While inmates are sleeping, the correctional officers have time available for mail processing. This enables two mailroom employees to process outgoing mail in one hour in the morning. California State Prison, Solano and the California Institution for Women use “light duty” correctional officers, or ground crews when it is raining, to help search incoming mail. Correctional officers at the two other prisons visited do not perform these duties, and mailroom employees spend four to six hours each morning searching and sealing outgoing envelopes. Some prisons do not use correctional officers to transport mailbags. At the California Institution for Women and California State Prison, Solano, correctional officers drop off empty mailbags at the mailrooms and pick up full mailbags to be delivered to the inmate housing units. Mailroom staff members do not spend their time transporting mail and mailbags between the housing units and the mailroom. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 8 At the California Institution for Men, correctional officers do not help transport mail. Instead, a mailroom employee spends about three hours a day collecting outgoing mail and delivering incoming mail. Officials at the California Institution for Men said correctional officers do not transport mail because it is not provided for in their union agreement. Correctional officers do not separate inmate mail or re-route mail. The Office of the Inspector General also noted that none of the selected prisons use correctional officers to segregate outgoing inmate mail that requires special attention from the mailroom— specifically legal mail, certified mail, and mail to be re-routed. Instead of re-routing mail for inmates who have left their units, the correctional officers return the mail to the mailroom for processing, even though they have the computers necessary to deliver mail or mark it for delivery to the proper unit within a correctional facility. RECOMMENDATIONS The Office of the Inspector General recommends that the prisons use correctional officers, perhaps those who are on “light duty” for the following mail processing purposes: • Helping search mail for contraband; • Segregating legal, certified, and re-routed mail, and searching incoming mail when schedules permit to save time of mailroom employees; • Setting aside items received from inmates requiring special handling; • Re-routing mail for inmates who have moved; and • Helping search incoming and outgoing mail. The Office of the Inspector General estimates that the Department of Corrections could save $300,000 a year by implementing these recommendations. FINDING 3 The Office of the Inspector General found that the institutions are often inefficient in conducting the initial search of incoming mail. When correctional facilities receive incoming mail, the mailroom staff must identify legal mail that must be delivered within 24 hours of receipt under California Code of Regulations, Title 15. During the initial search, mailroom employees also must identify certified mail, mail addressed to employees, and other mail requiring special handling. The remaining inmate mail is held until the mailroom staff can search it for contraband and other inappropriate contents. Some mailrooms take unnecessarily steps in sorting and searching mail. The Office of the Inspector General found that some facilities do not perform the initial search in conjunction with the initial mail sort. Only the California Institution for Women optimized the initial search by also sorting the mail into other categories: administration mail, mail requested by STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 9 the Special Investigations Unit, inmate-housing unit mail, and legal mail. Once employees have sorted the mail, inmate mail is bundled by housing unit and the bundles are kept together until they are searched. By sorting during the initial search, mailroom employees reduce the mail-handling time. Once searched, the bundles are placed in the proper housing unit mailbags instead of requiring another sort. In addition to bundling the letters by housing units, the California Institution for Women opens all incoming mail immediately after the initial sort, using an automatic envelope opener. All the facilities that the Office of the Inspector General visited have automatic letter openers, but not all the facilities require employees to use them. Some prisons waste staff time in the process of reviewing publications. In sorting mail, employees must review each publication received to ensure that it is permitted under California Code of Regulations, Title 15. Some publications are known to be acceptable for delivery to inmates, while others must be reviewed whenever they are received. The Office of the Inspector General found that some mailroom employees were searching publications after another employee had already reviewed them. At California State Prison, Sacramento, the mailroom uses a correctional officer knowledgeable about obscene material criteria to review all pornographic material, thereby reducing possible emotional stress to other mailroom employees. Some prisons needlessly verify inmate addresses. At some institutions, the mailrooms verify addresses for all inmate mail, a step that reduces the potential benefit of having