Homeland Security

Performance of Information System to Monitor Foreign Students and Exchange Visitors Has Improved, but Issues Remain Gao ID: GAO-04-690 June 18, 2004

The Department of Homeland Security (DHS) has implemented the Student and Exchange Visitor Information System (SEVIS) to collect and record key data on foreign students, exchange visitors, and their dependents--prior to their entering the United States, upon their entry, and during their stay. In accordance with Conference Report 108-280, GAO reviewed SEVIS. Among the areas it examined were (1) system performance, (2) actions to improve performance, and (3) plans for collecting the fee to be paid by foreign students and exchange visitors to cover SEVIS costs.

Several indicators show that SEVIS performance is improving. First, program office reports for some key system performance requirements show that these requirements are being met. However, not all key performance requirements are being monitored or reported on. Without formally monitoring all key performance requirements, DHS cannot adequately assure itself that potential problems will be identified and addressed early. Second, other, less formal indicators of performance, such as daily system use by program officials and unsolicited user feedback, indicate that the system is meeting requirements. Third, GAO's analysis of new requests for system changes, including changes to address reported performance problems, shows these requests are declining. Finally, officials representing educational organizations generally see performance as having improved. DHS has taken specific actions to improve SEVIS performance. In particular, it has installed a series of new software releases and increased Help Desk staffing and training. In addition, program officials are holding regularly scheduled meetings, both internally and with educational representatives, and are asking user groups to test new releases. Despite these efforts, however, educational organizations continue to report problems, such as the quality of Help Desk assistance. DHS submitted its final rule on the SEVIS fee to the Office of Management and Budget (OMB) in February and plans to collect the fee once OMB approves it. Representatives of educational organizations are concerned that two of the three payment options in DHS's final rule are either not available to all students in developing countries or will result in significant delays. Program officials acknowledge the increased demands on students and visitors, but do not believe that these demands warrant changes to their plans.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

Director: Team: Phone:


GAO-04-690, Homeland Security: Performance of Information System to Monitor Foreign Students and Exchange Visitors Has Improved, but Issues Remain This is the accessible text file for GAO report number GAO-04-690 entitled 'Homeland Security: Performance of Information System to Monitor Foreign Students and Exchange Visitors Has Improved, but Issues Remain' which was released on June 18, 2004. This text file was formatted by the U.S. General Accounting Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Report to Congressional Committees: June 2004: HOMELAND SECURITY: Performance of Information System to Monitor Foreign Students and Exchange Visitors Has Improved, but Issues Remain: GAO-04-690: GAO Highlights: Highlights of GAO-04-690, a report to congressional committees. Why GAO Did This Study: The Department of Homeland Security (DHS) has implemented the Student and Exchange Visitor Information System (SEVIS) to collect and record key data on foreign students, exchange visitors, and their dependents” prior to their entering the United States, upon their entry, and during their stay. In accordance with Conference Report 108-280, GAO reviewed SEVIS. Among the areas it examined were (1) system performance, (2) actions to improve performance, and (3) plans for collecting the fee to be paid by foreign students and exchange visitors to cover SEVIS costs. What GAO Found: Several indicators show that SEVIS performance is improving. First, program office reports for some key system performance requirements show that these requirements are being met. However, not all key performance requirements are being monitored or reported on. Without formally monitoring all key performance requirements, DHS cannot adequately assure itself that potential problems will be identified and addressed early. Second, other, less formal indicators of performance, such as daily system use by program officials and unsolicited user feedback, indicate that the system is meeting requirements. Third, GAO‘s analysis of new requests for system changes, including changes to address reported performance problems, shows these requests are declining. Finally, officials representing educational organizations generally see performance as having improved. DHS has taken specific actions to improve SEVIS performance. In particular, it has installed a series of new software releases and increased Help Desk staffing and training. In addition, program officials are holding regularly scheduled meetings, both internally and with educational representatives, and are asking user groups to test new