Information on Immigration Enforcement and Supervisory Promotions in the Department of Homeland Security's Immigration and Customs Enforcement and Customs and Border Protection
Gao ID: GAO-06-751R June 13, 2006After the creation of the Department of Homeland Security (DHS) in March 2003, two legacy enforcement agencies--the former Immigration and Naturalization Service (INS) and the U.S. Customs Service (USCS)--were among the 22 federal agencies brought together within DHS. This transformation in turn merged the legacy INS and USCS investigators into the U.S. Immigration and Customs Enforcement (ICE) Office of Investigations (OI), and legacy INS and USCS inspectors, among others, into Customs and Border Protection (CBP). It has been nearly 3 years since the merger and efforts to integrate thousands of federal employees within ICE and CBP continue. Congress raised questions about ongoing human capital challenges brought about by the integration of legacy enforcement employees within ICE and CBP. In prior work, we have reported on the management and human capital challenges DHS faces as it merges the workforces of legacy agencies, including the need to clarify the roles and responsibilities of the new agencies, the difficulty of legacy staff operating from separate locations, and how it decides to allocate investigative resources. This report addresses the following objectives: (1) How many investigative work years were dedicated to immigration enforcement activities for fiscal years 1999 through 2005? (2) What factors does ICE use as the basis for allocating its investigative resources? (3) What assessments do ICE and CBP use as a basis for making decisions on supervisory promotions? (4) Have ICE and CBP supervisory promotions been distributed between legacy INS and USCS staff in proportion to the supervisory staff each legacy agency brought to ICE and CBP?
Investigative work years for immigration enforcement were generally declining under INS, but have increased since ICE was formed in 2003. Specifically, investigative work years for immigration enforcement under INS decreased by about 14 percent from fiscal years 1999 through 2002, and increased in fiscal year 2003. From fiscal year 1999 through fiscal year 2001, INS was having difficulty recruiting and retaining staff and INS experienced about an 8 to 9 percent annual attrition in investigative staff, which in part explains the decrease in work years during the 1999 through 2002 period. The number of investigative work years spent on immigration enforcement investigations rose by 2 percent in fiscal year 2004 and by 16 percent in fiscal year 2005. ICE uses a combination of factors to allocate its investigative resources, including whether an investigation indicates a potential threat to national security, the execution of special programs run out of headquarters divisions and units like Operation Community Shield, which targets violent street gang members, and carry-over legacy activities, such as support for implementation of the national drug control strategy. About half of ICE investigative resources were used for drug, financial (the criminal or civil violation of financial laws enforced by ICE, such as money laundering), and general alien (the varied criminal and administrative cases where the subject's alienage is a requirement of the offense) investigations in fiscal years 2004 and 2005. ICE and CBP supervisory promotion decisions are based on weighted assessments measuring supervisory skills as well as knowledge of investigative and inspectional procedures and laws. Assessments common to ICE and CBP that do not require specialized legacy agency knowledge and are evaluated through testing are Critical Thinking (logic and problem solving), Managerial Writing (written communication), and an In-basket Job Simulation (ability to prioritize and manage). The Job Knowledge Test in ICE measures knowledge of customs and immigration laws and general investigative procedures across the range of ICE investigative activities and is divided into equally weighted sections testing knowledge of smuggling and public safety, financial investigations, investigative services, national security investigations, and general criminal investigations techniques. CBP's Career Experience Inventory measures knowledge of customs and immigration laws and inspectional procedures as well as experience performing supervisory and management functions. We did not verify these assessments or test how well they measure the knowledge and skills they address. For one promotion cycle in ICE, legacy INS staff received about two-thirds of the total supervisory promotions to GS grades 14 and 15. In fiscal year 2004, ICE noncompetitively promoted more than 200 legacy INS GS-13 supervisors to GS-14 to bring about parity with legacy USCS supervisory investigators who were at the GS-14 grade level. Promotions were more proportional to existing on board distributions of legacy supervisory personnel in fiscal year 2005, that is, legacy INS supervisors constituted 34 percent of the GS-14 and -15 supervisors and received 36 percent of the promotions that year. At CBP, the distribution of GS-12 to -15 supervisory promotions for fiscal years 2004 through 2006 was generally proportional to the distribution of legacy staff in those positions at the start of each fiscal year. For example, in fiscal year 2004, legacy INS staff constituted 34 percent of the on board supervisors and received 30 percent of the promotions, while legacy USCS staff constituted 66 percent of the on board supervisors and received 70 percent of the promotions.