separate post office boxes [See Finding 1]. Verification of inmate addresses is performed primarily through the Dedicated Data Processing System, but because inmates who have been moved may not be in the Dedicated Data Processing System; mailroom staff must call the prison administrative offices to search for the inmate in the Offender Based Information System. None of the mailrooms visited has direct access to the Offender Based Information System. RECOMMENDATIONS The Office of the Inspector General recommends that correctional facilities improve the efficiency of the initial search of incoming mail by taking the following actions: • Require mailroom employees to use automatic letter openers to ensure full use of available equipment and save time; • Develop a list of acceptable publications that employees can immediately place in the housing unit mailbags when publications are reviewed; • Designate a specific staff member to review all publications because of the nature of some of the publications; • Eliminate the practice of verifying all inmate addresses. Mailrooms should verify inmate addresses only when inmate mail is returned for an incorrect address; and STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 10 • Provide mailrooms with direct access to the Dedicated Data Processing System and the Offender Based Information System to verify inmate addresses more quickly. The Office of the Inspector General estimates that implementing the recommendations will generate savings based on staff hours reduced by eliminating unnecessary or duplicative procedures. However, because the time saved by these efficiencies cannot be easily quantified, the Office of the Inspector General has not estimated a dollar savings for this recommendation. FINDING 4 The Office of Inspector General found that the processing of standard mail is often delayed by mail requiring special handling. Mailroom employees identify and segregate mail that requires special attention or handling. In addition, they segregate legal and certified mail from “regular” inmate mail. Legal and certified mail is processed immediately, while regular mail is set aside to be searched to identify items requiring special attention, including mail with enclosures such as stamps, photographs, money orders, or contraband. The current search process interrupts the workflow. When mailroom employees find items considered contraband, the search of other regular mail effectively comes to a stop. The employee finding potential contraband completes a contraband form and takes additional steps for that item before he or she continues processing other mail. Mail processing delays may occur when an inmate is moved because employees must locate the proper mailing address using the Department Data Processing System or the Offender Based Information System. Employees spend significant amounts of time processing a piece of “bad” mail (one that is misaddressed or contains contraband) at the expense of “good” mail. Re-sealing envelopes takes too much staff time. The greatest delay appears to be the practice of re-sealing all envelopes after they are searched. The Office of the Inspector General observed this practice at three correctional facilities. At the fourth facility, the mailroom re-seals only envelopes that pose a risk of items falling out, such as envelopes containing loose stamps or photographs, thereby greatly reducing the time spent re-sealing envelopes in the majority of incoming mail. Different contraband lists at the state’s institutions add to the mailroom workload. Correctional facility staff must take great care in screening items sent to inmates. The department has a list of contraband items prohibited at all correctional facilities, but partly because of differing security levels, wardens have the discretion to add items to the list. As a result, contraband lists are different at each facility. Mailroom employees said the different provisions place an additional workload on the mailroom because when a transferred inmate receives items not allowed at the new facility, mailroom employees must fill out contraband forms for items previously allowed. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 11 At some prisons, the form for processing contraband requires too much time. Employees must hand-write the reason an item has been identified as contraband and note the specific section of California Code of Regulations, Title 15 the item violates. At some prisons, this process consumes a great deal of staff time. California State Prison, Sacramento, however, has stream-lined the process by using addenda to the department’s contraband forms. The addenda contain check-boxes defining contraband by the corresponding section of the code and are used in conjunction with the contraband form, thereby reducing the time mailroom employees spend handling contraband. RECOMMENDATIONS The Office of the Inspector General recommends that the prisons take the following actions: • Set up mailroom procedures to enable employees to process standard mail without interruption. • Have employees first sort properly addressed mail from mail with problems, then search and process the “good mail, and last, locate the correct addresses on misaddressed mail. • Handling of mail containing contraband should not delay other