Border Security
DHS's Visa Security Program Needs to Improve Performance Evaluation and Better Address Visa Risk Worldwide Gao ID: GAO-11-315 March 31, 2011Since 2003, the Department of Homeland Security's (DHS) Visa Security Program (VSP) has participated in the visa process by reviewing applications at some embassies and consulates, with the intention of preventing individuals who pose a threat from entering the United States. The attempted bombing of an airline on December 25, 2009, renewed concerns about the security of the visa process and the effectiveness of the VSP. For this report GAO assessed (1) the ability of DHS's Immigration and Customs Enforcement (ICE) to measure the program's objectives and performance, (2) challenges to VSP operations, and (3) ICE efforts to expand the VSP program. To evaluate the VSP, we reviewed VSP data, guidance, and the ICE's 5-year expansion plan. We also interviewed ICE officials, and observed VSP operations at 6 posts overseas.
ICE cannot accurately assess progress toward its VSP objectives. ICE outlined three primary objectives of the VSP--identifying and counteracting potential terrorist threats from entering the United States, identifying not-yet-known threats, and maximizing law enforcement and counterterrorism value of the visa process--and established performance measures intended to assess VSP performance, including situations where VSP agents provide information that results in a consular officer's decision to deny a visa. ICE's VSP tracking system, used to collect data on VSP activities, does not gather comprehensive data on all the performance measures needed to evaluate VSP mission objectives. In addition, data collected by ICE on VSP activities were limited by inconsistencies. ICE upgraded its VSP tracking system in April 2010 to collect additional performance data, but the system still does not collect data on all the performance measures. Therefore, ICE's ability to comprehensively evaluate the performance of the VSP remains limited. While ICE can provide some examples demonstrating the success of VSP operations, ICE has not reported on the progress made toward achieving all VSP objectives. Several challenges to the implementation of the VSP affected operations overseas. DHS and the Department of State (State) have issued some guidance, including several memorandums of understanding, to govern VSP operations. However, some posts experienced difficulties because of the limited guidance regarding interactions between State officials and VSP agents, which has led to tensions between the VSP agents and State officials at some posts. In addition, most VSP posts have not developed standard operating procedures for VSP operations, leading to inconsistency among posts. Additionally, the mandated advising and training of consular officers by VSP agents varies from post to post, and at some posts consular officers received no training. Finally, VSP agents perform a variety of investigative and administrative functions beyond their visa security responsibilities that sometimes slow or limit visa security activities, and ICE does not track this information in the VSP tracking system, making it unable to identify the time spent on these activities. In 2007, ICE developed a 5-year expansion plan for the VSP, but ICE has not fully followed or updated the plan. For instance, ICE did not establish 9 posts identified for expansion in 2009 and 2010. Furthermore, the expansion plan states that risk analysis is the primary input to VSP site selection, and ICE, with input from State, ranked visa-issuing posts by visa risk, which includes factors such as the terrorist threat and vulnerabilities present at each post. However, 11 of the top 20 high-risk posts identified in the expansion plan are not covered by the VSP. Furthermore, ICE has not taken steps to address visa risk in high-risk posts that do not have a VSP presence. Although the expansion of the VSP is limited by a number of factors, such as budgetary limitations or limited embassy space, ICE has not identified possible alternatives that would provide the additional security of VSP review at those posts that do not have a VSP presence. GAO made several recommendations designed to address weaknesses we identified in the VSP. DHS concurred with the recommendations that the VSP provide consular officer training and develop a plan to provide more VSP coverage at high-risk posts. DHS did not concur with the recommendations that the VSP collect comprehensive data on all performance measures and track the time spent on visa security activities. GAO continues to maintain that these recommendations are necessary to accurately assess VSP performance.
RecommendationsOur 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: Jess T. Ford Team: Government Accountability Office: International Affairs and Trade Phone: (202) 512-4268GAO-11-315, Border Security: DHS's Visa Security Program Needs to Improve Performance Evaluation and Better Address Visa Risk Worldwide
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United States Government Accountability Office:
GAO:
Report to the Committee on Homeland Security and Government Affairs,
U.S. Senate:
March 2011:
Border Security:
DHS's Visa Security Program Needs to Improve Performance Evaluation
and Better Address Visa Risk Worldwide:
GAO-11-315:
GAO Highlights:
Highlights of GAO-11-315, a report to the Committee on Homeland
Security and Government Affairs, U.S. Senate.
Why GAO Did This Study:
Since 2003, the Department of Homeland Security‘s (DHS) Visa Security
Program (VSP) has participated in the visa process by reviewing
applications at some embassies and consulates, with the intention of
preventing individuals who pose a threat from entering the United
States. The attempted bombing of an airline on December 25, 2009,
renewed concerns about the security of the visa process and the
effectiveness of the VSP. For this report GAO assessed (1) the ability
of DHS‘s Immigration and Customs Enforcement (ICE) to measure the
program‘s objectives and performance, (2) challenges to VSP
operations, and (3) ICE efforts to expand the VSP program. To evaluate
the VSP, we reviewed VSP data, guidance, and the ICE‘s 5-year
expansion plan. We also interviewed ICE officials, and observed VSP
operations at 6 posts overseas.
What GAO Found:
ICE cannot accurately assess progress toward its VSP objectives. ICE
outlined three primary objectives of the VSP-”identifying and
counteracting potential terrorist threats from entering the United
States, identifying not-yet-known threats, and maximizing law
enforcement and counterterrorism value of the visa process-”and
established performance measures intended to assess VSP performance,
including situations where VSP agents provide information that results
in a consular officer‘s decision to deny a visa. ICE‘s VSP tracking
system, used to collect data on VSP activities, does not gather
comprehensive data on all the performance measures needed to evaluate
VSP mission objectives. In addition, data collected by ICE on VSP
activities were limited by inconsistencies. ICE upgraded its VSP
tracking system in April 2010 to collect additional performance data,
but the system still does not collect data on all the performance
measures. Therefore, ICE‘s ability to comprehensively evaluate the
performance of the VSP remains limited. While ICE can provide some
examples demonstrating the success of VSP operations, ICE has not
reported on the progress made toward achieving all VSP objectives.
Several challenges to the implementation of the VSP affected
operations overseas. DHS and the Department of State (State) have
issued some guidance, including several memorandums of understanding,
to govern VSP operations. However, some posts experienced difficulties
because of the limited guidance regarding interactions between State
officials and VSP agents, which has led to tensions between the VSP
agents and State officials at some posts. In addition, most VSP posts
have not developed standard operating procedures for VSP operations,
leading to inconsistency among posts. Additionally, the mandated
advising and training of consular officers by VSP agents varies from
post to post, and at some posts consular officers received no
training. Finally, VSP agents perform a variety of investigative and
administrative functions beyond their visa security responsibilities
that sometimes slow or limit visa security activities, and ICE does
not track this information in the VSP tracking system, making it
unable to identify the time spent on these activities.
In 2007, ICE developed a 5-year expansion plan for the VSP, but ICE
has not fully followed or updated the plan. For instance, ICE did not
establish 9 posts identified for expansion in 2009 and 2010.
Furthermore, the expansion plan states that risk analysis is the
primary input to VSP site selection, and ICE, with input from State,
ranked visa-issuing posts by visa risk, which includes factors such as
the terrorist threat and vulnerabilities present at each post.
However, 11 of the top 20 high-risk posts identified in the expansion
plan are not covered by the VSP. Furthermore, ICE has not taken steps
to address visa risk in high-risk posts that do not have a VSP
presence. Although the expansion of the VSP is limited by a number of
factors, such as budgetary limitations or limited embassy space, ICE
has not identified possible alternatives that would provide the
additional security of VSP review at those posts that do not have a
VSP presence.
What GAO Recommends:
GAO made several recommendations designed to address weaknesses we
identified in the VSP. DHS concurred with the recommendations that the
VSP provide consular officer training and develop a plan to provide
more VSP coverage at high-risk posts. DHS did not concur with the
recommendations that the VSP collect comprehensive data on all
performance measures and track the time spent on visa security
activities. GAO continues to maintain that these recommendations are
necessary to accurately assess VSP performance.
View [hyperlink, http://www.gao.gov/products/GAO-11-315] or key
components. For more information, contact Jess Ford at (202) 512-4268
or fordj@gao.gov.
[End of section]
Contents:
Letter:
Background:
ICE Remains Unable to Accurately Measure the Performance of the Visa
Security Program:
Several Challenges Affect Visa Security Operations Overseas:
ICE Has Not Fully Adhered to the VSP Expansion Plan:
Conclusion:
Recommendations for Executive Action:
Agency Comments and our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Homeland Security:
Appendix III: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Objectives and Performance Measures of the Visa Security
Program:
Figures:
Figure 1: Organizational Chart of DHS and the VSP:
Figure 2: Timeline for the Establishment and Expansion of the VSP:
Abbreviations:
DHS: Department of Homeland Security:
DS: Bureau of Diplomatic Security:
ICE: Immigration and Customs Enforcement:
MOU: memorandum of understanding:
SAO: security advisory opinion:
TECS: Treasury Enforcement and Communications System:
VSP: Visa Security Program:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
March 31, 2011:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Since its establishment in 2002, following the September 2001
terrorist attacks on the United States, the Department of Homeland
Security (DHS) has been responsible for the issuance of visa policy.