releases. Despite these efforts, however, educational organizations continue to report problems, such as the quality of Help Desk assistance. The following table identifies reported system problems, examples, and DHS‘s responses. DHS Actions to Address User Problems: [See PDF for image] [End of table] DHS submitted its final rule on the SEVIS fee to the Office of Management and Budget (OMB) in February and plans to collect the fee once OMB approves it. Representatives of educational organizations are concerned that two of the three payment options in DHS‘s final rule are either not available to all students in developing countries or will result in significant delays. Program officials acknowledge the increased demands on students and visitors, but do not believe that these demands warrant changes to their plans. What GAO Recommends: To strengthen SEVIS, GAO is making recommendations designed to improve DHS‘s monitoring of key system performance requirements, address educational association performance concerns, and expedite collection of the fee. DHS agreed with most of our findings, conclusions, and recommendations. It did not fully agree with two of our findings and their associated recommendations. www.gao.gov/cgi-bin/getrpt?GAO-04-690. To view the full product, including the scope and methodology, click on the link above. For more information, contact Randolph C. Hite at (202) 512-3439 or hiter@gao.gov. [End of section] Contents: Letter: Recommendations for Executive Action: Agency Comments and Our Evaluation: Appendixes: Appendix I: Briefing to the Staffs of the Subcommittees on Homeland Security, Senate and House Committees on Appropriations: Appendix II: Comments from the Department of Homeland Security: GAO Comments: Appendix III: Comments from the Department of State: GAO Comments: Appendix IV: GAO Contact and Staff Acknowledgments: GAO Contact: Staff Acknowledgments: Abbreviations: DHS: Department of Homeland Security: ICE: Immigration and Customs Enforcement: SEVP: Student and Exchange Visitor Program: SEVIS: Student and Exchange Visitor Information System: OMB: Office of Management and Budget: IIRIRA: Illegal Immigration Reform and Immigrant Responsibility Act: OIRM: Office of Information Resource Management: CCD: Consular Consolidated Database: NIV: Nonimmigrant Visa System: US-VISIT: United States Visitor and Immigration Status Indicator Technology: CLAIMS 3: Computer Linked Application Information Management System: CPU: Central Processing Unit: SCR: System Change Request: Letter June 18, 2004: The Honorable Thad Cochran: Chairman: The Honorable Robert C. Byrd: Ranking Minority Member: Subcommittee on Homeland Security: Committee on Appropriations: United States Senate: The Honorable Harold Rogers: Chairman: The Honorable Martin Olav Sabo: Ranking Minority Member: Subcommittee on Homeland Security: Committee on Appropriations: House of Representatives: The Student and Exchange Visitor Information System (SEVIS) is an Internet-based system that collects and records information on foreign students, exchange visitors, and their dependents prior to their entering the United States, upon their entry, and during their stay. SEVIS has the following objectives: * support the oversight and enforcement of laws and regulations pertaining to foreign students, exchange visitors, schools, and exchange visitor program sponsors authorized by the government to issue eligibility documents, and: * improve the Department of Homeland Security's (DHS) processing of foreign students and exchange visitors at ports of entry through streamlined procedures and modernized data capture. Within DHS's Immigration and Customs Enforcement organization, the Student and Exchange Visitor Program is responsible for certifying schools to accept foreign students in academic and vocational programs and managing SEVIS. DHS required schools and exchange programs to start using the system for new students and exchange visitors beginning February 15, 2003, and for all continuing students beginning August 1, 2003. In accordance with Conference Report 108-280,[Footnote 1] we reviewed various aspects of SEVIS. Specifically, our objectives were to (1) determine how well the system is performing, (2) identify what actions DHS has taken to improve system performance, (3) determine what data the system collects and who uses it, and (4) determine the government's plans for collecting the SEVIS fee.[Footnote 2] On April 1, 2004, we provided your offices with a written briefing on the results of our review. The full briefing, including details of our scope and methodology, is reprinted as appendix I. The purpose of this report is to provide the published briefing slides to you and to officially transmit our recommendations to the Secretary of Homeland Security. In summary, our briefing made the following four main points: * According to several indicators, SEVIS performance is improving. First, program office reports relating to certain system performance requirements[Footnote 3] show that requirements are being met. However, several key system performance requirements are not being formally measured. This is problematic because, without formally monitoring and documenting key system performance requirements, DHS cannot adequately