GAO-06-751R, Information on Immigration Enforcement and Supervisory Promotions in the Department of Homeland Security's Immigration and Customs Enforcement and Customs and Border Protection
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June 13, 2006:
The Honorable John N. Hostettler:
Chairman:
The Honorable Sheila Jackson-Lee:
Ranking Minority Member:
Subcommittee on Immigration, Border Security, and Claims:
Committee on the Judiciary:
House of Representatives:
Subject: Information on Immigration Enforcement and Supervisory
Promotions in the Department of Homeland Security's Immigration and
Customs Enforcement and Customs and Border Protection:
After the creation of the Department of Homeland Security (DHS) in
March 2003, two legacy enforcement agencies--the former Immigration and
Naturalization Service (INS) and the U.S. Customs Service (USCS)--were
among the 22 federal agencies brought together within DHS.[Footnote 1]
This transformation in turn merged the legacy INS and USCS
investigator[Footnote 2]s into the U.S. Immigration and Customs
Enforcement (ICE) Office of Investigations (OI), and legacy INS and
USCS inspector[Footnote 3]s, among others, into Customs and Border
Protection (CBP). It has been nearly 3 years since the merger and
efforts to integrate thousands of federal employees within ICE and CBP
continue. You raised questions about ongoing human capital challenges
brought about by the integration of legacy enforcement employees within
ICE and CBP. In prior work, we have reported on the management and
human capital challenges DHS faces as it merges the workforces of
legacy agencies, including the need to clarify the roles and
responsibilities of the new agencies, the difficulty of legacy staff
operating from separate locations, and how it decides to allocate
investigative resources[Footnote 4].
This report addresses the following objectives:
1. How many investigative work years were dedicated to immigration
enforcement activities for fiscal years 1999 through 2005?
2. What factors does ICE use as the basis for allocating its
investigative resources?
3. What assessments do ICE and CBP use as a basis for making decisions
on supervisory promotions?
4. Have ICE and CBP supervisory promotions been distributed between
legacy INS and USCS staff in proportion to the supervisory staff each
legacy agency brought to ICE and CBP?
To obtain information on investigative work years on immigration
enforcement, we compared investigative resource use data from legacy
INS for fiscal years 1999 through 2003 from its Performance Analysis
System[Footnote 5] to similar data for ICE for fiscal years 2004 and
2005 using the investigative case categories added to its Treasury
Enforcement Communication System (TECS) after the formation of
ICE.[Footnote 6] We define immigration enforcement as the number of
work years[Footnote 7] spent on investigations by legacy INS and ICE
investigative staff of criminal aliens (aliens who were arrested for
criminal activity unrelated to their immigration status), human
smuggling (the surreptitious entry of people into the United States for
profit by a third party in violation of immigration laws) and
trafficking (the surreptitious entry of people into the United States
for profit by a third party in violation of immigration laws that
involves the threat of force or coercion), employers of unauthorized
workers (improper employment of undocumented workers), identity and
benefit fraud (willful misrepresentation of material fact on the
petition or application for an immigration benefit and the
manufacturing, counterfeiting, alteration, sale and use of fraudulent
documents to circumvent immigration laws and/or for other criminal
activity), and other immigration violations.
To determine the factors ICE uses to allocate investigative resources,
we used our previous 2006 report that examined how ICE allocates its
investigative resources.[Footnote 8] To determine the assessments ICE
and CBP use to make supervisory promotion decisions, we interviewed ICE
and CBP human capital and program officials who were knowledgeable
about human capital policies and actions and reviewed documentation
concerning these policies and actions. Finally, to determine if ICE and
CBP supervisory promotions have been distributed between legacy INS and
USCS staff in proportion to the supervisory staff each legacy agency
brought to ICE and CBP, we analyzed ICE and CBP personnel and
supervisory promotion decisions. We did not independently review any
ICE or CBP promotion decisions.
To assess the reliability of the investigative resource and human
capital data, we discussed the data collection methods and internal
control processes for ensuring data quality with responsible officials
and staff and reviewed the data for reasonableness. To test the human
capital data for reasonableness, we used the data to compute
frequencies and other summary analyses, examined the data and summary
analyses for outliers (large values that are inconsistent with other
data), and compared the data/analyses to other known agency
documentation. We found that the data we used for our analyses were
sufficiently reliable for the purposes of this report.
In April 2006, we briefed your offices on the results of our work. This
report conveys the information provided during those discussions with
some additional detail (see enclosure).
We performed our work from January 2006 through May 2006 in accordance
with generally accepted government auditing standards.
