Tuesday, July 15, 2025
The FSA: Its Implementation, Whatís Wrong, and How to Fix It.
Susan M. Giddings, PhD
Bruce W. Cameron, MS LPC-S, LSOTP-S
© 2025, National Association of Criminal Defense Lawyers. All rights reserved. Reprinted with permission.
The First Step Act (FSA) was signed into law by President Trump on December 21, 2018; it was the single most significant piece of legislation to impact federal incarceration and the incarcerated population since the end of parole in 1987. Among other things, the FSA sought to incentivize participation in Evidence-Based Recidivism Reducing (EBRR) Programs and Productive Activities (PAs), which were developed to address identified criminogenic needs and thereby reduce the risk of recidivism. John C. Maxwell tells us, "What gets rewarded gets done," and the big reward for program participation under FSA is earned time credits—the gold medal of incentives. They allow an individual to earn credits that are applied either toward early transfer to Supervised Release and/or early prerelease placement. This article will highlight key points of the FSA implementation; the structural flaws of the FSA that have excluded the highest risk, highest need individuals, while at the same time undermining the Second Chance Act needs-based prerelease placement, and finally, recommendations for fixing the statutory flaws preventing the FSA from realizing its full value.
† How does it work? An eligible individual would complete a series of risk and need assessments. Based on the results, their unit team would, in consultation with other program providers, develop an individualized program plan with recommendations for specific programs linked to the identified needs. During subsequent reviews, the unit team would monitor the personís program progress, conduct follow-up assessments to identify the individualís evolving needs, and adjust the program plan, as necessary. In exchange for having completed all the necessary assessment tools and agreeing to comply with all the EBRR programs and PAs as recommended, the individual begins accruing programming days that allow him to earn Federal Time Credits. Then, on a monthly basis, the Bureau would review every individual, and individuals who accrue a sufficient number of program days, they could ìcash them in,î and the earned time credits would be posted to their record, advancing their release date. Simple, right? Not in the least.
† The FSA arrived six years ago like a shiny new Christmas gift under the tree with all its ribbons and bows, and the promise of something that was really good, even greató a program designed to give people second chances, reward good behavior, and get people home to their families and communities sooner because they earned it, and maybe even save some money as an added bonus. So, what happened? When Bureau officials opened that beautifully wrapped gift box, there was no shiny new toy. Instead, there was a box full of nuts and bolts, pieces and parts; some pieces were broken, others didnít fit together quite right, and some of it looked new, but the instructions just didnít make sense to everyone. Before getting into what was wrong, and more importantly, some ideas to fix it, it might be helpful to review the major legislative components and how the Bureau of Prisons applied those components to implement the First Step Act.
The FSA Federal Time Credits Program
†
Initial Classification and the FSA Risk & Need Assessment System. While the FSA was new, the requirements of the Risk and Need Assessment System outlined in 18 USC ß 3632(a) were not, at least not entirely. The Bureauís Initial Classification and Program Review system has been in place for decades and predicated on the authority granted to the Bureau in 18 USC ß4042(a)(1), regarding the management of all federal prisons. During an initial classification, the case manager reviewed the Presentence Investigation Report, identifying relevant issues, and recommended programming. It was both intuitive and obvious. For example: No high school diploma? Recommended the GED program. A history of substance abuse? Recommended drug treatment. Had minor children? Recommended the parenting program. Over the decades the forms and format changed, technology was introduced, and more structured reviews were developed, but the core of the process was still the same: review for needs, recommend programs to meet the needs, monitor progress at later teams, and modify initial recommendations, as required.
† Regardless of how complex the it may have looked, the FSA Risk and Needs Assessment System was as simple as review, recommend, monitor, and modify. The FSA statute required eight specific elements that had to be incorporated into the new FSA assessment system but also allowed the Bureau to use both new and existing risk/need assessment tools. The eight required elements included:
* Determine an individualís recidivism risk during the intake process, classifying him or her as having a risk level of high, medium, low, or minimum.
* Determine an individualís risk for violent or serious misconduct.
* Determine the type and amount of EBRR programming necessary, and assign the individual to the programming based on the individualís criminogenic needs.
* Reassess the recidivism risk level of each person periodically.
* Reassign each person to appropriate EBRR programs or PAs based on their progress, or lack thereof ensuring individuals:
o Have meaningful opportunities to reduce their level while in custody.
† o Address the specific criminogenic needs.
† o Are able to successfully participate in programs.