assure itself that potential system problems are identified and addressed early before they have a chance to become larger problems that could affect the DHS mission objectives supported by SEVIS. Second, other, less formal indicators of performance--such as the program office's daily use of the system and unsolicited feedback from users--likewise indicate that the system is meeting requirements. Third, our analysis of new system change requests[Footnote 4] shows that the number of new requests is steadily declining, which similarly suggests that performance has improved. Finally, officials representing ten educational organizations[Footnote 5] stated that system performance had improved. * To DHS's credit, it has taken a number of actions to improve SEVIS performance. In particular, it has installed a series of new software releases and has increased Help Desk staffing and training. Nonetheless, problems continue to be reported, such as the quality of Help Desk support.[Footnote 6] * SEVIS collects a wide range of data, most of which are required by legislation, regulation, or presidential directive. The system also collects some data that are not required. Most of these elements, such as information regarding visas and passports, are important to managing the SEVIS program, but are not required and are only captured on a voluntary basis. The data are used by schools, exchange programs, and offices within DHS and State to oversee the pre-entry, entry, and stay of foreign students, exchange visitors, and their dependents. The data are also used by DHS and State to oversee the schools and exchange visitor programs. * DHS intends to collect the SEVIS fee starting this year, but almost 7 years have passed since collection of this fee was required; thus millions of dollars in revenue have been and will continue to be lost until the fee is actually collected.[Footnote 7] DHS submitted its final rule on the fee, which includes three payment options, to the Office of Management and Budget on February 19, 2004, and is waiting to hear if the rule is approved.[Footnote 8] Representatives of educational organizations are concerned that two of the payment options are either not available to all students in developing countries, or that they will result in significant delays. While program officials acknowledge that collection of the fee will increase the demands placed on students and exchange visitors, they stated that such concerns do not warrant changes to their plans for collecting the fee. The longer disagreements over how the fee should be collected go unresolved, the longer SEVIS reduces the Immigration Examination Fee funds available to other programs. Resolution of such differences in perspective is precisely what the rulemaking process is intended to accomplish. Therefore, it is important that the outcome of this process be implemented quickly. Recommendations for Executive Action: To strengthen SEVIS performance, we recommend that the Secretary of Homeland Security direct the Assistant Secretary of Immigration and Customs Enforcement to ensure that the Student and Exchange Visitor Program Director take the following three actions: * Assess the extent to which defined SEVIS performance requirements are still relevant and are being formally measured. * Provide for measurement of key performance requirements that are not being formally measured. * Assess educational organization Help Desk concerns and take appropriate action to address these concerns. We further recommend that the Secretary direct the Assistant Secretary of Immigration and Customs Enforcement to take the necessary steps to provide for the expeditious implementation of the results of the SEVIS fee rulemaking process. Agency Comments and Our Evaluation: Both DHS and State provided comments on a draft of this report. In written comments signed by the Assistant Secretary, Immigration and Customs Enforcement (reprinted in app. II, along with our responses), DHS agreed with most of our findings, conclusions, and recommendations. However, it did not fully agree with two of our findings and their associated recommendations. First, DHS did not agree with our finding that the SEVIS program was not monitoring and reporting on all system performance requirements, and it agreed in part with our associated recommendation, adding that it believes that we did not fully assess all data that the program office provided to us on this matter. DHS said it was resubmitting these data to clarify our finding. We acknowledge that DHS provided in its comments data on system performance monitoring and reporting, but we do not agree that we did not fully assess the data previously provided, and thus we have not modified our finding and associated recommendation. In particular, neither the data enclosed with its comments, nor the data previously provided, specifically addresses measurement of SEVIS availability. As we state in our report, while the program monitors and reports on the availability of the communications software on its application servers, which can be used to identify problems that could affect SEVIS availability, it does not specifically measure SEVIS availability (i.e., the SEVIS application may not be available even though the