[Footnote 1] In 2003, DHS implemented the Visa Security Program (VSP),
and has since deployed DHS officials to certain U.S. embassies and
consulates to strengthen the visa process by working with Department
of State (State) officials in reviewing visa applications.[Footnote 2]
However, the attempted bombing of Northwest Airlines flight 253 on
December 25, 2009, by a Nigerian citizen in possession of a valid U.S.
visa renewed concerns about the security of the visa process.
In 2005, we reported on VSP activities in Saudi Arabia--at that time,
the only country where DHS had implemented the program--and on the
department's plans to expand the program to other countries.[Footnote
3] To help ensure effective management of the VSP and its expansion,
we recommended that the Secretary of Homeland Security develop a
strategic plan that includes, among other things, information on
criteria for selecting locations for expansion. We also recommended
that the Secretary maintain performance data that could be used to
assess the program's impact at each post.[Footnote 4] In response to
our recommendations, DHS's Immigration and Customs Enforcement (ICE),
which oversees the program, developed a 5-year expansion plan and
deployed a tracking system to capture performance data. As of December
2010, ICE had established VSP units at 19 posts in 15 countries.
In response to your request, this report (1) assesses the ability of
DHS to measure the program's objectives and performance, (2)
identifies potential challenges to VSP operations overseas, and (3)
examines DHS efforts to expand the VSP program.
To conduct our evaluation, we reviewed relevant legislation, such as
the Homeland Security Act of 2002, and documentation including
internal guidance and interagency memorandums. To assess ICE's ability
to measure the objectives and performance of the VSP, we reviewed the
VSP mission objectives and performance measures identified by ICE. We
also reviewed data from VSP's tracking system, and compared the data
collected with the performance measures to identify the ability of ICE
to assess its performance and progress toward the identified
objectives. To evaluate the challenges to VSP operations, we reviewed
the issued guidance governing the implementation of the VSP. We met
with ICE and State officials in Washington, D.C., and interviewed VSP
agents and consular officials, via telephone and e-mail, at 13 VSP
posts that were operational as of April 2010 to identify some VSP
operational challenges. We also visited six U.S. embassies and
consulates with VSP operations to observe VSP operations. To assess
ICE's efforts to expand the VSP, we reviewed the VSP 5-year expansion
plan and compared the expansion with the plan. We also reviewed the
criteria for the selection of posts identified for expansion. We also
interviewed ICE and State officials regarding the expansion plan and
the challenges of expanding the VSP.
We conducted this performance audit from March 2010 through March 2011
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Background:
Legislative Authority for the Visa Security Program:
The Homeland Security Act of 2002 established DHS and gave the agency
responsibility for visa policy. Specifically, the act granted DHS the
authority to issue regulations on, administer, and enforce the
Immigration and Nationality Act and other immigration and nationality
laws relating to the functions of U.S. consular officers in connection
with the granting and denial of visas. Section 428 of the act also
authorized DHS to immediately assign personnel to Saudi Arabia to
review all visa applications prior to final adjudication, and
authorized DHS to assign officers to other locations overseas to
review visa applications. Section 428 designated the following
functions for DHS officers assigned overseas:
1. provide expert advice and training to consular officers regarding
specific security threats relating to the adjudication of individual
visa applications or classes of applications,
2. review visa applications either on the initiative of the employee
of the department or at the request of a consular officer, or other
persons charged with adjudicating such applications, and:
3. conduct investigations with respect to consular matters under the
jurisdiction of the Secretary of Homeland Security.
Establishment of the Visa Security Program:
DHS designated ICE to handle the operational and policy-making
responsibilities outlined in section 428 in January 2004.
Subsequently, ICE established the Office of International Affairs and
gave it responsibility for overseeing the Visa Security Program.
Figure 1 shows the organization of the Visa Security Program within
DHS.
Figure 1: Organizational Chart of DHS and the VSP:
[Refer to PDF for image: organizational chart]
Top level:
Department of Homeland Security.
Second level:
Immigration and Customs Enforcement.
Third level:
Homeland Security Investigations.
Fourth level:
Office of International Affairs.
Fifth level:
Visa Security Program:
* Visa Security Program Section;
* Security Advisory Opinion Unit.
Source: GAO analysis of DHS documents.
[End of figure]
Primary Guidance Governing Visa Security Program Operations:
Since the establishment of the Visa Security Program, ICE and State
have issued four primary forms of guidance governing VSP operations
overseas: (1) a 2003 memorandum of understanding (MOU) concerning
implementation of the Homeland Security Act; (2) a 2004 MOU on
administrative aspects of assigning personnel overseas; (3) a 2008
cable directing State Bureau of Diplomatic Security (DS) officers,
[Footnote 5] VSP agents, and the senior consular officer at each post
to develop standard operating procedures; and (4) a 2011 MOU
delineating the roles and responsibilities of VSP agents, consular
officers, and diplomatic security officers in daily operations of VSP
at posts overseas.
2003 MOU. In 2003, DHS and State issued a memorandum of understanding
to govern the implementation of section 428. In accordance with the
legislation, the memorandum outlined the following responsibilities of
DHS officers assigned to posts overseas to perform visa duties:
* Advising and training consular officers. DHS employees are to
provide expert advice to consular officers regarding specific security
threats relating to visa adjudication and provide training to consular
officers on terrorist threats and detecting applicant fraud.
* Reviewing visa applications. DHS employees have the authority to
review visa applications on their own initiative or at the request of
consular officers, and provide input on or recommend security advisory
opinion requests.
* Conducting investigations. DHS employees are authorized to conduct
investigations on consular matters under the jurisdiction of the
Secretary of Homeland Security, as well as conduct and support
investigations under other DHS authorities.
2004 MOU. In 2004, ICE and State signed a MOU on administrative
aspects of assigning personnel overseas. Among other things, this MOU
described administrative support, security, facilities, security
awareness training, and information systems for VSP personnel.
2008 cable. In 2008, State issued a cable in which ICE and State
directed VSP posts to develop standard operating procedures. The cable
stated that these standard operating procedures should include, but
not be limited to:
* chain of command;
* clearance procedures for cables and other correspondence;
* dispute resolution practices;
* specific coordination procedures among the fraud prevention unit,
VSP agents, and the regional security officer;
* procedures for determining case selection;
* specific hours of operation and other coordination issues;
* stating how electronic reviews will be conducted and documented;
* stating how physical reviews will be conducted and documented;
* coordination of procedures for handling expedited or exceptional
visa cases;
* procedures for sharing and documenting applicant information
constituting grounds for ineligibility; and:
* procedures for VSP applicant interviews and re-interviews.
2011 MOU. On January 11, 2011, ICE and State issued a MOU that
explains the roles, responsibilities, and collaboration of VSP agents,
consular officers, and diplomatic security officers in daily
operations of VSP at posts overseas. The MOU outlines the following,
among other things:
* general collaboration between ICE and State for VSP operations;
* roles and responsibilities of VSP agents and consular officers and
routine interaction between the officers and agents;
* development of formal, targeted training and briefings by VSP agents
for consular officers and other U.S. government officials at post;
* clarification of the dispute resolution process; and:
* collaboration between diplomatic security officers and VSP agents on
visa and passport fraud investigations.
Visa Adjudication Process:
The review of visa applications by VSP agents is incorporated into the
visa process at overseas posts where the VSP is located. After
consular officers interview an applicant and review the relevant
supporting documentation, they make a preliminary determination about
whether to issue or refuse the visa or refer the case to Washington
for additional security clearances.[Footnote 6] The VSP agents screen
the applicant information against DHS's Treasury Enforcement and
Communications System (TECS) database to identify applicants that
potentially match records of individuals who are known threats to the
United States.[Footnote 7] The VSP agents then perform a vetting
process on a smaller number of applications, based upon a threat-based
targeting plan. During vetting, the VSP agents perform checks against
additional law enforcement and other databases, and review the
applications and supporting documentation for evidence of fraud or
misrepresentation, indicators of potential national security risks,
criminal activity, and potential illegal immigration risks. During the
review, the VSP agents may also consult consular officers and other
law enforcement officials as needed. On the basis of these reviews,
the VSP agents will either agree with the consular officer's original
decision or recommend refusal of the visa. The consular officer
decides to issue or deny the visa.[Footnote 8] If the consular section
chief and the VSP agents disagree on a case, a dispute resolution
process is started to render a final determination of the application.
Several other agencies stationed overseas have roles in the visa
process. For example, State regional security officers assist the
consular section by investigating passport and visa fraud detected
through the consular officers' reviews of visa applications and
supporting documents. In addition, officials from the Federal Bureau
of Investigation overseas can assist consular officers when questions
about an applicant's potential criminal history arise during
adjudication. DHS's Bureaus of Citizenship and Immigration Services
and Customs and Border Protection have responsibility for some
immigration and border security programs overseas. For example,
consular officers may seek advice from these officials on issues such
as DHS procedures at U.S. ports of entry.