* Determine when to provide incentives/rewards for successful participation in EBBR programs and PAs.
* Determine when the individual is ready to transfer into prerelease custody or supervised release.
* Determine the appropriate use of audio technology for course material for individuals with dyslexia.
Given that the statutory requirements for the Risk and Need Assessment System were clearly consistent with the activities of the existing Initial Classification and Program Review process, it was an obvious choice to fold the new PATTERN Risk Assessment and SPARC-13 Needs Assessment into the existing process. Further, when coupled with the provision in the statute which allowed for the use of existing assessment tools, expanding the existing process was both an effective and efficient way to integrate all the changes in as seamless a manner as possible.
† Earning Federal Time Credits. In terms of earning credits, the statute addresses only a handful of specific limitations and prohibitions. First, the statute specifies who is eligible to earn time credits based on individualís sentencing procedure, conviction, and deportation status. Second, the statute sets out when an individual cannot earn credit. Lastly, the statute addresses how much credit can be earned and states that earning credit is based on successful participation and completion of EBRR programs and PAs. This last point is at the center of the Bureauís earned time credit calculator. Individuals do not earn time credits directly, rather they accrue programming days through the successful participation and completion in EBBR programs and PAs assigned by Bureau staff to address identified criminogenic needs, which are then cashed in for time credits. Both the formula and programming requirement for earning are annotated in 18 USC ß 3632(d)(4)(A)(i) & (ii):
(i) A prisoner shall earn 10 days of time credits for every 30 days of successful participation in evidence-based recidivism reduction programming or productive activities.
(ii) A prisoner determined by the Bureau of Prisons to be at a minimum or low risk for recidivating, who, over 2 consecutive assessments, has not increased their risk of recidivism, earns an additional 5 days of time credits for every 30 days of successful participation in evidence-based recidivism reduction programming or productive activities.
The intent of Congress was clearó time credits are earned for successful programming, and successful programming is based on participating in programs for which the individual was assigned to by staff and based on their specific identified needs. Despite the opinions of some courts, nothing in the statute suggests that time credits were to be given merely for being sentenced or for participation is just any programming. Congress intended that the opportunity to earn credits is a structured process where the Bureau was responsible for assessing criminogenic needs and then linking those criminogenic needs to specific programming opportunities, and the individual inmate was responsible for participating and completing the programs identified for them.
† Applying Time Credits. The statutory language for applying time credits is articulated in subparagraph (d)(4)(C) of the same ß3632, directing the application of time credits toward prerelease custody or supervised release with the specific conditions laid out in subparagraph (g)(1). First, the conditions referenced in subparagraphs (g)(1) (A), (B), and (C) cover application of time credits to either early transfer to supervised release or early prerelease placement, and include:
* The amount of time credits applied is equal to the remaining amount of time to serve.
* The person has a minimum or low recidivism risk level.
* The remainder of their prison term computed under the applicable law.
The first condition referenced above has created some of the most significant challenges in the implementation of time credit due in part of the language itself, but also as a result of the consequences of the 2020 election. The law gives the Bureau the discretion to apply time credits toward either early supervised release or early prerelease placement. Accordingly, the Bureauís initial implementation plan proposed allowing individuals to apply time credits toward early Supervised Release up to 365 days or until they were within 18 months of their release, with the remaining amount of credit applied to early prerelease placement. The purpose of this strategy was to create a predictable release date, while still allowing sufficient time to transfer to the individual to prerelease placement. This would have meant individuals with shorter sentences would see less time applied toward early release but would have allowed them to transfer to prerelease placement much sooner. Further, because the FSA does not restrict home confinement like Second Chance Act (SCA) and many, if not most, of these individuals do not require the residential services of halfway house, these individuals would have benefited from longer and direct home confinement placements.
† Unfortunately, with the 2020 election and the change in the administration, this proposed implementation was rejected, and the decision was made to create conditional release and placement dates for eligible individuals. While the Bureau developed and deployed both a Conditional Release Date Calculator and a Conditional Placement Date Calculator to facilitate release planning, they are as complex as they are useful with both limitation and presumptions. Further, these calculators are difficult to understand and explain by all but the most experienced Bureau staff, but the complexity of the calculators is unavoidable due to the complexity of the task at hand.
