Policy Writing and Program Development

Mission Statement

Layered Solution's Policy Writing and Program Development creates (or updates) internal written policy for correctional agencies that provides clear direction to staff, thus maximizing operational understanding and efficiency. Providing clear program direction through written policy benefits inmates, staff, and the agency by establishing shared expectations. Well written policy reduces errors and protects the agency, staff, and inmates in litigation.

Layers of Excellence

Layered Solutions’ Policy Writing and Program Development is a process for creating (or updating) a working policy environment that protects the agency, staff, and inmates through expertly crafted written guidance.

Client Needs

Assess the agency’s unique needs, resources, current practices, and program goals.

Collaborate with Agency SMEs

Collaborate with the agency’s subject matter experts to identify the goals, parameters, and unique challenges of the program.

Clear Instructions

Clear and simply written policy allows everyone to understand it the first time they read it; especially when the subject matter is complex.

Review, Edit, Approve

Great policy requires reviewing and editing by the subject matter experts involved in its drafting; from Correctional Officers to Executives, every level of staff is involved before implementation.

Implementation and Training

Great policy is made greater by carefully choreographed implementation and training for those executing the policy, and those impacted.


During my career as an attorney for the Federal Bureau of Prisons, I was the primary architect and editor of numerous national level policy initiatives. Each one required my expertise as a correctional worker, collaborator, legal analyst, writer, and trainer.

    Regulations and Policies
  • Civil Commitment of a Sexually Dangerous Person (Adam Walsh Act) 28 CFR 549.90 – 549.95;
  • Psychiatric Evaluation and Treatment 28 CFR 549.40 - 549.46;
  • Use of Force and Application of Restraints on Inmates – 28 CFR 552.20 – 552.27;
  • Searching and Detaining or Arresting Non-Inmates – 28 CFR 511.10 – 511.18;
  • Communication Management Housing Units – 28 CFR 540.200 – 540.205;
  • Ion Spectrometry Program – Program Statement No. 5522.02, April 1, 2015;
  • American Flag Protocol – Program Statement No. 1020.02, December 23, 2013;
  • Pre-Release Residential ReEntry Center Placements Following the Second Chance Act of 2007;
  • Fees for Healthcare Services - 28 CFR 549.70 - 549.74;
  • Inmate Discipline Program – 28 CFR 541.1 – 541.8;
  • Special Housing Units – 28 CFR 541.20 – 541.33;
  • Incoming Publications - 28 CFR 540.71 – 540.72;
  • Administrative Remedy Program – 28 CFR 542.10 – 542.19;
  • Smoking / No Smoking Areas – 28 CFR 551.160 – 551.163;
  • Youth Corrections Act (YCA) Programs – 28 CFR 524.20 – 524.25;
  • BOP Director’s Guidance Regarding the Law Enforcement Officers Safety Act (LEOSA) (P.L. 108-277; 18 U.S.C. §§ 926B and 926C; July 22, 2004);
  • Good Conduct Time – 28 CFR 523.20; and
  • D.C. Revitalization Act – District of Columbia Educational Good Time Credit 28 CFR 523.30 – 523.34.

Other Significant Projects

A sample of my other significant Bureau of Prisons projects:

The “Johnson” Cases before the U.S. Supreme Court – I worked closely with the U.S. Solicitor General’s Office, including sitting at counsel table during oral arguments, on the “Johnson” cases, which were two separate cases involving Bureau of Prisons issues related to sentence calculation (U.S. v. Johnson, 529 U.S. 53 (2000), and Johnson v. U.S., 529 U.S. 694 (2000)). Both were decided favorably for the U.S.

    After Action Reviews
  • Staff shooting incident, Federal Correctional Institution, Tallahassee, FL; and
  • Inmate disturbance, Reeves County Detention Center, Pecos, TX.
  • Other Projects
  • Review of Conditions of Confinement and Designation Procedures, Administrative Maximum Facility, Florence, CO;
  • Review of conditions of confinement for detainees at Guantanamo Bay, Cuba;
  • Memorandum Of Agreement Between the District of Columbia Corrections Information Council (CIC) and the Federal Bureau of Prisons;
  • Successfully implemented the Prison Litigation Reform Act (PLRA; 42 U.S.C. 1997e), and amended pauper provisions (28 U.S.C. 1915) to decrease frivolous inmate litigation;
  • Final adoption of a revised Master Agreement between the Council of Prison Locals and Bureau of Prisons; and
  • U.S. Department of Justice Policies on the Use of Less-Than-Lethal Devices, and Use of Deadly Force.