Expansion Plan for the Visa Security Program:
ICE's 5-year plan for expanding the VSP, which ICE released in
consultation with State in 2007, states that global visa risk is
substantial and that the VSP must be expanded in order to mitigate
threats identified through the visa process and to address visa risk.
The plan also includes the following principles to guide the program's
expansion:
* concentrate expansion on risk by deploying personnel sooner to the
highest-risk visa-issuing locations;
* develop a global capacity by expanding to select high-risk posts in
diverse regions; and:
* cover the highest-risk visa activity while incorporating dynamic
conditions such as funding, personnel, and logistical issues such as
the availability of space.
* The 5-year plan also includes the following site selection
methodology to inform the expansion process:
* Initial quantitative risk analysis. ICE and State developed a list
of 216 visa-issuing locations that are ranked according to risk. The
underlying analysis incorporates information on terrorist activity,
DHS enforcement and removals, host government circumstances,
corruption, visa activity, and several other factors.
* Interagency and interdepartmental consultation. Throughout the site
selection process, ICE coordinates with State, law enforcement and
intelligence communities, and other components of DHS. This
coordination helps to establish mutual understanding among interested
parties and to inform and refine the decision-making process.
* Site assessments. ICE selects a smaller number of locations for on-
site assessments to further improve communication and gather
information about local conditions at post.
* Final evaluation and selection. Using all of the information
gathered, ICE makes a final evaluation and selection for new VSP unit
locations.
Figure 2 shows a timeline for the establishment of the VSP and the
expansion of the program. As of December 2010, ICE had established VSP
units at 19 posts in 15 countries.
Figure 2: Timeline for the Establishment and Expansion of the VSP:
[Refer to PDF for image: timeline]
November 2002:
Homeland Security Act of 2002 passed.
August 2003:
VSP operations start in Riyadh, Saudi Arabia.[A]
September 2003:
MOU on section 428 between DHS and State signed.
October 2005:
VSP operations start at four posts.
January 2007:
VSP operations start at one post.
March 2007:
VSP operations start at one post.
May 2007:
VSP operations start at one post.
September 2007:
VSP operations start at one post.
November 2007:
VSP operations start at one post.
September 2008:
VSP operations start at one post.
January 2009:
VSP operations start at one post.
May 2009:
VSP operations start at one post.
2010:
VSP expands to four new posts.
Source: GAO analysis of DHS documents.
Note: Locations are not specified for security reasons.
[A] VSP operations start at other posts in Saudi Arabia in October
2003.
[End of figure]
Visa Security Program Funding:
For fiscal years 2007 through 2010, ICE reported that approximately
$94 million in appropriated funds was allotted for the Visa Security
Program. Of these amounts, in fiscal years 2009 and 2010, Congress
specified that $6.8 million and $7.3 million, respectively, would
remain available for 1 additional year. In fiscal year 2010, the Visa
Security Program received $30.7 million in appropriated funds, and the
agency requested $30.7 million in the fiscal year 2011 budget request.
ICE Remains Unable to Accurately Measure the Performance of the Visa
Security Program:
ICE does not maintain comprehensive performance data to accurately
evaluate progress toward all VSP mission objectives. In 2007, ICE
outlined three primary objectives of the Visa Security Program in its
5-year expansion plan and identified and established performance
measures intended to assess performance toward the stated objectives.
However, the initial VSP tracking system did not gather data on all
the performance measures and mission objectives identified in the VSP
expansion plan. Although ICE upgraded the VSP tracking system in April
2010 to collect additional performance data, the system still does not
collect data on all the performance measures, hampering ICE's efforts
to comprehensively evaluate the performance of the VSP. While ICE can
provide some examples demonstrating the success of VSP operations, ICE
has not produced reports identifying the progress made toward
achieving VSP objectives. In addition, data collected by ICE on VSP
activities prior to 2010 were limited by inconsistencies.
ICE Unable to Accurately Assess the Value of the VSP:
From 2003 to 2010, ICE did not maintain comprehensive data on its
identified performance measures to fully assess progress toward VSP
objectives. As we reported in 2005, ICE did not maintain data on VSP
activities in order to assess the program's performance since its
establishment in 2003.[Footnote 9] In the fall of 2005, in response to
GAO recommendations, ICE developed a database to track VSP workload
and to serve as a performance management tool. The initial VSP
tracking system, which was operational until 2010, collected
information on the results of the review of visa applications by VSP
agents, including tracking the number of visas screened, the number of
visas vetted, and the number of visas recommended for denial by VSP
agents.
While the initial tracking system allowed ICE to track VSP workload
and assist with performance assessment, the VSP did not establish
program objectives until 2007. The Government Performance and Results
Act of 1993 requires agencies to develop objective performance goals
and report on their progress.[Footnote 10] In addition, GAO's
Standards for Internal Control in the Federal Government state that
U.S. agencies should monitor and evaluate the quality of performance
over time.[Footnote 11] ICE's 5-year expansion plan for the VSP,
issued in 2007, identified three primary mission objectives to enhance
national security and public safety:
1. identify and counteract threats before they reach the United States,
2. identify not-yet-known threats to homeland security, and:
3. maximize the law enforcement and counterterrorism value of the visa
process.
Furthermore, the expansion plan indicates that the program must
measure its performance and demonstrate the value it contributes to
homeland security, with mechanisms in place to adequately and
accurately measure its performance. ICE identified six categories of
performance measures to assess the progress toward the objectives of
the program (see table 1):
Table 1: Objectives and Performance Measures of the Visa Security
Program:
VSP objective: Identify and counteract threats before they reach the
United States;
VSP activities: Review of visa applications;
Performance measures:
1. Recommendations for refusal;
Description: Any instance in which a VSP agent provides input, advice,
or information that results in a consular officer's decision to deny a
visa to an ineligible applicant.
2. Additional enforcement outputs;
Description: Represents the generation of additional law enforcement
value, including terrorist watchlist entries, intelligence reports,
investigative leads, and identification of terrorist trends and
tactics.
3. Derogatory information removal;
Description: This measure reflects the removal of derogatory
information by VSP agents that assists the travel of legitimate,
eligible applicants.
VSP objective: Identify not-yet-known threats;
VSP activities: Initiate investigations;
Performance measures:
4. Open/closed investigations;
Description: Captures the number of investigations opened and closed
and the hours spent supporting domestic and foreign investigations.
VSP objective: Maximizing law enforcement and counterterrorism value;
VSP activities: Advice and training;
Performance measures:
5. Consular and other training;
Description: Tracks the expert advice and training provided to
consular officers.
VSP objective: Maximizing law enforcement and counterterrorism value;
VSP activities: Information sharing and liaison;
Performance measures: 6. Assistance and liaison provided;
Description: Measure the ways in which VSP agents liaise with other
law enforcement, intelligence, and host country officials.
Source: DHS 5-year expansion plan.
[End of table]
The VSP tracks and reports on activities through reports submitted
regularly by VSP agents at overseas posts, through the activities
recorded in the TECS database, and through the VSP tracking system.
The VSP tracking system is used by ICE to monitor and report on
performance of its VSP agents overseas.
While ICE developed a VSP tracking system before the expansion plan
identified the VSP objectives in 2007, ICE did not modify the system
to collect data related to the performance measures and objectives in
the expansion plan. The initial VSP tracking system tracked the
results of one of the six identified performance measures--the number
of recommendations for refusal--and the system did not track the other
five performance measures (see table 1). Furthermore, the initial VSP
tracking system did not collect performance data to evaluate progress
toward two of its overall objectives, identifying not-yet-known
threats and maximizing law enforcement and counterterrorism value.
According to VSP officials, in April 2010, ICE implemented a new data
tracking system intended, among other things, to better track
performance, to better reflect the work performed by the VSP agents
overseas, and to provide management with improved reports to better
evaluate the VSP activities performed overseas. However, the new
system does not collect performance data on three of the measures
identified in the plan: (1) investigations opened or closed and hours
spent supporting investigative activity, (2) consular and other
training provided, and (3) assistance and liaison provided by VSP
agents. Furthermore, while ICE has some information regarding the
hours charged to VSP activities at posts, it cannot accurately
determine the time VSP agents spend on non-VSP activities. An ICE
official indicated that some activities are recorded outside of the
VSP tracking system. For example, training for consular officers
performed by VSP agents are often included in the weekly reports
submitted to ICE. In addition, some of the liaison activities and
assistance VSP agents provide to local law enforcement is captured in
TECS and other DHS reports, such as search, arrest, and seizure
reports. However, ICE does not track these activities systematically
and cannot evaluate the comprehensive effort of these activities. ICE
has requested upgrades to the VSP tracking system to capture
additional data on training and liaison activities, but according to
an ICE official, because of development delays, the system upgrades
are not complete.