† Second, subparagraph (g)(1)(D) provides different application conditions related to the specific recidivism risk level and whether the credit is being applied to prerelease placement or early supervised release. In terms of prerelease placement, an individual must have a recidivism risk level of minimum or low risk for two FSA assessments, or lacking that (i.e., having minimum or low risk or two assessments at the minimum or low risk level), the individual can petition the Warden as an exception case. In contrast, in order to apply the time credits toward their early transfer to supervised release, the individualís last FSA assessment must be low or minimum risk level. This application requirement means even though prerelease placement, which requires two assessments for early transfer, occurs before supervised release, the Bureau must start posting earned time credits toward early release as soon as the individual achieves low or minimum risk level. The process must proceed in this way in order to create a predictable, albeit moving release date, but those early release credits are not officially applied until the end of the individualís sentence and after transfer to prerelease custody.
† Finally, subparagraph (g)(3) stipulates the limitation on the amount of time credits that can be applied toward early supervised release, specifically, the individual may transfer to their Supervised Release Term up 12 months early. This means individuals with no supervision term are unable to release early from prison, with earned time credits exclusively applied to prerelease placement. Early in the implementation, in some cases individuals without supervision went back to the courts, and courts ordered one day of supervised release. If the reason for the Supervise Release requirement was to ensure these early releasees were supervised, such court actions defeated the purpose.
Where is the FSA Going Wrong?
† The FSA was designed to incentivize individuals to participate in recidivism-reducing programs and activities so that when they released from prison, they returned to their families and communities in a better position, increasing the likelihood they do not reoffend and return to prison. The law obligated the development and use of structured risk and need assessment tools so that individualized program plans would be developed with specific program participation linked to identified needs, and by addressing those specific needs, an individualís risk to recidivate was lowered. So, where is the FSA going wrong?
* The highest risk, highest needs individuals are either statutorily or functionally excluded from the time credit benefit, while the lowest risk, lowest need individuals benefit the most.
* The FSA language created conflicts with the SCA, effectively undermining need-based prerelease placements.
* The statutory language regarding eligibility, earning, and applying of time credits, coupled with the changing political winds of the last six years, has created an extraordinary administrative burden for the agency.
Highest Risk Individuals Locked Out and Lowest Risk Individuals Benefit the Most
† The FSA statute, as currently designed, excludes the majority of the federal incarcerated population from earning and applying time credits. The statute includes restrictions on earning time credits based on conviction offense and on applying time credits based on risk level. According to the Department of Justice 2024 First Step Act Annual Report, 36.6% of the population was statutorily ineligible to earn time credits. Further, another 25.5% of the population was ineligible to apply credits earned due to their risk level. These numbers translate to nearly 90,000 individuals(1) or 65.2% of the incarcerated population were ineligible(2) to apply the credits earned (DOJ, 2024).
† Because the exclusion list uses offense and penalty statutes rather than classes of offenses (e.g., crimes of violence), it mostly excludes individuals convicted of violent (including sex crimes) crimes and certain drug offenses, but not entirely. The result is a haphazard exclusion of individuals from the time credit incentive that at times makes little sense. For example, 18 USC ß924(c), concerning the use or possession of a firearm during a crime of violence or drug trafficking, is the only firearms violation included on the exclusion list. However, 18 USC ß924(j), which sets the penalty for a person who causes the death of another while committing 924(c), is not excluded. Further, the range of behaviors that can be associated with 924(c) conviction is broad and may not involve actual violence.
† Separate from the conviction exclusion, many individuals are unable to earn time credits due to their risk level. The same 2024 DOJ Report finds 45% of individuals had high or medium risk levels, separate from their eligibility status. While some individuals may eventually be able to work their risk level down, others will never be able to despite programming. Why? Because age and criminal history scores are the two most heavily weighted items in the entire risk instrument, and while the age score may change as they serve their sentence, the criminal history score will not. Couple these two scores will other elements like history of violence or escape, and even aggressive programming may not be enough. Even when their risk level does drop, they are unable to maximize the time credits earned because they do not reach the 15-day earning rate until much later in their sentence.
† While not discounting the exclusion list and/or the recidivism risk levels entirely, it can be easily argued that these are the very individuals who should be incentivized to participate in programming. Many of these individuals often have the highest needs ñ substance abuse, lack of education and work skills, anger issues, and criminal thinking ñ and should be incentivized to participate in the EBRR reducing programs, making them precisely the individuals for which successful programming can have the greatest impact.