mail processing. • Provide mailroom employees with tools and materials acceptable for use within the facility. If inmates are allowed to receive staples or stickers, facilities should provide staplers and stickers to the mailroom for re-sealing inmate mail. . Because the time saved could not be easily quantified, the Office of the Inspector General did not estimate a dollar savings that might result from these recommendations. Implementing the recommendations, however, would reduce the time it takes to process regular inmate mail—which in turn would benefit the institution overall by reducing the number of mail-related inmate appeals and contribute to improved inmate morale. FINDING 5 The Office of the Inspector General found that procedures for handling cash found in inmate mail differ at each facility and that the mailroom process for handling checks and money orders is inefficient. Because the mailrooms visited by the Office of the Inspector General are the only point of entry for mail at the correctional facilities, the receipt of inmate funds is a vital responsibility of the mailroom staff. The review found that each correctional facility processed funds sent to inmates differently and that in each case, the processes appeared to be time-consuming and to include many duplicative steps. For example, all correctional facilities logged the money orders and checks before forwarding them to the accounting office, where they were logged again. At California State Prison, Solano and California STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 12 State Prison, Sacramento, the mailroom logged the money orders and checks multiple times, resulting in a greater burden to the mailroom staff. Time spent to process the money orders and checks delays searching and processing other incoming mail. Cash is defined as contraband and also requires special handling. Under California Code of Regulations, Title 15, cash constitutes contraband, but because of the nature and inherent risks surrounding cash, it is handled differently from other contraband. Even though each of the facilities reviewed processes fewer than five cash enclosures a day, the review found that each facility used a different process for handling cash found in inmate mail and that in each case the process was time-consuming and represented a burden to the mailroom staff. Three facilities deposit the cash into an institutional bank account and then draft a check to return the money to the sender, requiring not only staff time in the mailroom and in the accounting office, but also resulting in the facility incurring costs for the check stock and postage. California State Prison, Sacramento, on the other hand, simply sends the cash back to the sender by return mail. At $10 per item, and an average of four cash collections per day at each facility, cash handling could be costing the Department of Corrections as much as $396,000 a year at its 33 prisons. Based on estimates of the cost to process a revolving fund check made by the State Controller’s Office, the Office of the Inspector General estimates that modifying the cash handling process could save the Department of Corrections $10 to $25 per cash item received. Mailroom employees are not bonded and are not trained to handle money. Mailroom supervisors expressed concern that their employees generally have no accounting or financial background, no training in handling large sums or money, and are not bonded. The supervisors said they are unsure whether it is appropriate for office assistants or office technicians to handle the large amounts of money flowing through the mailrooms (ranging from $3,000 to $5,000 a day). RECOMMENDATION The Office of the Inspector General recommends that the Department of Corrections take the following actions: • Standardize the process for handling cash similar to the process for handling other contraband. The process should include a special “cash as contraband” form, giving the inmate the option of donating the cash to a predetermined charity or returning it at the inmate’s expense. • Set up a standard procedure for handling money orders and checks sent to inmates to limit the handling of money orders and checks by mailroom employees while retaining staff accountability. • Establish procedures for institution mailrooms in which, upon receiving a check or money order, mailroom employees would ensure that the item includes all required information, including the inmate’s name and number. Employees would then add any additional information required; stamp the STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 13 envelope to verify receipt, and write the date and amount on the envelope for delivery to the inmate. The envelope becomes the inmate’s receipt and the check or money order is held for delivery to accounting. • Create a standard “funds received” form, in triplicate, for the mailroom staff to use to list all money orders and checks received each day. Each mailroom employee searching mail would be issued one form for use that day. The employee would record the inmate’s name and the amount of the funds on the form. At the end of the shift, employees would give the forms, along with all money orders and checks received, to the mailroom supervisor. The supervisor would deliver the forms, along with the