ICE Does Not Produce Reports Evaluating VSP Performance:
ICE has reported on the results of some VSP activities, but these
reports do not address all of the VSP performance measures and
therefore do not show progress toward each of the VSP mission
objectives. For example, ICE annual reports and DHS's performance
report for fiscal years 2008 to 2010 address only one of the six VSP
performance measures--the number of visa applications denied because
of recommendations from VSP agents. For example, ICE reported that the
VSP recommended refusal of more than 900 visa applications in fiscal
year 2008. ICE has presented some anecdotal examples of VSP
participation in the visa process. For example, in testimony in 2009,
the Assistant Secretary of ICE stated that the review of a specific
visa applicant revealed information that resulted in the denial of the
applicant's visa on the basis of national security. However, because
these reports do not address all VSP performance measures, they do not
comprehensively show progress toward all of the VSP objectives
identified in the expansion plan.
According to ICE officials, the VSP reviews monthly statistical
reports on the activities performed by the VSP agents at each post,
which allows management to identify discrepancies in the VSP
activities and eliminate potential errors in the system. According to
ICE, reports and information from the VSP tracking system are
routinely used to inform budget decisions as well as other resource
decisions including permanent and temporary duty staffing of VSP posts.
VSP Data Collected at Posts Have Not Been Reliable:
VSP data collected through the initial tracking system are
significantly limited by inconsistencies. As we reported in 2005, ICE
had not maintained measurable data to fully demonstrate the impact of
VSP agents on the visa process.
We have reported that for agencies to be able to assess progress
toward performance goals, the performance measures, and the quality of
the data supporting those measures, must be reliable and valid.
[Footnote 12] Our analysis of VSP data collected at posts in fiscal
years 2007 to 2010 identified significant limitations to the data's
reliability. For example, at one post the data recorded for the
category "sum of post-adjudication: vetted" rose from 1,630
applications in fiscal year 2007 to 28,856 in fiscal year 2008, and
then decreased to 2,754 in fiscal year 2009. In addition, another post
recorded in fiscal year 2007 that VSP agents screened and vetted over
13,000 applicants that received security advisory opinions, but
recorded zero applicants in the security advisory opinion categories
in any subsequent year. ICE officials indicated that ICE did not
provide guidance to the VSP agents on the proper use of the tracking
system, which likely resulted in inconsistent use of the system.
Furthermore, according to an ICE official, the accuracy of the data in
the tracking system is contingent upon VSP agents at post entering the
data and using the system consistently across all posts. ICE officials
acknowledged that turnover of VSP agents at many posts likely resulted
in inconsistent use of the tracking system.
Several Challenges Affect Visa Security Operations Overseas:
The Visa Security Program faces several key challenges in implementing
operations at overseas posts. First, limited guidance from
headquarters regarding VSP operations has led to confusion and
inconsistency among posts. Both VSP and consular officials indicated
that ICE and State have issued limited official guidance about how VSP
agents, consular officers, and DS officials should interact with one
another at post or resolve disputes concerning specific visa
applications. Second, VSP agents' advising and training of consular
officers, as mandated by section 428 of the Homeland Security Act,
varies from post to post, and some posts provided no training to
consular officers. Third, VSP agents perform a variety of
investigative and administrative functions beyond their visa security
responsibilities, including criminal investigations, attaché
functions, and regional responsibilities. Fourth, ICE's use of 30-day
temporary duty assignments has created challenges and affected
continuity of operations at some posts. Last, ICE does not provide
language or country-specific training for its agents serving overseas,
thereby limiting agents' ability to conduct interviews and coordinate
with host country officials.
VSP and Consular Interaction Has Been Difficult at Some Posts, and ICE
Has Provided Limited Guidance for Such Interaction:
Some VSP posts reported difficulties in the interactions between VSP
agents and consular officers at post, and ICE and State had provided
limited guidance in this regard. During our visits to several posts in
2010, both VSP agents and consular officers at several posts we
visited indicated that difficulties arose from confusion surrounding
the VSP-consular relationship. For example, a consular official at one
post stated that he does not know how to interact with the VSP agents
or what to do with the information VSP agents provide on visa
applicants, particularly when that information is insufficient to
render an applicant ineligible for a visa. This official suggested
State's Visa Office provide yearly guidance on the VSP-consular
relationship and instructions on how to use information from the VSP
tracking system reports. At another post, disagreement over how the
consular section should share information with law enforcement
agencies at post led to significant tension between VSP agents and DS
officials. One consular official at this post stated that tension
between VSP agents and DS officials at post sometimes prevents the
consular section from receiving information in a timely manner. At a
third post, the Consular Chief stated that VSP agents and consular
officials rarely interacted with one another and that visa
applications sometimes "disappeared" in the VSP unit. Consular
officers at this post stated they did not understand the VSP's mission.
ICE had issued limited guidance for VSP-consular interaction. ICE
guidance, including the 2003 joint DHS-State MOU and the 2008 cable,
does not explicitly address VSP-consular interaction at posts. The
2003 MOU states that DHS, in consultation with State, will develop
policies and procedures for DHS employees' overseas functions, but
does not detail such policies. The 2008 cable directs VSP posts to
develop standard operating procedures for a number of operational
areas requiring interaction among VSP, consular officers, and DS
officials, such as chain of command, dispute resolution practices,
specific coordination procedures between VSP agents and State
officials at post, and case selection procedures. However, the cable
does not include guidelines for such procedures. The most recent ICE-
State MOU, issued in January 2011, addresses roles, responsibilities,
and collaboration at VSP posts abroad. Specifically, the new MOU
provides additional information on routine interaction between VSP
agents and consular officers at post. For example, it indicates that
interviewing officers can request VSP screening prior to an interview,
VSP can request cases to be put on hold for additional investigation,
and the consular chief may ask VSP to expedite cases.
Most VSP Posts Have Not Developed Standard Operating Procedures:
Most of the VSP posts had not developed written standard operating
procedures as recommended by the 2008 ICE-State cable. Two of the 13
posts had developed written standard operating procedures, but those
procedures did not include all of the components identified in the
2008 cable. Nine of the 13 consular sections and 13 of 13 VSP units
reported having developed informal standard operating procedures, but
the scope and content of these procedures varied widely. VSP agents at
1 post told us that they were waiting for the issuance of the 2011 MOU
before developing standard operating procedures and hoped that the MOU
would provide additional operational guidance. At 1 post, VSP agents
said that they had declined to develop standard operating procedures
with the consular section and told consular officials that
headquarters did not want them to develop "post-specific" standard
operating procedures.
The 2008 cable issued by ICE and State--intended to address consular
concerns about the VSP, according to VSP officials--recommends that
VSP posts develop standard operating procedures. The 2008 cable also
directs regional security officers and VSP agents to work with
consular officers to establish post-specific procedures to manage
fraud investigations that comply with the 2003 MOU. However, VSP
officials told us that they later instructed VSP agents to postpone
development of post-specific standard operating procedures pending
completion of the new MOU with State. The 2011 MOU states that ICE and
State may develop post-specific standard operating procedures or other
agreements regarding VSP operations, adding that these procedures may
further refine, but must remain consistent with, the roles,
responsibilities, and collaboration described in previous guidance.
At posts that had developed standard operating procedures, consular
officers stated that these procedures had improved the VSP-consular
relationship. For example, a VSP agent at 1 post developed standard
operating procedures with both the consular section and DS officials.
The standard operating procedures at this post address the timing of
VSP screening and vetting activities, how much time those activities
will take, and points of contact in each agency. One VSP agent at this
post described the process of developing these standard operating
procedures as "painless," and the Consular Chief at post indicated
that the VSP agents' reviews of visa applications were helpful because
they provided a second review of visa applicants. In addition, a State
official at another post that had developed standard operating
procedures stated that having written guidance is crucial to a good
relationship and valuable for new consular officers.
Advising and Training Performed by VSP Agents Varies among Posts:
Although the Homeland Security Act requires DHS to advise and train
consular officers, VSP agents' training and advising of consular
officers varies among posts. Section 428 of the Homeland Security Act
directs VSP agents to provide "expert advice and training to consular
officers regarding specific security threats relating to the
adjudication of individual visa applications or classes of
applications." In addition, the 2003 and 2011 MOUs also state that VSP
agents will provide training to consular officers.
Five of the 13 consular sections we interviewed stated that they had
received no training from the VSP agents in the last year, and none of
the VSP agents we interviewed reported providing training on specific
security threats. At posts where VSP agents provided formal training
for consular officers, topics covered included fraudulent documents,
immigration law, human smuggling, and interviewing techniques.
[Footnote 13] In addition, 6 of the 13 VSP agents interviewed provided
introductory briefings to new consular officers during the past year,
but the VSP agents at the other 7 posts did not provide these
briefings. VSP agents at 3 posts stated that they do not have time to
deliver advice and training to consular officers. At 1 post, VSP
agents refused to allow consular officers to observe VSP screening and
vetting activities on the ground that they did not have a law
enforcement "need to know." At the embassy in Riyadh, consular
officers generally agreed that the VSP agents do not provide advice
and training and are not proactive in developing such programs.