Summary:
* Investigative work years for immigration enforcement were generally
declining under INS, but have increased since ICE was formed in 2003.
Specifically, investigative work years for immigration enforcement
under INS decreased by about 14 percent from fiscal years 1999 through
2002, and increased in fiscal year 2003. From fiscal year 1999 through
fiscal year 2001, INS was having difficulty recruiting and retaining
staff and INS experienced about an 8 to 9 percent annual attrition in
investigative staff, which in part explains the decrease in work years
during the 1999 through 2002 period. The number of investigative work
years spent on immigration enforcement investigations rose by 2 percent
in fiscal year 2004 and by 16 percent in fiscal year 2005.
* ICE uses a combination of factors to allocate its investigative
resources, including whether an investigation indicates a potential
threat to national security, the execution of special programs run out
of headquarters divisions and units like Operation Community Shield,
which targets violent street gang members, and carry-over legacy
activities, such as support for implementation of the national drug
control strategy. About half of ICE investigative resources were used
for drug, financial (the criminal or civil violation of financial laws
enforced by ICE, such as money laundering), and general alien (the
varied criminal and administrative cases where the subject's alienage
is a requirement of the offense) investigations in fiscal years 2004
and 2005.
* ICE and CBP supervisory promotion decisions are based on weighted
assessments measuring supervisory skills as well as knowledge of
investigative and inspectional procedures and laws. Assessments common
to ICE and CBP that do not require specialized legacy agency knowledge
and are evaluated through testing are Critical Thinking (logic and
problem solving), Managerial Writing (written communication), and an In-
basket Job Simulation (ability to prioritize and manage). The Job
Knowledge Test in ICE measures knowledge of customs and immigration
laws and general investigative procedures across the range of ICE
investigative activities and is divided into equally weighted sections
testing knowledge of smuggling and public safety, financial
investigations, investigative services, national security
investigations, and general criminal investigations techniques. CBP's
Career Experience Inventory measures knowledge of customs and
immigration laws and inspectional procedures as well as experience
performing supervisory and management functions. We did not verify
these assessments or test how well they measure the knowledge and
skills they address.
* For one promotion cycle in ICE, legacy INS staff received about two-
thirds of the total supervisory promotions to GS grades 14 and 15. In
fiscal year 2004, ICE noncompetitively promoted more than 200 legacy
INS GS-13 supervisors to GS-14 to bring about parity with legacy USCS
supervisory investigators who were at the GS-14 grade level. Promotions
were more proportional to existing on board distributions of legacy
supervisory personnel in fiscal year 2005, that is, legacy INS
supervisors constituted 34 percent of the GS-14 and -15 supervisors and
received 36 percent of the promotions that year. At CBP, the
distribution of GS-12 to -15 supervisory promotions for fiscal years
2004 through 2006 was generally proportional to the distribution of
legacy staff in those positions at the start of each fiscal year. For
example, in fiscal year 2004, legacy INS staff constituted 34 percent
of the on board supervisors and received 30 percent of the promotions,
while legacy USCS staff constituted 66 percent of the on board
supervisors and received 70 percent of the promotions.
Agency Comments:
We requested comments on a draft of this report from the Department of
Homeland Security. The Department of Homeland Security responded that
it had no comments.
As we agreed with your office, we will send copies to the Department of
Homeland Security, and other interested congressional committees.
If your office or staff has any questions concerning this report,
please contact me at (202) 512-8816 or by e-mail at Stanar@gao.gov or
Michael Dino, Assistant Director, at (213) 830-1150 or Dinom@gao.gov.
Key contributors to this report were Amy Bernstein, Tony DeFrank,
Curtis Groves, Wilfred Holloway, Wendy Johnson, Mimi Nguyen, and Jeremy
Sebest.
Signed by:
Richard M. Stana, Director:
Homeland Security and Justice Issues:
Enclosure:
Enclosure I:
Homeland Security:
Immigration Enforcement and Supervisory Promotions Under ICE and CBP:
Briefing to the House Subcommittee on Immigration, Border Security, and
Claims, Committee on the Judiciary:
Introduction:
When the Department of Homeland Security (DHS) was established in March
2003 Immigration and Naturalization Service (INS) and U.S. Customs
Service (USCS) along with other agencies, were merged into DHS.
Investigators from legacy INS and USCS became part of the newly created
U.S. Immigration and Customs Enforcement (ICE) Office of Investigations
(DI) and legacy INS and USCS inspectors became part of the newly
created Customs and Border Protection (CBP) which serve as the
investigative and border security agencies of DHS.