communication software is). Further, we acknowledge DHS's statement in the enclosure that it has implemented a new SEVIS-specific processor utilization tool, which relates to one of the performance requirements that our report cited as not being monitored and reported on. However, information on this tool was not previously provided to us and thus could not be verified by us and included in our briefing. We are nevertheless supportive of any recent program actions that would expand system monitoring and reporting to include all key performance requirements. Second, DHS did not fully agree with our finding regarding the use of taxpayer dollars to fund SEVIS. According to DHS, SEVIS has been funded by both appropriated funds and immigration examination user fees, which are collected from nonimmigrants seeking benefits. We do not question DHS's statement that the program has been supported by $36.8 million in appropriated (taxpayer-funded) and $34.3 million in immigration examination user fees funds. Our finding is that 7 years have passed since the fee collection was required, and millions of dollars have been spent (both appropriated and user fees) and will continue to be spent until the SEVIS fee is actually collected. Even if SEVIS is prospectively funded with the immigration examination user fees, until the SEVIS fee is collected, the amount of funds available to other programs funded by this account is reduced. With respect to our associated recommendation, DHS commented that it agreed in part, noting that while it shared the recommendation's sense of urgency in implementing the SEVIS user fee, it did not agree that the Assistant Secretary needed to be directed to take the necessary steps to expeditiously do so because these steps were already being taken. As we stated in our report, although we were told that steps were under way to begin collecting the fee, DHS officials did not provide us with a plan showing, for example, what these steps are. Our recommendation is intended to address this absence of explicit planning for how this shared sense of urgency in implementing the fee will be accomplished. In written comments signed by the Department of State's Assistant Secretary and Chief Financial Officer (reprinted in app. III, along with our response), the department stated that its concerns with collecting the SEVIS fee that we cite in the report remain valid. It also stated that since the report was originally drafted, it has initiated a pilot project with DHS to explore the feasibility of collecting the fee at both consular offices using foreign financial institutions and at consular offices with internal cashiers. According to State, the pilot is to be conducted in a small number of consulates, and will only be extended on a post-by-post and country-by-country basis. The department also provided technical comments, which we have incorporated as appropriate in the report. We are sending copies of this report to the Secretary of Homeland Security, the Secretary of State, and to the Director, Office of Management and Budget. We will also make copies available to others upon request. In addition, the report will be available at no charge on the GAO Web site at [Hyperlink, http://www.gao.gov. Should you have any question on matters contained in this report, please contact me at (202) 512-3439, or by e-mail at [Hyperlink, hiter@gao.gov]. The GAO contact and key contributors to this report are listed in appendix IV. Signed by: Randolph C. Hite: Director, Information Technology Architecture and Systems Issues: [End of section] Appendixes: Appendix I: Briefing to the Staffs of the Subcommittees on Homeland Security, Senate and House Committees on Appropriations: [See PDF for image] [End of figure] [End of section] Appendix II: Comments from the Department of Homeland Security: Office of the Assistant Secretary: U.S. Department of Homeland Security: 425 I Street, NW: Washington, DC 20536: U.S. Immigration and Customs Enforcement: May 27, 2004: Mr. Randolph C. Hite: Director, Information Technology Architecture and Systems Issues: U.S. General Accounting Office 441 G Street, NW: Washington, DC 20548: Dear Mr. Hite: We have received your draft report, SEVIS Performance, GAO-04-690, (310271) and appreciate being provided the opportunity to comment. Below we have commented on each recommendation as well as on information presented in the report. Recommendations 1 and 2: 1. Assess the extent to which defined SEVIS performance requirements are still relevant and are being formally measured; and, 2. Provide for measurement of key performance requirements that are not being formally measured. We concur with the first part of the performance-related recommendation and concur in part on the second part of the recommendation. By November 19, 2004, U. S. Immigration and Customs Enforcement (ICE) will complete the Government Accounting Office's (GAO's) recommended assessment for determining the extent to which SEVIS' defined performance requirements are still relevant. However, we respectfully believe GAO has not assessed all of the data provided to them for determining that ICE must "provide for measurement of key performance requirements that are not being formally measured." In Enclosure 1 ICE has