Additionally, Riyadh consular officers stated that the VSP agents do
not advise them on the security situation, current trends, or types of
information to collect to assist the agents.
During our site visits and interviews, consular officers at several
posts stated that they do not understand either the VSP's mission, or
what the VSP agents do, or what types of information they collect.
Officers at 6 of 13 consular sections interviewed requested additional
training on the VSP's procedures and activities. For example, in
Riyadh, consular officers generally agreed that greater knowledge of
VSP activities would inform their interviews of visa applicants. At 1
post the VSP agents provided lunchtime briefings on patterns or trends
with implications for visa issuance, as well as an orientation for all
new consular officers and allow consular officers to observe screening
and vetting activities. The Consular Chief at this post stated that
the training was very useful to consular officers and provided a
better appreciation for how the VSP operates.
Guidance for Visa Dispute Resolution Mechanism Has Not Helped Resolve
Some VSP-Consular Disagreements:
Although ICE and State have developed formal and informal procedures
for resolving disputes about specific visas, both VSP and consular
officials stated that these procedures are sometimes insufficient for
resolving such disputes. Disagreement between VSP and consular
officials about specific visa applications is generally infrequent,
and posts usually resolve these disputes through informal discussions
between VSP and consular officials. However, 4 of 6 posts we visited
reported disagreements about specific visa cases that could not be
resolved informally at the post, and that in some cases, unresolved
disputes have led to tension at post.
ICE and State officials told us that the two agencies sometimes have
different interpretations of visa law, such as criteria for
ineligibility based on "fraud or misrepresentation" or "crimes of
moral turpitude." VSP officials also told us that they sometimes
disagree with consular officials as to what degree of "association"
with a terrorist is sufficient to render an applicant ineligible for a
visa. Further, according to State officials, ICE and State have
differing understandings of the VSP's jurisdiction under the Homeland
Security Act.
Although the 2003 MOU outlines a dispute resolution mechanism, both
ICE and State officials told us in May 2010 that this mechanism is not
sufficient. The 2003 MOU states, "If the chief of section or
supervisory consular officer does not agree that the visa should be
refused or revoked, the post will initiate a request for a security or
other advisory opinion and the DHS employee will be consulted in its
preparation." The MOU goes on to state that no advisory opinion will
be issued thereafter without the full consultation of State and DHS.
However, both VSP and consular officials told us that this process has
not always worked well in practice and that security advisory opinions
sometimes do not result in the resolution of the dispute. According to
ICE and State officials, because the Secretary of Homeland Security
has not delegated authority to refuse visas under section 428 of the
Homeland Security Act, any irreconcilable dispute about a visa
application ultimately must be elevated to the Secretary level for
final resolution. ICE and State officials stated that to supplement
this process, ICE and Consular Affairs officials at headquarters have
sometimes used other informal methods to reach agreement on the
adjudication of a visa. For example, ICE and State tried to resolve
disagreements at the unit chief level when possible.
The 2011 MOU addresses some of these issues by specifying that posts
can raise disputes to the Managing Director of the Visa Office and the
Assistant Director of ICE Homeland Security Investigations-
International Affairs and, subsequently, to the State Assistant
Secretary for Consular Affairs and the Director of ICE.
VSP Agents' Performance of Nonconsular Activities Sometimes Constrains
Visa Security Operations:
In some cases, VSP agents' performance of activities unrelated to visa
security has limited their ability to carry out visa security
activities. VSP agents perform a variety of investigative and
administrative functions in addition to their visa security workload,
such as conducting nonconsular investigations, serving as ICE's
official presence in the region, and performing the duties of DHS
attachés. According to ICE officials, VSP agents perform non-VSP
functions only after completing their visa security screening and
vetting workload. However, both VSP agents and State officials at some
posts told us that these other investigative and administrative
functions sometimes slow or limit VSP agents' visa security-related
activities.
Existing guidance for VSP agents' performance of other non-VSP
functions is limited. Section 428 of the Homeland Security Act states
that one of the functions of VSP employees assigned to overseas posts
is to conduct investigations with respect to consular matters under
the jurisdiction of the Secretary of Homeland Security. For example,
VSP agents may uncover and follow up on leads as a result of their
screening and vetting activities. While the 2003 MOU between DHS and
State states that DHS employees may conduct investigations with regard
to consular matters under the jurisdiction of the Secretary of
Homeland Security, those officials shall not conduct investigations
that are within the jurisdiction of the Bureau of Diplomatic Security
or the State Inspector General. Furthermore, VSP agents have the same
position description as other ICE agents and have the authority to
perform a wide range of tasks unrelated to visa security, including
the ability to investigate a wide range of cases within ICE's
jurisdiction. For example, VSP agents pursue cases related to bulk
cash smuggling or human rights violations. According to ICE officials,
ICE has not issued formal guidance that dictates how VSP agents should
spend their time. ICE officials told us that, in some cases, requests
to VSP agents come directly from other agencies, not from ICE itself.
The 2011 MOU states that the primary responsibility of VSP agents is
visa security. However, the 2011 MOU acknowledges that ICE personnel
perform functions of regional or worldwide scope related to the post
where they are assigned and that VSP agents may be called upon to
perform other functions in support of the consulate.
ICE officials told us that, at most Visa Security Program posts, the
VSP units represent the only ICE presence at post, and that some VSP
agents have ICE responsibilities for other countries in the region.
ICE officials told us that VSP agents are frequently tasked with
collateral requests to assist other ICE offices with investigations.
For example, as part of an ongoing investigation into a U.S.-hosted
Web site, one VSP agent assisted in the arrest of two individuals who
were producing and distributing child pornography. VSP agents are also
tasked with a variety of attaché functions, including serving as the
liaison between ICE and other U.S. government agencies. For example,
as the only DHS representative in Saudi Arabia, the VSP in Riyadh is
also responsible for supporting the Coast Guard, Transportation
Security Administration, official visitors, and detention and removal
operations. In addition, the regional responsibilities of the VSP
agent may require the agent to work on other investigations or respond
to collateral requests in other countries in the region. At one post,
VSP agents told us that these responsibilities were essentially
nominal and involved very little additional work. In Riyadh, these
regional responsibilities involved frequent travel throughout the
region to perform other investigations.
ICE officials told us that agents pursue these other investigations
only after completing Visa Security Program responsibilities. However,
consular officers at some posts told us that these additional
investigations interfered with completion of visa security work and
made ICE agents less available to consular officers. For example, at
one post, the VSP agent told us he was sometimes unable to complete
his screening and vetting activities because of other ICE
responsibilities. At another post, VSP agents worked alongside other
ICE agents, and the VSP agent at this post told us he focused
primarily on visa security work. In our interviews, VSP agents'
estimates of the amount of time spent on nonvisa requests and
investigations ranged from 5 percent to 40 percent. ICE does not track
the time VSP agents spend on both its visa security activities and its
nonvisa requests and investigations. While the VSP expansion plan
identifies the hours spent performing investigations as a performance
measure, ICE can not accurately determine the amount of time that VSP
agents spend on investigative and visa security activities, as its
systems do not distinguish between the time VSP agents and other ICE
officials spend on investigations at post. Furthermore, the VSP
tracking system does not collect data on the time VSP agents spend on
visa security activities. ICE cannot identify the time VSP agents
spend on visa security operations or on the other investigation and
attaché functions performed by VSP agents stationed overseas.
VSP agents' additional investigations also overlap with consular and
DS investigations at some posts, leading to confusion in the consular
section. According to the 2008 joint ICE-State cable to VSP posts, VSP
agents' responsibility to identify the potential exploitation of the
visa process by terrorists frequently overlaps the responsibilities of
consular units investigating fraud and criminal investigations.
According to one State official, all three units have a general
understanding of their respective jurisdictions but sometimes
interpret these jurisdictions differently. Generally, consular fraud
investigations begin with consular officers, who check for fraudulent
documentation and application information. When consular officers
notice organized fraud activity, they refer the case to the post's
Fraud Prevention Unit. When this organized activity is criminal, the
post's DS office launches an investigation. When the activity is
terrorism-related, the post's VSP agents investigate. However, some
posts we visited had experienced tension between VSP agents and other
law enforcement agency officials at post. For example, at one post,
the VSP agents and DS officials disagreed about whether the VSP agent
had authority and responsibility to conduct investigations locally.
Consular officials at another post wanted a DS officer to serve as a
liaison between VSP and the consular section. The 2011 MOU describes
the types of cases that fall under the jurisdiction of diplomatic
security investigators and VSP agents, and states that cases that fall
under the responsibility of both parties will require the officials to
notify each other.
Staffing Shortages and Use of Temporary Duty Agents Have Caused
Difficulties at Some Posts:
Staffing shortages, and a reliance on temporary duty VSP agents to
fill such shortages, have led to difficulties at some posts. Consular
officers at 3 of 13 posts we interviewed discussed challenges caused
by this use of temporary duty agents. For example, the VSP unit in
Riyadh used two temporary duty agents per month in fiscal year 2009
and one temporary duty agent per month in fiscal year 2010. Although
ICE officials indicated that the VSP filled its positions in Riyadh as
of December 2010, both VSP and consular officials stated that this
reliance on temporary duty agents affected continuity of operations.