† Who are these higher risk individuals? They are younger, lower educated, lower skilled individuals with longer criminal histories who are serving longer sentences, making reentry even more difficult. Compare them to the individuals benefitting most from time credits. They are people who enter prison with low or minimum risk levels from the very beginning. These individuals are older, more educated with little or no criminal history serving shorter sentences who are mostly non-violent, white collar, property, or low-level drug offenders. Further, these inmates tend to have minimal release needs as a result of having intact families, supportive communities, a college education, and substantial work skills, all of which support successful reentry. They are often individuals who would have chosen to participate in programming regardless of the incentives, if for no other reason than to pass the time. So again, if the purpose of the FSA was to incentivize program participation and recidivism risk reduction, shouldnít the needs of higher risk individuals be the focus?
Failed to Reconcile the Purpose, Scope, and Limitations of the Second Chance Act
The Second Chance Act, signed into law on April 9, 2008, did three specific things in terms of the Bureau of Prisons and the federally incarcerated population:
* Its purpose was to end the cycle of recidivism through, among other things, increased transitional, community-based residential programming designed to assist releasing offenders with community reentry services.
* In its scope, it directed the Bureau to develop regulations to ensure individuals were designated to prerelease placement consistent with 18 USC ß3621(b), and that these placement decisions were individualized, as well as for a sufficient amount of time, creating the greatest likelihood for successful reentry within the limitations.
* It limited prerelease placement (halfway house and/or home confinement) to no more than the last 12 months of the individualís sentence, and further restricted home confinement to 10% of the sentence or 180 days, whichever was less.
While the FSA limited the maximum amount of earned credits applied toward early transfer to Supervised Release to 12 months, it placed no limitation on the amount of credits applied toward prerelease placement other than the application of earned credit equals the remaining time to serve. This means, depending on the length of a sentence coupled with how early in the sentence the individual scores out at a minimum or low risk, there is the potential for individuals to earn several years of time credits, with all but the first year, in prerelease placement. However, at this point, it is no longer prerelease placementó this is community incarceration.
† Whether in halfway house and/or home confinement, a multi-year placement is not transitional, and the likelihood that it becomes counterproductive is concerning. With the exception of the Bureauís research regarding home confinement results under the Cares Act, studying the impact of long-term community incarceration as not been widely reviewed, if at all. The Bureau evaluated recidivism rates within the 12 months of release for individuals who were released from home confinement and compared recidivism rates for those whose home confinement was under the Cares Act versus those in routine home confinement. The results showed those placed in home confinement under the Cares Act were less likely to recidivate. Even with the seemingly positive results documented in the Cares Act study, the evaluation did not appear to examine differences in the length of home confinement, nor whether individuals required transfer to more restrictive community programs in lieu of being returned to a Bureau prison facility(3). In contrast, a simple Google search regarding restrictive post-release supervision and recidivism rates reveals mixed results, suggesting post-release supervision may actually contribute negatively to recidivism rates(4). Even the proposed Safer Supervision Act (2023) states,
The Administrative Office of the United States Courts has explained that ìexcessive correctional intervention for low-risk defendants may increase the probability of recidivism by disrupting prosocial activities and exposing defendants to antisocial associates.î
Aside from the potential negative impact of a long-term placement, time credits are by definition a reward ñ reentry needs and/or the appropriateness of the placement are nonissues. The FSA statutory language has been interpreted to mean the Bureau has no discretion to reduce or deny placement even when there is no bedspace in the individualís release area, or if the individual is otherwise not eligible. The impacts of this interpretation, which is in direct conflict with the historical purpose of prerelease placement, have been significant. First, prerelease placement was not designed for long-term placements; once the basic provisions of actual reentry are met, continued placement in either halfway house or home confinement is a drain on resources and prevents other individuals from being placed. Second, because of the apparent mandatory nature, the Bureau has had to prioritize FSA placement cases over SCA placement cases. This means that individuals who have been assessed to have actual release needs but are either not eligible to earn and/or apply time credits or are not earning time credits toward prerelease placement are relegated to whatever capacity is left. This often means receiving a placement that is less than what was recommended by their institutions to meet their needs, if at all.