defined formal measurements for the key performance requirements and is resubmitting them for your convenience and clarification of this issue. Recommendation 3: Assess educational organization Help Desk concerns, and take appropriate actions to address these concerns. We concur with this recommendation. As stated on Slide 50, we have addressed six of the seven areas regarding Help Desk support. The seventh area, "Inability to download data so that users could manipulate it themselves and create useful reports" is much more complex. We stated that we are evaluating software options to extract user requested data, provide summary reports, and perform statistical analyses. Please see Enclosure 2 for our detailed explanation. Recommendation 4: We further recommend that the Secretary direct the Assistant Secretary of Immigration and Customs Enforcement to take the necessary steps to provide for the expeditious implementation of the results from the SEVIS fee rulemaking process. We concur in part. The Department of Homeland Security (DHS) shares the sense of urgency in implementing the SEVIS fee, but does not agree with the need for any directive. The ICE Student and Exchange Visitor Program (SEVP) is taking all steps necessary to implement the SEVIS fee in an expeditious and organized manner. The requirement of any directive as insinuated in the recommendation is unnecessary and fails to recognize the efforts taken to implement this fee. ICE and the DHS are committed to making this program, including the fee requirement, operational and successful and have dedicated senior level attention to the matter. To date, SEVP has actively worked with the Office of Management and Budget (OMB) and achieved clearance of the SEVIS Fee Rule from OMB on May 19, 2004. Our original intent in February 2004 was to publish the rule immediately upon OMB clearance and require the fee collection to be effective in early June 2004. However, due to required system changes and delays in implementing the Form 1-901, Fee Collection Process, the effective date for fee collection was changed. Taking into consideration the timelines associated with the Form 1-901, Fee Collection Process, as well as, the concerns raised by the educational community, implementation of the collection of the SEVIS fee was changed to September 1, 2004. The effective date will be published as part of a comprehensive communication/ outreach strategy aimed at educating all stakeholders about the SEVIS Fee process (to include academic institutions, exchange visitor programs, prospective students and exchange visitors, academic organizations and exchange visitor sponsors). The GAO Report states that "Notwithstanding DHS's plans to begin collecting the SE VIS fee, almost 7 years have passed since collection of this fee was required, and thus millions of dollars in revenue have been and will continue to be lost until the fee is actually collected. While DHS, State and educational institutions do not fully agree on how the fee should be collected, the fact remains that the longer this goes unresolved, the longer taxpayers will have to pay for SE VIS (emphasis added). Further, resolution of such differences in perspective is precisely what the rulemaking process is intended to accomplish. Therefore, it is important that the outcome of this process be implemented quickly." SEVP does not fully agree with the specific statement regarding the use of taxpayer funds and wishes to provide additional information. To date SEVP has been supported by $36.8 million in appropriated (taxpayer-funded) Counter-Terrorism funds and $34.3 million in Immigration Examinations Fee funds, which were used for historical development costs from fiscal years: (FYs) 1997 through 2003. The Examinations Fee funds were collected from non-immigrants seeking benefits. Funds for Counter-Terrorism will no longer be available to SEVP after this fiscal year. SEVP wholeheartedly concurs with the GAO that the SEVIS fee be implemented in an expeditious manner to avoid the need for any additional taxpayer funding beyond the Counter-Terrorism funds. Thank you again for the opportunity to respond to the draft report. If you have any questions, please contact Eddie L. Carlisle, Audit Liaison, U.S. Immigration and Customs Enforcement, at (202) 305-0132. Sincerely, Michael J. Garcia: Assistant Secretary: Enclosures (2): Enclosure 1: GAO stated on Page 3 of the April 1, 2004 Briefing to the Staffs of the Subcommittees on Homeland Security Senate and House Committees on Appropriations that: "However, not all key performance requirements are being monitored or reported on." And, Slide 29 supporting the same briefing stated: "Without formally monitoring and documenting all key system performance requirements, DHS cannot adequately assure itself that potential system problems are identified and addressed early, before they have a chance to become larger problems that could affect DHS mission objectives supported by SEVIS." We request that GAO amend their statements because of the detailed formal information that ICE employs to monitor our performance as cited on Slides 30-33 that address the documented performance requirements stated on Slide 29. In several lengthy meetings with the GAO, ICE provided