DHS Lacked Technology
Needed to Successfully
Account for Separated
Migrant Families

November 25, 2019
OIG-20-06

DHS OIG HIGHLIGHTSDHS Lacked Technology Needed to Successfully
Account for Separated Migrant Families
November 25,
2019

Why We Did
This Audit
In fiscal year 2018, theDepartment of Homeland
Security apprehended
more than 100,000
families for illegal entry.
From May 5, 2018, toJune 20, 2018, DHS
adopted a Zero Tolerance
Policy to refer for
prosecution all adults
illegally entering theUnited States. We
conducted this audit todetermine theeffectiveness of DHS’ IT
systems in tracking
detainees and supporting
efforts to reunify
unaccompanied alienchildren with separated
families.

What We
Recommend
We made fiverecommendations to DHS
to improve its IT systems
to support tracking andreunification of separated
family units.
For Further Information:

Contact our Office of Public Affairs at(202) 981-6000, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov

What We FoundDHS did not have the information technology (IT) system
functionality needed to track separated migrant families
during the execution of the Zero Tolerance Policy. U.S.
Customs and Border Protection (CBP) adopted various ad
hoc methods to record and track family separations, butthese methods led to widespread errors. CBP officials havebeen aware of these IT deficiencies since at least November
2017 when U.S. Border Patrol conducted an initiative thatmirrored the Zero Tolerance Policy. These conditions
persisted because CBP did not address its known IT
deficiencies adequately before implementing Zero Tolerance
in May 2018. DHS also did not provide adequate guidance topersonnel responsible for executing the Zero Tolerance Policy.
Because of these IT deficiencies, we could not confirm the total
number of families DHS separated during the Zero Tolerance
period. DHS estimated that Border Patrol agents separated
3,014 children from their families while the policy was inplace. DHS also estimated it had completed 2,155
reunifications in response to a court order, although this effort
continued for 7 months beyond the July 2018 deadline forreunifying children with their parents. However, we
conducted a review of DHS data during the Zero Tolerance
period and identified 136 children with potential family
relationships who were not accurately recorded by CBP. In a
broader analysis of DHS data between the dates of October 1,
2017, to February 14, 2019, we identified an additional 1,233
children with potential family relationships that were notaccurately recorded by CBP. Without a reliable account of all
family relationships, we could not validate the total number of
separations, or reunifications.
Although DHS spent thousands of hours and more than $1
million in overtime costs, it did not achieve the original goalof deterring “Catch-and-Release” through the Zero Tolerance
Policy. Instead, thousands of detainees were released into
the United States. Moreover, the surge in apprehended
families during this time resulted in children being held in
CBP facilities beyond the 72-hour legal limit.

Agency Response

DHS concurred with our recommendations.
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1RYHPEHUOFFICE OF INSPECTOR GENERAL
Department of Homeland Security

Consistent with our responsibility under the Inspector General Act, we will
provide copies of our report to congressional committees with oversight andappropriation responsibility over the Department of Homeland Security. We
will post the report on our website for public dissemination.
Please call me with any questions, or your staff may contact Kristen Bernard,
Deputy Assistant Inspector General, at (202) 981-6000.
Attachment

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Table of Contents
Background .............................................................................................. 1
Results of Audit ....................................................................................... 7
DHS Lacked Adequate IT Functionality to Record and Track Family
Separations ................................................................................................. 8
DHS Did Not Address IT Deficiencies or Provide Guidance and Standard
Procedures Prior to Zero Tolerance Implementation .................................... 17
DHS Could Not Accurately Account for Separated Families or Accomplish
Reunifications as Mandated ....................................................................... 24
DHS Did Not Achieve Zero Tolerance Goals Amid Ineffective IT Tracking andManagement of Separated Families ............................................................ 34
Recommendations ................................................................................. 37
Appendices
Appendix A: Objective, Scope, and Methodology ................................. 46
Appendix B: DHS Comments to the Draft Report ................................. 48
Appendix C: Report Distribution .......................................................... 55
Abbreviations
CBP
e3
EARM
EID
ERO
FMUA
GAO
HHS
ICE
IT
OFO
OIG
OMB
ORR
SIGMA
UAC

www.oig.dhs.gov

U.S. Customs and Border Protection
ENFORCE 3
ENFORCE Alien Removal Module
Enforcement Integrated Database
Enforcement and Removal Operations
Family Units
Government Accountability Office
Department of Health and Human Services
U.S. Immigration and Customs Enforcement
information technology
Office of Field Operations
Office of Inspector General
Office of Management and Budget
Office of Refugee Resettlement
Secured Integrated Government Mainframe Access
Unaccompanied Alien Child(ren)OIG-20-06

