I can't speak exclusively to the process because I don't have an operational process yet. I don't have something from a commissioner's directive to direct me to what the process would look like. I certainly have looked at it from the same proposal as you.
It would allow us the means to separate these inmates from the other inmates who are submitting genuine complaints and try to work with them, at least. I mentioned the MBIS, the motivation-based intervention strategies to try to sit down to root out the problem behind the submission of all these complaints and grievances. At this point I don't have a process to get to the root of what this is really about and what's driving it. They just continue to submit them.
The other significant impact is that this will allow us to prevent them from moving it on to the grievance process in our current system, where they can now take a grievance. They can actually grieve the fact that I've identified them as multiple grievers in our current process. So this policy will assist us in stopping them from moving it beyond the local institutional level to a grievance process.
Any inmate can pursue judicial review if they so choose. But I truly believe there is some merit to the process, in my experience.
I hope that answers your question.