† Finally, the FSA statute did not reconcile the language regarding home confinement. While the SCA restricts home confinement to 10% of the sentence or 180 days, whichever is less, the FSA has no such restrictions. Because time credits are earned, they are not frontloaded into the sentence computation like Good Conduct Time. They advance the projected release date as they are earned monthly until the individual earns 365 days or releases from custody. In complying with the SCA, the Bureau created the Home Confinement Eligibility Date, which reflects the lesser of 10% of the sentence or 180 days. This date is attached to the individualís projected release date and informs the staff and the individual when he is eligible for either direct home confinement, or if he is already in halfway house, when he is are eligible to transfer to home confinement. However, with FSA, the Bureau is also using a Conditional FSA Release Date and Conditional FSA Placement Date to facilitate release preparation and timely transfer to prerelease placement. Thus, for individuals who are only earning time credits toward early Supervised Release, they are often unable to maximize their home confinement eligibility because their eligibility is attached to their projected release date, which only includes earned credit, as opposed to their conditional release date that includes both earned and unearned credit. The result is not only that these individuals are getting less home confinement than they could have before FSA, but because they are otherwise eligible for home confinement with a verified home plan, they are taking critical physical bedspace from other individuals who need the residential services a halfway house provides.
The Substantial Administrative Burden
† The FSA time credit benefit as currently constructed is an administrative nightmare. Because of the statutory language regarding ineligible offenses and penalty statutes, as well as criteria differences for earning and applying credit including, earning rates, immigration status, and application exceptions, the time credit calculation systems had to be built separately from the current sentence computation system with monthly credits calculated and then imported into the system. While the system is fully automated in terms of the actual calculation and posting, it is still manually initiated by staff each month. Because of the size of the application, which has been expanded several times since the program was initially envisioned, it cannot be run continuously due to the significant processing capacity requirements.
† To perform correctly, the application required data integration of the risk and need assessment systems, as well as all the inmate programming status data because time credits are not earned directly but are a function of the successful programming. The risk and need assessment systems also needed to be automated and integrated into the case management system, while at the same time, standardizing all the EBRR program and PA assignment codes, as they were required to be integrated in the risk and need assessment systems as well.
† Aside from significant technological investment, the burden on Bureau staff in the field has been enormous. Oddly enough, the additional work related to completing the various assessments, generating additional reports, or even providing additional program opportunities was not excessively burdensome as it was merely an expansion of what the agency was already doing. The excessive burden was created by (1) the statutory language, which is lacking in both content and clarity in various areas; (2) the overly complex, yet necessary, system created to meet the requirements of the law; and (3) the changing political winds since the law was enacted. These issues combined to create an extraordinary level of confusion for both the staff and the incarcerated population. The result was staff who have difficulty explaining to the population why certain credits have or have not been applied, or worse, do not have the bandwidth to take the time to figure it out and/or explain it because of increasing caseloads.
† Finally, because of the aforementioned issues with the statute ñ the complexity of the time credit calculation and the conditional date calculation applications, and the degree to which staff can adequately explain and answer questions from the individual offenders ñ there has been an enormous uptick in agency administrative remedy requests, as well as court actions. The court outcomes have varied widely based on the issue and the disposition of the court. Further, the politicization of FSA meant the previous DOJ administration seemed to have little interest in supporting the Bureauís positions, regardless of the issue. Whether an individual court rules in the Bureauís favor or not, it does not mitigate the time and resources spent either by the Bureau or the courts, nor does it curb the flow of new cases because very few cases have been elevated to the circuit court level.
What are the Fixes?
† The things not working with the FSA time credits can be fixed, but it will take both work and intestinal fortitude by Congress. The changes need to focus on effective use of existing resources and incentivizing program participation for those individuals at highest risk and for whom program participation will produce the biggest bang for the buck. Moreover, there should be focus on streamlining the entire process to reduce the administrative burden, allowing staff to focus on providing programming and prerelease planning for the incarcerated population. This list of 11 suggestions tackles both effectiveness in terms of the FSAís purpose and efficiency in terms of process and use of resources.
1. Amend the Second Chance Act to eliminate the home confinement restriction. This change will allow more minimum risk, minimum security individuals to transfer directly to home confinement rather than to take up halfway house bedspace required for individuals who actually need the residential services.
2. Grant the Bureau of Prisons special, expediting contracting authority to expand home confinement capacity more quickly and provide the needed funding to pay for the increased capacity. With rapid expansion of home confinement capacity coupled with eliminating the home confinement restriction, the current bed space crisis could be sufficiently resolved, allowing the Bureau to use halfway house space as intended to provide transitional residential services.
3. Amend the FSA language to allow credits to be applied toward early release from incarceration, regardless of Supervised Release status. In light of the bipartisan Safer Supervision Act making its way through Congress, the current restriction is counterproductive.