checks and money orders received that day to the accounting office, while retaining the carbon copies: one for the supervisor and one for each staff member for their records. This process will reduce the time spent processing money orders and checks. Checks and money orders would be logged only at the point of entry. The accounting office would review the forms for accuracy while preparing the funds for deposit and crediting the inmates’ trust accounts. The form creates accountability because the accounting office can identify the employee who processed each money order or check. The Office of the Inspector General estimates that the Department of Corrections could save $200,000 a year by adopting a standard process for processing money orders and checks and another $396,000 by standardizing the process for handling cash—for a combined savings of $596,000. FINDING 6 The Office of the Inspector General found that some of the selected institutions have inefficient processes for handling unstamped mail. When inmates submit mail without postage, some of the institutions add to the mailroom workload by using time-consuming extra steps to process the items. The extra processing takes place 1) when the inmate is indigent and has no money for postage, or 2) when an inmate asks that postage be taken from his or her trust account. Under these circumstances, for example, mailroom employees may have to determine whether the inmate has been identified as indigent, and, if not, determine the postage amounts due, access inmate trust accounts to see whether there are sufficient funds to pay the postage, and note the postage amount on an authorization form. Possible improvements in the process include eliminating the step of accessing the institution database to verify whether an inmate has sufficient funds for a trust withdraw request to cover postage. At present, the prisons reviewed access the Dedicated Data Processing system each time a trust authorization form is attached to a piece of outgoing mail. The Office of the Inspector General observed that the prisons spend approximately half-hour a day verifying trust account balances for what primarily amount to .34 charges. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 14 Instead, the mailroom staff could note the postage amount on the trust authorization form, post the letter, and forward the trust authorization forms to the institution’s accounting offices without verifying the trust balance. Because the accounting staff already accesses inmate trust accounts to process the authorization request, they would also be able to identify when an inmate’s trust account no longer has sufficient funds to cover postage expenses. At that point they could include the inmate’s name on a list of “overdrawn” inmate accounts and supply the list to the mailroom. The mailroom could then stop processing mail for those inmates, thereby decreasing the time spent by the mailroom staff duplicating the task of accessing inmate trust account records while limiting an inmate’s ability to send outgoing mail without sufficient funds. Another improvement would be providing indigent inmates with their weekly allotment of mail supplies, including five pre-stamped envelopes. This process, already in effect at the California Institution for Women, reduces the number of pieces of unstamped mail requiring the mailroom staff to verify whether it originated from an indigent inmate. Because California Code of Regulations, Title 15 allows indigent inmates unlimited postage for specified legal documents, the new procedures should not apply to legal mail. RECOMMENDATIONS The Office of the Inspector General recommends that the facilities rely on accounting personnel to monitor inmate trust accounts for sufficient funds to pay postage on outgoing mail and provide pre-stamped envelopes to indigent inmates. The Office of the Inspector General estimates that the Department of Corrections could save $54,000 a year by implementing this recommendation. FINDING 7 The Office of the Inspector General found that the prisons reviewed spend significant amounts of time creating duplicate logs when processing legal mail. The California Code of Regulations, Title 15, Section 3165, requires that mail containing legal documents must be posted each working day. The Office of the Inspector General observed that the four facilities visited give legal mail a priority over non-legal mail to ensure that the mail is processed within 24 hours. However, the Office of the Inspector General also observed that mailroom handling of legal mail includes significant duplicate logging. Logging generally includes recording the inmate’s name and identification number, the name and address of the legal entity that sent or will receive the legal documentation, and the date the letter is processed by the mailroom. Some prisons create two or three logs for each document. Logging procedures vary at each prison. The California Institution for Women requires correctional officers in the housing units and employees in the mailroom to create separate logs for legal mail, with approximately two hours per day spent at the institution logging legal mail. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 15 Legal mail procedures at two other facilities involve even more repetition. At California State Prison, Solano, legal mail is recorded on three logs: first on a hand-written form, then in a logbook used to record legal letters processed by date, and third into an Excel database spreadsheet. Mailroom employees said this logging takes approximately an hour a day to complete. The spreadsheet is saved daily and the logbook is kept in the mailroom. The handwritten forms are sent with the legal mail to the housing units, where correctional officers have the inmates initial the forms on delivery. The California Institution for Men requires inmates to fill out three copies of a “proof of service” form for each legal envelope they send. Inmates record their names, identification numbers, a description of the legal document being sent, the destination address, and the date the letter is sent to the mailroom. When the mailroom receives the envelope and forms, the mailroom employee signs and dates each copy of the form. One copy is placed in the envelope, one is sent to the inmate as proof of mailing, and one is kept by the mailroom. Once the “proof of service” forms are completed, mailroom employees fill out additional logs, recording the information on the “proof of service” form onto a card created for each inmate. The employee who processes mail for that inmate’s housing unit keeps these cards. After the information is logged onto the card, a mailroom employee records the same information in a notebook that tracks the legal letters processed on a specific date. The procedure used by the California Institution for Men for incoming legal letters is similar, except that “proof of service” forms are not used. Instead, mailroom employees fill out a separate tracking log for each housing unit. The tracking log is sent with the legal mail to be initialed by the inmate in the presence of a correctional officer. Mailroom employees also fill out a card stock form and the log notebook. Mailroom employees estimate they spend two to three hours a day logging legal mail. The Office of the Inspector General was told by each facility that the repeated logging procedures are intended to minimize the risk of litigation over non-delivery of legal mail. Officials at the California Institution for Men said their logging process has reduced the number of second-level inmate 602 complaints. In addition, the duplicate logging provides the facility with several sources of documentation for when an inmate complaint about legal mail is researched. One institution reviewed uses a simpler process to handle legal mail. At California State Prison, Sacramento legal mail is logged only once. Correctional officers log incoming legal mail on a form when the mail is given to the inmate. Outgoing legal mail is entered into an Excel database by the mailroom before it is mailed out. These procedures reduce time spent logging legal mail, yet still provide documentation for use if an inmate complaint arises. RECOMMENDATION The Office of the Inspector General recommends that the Department of Corrections establish standard procedures for processing legal mail. Facilities should use the “proof of service” form presently used at the California Institution for Men to track outgoing legal mail. Since the inmate fills out the form, the mailroom could simply verify the information and file the mailroom STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 16 copy for future reference. This would greatly reduce the time spent creating duplicate logs. The Office of the Inspector General estimates that the Department of Corrections can save $110,000 a year by reducing the time spent logging legal mail. FINDING 8 The Office of the Inspector General found that some prisons do not fully comply with California Code of Regulations, Title 15 requirements. California Code of Regulations, Title 15, Division 3, Section 3131 requires the warden at each institution to prepare a plan of operation for processing mail and submit the plan to the Director of the Department of Corrections for review and approval to ensure conformity with Title 15 requirements. The Office of the Inspector General reviewed the mail operation plans for nine institutions, including three from the northern region, four from the central region, and two from the southern region to assess compliance with Title 15 requirements. Of the 70 mail-related requirements in California Code of Regulations, Title 15, the Office of the Inspector General found that only 13 requirements were addressed in all nine plans reviewed. Five requirements were not addressed in six or more of the nine sample plans reviewed, and one requirement related to business mail was ignored in all nine plans. Clearly, department headquarters is not adequately reviewing the plans submitted, providing corrective feedback, or monitoring the mail operations of the institutions. Specifically, the Office of the Inspector General found the following compliance deficiencies. • One institution does not inform new inmates about inmate mail regulations. California Code of Regulations, Title 15, Division 3, Section 3131 requires the correctional staff to promptly inform newly arrived inmates of all department regulations and institution procedures governing inmate mail. The California Institution for Men does not fulfill the requirement. More than a year ago, the California