Merging these legacy enforcement agencies has raised concerns about
human capital challenges that DHS faces as it merges the workforces of
legacy agencies, including the need to clarify the roles and
responsibilities of the new agencies, the difficulty of legacy staff
operating from different locations, and how it decides to allocate
investigative resources.[Footnote 9]
This briefing addresses the levels of immigration enforcement activity
conducted by legacy INS and ICE for certain years, and the human
capital issues related to supervisory promotions in ICE and CBP.
Objectives:
1) How many investigative work years were dedicated to immigration
enforcement activities for fiscal years 1999-2005?
2) What factors does ICE use as the basis for allocating its
investigative resources?
3) What assessments do ICE and CBP use as a basis for making decisions
on supervisory promotions?
4) Have ICE and CBP supervisory promotions been distributed between
legacy INS and USCS staff in proportion to the supervisory staff each
legacy agency brought to ICE and CBP?
Scope & Methodology:
Compared investigative resource use data from legacy INS and ICE.
Reviewed previous GAO work that examined how ICE allocates its
investigative resources.[Footnote 10]
Interviewed ICE and CBP staff knowledgeable about human capital
policies and actions, and reviewed documentation concerning these
policies and actions.
Reviewed ICE and CBP promotion criteria that included their assessment
test study guides and CBP's career experience inventory for promotion
decisions.
Analyzed ICE and CBP personnel and promotion data by pay
grade.[Footnote 11]
We performed our work in accordance with generally accepted government
auditing standards from January 2006 through May 2006.
Background:
ICE Investigators and Supervisors (GS 14-15):
Figure: ICE Investigators and GS 14-15 Supervisors On Board as of
October 2003 and February 2006, by Legacy Agency:
[See PDF for Image]
Source: GAO analysis of ICE personnel data.
[End of figure]
Background:
CBP Officers and Supervisors (GS12-15):
Figure: CBP Officers and GS 12-15 Supervisors On Board as of October
2003 and February 2006, by Legacy Agency:
[See PDF for Image]
Source: GAO analysis of CBP Personnel data.
[End of figure]
Objective 1:
Investigative work years dedicated to immigration enforcement
activities for fiscal years 1999-2005:
Figure: Investigative Work Years for Immigration Enforcement Were
Declining under INS, but Have Increased since ICE Was Formed: [Footnote
12]
[See PDF for Image]
Source: GAO analysis of INS (1999-2003) and ICE (2004-2005)
investigative data.
[End of Figure]
Objective 2:
ICE allocation of investigative resources:
Resource Allocation in ICE Is Determined by Priorities Set by Local
Special Agents-in-Charge (SAC), with Headquarters Direction and
Carryover Legacy Activities Playing a Role:
Local SACs take various factors into account when making resource
allocation decisions, such as whether the investigations under
consideration indicate threats to national security.
Divisions and units within ICE headquarters develop and manage special
programs like Operation Community Shield, a program targeting violent
street gangs, that are implemented in multiple SAC offices.
Carryover legacy activities, such as implementing the national drug
control strategy, also drive resource use. About half of investigative
resources were used for drug, financial, and general alien
investigations in fiscal years 2004 and 2005.
As we have reported, ICE does not have a formal risk management process
for prioritizing and allocating resources.[Footnote 13]
Objective 3:
Assessments used by ICE and CBP as a basis for supervisory and
management promotions:
ICE and CBP Promotions Based on Competencies and Assessments Measuring
Supervisory Skills as well as Knowledge of Investigative or
Inspectional Procedures and Laws:
Promotion competencies (management, leadership, thinking, and
communication) and assessments developed by subject matter and human
capital experts. The assessments include the following components:
* Job knowledge test (JKT) - ICE:
* Career experience inventory (CEI) - CBP:
* Critical thinking skills test - ICE and CBP:
* Managerial writing test - ICE and CBP:
* In-basket job simulation test - ICE and CBP:
* Structured Oral Interview - ICE:
ICE and CBP promotion assessments are not tied exclusively to agency
knowledge. The ICE JKT measures knowledge of immigration and customs
laws and investigative procedures and CBP's CEI measures knowledge of
immigration and customs laws and Inspectional procedures in addition to
capturing the quantity and quality of legacy agency and managerial
experience.
We did not verify these assessments or test how well they measure the
knowledge and skills they address.