One consular official pointed to a "severe lack of coverage" for
consular operations in Riyadh, because the unit was not fully staffed
and relied on temporary duty agents. Consular officers stated that
agents in Riyadh are rarely available to answer questions and that the
value of these temporary duty agents was limited, because it took them
several weeks of their 30-day tour to learn VSP policies and
procedures. Additionally, consular officers stated that temporary duty
agents' grounds for recommending refusal of visa applications were
sometimes inconsistent or insufficient. Lack of staff at VSPs in
Jeddah and Dhahran also created delays and forced consular officers to
re-adjudicate cases because VSP agents delayed an application beyond
the point where consular "name checks" of applicants expire. According
to one VSP official, reliance on temporary duty agents limits
continuity of operations at post.
The Visa Security Program's 5-year plan identified recruitment of
qualified personnel as a challenge and recommended incentives for VSP
agents as critical to the program's mission, stating, "These
assignments present significant attendant lifestyle difficulties. If
the mission is to be accomplished, ICE, like State, needs a way to
provide incentives for qualified personnel to accept these hardship
assignments." However, according to ICE officials, ICE has not has not
provided incentives to facilitate recruitment for hardship posts.
[Footnote 14] ICE officials stated that they have had difficulty
attracting agents to Saudi Arabia, and ICE agents at post told us they
have little incentive to volunteer for Visa Security Program
assignments. ICE officials in headquarters stated that opportunities
to gain international experience and earn danger pay are the primary
recruitment incentives for VSP service. Additionally, according to ICE
officials, some hardship posts, such as Riyadh, now allow spouses to
accompany agents during their tour. However, according to an ICE
official, ICE does not offer career and financial incentives for
personnel at hardship posts, such as Washington, D.C.-based locality
pay or priority consideration for onward assignments, which State
Foreign Service Officers receive when posted at the same locations.
[Footnote 15]
VSP Agents Do Not Receive Language Training, and Additional Training
May Be Helpful:
VSP agents generally do not receive foreign language training before
deployment overseas. Section 428 of the Homeland Security Act allows
that, to the extent possible, VSP agents shall be provided the
necessary training to enable them to perform their designated
functions--reviewing visa applications, and conducting investigations
on consular matters--including training in foreign languages,
interview techniques, and fraud detection techniques, in conditions in
the particular country where each employee is assigned, and in other
appropriate areas of study. The 2003 MOU states that DHS training and
assignment policies will emphasize identification or development of
personnel with the ability to speak the host country language and
"experience in or knowledge of the host country and extensive
understanding of terrorism or other homeland security concerns in the
host country." The 2011 MOU states that whenever practical, VSP staff
should receive interagency training and, prior to deployment, should
undergo orientation including, if possible, appropriate specialized
consultations and briefings with Consular Affairs and Diplomatic
Security officers.
ICE provides some training for VSP agents. ICE trains agents for Visa
Security Program duties in a 3-week training course, sponsored by ICE
and two other DHS divisions and conducted three times per year at the
Federal Law Enforcement Training Center in Glynco, Georgia. This
training includes, among other things, interview techniques, VSP
systems, document examination, and terrorist trends.
However, ICE does not have a program for language training and has not
established language training as a requirement for VSP agents. To
date, VSP agents at one post have received language training. This was
because, at one post, the Chief of Mission required language training
as a condition for approving the VSP's request to send personnel to
post. According to a VSP agent who received this training at the start
of his deployment, language skills were "critical" because he was able
to interact with host country law enforcement and conduct interviews.
Both the VSP agent and Consul General at this post recommended that
all VSP agents receive language training. According to ICE officials,
ICE's ability to provide language training for VSP agents is limited
by budgetary constraints. Because some VSP agents serve 1-or 2-year
tours, language training can be an expensive investment given the
amount of time an agent would actually use this training. ICE
officials told us that, when possible, they deploy ICE agents with
existing language skills. ICE also indicated that self-study language
training is available for VSP agents.
According to some consular officers and VSP agents, VSP agents who
have prior experience with immigration law may be better able to
advise consular officers than officers whose training on the subject
is limited to the VSP training course. For example, a consular
official at one post stated that she found VSP agents with backgrounds
in the former Immigration and Naturalization Service to be
particularly helpful because they have extensive expertise on
immigration law. All ICE agents receive basic instruction on
immigration law, and ICE provides additional instruction to its agents
during VSP training. One VSP agent stated he was unsure whether this
training would provide sufficient expertise in immigration law for
less experienced agents. VSP agents do not attend State's Consular
General training at the Foreign Service Institute, although VSP agents
and consular officials at some posts stated that attending such
training would be beneficial. VSP agents at several posts also
expressed a desire for more frequent opportunities to share problems,
techniques, and best practices with headquarters and other VSP units.
ICE Has Not Fully Adhered to the VSP Expansion Plan:
Although ICE developed a plan to expand the VSP to additional high-
risk visa-issuing posts, ICE has not fully adhered to the plan or kept
it up to date. The VSP 5-year expansion plan, developed in 2007,
identifies 14 posts for expansion between 2009 and 2010, but 9 of
these locations have not been established, and ICE has not updated the
plan to reflect the current situation. Furthermore, ICE has not fully
addressed remaining visa risk in high-risk posts that do not have a
VSP presence. ICE, with input from State, developed a list of
worldwide visa-issuing posts that are ranked according to visa risk.
Although the expansion plan states that risk analysis is the primary
input to VSP site selection and that the expansion plan represents an
effort to address visa risk, ICE has not expanded the VSP to some high-
risk posts. For example, 11 of the top 20 high-risk posts identified
by ICE and State are not covered by VSP. The expansion of the VSP may
be limited by a number of factors--including budget limitations and
objections from State officials at some posts--and ICE has not
identified possible alternatives that would provide the additional
security of VSP review at those posts that do not have a VSP presence.
VSP Expansion Plan Has Not Been Fully Followed or Updated:
Although ICE has expanded the VSP to a total of 19 posts in 15
countries, the agency has not fully followed the 5-year expansion
plan. ICE's plan identified 14 posts for expansion in 2009 and 2010,
but ICE did not establish VSP units at 9 of these 14 posts. Further,
ICE officials stated that 3 locations planned for 2011 may not be
opened because of budget constraints. Moreover, the expansion plan has
not been updated since its release in 2007, although ICE officials
said that the expansion plan will be revised in 2011. In the expansion
plan, ICE notes that the locations it identifies for expansion reflect
its best current assessment of the factors relevant to decision makers
and that evolving variables, including changes in risk and the results
of site assessments to determine the feasibility and timing of
deployment, may affect, among other things, the ultimate selection of
locations for VSP expansion. The plan states that ICE will continue to
update its assessment of conditions based on the most current
information and intelligence.
A number of factors have limited the VSP's expansion and consequently
its coverage of global visa risk. According to ICE officials,
expansion of the VSP has been constrained by budget limitations,
difficulties in obtaining visas to certain countries, State's mandate
to reduce personnel overseas, and objections from State officials at
some posts for reasons such as limited embassy space and security
concerns. For example, space limitations and security concerns are
currently hindering VSP's expansion to a high-risk post of interest to
ICE officials. The inability to obtain visas to another country is
preventing ICE officials from conducting a preliminary site assessment
at a possible expansion post in that country.
ICE Has Not Taken Steps to Address Remaining Visa Risk:
ICE has not consistently located VSP units at the posts identified as
highest risk and has not ensured VSP coverage for the posts without a
VSP unit, leaving significant gaps in the program's capacity to
address global visa risk. The VSP expansion plan states that global
visa risk is substantial and that the VSP addresses threats that could
exploit the visa process. ICE, in consultation with State, ranked 216
overseas posts based upon the visa security risk posed at each
location. However, 5 of the 19 established VSP units are located at
posts other than the 50 posts in the top tier, or critical quartile,
of the agencies' rankings of high-risk posts. One established location
ranks 70th on the list, while another ranks 86th. ICE officials
explained that certain posts were opened to achieve regional coverage
for other ICE activities. Moreover, of the 20 posts identified by ICE
and State as highest risk, 11 do not have a VSP unit.
ICE officials stated that visa risk at posts without a VSP presence is
addressed through the security advisory opinion (SAO) process, which
provides in-depth screening and vetting of certain visa applicants at
posts worldwide, regardless of whether the post has a VSP unit.
[Footnote 16] SAOs are initiated when an applicant meets certain
predefined criteria or when a consular officer requests an SAO for a
specific visa application. Officials from several agencies, including
ICE and State, participate in certain categories of SAO reviews in
Washington, D.C. However, while the SAO process can mitigate some visa
risk at those locations without a VSP unit, it does not ensure the
breadth of coverage provided by VSP agents through the routine
screening and vetting of applicants who are not subjected to the SAO
process.