Institution for Men included an explanation of its mail procedures during new inmate orientation. Since then, the facility has overlooked presenting this information and instead has relied on correctional officers at each housing unit to address inmate questions about mail. The California Institution for Women and California State Prison, Solano both provide mail orientation to new inmates almost every week. • Two of the prisons do not maintain a current address list of courts in the mailroom. California Code of Regulations, Title 15, Division 3, Section 3165(a) requires each mailroom to maintain a current address list of federal, state, county, appellate, and district courts. Mailrooms at the California Institution for Men and the California Institution for Women do not maintain current court address lists and it appears that their listings may not have been updated since the mid-1980s. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 17 • One of the three state prisons visited does not open and inspect returned inmate mail. California Code of Regulations, Title 15, Division 3, Section 3147(a)(4) requires that all undelivered letters and packages returned by the post office be opened and inspected before they are returned to the inmates. The California Institution for Women opens and inspects the mail only if the envelope appears bulky or if it appears to have been tampered with or opened. • One institution does not comply with requirements for return of unallowed items. California Code of Regulations, Title 15, Division 3, Section 3147(a)(5) requires that an inmate be promptly notified in writing of the reasons mail is disallowed; the disposition to be made of the mail; the name of the official disallowing the mail; and the name of the official to whom an appeal may be directed. Form CDC 1819 provides this information to the inmates. The California Institution for Men does not comply with this regulation. Instead, the institution returns certain disallowed items to the sender without providing a written disposition to the inmate. The items are typically limited to musical cards, Polaroid pictures, and pens. The institution reseals the mail, notes on the outside that the enclosed items are not allowed, and returns the mail to the sender. The Chino Post Office has agreed not to charge postage for these items. Although California Code of Regulations, Title 15 is specific about the need to notify an inmate when mail is disallowed, the process used by the California Institution for Men reduces the time spent processing these contraband items. A review of California Code of Regulations, Title 15 may be needed to establish a more efficient process while ensuring that mail protocols help maintain a safe prison environment. • One of the institutions reviewed does not submit contraband for review. California Code of Regulations, Title 15, Division 3, Section 3136 requires that contraband items be referred to a staff member, not below the level of a facility captain, for review and disposition. Form CDC 1819 documents mail items that are confiscated, and the reason for confiscation. Inmates receive the form, enabling them to appeal the confiscation and to inform relatives of prison policy on contraband. At the California Institution for Men, however, a facility captain reviews only magazines that contain unallowable sexually explicit material, while other contraband items—including stamps and pictures over the allowable limit, stickers, and writing tablets—are not reviewed at that level. The institution allows mailroom employees to sign the Form CDC 1819 for disallowing nonoffensive contraband and the items are not referred to the mailroom supervisor or the mailroom sergeant. These contraband items therefore are being withheld from inmates without a proper level of approval. The procedure does allow inmates to receive the Forms CDC 1819 sooner than they would if a facility captain first reviewed the contraband items. The institution staff said that this procedure gives the facility captain more time for other duties while allowing for review and approval only of items identified as offensive contraband. Nevertheless, California Code of Regulations, Title 15 is specific about the level of review required to assure that facility management has reviewed all disapproved mail. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 18 RECOMMENDATIONS The Office of the Inspector General recommends that the Department of Corrections and the institutions reviewed take the following actions: • Department of Corrections headquarters should develop a standard checklist for reviewing mail operation plans submitted by the prisons. • The California Institution for Men should implement procedures to inform new inmates of department regulations and institution-level procedures governing inmate mail. • The Department of Corrections should periodically provide all 33 facilities with an updated list of courts and require that each facility keep its lists available for inmate use. • The California Institution for Women should search all returned inmate mail as required by California Code of Regulations, Title 15. • The California Institution for Men mailroom should process all identified contraband items using the established Form CDC 1819, and all forms should be provided