4. Revisit statutory ineligibility based on offense and penalty statutes to earn credit and consider eliminating offense-based ineligibility altogether. Instead, statutory ineligibility should be limited to individuals with life sentence or the death penalty. If the ability to earn time credits is tied to improving oneís risk level, participation and completion of programming, and behavior while in prison, then it truly could become an incentive to change behavior. An individual cannot change their conviction (absent an appeal), but the conviction should not be the disincentivizing factor toward future change.
5. Similarly, eliminate the ineligibility for the RDAP early release benefit due to current or prior criminal conviction. Individuals should earn and maintain the early release benefit by completing programming (including the community-based portion) and refraining from all serious misconduct for the remainder of the sentence.
6. Modify the time credit earning structure. Allow individuals to apply earned time credits toward early release in an amount up to 15% of their sentence, or alternatively time served, with an additional 12 months of earned credits applied toward early transfer to prerelease placement. Any remaining earned credits not applied to either early release or early prerelease placement, could be applied toward early termination of Supervised Release at the discretion of United Statement Probation and the court.
7. Simplify the earning rate to a single rate of 10 days per 30 programming days.
8. Expand the application of time credits, regardless of risk level, by allowing all eligible individuals to apply time credits earned if they lower either their violent or general recidivism risk score and then refrain from serious institution misconduct for the remainder of their sentence. Refraining from serious misconduct for the remainder of a sentence demonstrates behavioral change and creates a safer prison environment for both the incarcerated population and Bureau staff.
9. Revisit the statutory restriction prohibiting individuals with final orders of deportation from applying time credits toward early release. The Bureau relies on immigration officials to provide complete and timely information regarding final order status. While the Bureau accepts the information provided as factual, situations have occurred where it is determined that a final order has not been issued, or final orders are issued just prior to the individualís scheduled release. The process is inefficient with an increased administrative burden placed on Bureau staff as they are required to make repetitive inquiries to immigration officials and redo work already completed.
10. Create a program completion early release benefit (like RDAP) for other residential programs and certain non-residential programs, like GED and Department of Labor Apprenticeship programs. The amount of the early release benefit can vary based on the program. The program completion benefit would be in addition to time credit, and a person could earn more than one program completion benefit, but the total amount of early release benefits (time credits and program completions) would be capped based on a percentage of the sentence (e.g., 20%).
11. Amend the FSA language to eliminate those areas that have been contested as ambiguous including, but not limited to, when an individual is eligible to begin accumulating programming days and earning times credits, as well as issues related to community-based placements eligibility.
† While the list to fix is extensive and some proposals will be politically easier to implement than others, each of these items will contribute toward accomplishing what the First Step Act was intended to doó incentivize individuals to participate and complete those programs and activities which were specifically designed to address the criminogenic needs that create barriers to successful reentry and increase recidivism. It will allow more individuals the opportunity to earn a reduced sentence. These activities will also streamline the administration of the program, creating a more straightforward and efficient system and providing for more efficient use of resources. Finally, with more individuals able to reduce their prison term and a system that is more efficient, lower prisons populations and cost savings become a welcomed byproduct.
The opinions expressed are those of the authors and do not represent the opinions of the Bureau of Prisons.
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Resources
Notes
† 1. Based on cohort 137,485 individuals; excluded D.C. code cases and those unassessed for either recidivism risk level and/or FTC eligibility.
† 2. While these individuals are not eligible for time credits, they may be eligible for other incentives including additional telephone minutes and visitation, nearer release transfer, achievement awards, preferred housing, and incentive events.
† 4. Search string ìpost release supervision and recidivism rates.î
Postscript: In the weeks since this article was finalized for publishing, the Bureau has deployed enhancements to the auto-calculation application, which is allowing for more frequent posting of time credits. Additionally, on June 17, 2025, the Bureau announced the designation of pre-release placement would apply FSA and SCA authorities cumulatively and in sequence, and would include home confinement. This new directive will mitigate the negative impacts of the statute with regard to home confinement as addressed in this article. The new directive is currently under implementation and while this new directive will require staff training, inmate education, and yet another conditional calculator to manage the statute's shortcomings, the Bureau announced today, July 14, 2025, the establishment of a task force to expedite home confinement transfers using the Designation and Sentence Computation Center (DSCC) component to provide added support for the manual calculation of FSA conditional home confinement dates. More information regarding the task forces is available on www.bop.gov.