additional formal reporting information on the key performance requirements and stated that the last performance requirement, (Resource Usage bullet) on Slide 30, requires modification as it is not relevant as stated for our e-Gov environment and for a large national communications network. ICE has also implemented a SEVIS-specific CPU utilization tool, mentioned on Slide 34. Further, ICE has provided additional reports that depict our formal monitoring of the CPU usage prior to our implementing the new tool. Hence, we believe that the statement, "However, not all key performance requirements are being monitored or reported on.", does not factually reflect that we are formally monitoring all key performance requirements (with the understanding that some performance requirements must be reviewed for relevancy). Enclosure 2: To provide solutions for extracting user requested data, providing summary reports, and performing statistical analyses will take at least 12 months of analysis and perhaps longer (depending on the results of the analysis) to implement. The primary reason for the length of the analysis period is the sheer magnitude of the processing that occurs on a daily basis. In addition to thousands of Internet and Intranet users, we process 450-600 batch files each night for our large school and exchange program institutions; we also process numerous interfaces to the Department of State and the US-VISIT Program daily. And, because we are processing data 24 hours per day, our primary area of investigation will center on establishing an entirely new platform that would mirror the primary production platform. The following are GAO's comments on the Department of Homeland Security's letter dated May 27, 2004. GAO Comments: 1. We do not agree that we did not fully assess all data that the program office provided to us. We carefully considered all the data that were provided, and neither these data, nor the data enclosed with DHS's comments, addressed all key performance requirements, such as system availability. As we state in our report, DHS monitors and reports on the availability of the communications software on the application servers, which may be used to identify problems that could affect SEVIS availability, but does not specifically measure SEVIS availability (i.e., the SEVIS application may not be available even though the communication software is). Therefore, we have not modified our finding and associated recommendation. We acknowledge DHS's statement in the enclosure that it has implemented a new SEVIS-specific processor utilization tool, which relates to one of the performance requirements cited in our report as not being monitored and reported on. However, DHS had not previously provided this information to us and thus we could not verify the data and include it in our briefing. Nevertheless, we are supportive of any recent program actions that would expand system monitoring and reporting to include all key performance requirements. 2. We do not question DHS's commitment to making the SEVP program, including the fee requirement, operational and successful. However, as we state in our report, although program officials told us that they had developed a plan for implementing the SEVIS collection process, they did not provide us with the plan showing their intended actions. Further, DHS did not include in its comments a plan for implementing the fee. Our recommendation is intended to address this absence of explicit planning for implementing the fee collection process. 3. We do not question DHS's comment that SEVIS has been supported by $36.8 million in appropriated funds (counter-terrorism funds) and $34.3 million in immigration examinations fee funds, which are collected from nonimmigrants seeking benefits. This comment is consistent with our finding that 7 years have passed since the fee collection was required, and millions of dollars have been spent (both appropriated and user fees) and will continue to be spent until the SEVIS fee is actually collected. Even if SEVIS is prospectively funded with the immigration examination user fees, until the SEVIS fee is collected, the amount of funds available to other programs funded by this account is reduced. [End of section] Appendix III: Comments from the Department of State: United States Department of State: Assistant Secretary and Chief Financial Officer Washington, D.C. 20520: Ms. Jacqueline Williams-Bridgers Managing Director: International Affairs and Trade: General Accounting Office: 441 G Street, N.W. Washington, D.C. 20548-0001: Dear Ms. Williams-Bridgers: We appreciate the opportunity to review your draft report, "HOMELAND SECURITY: Performance of Information System to Monitor Foreign Students and Exchange Visitors Has Improved But Issues Remain," GAO Job Code 310271. The enclosed Department of State comments are provided for incorporation with this letter as an appendix to the final report. If you have any questions concerning this response, please contact Martin Tatuch, Deputy Division Chief, Bureau of Consular Affairs, at (202) 663-1156. Sincerely, Signed by: Christopher B. Burnham: cc: GAO - Jeanette Espinola CA - Daniel Smith State/OIG - Mark Duda State/H - Paul Kelly: Department of State Comments on GAO