In McDonald v. Pinchak, 139 N.J. 188, 202-03, 652 A.2d 700 (1995), the Court remanded to the Department of Corrections for further proceedings in order to amplify the record with respect to whether the inmate requested the opportunity to cross-examine and confront the witnesses against him. The hearing officer's report did not reflect that McDonald had made such a request. Id. at 193, 652 A.2d 700. According to the Court's opinion, the relevant boxes were not checked and the words "not requested" were written on the relevant lines. Ibid. In considering the fundamental rights of inmates as detailed in the constitutional decisions and DOC regulations, Justice Garibaldi wrote: Indeed, the daily interaction between inmates and prison officials can create a tense environment that requires special measures to ensure safety. Swift and certain punishment is one tool prison officials use to maintain order and discourage future misconduct by a perpetrator. Thus, a court must weigh any expansion or refinement of long-established due-process rights of prisoners against the safety of all the prisoners and of the corrections staff. Despite the need to avoid aggravation of the already high level of confrontation inherent in a prison setting and to maintain personal security within the system, the United States Supreme Court in Wolff v. McDonnell, 418 U.S. 539, 94 S. Ct. 2963, 41 L. Ed. 2d 935 (1974) held that inmates are entitled to certain protections. 418 U.S. at 556, 94 S. Ct. at 2974, 41 L. Ed. 2d at 951. At a minimum, the United States Constitution requires that an inmate facing disciplinary charges receive: (1) a written notice of the alleged violation; (2) a written statement of the evidence relied on and the reasons for the disciplinary action taken; (3) a right to call witnesses and a right to present documentary evidence, when doing so would not be unduly hazardous to institutional safety or correctional goals; (4) a right to assistance from a counsel substitute where the inmate is illiterate or the issues too complex for the inmate to marshal an adequate defense. Id. at 563-70, 94 S. Ct. at 2978-2982, 41 L. Ed. 2d at 955-59. One year after Wolff, this Court decided Avant v. Clifford, 67 N.J. 496, 341 A.2d 629 (1975) and extended State due-process guarantees beyond the federal constitutional minimum. See 67 N.J. at 520, 341 A.2d 629. To protect an inmate's interest, we held that DOC must structure an informal hearing to "'assure that the disciplinary finding . . . will be based on verified facts and that the exercise of discretion will be informed by an accurate knowledge of the . . . inmate's behavior.'" Id. at 523, 341 A.2d 629 (quoting Morrissey v. Brewer, 408 U.S. 471, 485, 92 S. Ct. 2593, 2601-02, 33 L. Ed. 2d 484, 496 (1972) The hearing may be informal, but the procedures must determine the factual accuracy of the charges. Id. at 194-95, 652 A.2d 700. In discussing the right to confrontation and cross-examination, the Court stated: N.J.A.C. 10A:4-9.14(a) provides that "if requested," the inmate shall be provided the opportunity for confrontation and cross-examination "where the Adjustment Committee or Disciplinary Hearing Officer deems it necessary for an adequate presentation of the evidence, particularly when serious issues of credibility are involved." Subsection (b) of that same provision further provides that a Disciplinary Hearing Officer or Adjustment Committee may refuse confrontation and cross-examination when they "would be unduly hazardous to correctional facility safety or goals." That State regulation provides more protection than the federal constitution. In interpreting the Fourteenth Amendment, the United States Supreme Court determined that requiring cross-examination and confrontation as a matter of course would lead to the "considerable potential for havoc inside the prison walls" and would result in longer, possibly unmanageable, proceedings. See Wolff, supra, 418 U.S. at 567, 94 S. Ct. at 2980, 41 L. Ed. 2d at 957. Thus, under the federal constitution, "adequate bases for decisions in prison disciplinary cases can be arrived at without cross-examination," and whether to permit cross-examination is left to the "sound discretion" of the prison officials. Id. at 568, 94 S. Ct. at 2980, 41 L. Ed. 2d at 958. Going beyond the minimum protections provided under the federal constitution, this Court in Avant determined that under the New Jersey Constitution, cross-examination and confrontation must be available to the inmate when "necessary for an adequate presentation of the evidence, particularly when serious issues of credibility are involved." 67 N.J. at 530, 341 A.2d 629. Expanding New Jersey's protection of inmates, this Court in Avant amended the standards "by requiring that in those cases where the Committee 'deems' confrontation and cross-examination 'unnecessary for an adequate presentation of the evidence' the reasons for such denial be entered in the record and made available to the inmate." Id. at 532, 341 A.2d 629 (quoting Standard 254.274) This New Jersey requirement exceeds those of most states, which often do not provide for a written explanation from the hearing officer of his or her denial of cross-examination and confrontation to an inmate. Columbia Human Rights Law Review, A Jailhouse Lawyer's Manual 509 (3d 1992). This Court determined that such a requirement represented a "more precise accommodation of the competing interests and would afford greater flexibility than would an absolute bar to or requirement of confrontation and cross-examination." Avant, supra, 67 N.J. at 532, 341 A.2d 629. Indeed, requiring that prison officials record reasons for not permitting an inmate to confront or cross-examine witnesses deters administrative arbitrariness. Case Comment, "Prisoners' Rights-New Jersey Fairness and Rightness Standard-Procedural Requirements Delineated for Prison Disciplinary Hearings," 29 Rutgers L.Rev. 729, 752 (1976). Furthermore, compliance with the requirement would permit reviewing authorities to determine whether or not there had been a proper exercise of discretion. See id. at 752-53 n.134. Because N.J.A.C. 10A:4-9.14 not only complies with Avant but exceeds the requirements of Wolff, we find no need to expand or even to modify an inmate's right to confrontation and cross-examination. Id. at 197-99, 652 A.2d 700. Given the lack of clarity of the record, with no statement of the hearing officer regarding the reason for refusing any request for confrontation, and the words "not requested" near the line relevant to cross-examination, the Court remanded "to DOC to clarify and amplify the record to determine whether McDonald did indeed request witnesses and whether he requested an opportunity to cross-examine and confront witnesses at the original hearing." Id. at 201, 652 A.2d 700.