ICE's expansion plan does not identify ways in which to address this
lack of VSP coverage at the remaining high-risk posts it identified.
However, ICE officials in headquarters indicated that they have used
TECS, the primary database used by VSP agents to screen and vet visa
applicants, to conduct screening and vetting domestically when a VSP
unit at a post experienced computer problems or temporary personnel
shortages. TECS interfaces with other law enforcement databases can be
accessed by ICE officials. Similarly, one VSP agent stated that agents
can perform screening and vetting for other posts in the event of a
computer systems outage. In addition, ICE officials stated that they
are currently developing a system that will make the screening and
vetting process more automated and will provide information to
consular officers in advance of the visa applicant's interview and
adjudication decision. Further, several ICE and State officials at
post indicated that the screening and vetting of visa applicants could
be performed domestically on a permanent basis.
Conclusion:
The Visa Security Program is intended to build additional security
into the visa process by incorporating a law enforcement function at
posts with the highest risk. However, the program is hampered in its
efforts to strengthen visa security globally. A lack of comprehensive
performance data collected since the establishment of the VSP in 2003
hinders ICE's ability to evaluate and report on the extent to which
the VSP enhances the security of the visa process. Although ICE
officials state that they have made improvements to their data
tracking systems, the agency cannot demonstrate the progress of the
VSP prior to 2010 toward its stated objectives of enhancing public
safety and national security. Furthermore, the responsibility of VSP
agents to perform investigations unrelated to visa security may limit
their ability to carry out visa security activities, their primary
responsibility, further affecting the relationship with consular
officials, and may limit the VSP's performance and its ability to
enhance national security and public safety. In addition, the VSP is
not contributing to the visa process at many high-risk posts. As a
result, there is a significant gap in the additional scrutiny that VSP
provides in the visa process among many posts considered to be of high
risk. ICE has not considered other options to strengthen security at
those posts where VSP does not have a physical presence. The VSP will
be limited in its goal to minimize global visa risk until DHS
addresses the challenges of guidance, staffing, and data collection,
and provides coverage and support to those high-risk posts without VSP
agents at post.
Recommendations for Executive Action:
To ensure that the Visa Security Program enhances the security of the
visa process at posts overseas, we recommend that the Secretary of
Homeland Security take the following four actions:
1. ensure that the VSP tracking system collects reliable data on all
performance measures, to allow ICE to accurately evaluate VSP
performance and report to Congress on progress toward the VSP mission
objectives;
2. issue guidance requiring VSP agents to provide training for
consular officers as mandated by section 428 of the Homeland Security
Act;
3. develop a mechanism to track the amount of time spent by VSP agents
on visa security activities and other investigations, in order to
determine appropriate staffing levels and resource needs for VSP
operations at posts overseas to ensure visa security operations are
not limited; and:
4. develop a plan to provide VSP coverage at high-risk posts where the
possibility of deploying agents may be limited.
Agency Comments and our Evaluation:
We provided a draft of our report to DHS and State. DHS provided
written comments about the draft, which are reproduced in appendix II.
State did not provide official comments on the draft. In addition, DHS
and State provided technical comments, which we incorporated as
appropriate.
DHS agreed with our recommendation that the department issue guidance
instructing VSP agents to provide training to consular officers as
mandated by section 428 of the Homeland Security Act. In addition, DHS
concurred with our recommendation that it develop a plan to provide
coverage for posts that lack a VSP presence and indicated that it is
taking steps to address this recommendation.
DHS did not agree with our recommendation that it ensure that the VSP
tracking system collected reliable data on all performance measures.
In its written comments, DHS stated that the VSP currently captures
all the required performance metrics identified in its 5-year
expansion plan through the VSP tracking system and TECS. Although we
acknowledge that ICE is collecting some data on the performance
measures identified in the VSP expansion plan, our analysis showed
that the data were not sufficient to accurately demonstrate the
progress made toward the stated objectives. As we report, the 5-year
expansion plan identifies six performance measures to assess VSP
performance. The documents that ICE provided us indicate that ICE has
collected comprehensive data on three of the performance measures, but
not on the three remaining performance measures. Specifically, ICE did
not provide us evidence that it collected data on the assistance and
liaison activities performed by VSP. Furthermore, although ICE
collects some information on the hours that VSP agents spend on
investigations and the training they provided to consular officials,
the VSP tracking system and TECS do not collect comprehensive data on
the activities performed by all of its VSP agents abroad. Without
collecting comprehensive data on the performance measures identified
by ICE, DHS cannot accurately demonstrate progress toward its stated
objectives of enhancing national security. Therefore we have retained
our recommendation.
DHS did not agree with our draft recommendation to issue operational
guidance for VSP posts. DHS stated that the 2011 MOU provides general
guidance for the visa process and the development of standard
operating procedures. We acknowledge that the MOU between ICE and
State, signed on January 11, 2011, clarifies the respective roles and
responsibilities of VSP agents and consular officers at post and
states that posts may develop standard operating procedures that were
identified in the 2008 cable. Therefore, we are removing our draft
recommendation from the report. However, although the 2011 MOU and the
2008 cable provide a basis for developing effective standard operating
procedures, we remain concerned that, during our review, most posts
had not developed these procedures. Only 2 of 13 posts we contacted
had developed standard operating procedures as recommended in the 2008
cable. At the 2 posts that developed standard operating procedures,
consular officers stated that procedures had improved the consular-VSP
relationship. It is critical for DHS to encourage posts to develop
standard operating procedures to improve the VSP-consular relationship
and strengthen VSP operations at posts.
DHS also did not agree with our recommendation to develop a mechanism
to track the amount of time that VSP agents spend on visa security
activities and other investigations. DHS states that ICE currently
tracks case investigation hours through TECS, and that adding the
metric to the VSP tracking system would be redundant. DHS's response
does not address our finding that ICE does not have a mechanism that
allows the agency to track the amount of time VSP agents spend on both
investigation hours and hours spent on visa security activities.
Although ICE states that its system tracks case hours of its agents,
we found, based on ICE documentation, that ICE cannot accurately
determine the amount of time that VSP agents spend on investigative
and visa security activities. First, the reports that ICE provided us
show the hours ICE officials spent on investigative and
noninvestigative activities, but do not distinguish between the hours
logged by VSP agents and hours logged by other ICE officials at posts
abroad. During our structured interviews, VSP agents indicated that
the time they spent on activities other than visa security reviews
ranged from 5 to 40 percent. Second, our analysis of the VSP tracking
system, which is intended to track visa-related activities of VSP
agents, identified significant limitations to the reliability of the
data. Thus, ICE does not maintain accurate data on the time VSP agents
spend on visa security activities at posts. The VSP is intended to add
additional security to the visa process through the screening and
vetting of visa applications by experienced law enforcement officers.
Without accurate data to determine the amount of time VSP agents spend
on the visa security activities, ICE will not be able to determine
whether the current allocations of staffing and resources at posts are
adequate to carry out the visa security reviews and thereby fulfill
the VSP objective of enhancing national security and public safety.
Therefore, we have not changed our recommendation.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Secretaries of Homeland Security and State, as well as other
interested Members of Congress. In addition, this report will be
available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
If you or your staff have any questions, please contact me at (202)
512-4128 or fordj@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contribution to this
report are listed in appendix III.
Signed by:
Jess T. Ford:
Director, International Affairs and Trade:
[End of section]
Appendix I: Scope and Methodology:
To assess the ability of the Department of Homeland Security (DHS) to
measure the objectives and performance of the Visa Security Program
(VSP), we reviewed VSP mission objectives and performance measures
identified in Bureau of Immigration and Custom Enforcement's (ICE) 5-
year expansion plan. We reviewed data from the VSP tracking system,
used to collect information on daily VSP activities, and compared the
data collected from the system with the measures and mission
objectives identified in the expansion plan. On the basis of
inconsistencies of the data from the reporting systems prior to 2010
that we identified through our analysis of the reports and confirmed
with ICE officials, we determined that the data that we received were
not sufficiently reliable for the purposes of this report. We also
reviewed performance reports from DHS and ICE that included references
to the VSP. In addition, we met with ICE officials in Washington,
D.C., who manage the VSP. We also observed VSP agents at six U.S.
embassies and consulates conducting their daily screening and vetting
activities and using the VSP Tracking System.
To identify challenges to the VSP's capacity to accomplish its goals,
we reviewed the Homeland Security Act of 2002, which authorized DHS to
assign DHS employees to posts overseas to support the visa process
through various functions. We also reviewed documentation including
the 2003 memorandum of understanding (MOU) between DHS and the
Department of State (State) governing the implementation of section
428 of the Homeland Security Act; the 2004 administrative MOU; the
2008 cable directing VSP units to develop standard operating
procedures; the 2011 MOU explaining the roles, responsibilities, and
collaboration of VSP agents and other officials at posts overseas;
VSP's training curriculum; and the VSP expansion plan. We met with ICE
officials in Washington, D.C., who manage the VSP and State officials
from the Bureaus of Consular Affairs and Diplomatic Security. We also
visited six U.S. embassies and consulates with established VSP units
where we interviewed and observed VSP agents, State officials from the
Bureaus of Consular Affairs and Diplomatic Security, and chiefs of
mission or deputy chiefs of mission. In order to allow for post-by-
post comparison, we administered a set of structured interview
questions to both the VSP units and consular sections in person at the
six previously mentioned posts and by phone at an additional seven VSP
locations. The five most recently established VSP posts, as well as
one unit that underwent recent personnel turnover, were not included
in our review.