to the facility captain for review and approval. FINDING 9 The Office of the Inspector General was unable to determine whether the prisons reviewed are complying with delivery standards for regular inmate mail. In a memorandum dated April 13, 2000, the Department of Corrections directed all wardens to revise their inmate mail operational procedures to prescribed mail delivery time standards. The directive mandated that “All first class mail shall be issued to the inmate as soon as possible, but not later than seven calendar days from receipt of the mail from the post office.” Each warden was advised to conform immediately to the standards unless existing procedures were more restrictive. In those cases, wardens were encouraged to maintain the shorter timeframes. No system is in place to ensure that delivery standards are met. Mailroom employees at each of the prisons visited said they are able to meet the seven-day delivery timelines except during holiday periods, but none of the facilities record the receipt of incoming first-class mail. The postmark is not a reliable indicator of the date mail is received, as postmarks on mail received by the mailroom can be one to two weeks old. The only recording of incoming first class mail at the prisons visited was the dating of the trays or bins in which the mail was placed. A handwritten date on a Post-It note is affixed to each tray or bin. Mailroom supervisors generally instruct the staff to work on the oldest tray or bin first, until all that mail is processed, inspected, and delivered. As soon as a tray or bin is empty, the dated note is discarded. No record is kept to document when the mail in each day’s trays or bins was delivered, nor is there a notation, such as a stamped or hand-written STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 19 date on the envelope, on the regular first-class mail itself. In the absence of mail logs or date-stamped mail, the Office of the Inspector General cannot judge the institutions’ compliance with the seven-day delivery standard. Compliance testing was limited to observing the trays and bins being processed during the visits and to interviewing mailroom employees and supervisors. The Office of the Inspector General also reviewed mail-related inmate 602 complaints to identify patterns of complaints relating to late mail. None of the tests suggested that the institutions are out of compliance with the seven-day delivery standard, but the presence of reviewers at prison mailrooms could have influenced work effort, and statements of selfcompliance are by nature unreliable. The Office of the Inspector General recognizes that manually date-stamping and logging the thousands of pieces of first class mail received at each facility could create a significant cost in staff time and new equipment. On the other hand, demonstrating compliance with mail delivery standards could prevent future litigation and complaints from inmates and advocates. Accurate information on mail processing time is also important for the department in budgeting mailroom staff and resources and ensuring accountability. RECOMMENDATIONS The Office of the Inspector General recommends that the Department of Corrections either establish the following procedures for tracking first-class mail or explore other ways to show compliance with established standards. • • Institute a modified tracking system based on mail trays and bins rather than stamping or logging each piece of first class mail. At the beginning and end of the workday, the mailroom supervisor should enter into a log (preferably an automated spreadsheet) the following information for first class mail: • For regular envelopes and post cards in all mail trays: at the beginning of each workday, record the time and date of entry and supervisor’s name; date the mail was received; and number of inches of mail in each dated tray (normal trays contain approximately 850 letters when full). At the end of each workday, record the time and date of entry and supervisor’s name; the date the mail in the tray was received; and the number of inches of mail in each dated tray. • For large envelopes in mail bins: use the same process, except that, because of their irregular size, envelopes should be counted rather than measured. Require the correctional officer responsible for mailroom operations to review the daily logs at least three times a week to ensure that they are promptly and accurately prepared and to determine whether extraordinary circumstances may have affected mail processing and to annotate evidence of the review. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 20 Logging this way records unprocessed mail for each day, and over a period of days. For example, mail trays and bins received and recorded on January 7 should be delivered by January 14 and thus no longer would be logged. If mail received January 7 is still unprocessed on January 14, the institution is out of compliance with the seven-day mandate. The process would provide the department with low-cost, documented evidence of compliance with mail delivery standards. It would also provide management with mail volume statistics critical for workload and staffing decisions, as well as justification for equipment or other resource needs. It would also allow mailroom supervisors to assess employee accountability and productivity. If complaints arise about mail delivery times at a given facility, the department would be able to weigh the complaint against its record of mail delivery to determine the appropriate response. FINDING 10 The Office of the Inspector General found no first-class mail designated for disposal at the prisons reviewed. The Office of the Inspector General tested a sample of mail designated for disposal at two prisons. At the California Institution for Men, the mailroom designates two trash receptacles for disposal of mail. The Office of the Inspector General found no first class mail in either receptacle. California State Prison, Solano provides one box in the mailroom supervisor’s office for mailroom employees to dispose of mail. At the end of each week, the supervisor searches the box to verify that no pieces are first class mail. The box is then sealed, signed, and dated and the supervisor sends the box to be destroyed. The Office of the Inspector General found no first-class mail in the box during its visit and no first-class mail in boxes of mail that it requested be set aside. One prison does not discard fourth class and undeliverable mail. The Office of the Inspector General found that the California Institution for Women does not throw away mail at all, and instead returns all fourth-class and undeliverable mail to the post office. The institution staff said that it sees no value in throwing away fourth-class and undeliverable mail instead of returning it. However, the Office of the Inspector General observed that returning mail to the post office adds a minor additional step for the mailroom. RECOMMENDATIONS • The Office of the Inspector General recommends that correctional facilities limit how mailroom employees are allowed to dispose of mail. Mailroom supervisors should periodically review the type of mail being discarded to prevent mail from being inappropriately thrown away. • The Office of the Inspector General recommends that the California Institution for Women discard fourth class and undeliverable mail instead of returning it to the post office, using appropriate controls for disposal. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 21 APPENDIX INSTITUTIONS VISITED FOR THE REVIEW BY THE OFFICE OF THE INSPECTOR GENERAL OF MAIL PROCESSING AT CALIFORNIA DEPARTMENT OF CORRECTIONS FACILITIES The California Institution for Men. The California Institution for Men, located near the city of Chino, currently houses more than 6,200 male inmates. The institution operates on a $111 million operating budget and has approximately 1,700 custody and support service staff members. Ten office assistants and one supervisor staff the mailroom, which is located outside the facility’s security perimeter. Opened in 1941, the California Institution for Men accommodates three reception centers and one level I inmate housing unit on 2,500 acres. Nearly two-thirds of the inmate population of the institution is housed in the reception centers. The facility also operates a 24-hour licensed acute care in-patient hospital and an HIV unit. The California Institution for Women. The California Institution for Women, located near the city of Corona, currently houses more than 1,700 female inmates. The institution operates on a $42 million operating budget and has approximately 660 custody and support service staff members. One correctional sergeant, one correctional officer, and two clerical employees staff the mailroom, which is located within the facility’s security perimeter. Opened in 1952, the California Institution for Women accommodates all levels of female inmates and offers numerous inmate programs. California State Prison, Solano. California State Prison, Solano, located in the city of Vacaville, currently houses more than 5,800 male inmates. The institution operates on an $84 million operating budget and has approximately 1,280 custody and support service staff members. Seven office assistants, one supervisor, and two correctional officers on “light duty” staff the mailroom, which is located outside the facility’s security perimeter. Opened in 1984, California State Prison, Solano accommodates both II and III level inmates and offers numerous inmate vocational programs. The institution also has two drug-sniffing dogs for identifying drugs that may be smuggled into the facility through the mail or packages. California State Prison, Sacramento. California State Prison, Sacramento, located in the city of Sacramento, currently houses more than 2,900 male inmates. The institution operates on an $80 million operating budget and has approximately 1,160 custody and support service staff members. Four office assistants, one supervisor, and seven correctional officers on “light duty” staff the mailroom, which is located outside the facility’s security perimeter. In addition, the mailroom receives assistance from two employees who work on a part-time basis. Opened in 1986, California State Prison, Sacramento has both minimum and maximum security housing units and offers numerous inmate vocational programs. STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 22 ATTACHMENT VIEWS OF THE CALIFORNIA DEPARTMENT OF CORRECTIONS STATE OF CALIFORNIA OFFICE OF THE INSPECTOR GENERAL GRAY DAVIS, GOVERNOR CONFIDENTIAL PAGE 23