First Step Act connects to Intergovernmental Service Agreements (IGSAs)

1. How the First Step Act connects to Intergovernmental Service Agreements (IGSAs)
The BOP doesn’t run every facility where federal inmates are held.
It rents space from counties, cities, and private operators through Intergovernmental Service Agreements — or IGSAs.

These are contracts between:
A federal agency (like the U.S. Marshals Service or BOP), and
A local jail, county sheriff, or private operator
The county provides the “beds,” meals, and staff.

The federal agency pays a per-diem rate (e.g., $95 or $120 a day per inmate).
So when BOP changes how long or when inmates stay in certain facilities, it directly changes the financial flow and operational load under those IGSAs.

2. The new classification rule will shift the timelines that drive IGSA payments
Under the new policy:
Inmates who earn FSA credits will move sooner to lower-security or prerelease custody (halfway houses, home confinement, etc.).
That means fewer federal inmates held in county jails under USMS/BOP contracts.
Each earlier release or reclassification = less per-diem money for the county or contractor holding them.
So local jails that rely on BOP or USMS beds (e.g., Williamson County Jail) may lose revenue as more inmates qualify for early transfer.

That’s why this reform isn’t just about compassion — it reshapes the economics of detention.

3. The ripple effect for counties and states
When counties lose federal detainees sooner:
Their IGSA revenue drops, which can threaten local budgets.
Some counties may push back or delay classification updates to keep beds filled.
Others might renegotiate higher per-diem rates to make up the difference.
This ties into what you outlined in MAP-FEDERALISM:
“The rise of the Intergovernmental Service Agreement — why counties became federal landlords.”
Now, that “landlord” model is being squeezed by the FSA’s early-release incentives.
In short: the federal government is reclaiming custody control through algorithmic scheduling instead of local contracts.

4. Why this matters for your Dual Sovereignty argument
From a constitutional/federalism lens:
Old model: the feds depended on local jails to house overflow (dual sovereignty in practice).
New model: through data-driven timelines (Conditional Placement Dates), the feds can predict, plan, and reduce dependence on locals.

Result: power shifts back upward — from county-level sheriffs to the federal algorithm managing time credits and classification.
That’s a quiet centralization of custody authority, executed not by law but by administrative scheduling software.
It’s exactly what your Dual Sovereignty book explores — how federal mechanisms merge into local governance through shared systems, then quietly pull control back to Washington.

5. Summary — the “loop” between FSA and IGSAs

Step
Effect
Winner / Loser

FSA awards time credits
Reduces total days in BOP or IGSA custody
Federal inmates (win: earlier release)
BOP uses Conditional Placement Dates
Cuts reliance on county IGSA beds
BOP (efficiency win)
Counties lose per-diem days
Shrinks revenue from housing feds
County sheriffs (lose revenue)
Control over timelines shifts
From local jail scheduling → to federal system algorithms
Federal bureaucracy (centralizes control)