To examine DHS's efforts to expand the Visa Security Program, we
reviewed relevant documents such as the VSP 5-year expansion plan,
which includes the mission and contributions of the program, criteria
for selecting new expansion posts, cost estimates for establishing and
maintaining VSP posts, and projected budget information. In addition,
we reviewed the ranked list of visa-issuing posts identified by ICE,
in consultation with State. We then compared the expansion plan and
the ranked list of posts with the VSP's actual expansion between 2005
and 2010. In addition, we reviewed the requests submitted by ICE to
overseas posts for expansion of the program. Our interviews with ICE
and State officials at 13 VSP locations worldwide and in Washington,
D.C., also informed this analysis.
[End of section]
Appendix II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528
March 21, 2011:
Jess Ford:
Director, International Affairs and Trade:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Re; Draft Report GAO-11-315: "Border Security: The Department of
Homeland Security's Visa Security Program Needs to Improve Performance
Evaluation and Better Address Visa Risk Worldwide.
Dear Mr. Ford:
The Department of Homeland Security (DHS) and U.S. Immigration and
Customs Enforcement (ICE) appreciate the opportunity to comment on the
draft report. We have addressed each recommendation separately below:
Recommendation 1: Ensure that the VSP tracking system collects
reliable data on all performance measures, to allow ICE to accurately
evaluate VSP performance and report to Congress on progress toward the
VSP mission objectives.
Response: DHS does not concur. The Visa Security Program (VSP)
captures all required metrics associated with its five-year plan
through the VSPTS and Treasury Enforcement Communications System
(TECS). The VSPTS and TECS are the two systems of record for VSP.
Currently, the VSPTS records: recommendations for refusal, additional
enforcement outcomes, derogatory information removal, opened
investigations (with supplementary information such as case hours
regarding investigations recorded into TECS), and assistance and
liaison activities. Consular and other training is reported to the ICE
Homeland Security Investigations, Office of International Affairs (HSI
OIA) directly from ICE Attaché offices in a weekly metrics report.
This formalized procedure for reporting training would make reporting
in the VSPTS redundant.
Recommendation 2: Issue additional operational guidance for VSP posts,
including standard operating procedures for the visa process and the
dispute resolution process.
Response: DHS does not concur. The 2011 "Memorandum of Understanding
among U.S. Immigration and Customs Enforcement of the Department of
Homeland Security and the Bureaus of Consular Affairs and Diplomatic
Security of the Department of State on Roles, Responsibilities and
Collaboration at Visa Security Units Abroad" (MOU) recognizes that the
circumstances at each post are unique. The MOU provides general
guidance and recommends that management at each post negotiate a local
standard operating procedure (SOP) to fit their needs. ICE
headquarters' program managers assist posts in developing these SOPs
according to post specific needs. Standard procedures across all posts
would prove overly restrictive, given the dynamic environment of
overseas operations. Each VSP post currently has an individualized
plan that is specific to their location.
Recommendation 3: Issue guidance requiring VSP agents to provide
training for consular officers as mandated by section 428 of the
Homeland Security Act.
Response: DHS concurs. While VSP headquarters can provide general
training guidance for all posts, it is incumbent upon each ICE Attaché
and corresponding Department of State (DOS) manager to identify post-
specific training needs relative to their respective environments.
Recommendation 4: Develop a mechanism to track the amount of time
spend by VSP agents on visa security activities and other
investigations, in order to determine appropriate staffing levels and
resource needs for VSP operations at posts overseas to ensure visa
security operations are not limited.
Response: DHS does not concur. ICE currently tracks case hours through
existing ICE systems which are standardized throughout the agency.
TECS is the system of record that tracks case investigation hours of
all ICE agents worldwide. Adding this function to the VSPTS would be
redundant.
Recommendation 5: Develop a plan to provide VSP coverage at high-risk
posts where the possibility of deploying agents may be limited.
Response: DHS concurs. ICE is actively addressing this recommendation.
ICE identified alternatives for VSP review at high risk posts that
currently do not have a physical VSP presence. ICE currently
participates in the interagency Security Advisory Opinion (SAO)
process, which reviews the highest risk visa applicants, covering all
worldwide posts. ICE is currently enhancing its IT systems, in
coordination with U.S. Customs & Border Protection (CBP) and DOS.
These changes will allow the screening and reviewing of all applicants
at all posts worldwide. Use of TECS and CBP's Automated Targeting
System (ATS), in addition to improved transfer of information with
DOS's Consular Consolidated Database (CCD) and Visa Opinion
Information System (VOIS) will enhance communication within DHS
(ICE/CBP) and DOS, thereby strengthening the layered defense strategy.
Both the physical presence of ICE special agents abroad and worldwide
coverage via IT enhancements are integral parts of VSP. IT
enhancements will enable ICE to conduct visa security investigations
at all existing ICE Attaché offices thereby providing coverage to an
additional 34 high risk posts in furtherance of the VSP expansion plan.
DHS generally concurs with Government Accountability Office (GAO)
recommendations three and five; however, DHS does not concur with
recommendations one, two and four. DHS is taking corrective actions to
address the overall recommendations. Thank you for the opportunity to
comment on this Draft Report. We look forward to working with you on
future Department of Homeland Security issues.
Sincerely,
Signed by:
Jim H. Crumpacker:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Jess T. Ford, (202) 512-4128 or fordj@gao.gov.
Staff Acknowledgments:
In addition to the contact names above, Anthony Moran (Assistant
Director) and Jeff Miller, Ashley Vaughan, Dave Bieler, Katie Bernet,
Amanda Miller, Mary Moutsos, Sushmita Srikanth, and Brian Egger made
key contributions to this report.
[End of section]
Footnotes:
[1] The Homeland Security Act of 2002 (P.L. 107-296) established DHS
and gave the Secretary of Homeland Security authority to issue
regulations with respect to the issuance and refusal of visas.
[2] Section 428 of the Homeland Security Act authorizes the Secretary
of Homeland Security to assign DHS employees to consular posts
overseas to support the visa process through various functions.
[3] GAO, Border Security: Actions Needed to Strengthen Management of
Department of Homeland Security's Visa Security Program, [hyperlink,
http://www.gao.gov/products/GAO-05-801] (Washington, D.C.: July 2005).
[4] In this report, we use the word "post" to identify U.S. embassies
and consulates.
[5] The State Department Bureau of Diplomatic Security is responsible
for personal protection, protection of facilities, investigations,
threat analysis, and training. Overseas, Diplomatic Security personnel
include regional security officers, who are responsible for the
security of facilities, personnel, and information at U.S. overseas
facilities, and assistant regional security officer-investigators, who
focus on investigations into passport and visa fraud at posts with
high levels of fraud.
[6] The security advisory opinion process is a multi-agency review
process that collects additional information on applicants to provide
a recommendation to posts to issue or refuse a visa.
[7] TECS is an updated and modified version of the former Treasury
Enforcement Communications System, which is principally owned and
managed by U.S. Customs and Border Protection. TECS is an automated
enforcement and antiterrorism database that provides information for
law enforcement and border security purposes, and can exchange
information automatically with other U.S. government systems.
[8] Prior to adjudication, every visa application undergoes biometric
and biographic clearances against several databases, including Facial
Recognition, Consular Lookout and Support System, and Terrorist
Screening databases.
[9] [hyperlink, http://www.gao.gov/products/GAO-05-801].
[10] P.L. 103-62.
[11] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[12] [hyperlink, http://www.gao.gov/products/GAO/GGD-10.1.20], The
Results Act: An Evaluator's Guide to Assessing Agency Annual
Performance Plans (Washington, D.C.: April 1998).
[13] In our structured interview, we provided several examples of
training, including "briefings, brown bags, hands-on exercises,
reports or other written products" We asked both the VSP agents and
the consular section to determine whether these sessions were "formal"
or "informal."
[14] State has designated roughly two-thirds of its 268 overseas posts
as hardship posts. Staff working in such locations often encounter
harsh environmental and living conditions that can include inadequate
medical facilities, limited opportunities for spousal employment, poor
schools, high levels of crime, and severe climate.
[15] Locality pay is a salary comparability benefit, typically
available to domestic federal employees only to attract workers in the
continental United States to the federal government versus the private
sector.
[16] SAOs provide an opinion or clearance from Washington on whether
to issue a visa to an applicant. These clearances are required for a
number of reasons, including whether an applicant's name appears as a
"hit" in the name-check system, or if the applicant's country of
origin is a state sponsor of terrorism.
[End of section]
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