Draft Report Performance of Information System to Monitor Students and Exchange Visitors has Improved but Issues Remain (GAO job code 310271): Thank you for allowing the Department of State the opportunity to comment on the draft report "Performance of Information System to Monitor Students and Exchange Visitors has Improved But Issues Remain", which reviews the progress of the Department of Homeland Security's (DHS) Student and Exchange Visitor Information System program. The report (pg. 35) cites DHS statistics concerning the number of persons enrolled in the program, describing them as persons who have "used visas." It is important to note that the number of persons enrolled in SEVIS does not necessarily equate to the number of visas issued by consulates overseas. Some persons enrolled in SEVIS are not issued visas, other persons may have more than one SEVIS record. It is more accurate to say that there are a number of student or exchange visitor records active in the SEVIS system. Since this report was originally drafted, State and DHS have worked together to explore a pilot project to collect the SEVIS fee overseas through Department of State channels. This pilot is being developed to explore the feasibility of fee collection at both consular offices with outsourced fee collection using foreign financial institutions and at consular offices with internal cashiers. The pilot will be conducted in a small number of consulates. The concerns raised by the Department of State with the GAO team remain valid. We are concerned that collection of the SEVIS fee through consular channels will raise significant issues of cost and complexity. We have agreed with DHS that a needs analysis will be done to document the requirement for an alternative fee collection method in each individual country being considered. To avoid increased fee settlement costs that would be spread among all fee payers, this pilot would be extended only post-by-post, country-by-country, on the basis of documented need. The following are GAO's comments on the Department of State's letter. GAO Comments: 1. The information presented is based on DHS-provided data addressing active students and exchange visitors registered in SEVIS as of February 6, 2004, and is appropriately attributed to DHS. We have added a footnote to our briefing noting State's comment. [End of section] Appendix IV: GAO Contact and Staff Acknowledgments: GAO Contact: Deborah Davis, (202) 512-6261, d [Hyperlink, davisd@gao.gov.] avisd@gao.gov. Staff Acknowledgments: In addition to the individual named above, Camille M. Chaires, Neil Doherty, Jeanette Espinola, Michael P. Fruitman, Jamelyn Payan, and Nik Rapelje made key contributions to this report. (310281): FOOTNOTES [1] H.R. Conf. Rep. No. 108-280, at 32 (2003). [2] The fee is to be paid by foreign students and exchange visitors to cover SEVIS costs. The Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) first required that schools and exchange programs collect the fee (P.L. 104-208, Sept. 30, 1996). The Visa Waiver Permanent Program Act (2000) amended IIRIRA to require that the government collect the SEVIS fee (P.L. 106-396, Oct. 30, 2000). [3] Examples of performance requirements are (1) the system is to be available 99.5 percent of the time to all users 24 hours a day, 7 days a week, excluding scheduled downtime and (2) the time to respond to user queries, as measured as the response time between the application server and database, is to be less than 10 seconds. [4] Change requests are used to track all system changes, including corrections to erroneous system programming, as well as planned system enhancements. [5] We contacted representatives from the following 12 organizations: Accrediting Council for Continuing Education and Training, Alliance for International Educational and Cultural Exchange, American Association of Collegiate Registrars, American Association of Community Colleges, American Council on Education, Association of American Universities, Association of International Educators, Council for Standards for International Educational Travel, Council on International Educational Exchange, National Association for Equal Opportunity in Higher Education, National Association of College and University Business Officers, and the National Association of State Universities and Land- Grant Colleges. Two of the organizations stated that they did not have the detailed information in which we were interested for this engagement. [6] The SEVIS Help Desk was established to assist system users by providing troubleshooting and resolution of technical problems, along with problem escalation and resolution, and changes to the database. [7] In its comments, DHS stated that SEVIS has been supported by both appropriated and Immigration Examination fee funds. IIRIRA required that the SEVIS fee be deposited in the Immigration Examination Fee Account (P.L. 104-208, Sept. 30, 1996). [8] In agency comments on a draft of this report, DHS stated that it received clearance of the SEVIS rule from the Office of Management and Budget on May 19, 2004. GAO's Mission: The General Accounting Office, the investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. 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