Objective 4:
CBP and ICE promotion distributions for legacy staff:
Figure: For CBP, the Percentage of GS-12 through GS-15 Supervisors from
Legacy INS and USCS Stayed About the Same, While at ICE the Percentage
of Legacy INS GS-14 and GS-15 Supervisory Investigators Increased
[Footnote 14]:
[See PDF for Image]
Source: GAO analysis of CBP and ICE personnel data.
[End of figure]
Objective 4:
Supervisory promotion distributions for legacy staff in ICE:
Figure: In Fiscal Year 2004, the Majority of Supervisory Promotions to
GS 14-15 Went to Legacy INS Staff; in Fiscal Year 2005, the Percentage
of Promotions was About Equal to the Percentage of On Board Supervisors
in GS 14-15 for Legacy INS and USCS:
[See PDF for Image]
Source: GAO analysis of ICE personnel data.
[End of Figure]
Objective 4:
Overall distributions for legacy investigator staff in ICE:
Among ICE Criminal Investigator Staff, a Greater percentage of Legacy
INS and USCS Agents were at GS-13 or Higher in February 2006 than in
October 2003 [Footnote 15]:
[See PDF for Image]
Source: GAO analysis of ICE personnel data.
[End of Figure]
Objective 4:
Supervisory promotion distributions for legacy staff in CBP:
Figure: CBP Supervisory Promotions to GS-12 through GS-15 for FY04-06
were Generally Proportional to Distributions of Legacy Staff in Those
Positions at the Start of Each Fiscal Year:
[See PDF for image]
Source: GAO analysis of CBP personnel data.
[End of figure]
Objective 4:
Overall distributions for legacy staff in CBP:
Figure: A Greater Percentage of Legacy INS and USCS CBP Officers Were
at GS-11 or Higher in February 2006 than in October 2003:
[See PDF for Image]
Source: GAO analysis of CBP personnel data.
[End of Figure]
(440480):
[End of Slide Presentation]
FOOTNOTES
[1] Prior to the merger, INS was part of the Department of Justice and
USCS was part of the Department of the Treasury.
[2] Investigators in legacy INS conducted investigations into
immigration-related cases, such as alien smuggling, while legacy USCS
investigators conducted investigations into customs-related cases, such
as international money laundering and the import and export of illegal
drugs. ICE investigators conduct investigations of both immigration and
customs-related cases.
[3] Inspectors in legacy INS primarily conducted immigration-related
inspections at ports of entry, such as inspections of persons entering
the country for admissibility. Legacy USCS inspectors primarily
conducted customs-related inspections at ports of entry, such as
inspections for the entry of goods and merchandise into the country.
CBP officers conduct both immigration and customs-related inspections
at ports of entry.
[4] GAO, Homeland Security: Management Challenges Remain in
Transforming Immigration Programs, GAO-05-81 (Washington, D.C.: October
2004). GAO, Homeland Security: Better Management Practices Could
Enhance DHS's Ability to Allocate Investigative Resources, GAO- 06-48SU
(Washington, D.C.: December 2005).
[5] PAS is the system INS used to record the time it devoted to
immigration activities, including investigations.
[6] TECS is a management information system used by legacy USCS to
document its investigative activities. Before the formation of ICE,
TECS contained investigative case categories to capture activity for
Customs-related investigations. In fiscal year 2004, additional case
categories for immigration investigative activities were added to
these.
[7] Work years equal total investigative hours divided by 2,080, the
number of hours in a standard work year.
[8] See GAO-06-48SU.
[9] GAO Homeland Security: Management Challenges Remain in Transforming
Immigration Programs, GAO-05-81 (Washington, D.C.: October 2004). GAO
Homeland Security: Better Management Practices Could Enhance DHS's
Ability to Allocate Investigative Resources, GAO-06-48SU (Washington,
D.C.: December 2005).
[10] See GAO-06-48SU.
[11] Pay grades are defined in the Office of Personnel Management's
General Schedule (GS).
[12] According to INS data, the INS had about 8%-9% annual attrition in
investigative staff for FY 1999 through FY 2001, and was having
difficulty recruiting and retaining staff INS-wide. Investigative work
years are calculated by dividing the number of investigative hours in
immigration case categories by 2,080-the number of work hours in a
standard work year.
[13] GAO-06-48SU.
[14] 1n June 2004, over 200 GS-13 legacy INS supervisors received
promotions to GS-14. These promotions constituted over 75 percent of
legacy INS supervisory promotions that year.
[15] In fiscal year 2004, over 1200 legacy INS GS-12 investigators were
promoted to GS-13 to give them parity with legacy USCS investigators.
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