OFFICE OF INSPECTOR GENERAL
Department of Homeland Security

Background
Each year, hundreds of thousands of people attempt to enter the United Statesillegally through the southern border with Mexico. According to U.S. Customs
and Border Protection (CBP), in fiscal year 2018 DHS apprehended about
107,200 families and 50,000 children for unlawful entry at the Southwest
Border. Collectively, these crossings represent a 34 percent increase from FY
2017, when CBP apprehended more than 75,000 families and at least 41,400
children.
DHS has primary responsibility for securing U.S. borders from illegal activity
and regulating travel and legal trade. Within DHS, CBP’s U.S. Border Patrol
employs more than 21,000 individuals to enforce immigration laws andsafeguard approximately 6,000 miles of U.S. border, including 2,000 miles on
the Southwest Border. Border Patrol agents apprehend individuals illegallycrossing the border, as well as human traffickers and smugglers. In addition,
Immigration and Customs Enforcement’s (ICE) Enforcement and Removal
Operations (ERO) takes action against foreign nationals who pose a threat tonational security or public safety, or who illegally enter the United States. ERO
officers arrest, transport, detain, and deport individuals to their countries oforigin. ERO officers also monitor individuals released from detention into theinterior of the country while awaiting final rulings from immigration
proceedings, a practice commonly referred to as “Catch-and-Release.”1
DHS’ efforts are aided by the U.S. Department of Health and Human Services’(HHS) Office of Refugee Resettlement (ORR), which is responsible for the careand custody of children who enter the country alone or without legal
guardians, referred to as unaccompanied alien children (UAC). ORR places
UAC in temporary shelters and facilitates long-term placement with approved
sponsors.
Timeline of Family Separation Policies
On April 6, 2018, the President issued a memorandum to the heads of various
departments, including DHS, to submit within 45 days a summary of efforts
taken to end the practice of “Catch-and-Release.”2 On the same date, the U.S.
Attorney General issued a memorandum directing all Federal prosecutors’
offices along the Southwest Border to work with DHS to adopt a “Zero

1 “Catch-and-Release” refers to the practice of releasing aliens into the United States shortly
after their apprehension for violations of immigration laws.
2 Presidential Memorandum for the Secretary of State, the Secretary of Defense, the Attorney
General, the Secretary of Health and Human Services, and the Secretary of Homeland Security,
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Tolerance Policy,” which required criminal prosecution of DHS referrals of 8
U.S.C. § 1325(a) violations, to the extent practicable.3
In accordance with the requirements of the memorandum, on May 5, 2018,
DHS adopted the Zero Tolerance Policy department-wide and began referring forprosecution all adults, including those accompanied by children, who entered
the United States illegally. The Department’s Zero Tolerance Policy lasted
approximately six weeks from the May implementation date. Figure 1 shows
key policy implementation dates.
Figure 1: Timeline of Zero Tolerance Policy

Source: Office of Inspector General (OIG)-generated from DHS data and Zero Tolerance related
legal documentation

On June 20, 2018, the President issued Executive Order 13841,4 ending thepractice of family separations. On June 26, 2018, a Federal District Court
judge in the Ms. L. v. ICE litigation issued a preliminary injunction to stop DHS
from separating migrant adults from their children, absent a determinationthat the parent is unfit or presents a danger to the children, when they areheld in DHS custody.5 The judge also ordered the Government to reunify
children younger than age 5 with their parents within 14 days and children 5
years and older within 30 days of the court order.
See Dept. of Justice, Memorandum for Federal Prosecutors Along the Southwest Border, April 6,2018 (directing all United States Attorney’s Offices along the Southwest Border to “adopt
immediately a zero-tolerance policy for all offenses referred for prosecution under [8 U.S.C §1325(a)].”) Entering the United States without inspection and approval is a civil offense that
may also result in criminal charges. See 8 United States Code (U.S.C.) §§ 1227 (civil grounds
for removal), 1325 (crime of improper entry), 1326 (crime of reentry). The Department ofJustice has the authority to decide whether and to what extent to prosecute Federal crimes.
4 Exec. Order No. 13841, Affording Congress an Opportunity to Address Family Separations,
was announced and became effective on June 20, 2018, and was published in the Federal
Register at 83 FR 29,435 on June 25, 2018.
5Ms. L. v. ICE, 18-cv-428 (S.D. Cal. June 26, 2018).
3

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DHS Standard Operating Procedures for Processing Apprehended Families
and Children
When Border Patrol agents apprehend migrants for illegal entry into the UnitedStates, they interview them, review any identifying documentation (such as
birth certificates or passports), collect biometrics,6 and conduct criminal
history checks. If a migrant indicates an intention to apply for asylum or a fearof persecution, the agent will refer the migrant for an interview by an asylum
officer.7 During initial processing, Border Patrol agents determine whether
each apprehended individual is part of a family. Border Patrol agents use two
methods for classifying apprehended relatives, depending on the family
members’ relationships:
1. Family Unit Classification: Border Patrol defines a family unit as anadult, age 18 or older, accompanied by a child younger than age 18, whois able to demonstrate parentage or guardianship. Border Patrol agentsprocess all family members together and assign them an information
technology (IT) system-generated family unit (FMUA) number. Additionalcase notes are entered to provide details on each family member, such as
apprehension information and any addresses or information for thefamily's point of contact in the United States.
2. Family Group Classification: Border Patrol defines a family group as two
relatives, such as siblings or a child traveling with his/her aunt or
grandparent, and records them as a “Family Group” in its IT system andcase notes.
After initial processing, Border Patrol agents determine whether to refer anadult parent for criminal prosecution based on the circumstances of the initial
apprehension or the individual’s prior criminal history. If Border Patrol
determines that a parent is unfit or presents a danger to the child, or is held
for criminal prosecution, the Border Patrol agent separates the family. WhenDHS separates children from adults held for prosecution, the children are
deemed UAC and transferred to ORR custody. In such cases, Border Patrol
reclassifies the parent as a single adult and the child as a UAC in the IT
system.

6 CBP collects biometrics, such as fingerprints, for alien immigrants who are 14 years or older.

7 The Secretary of Homeland Security or the Attorney General may grant asylum to any alien
who qualifies as a “refugee” under U.S. Immigration Law [8 U.S.C. § 1158]. Generally, a“refugee” is a person outside his/her country of nationality who is unable or unwilling to returnto that country “because of persecution or a well-founded fear of persecution on account ofrace, religion, nationality, membership in a particular social group, or political opinion” [8U.S.C. § 1101(a)(42)(A)].

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However, CBP cannot detain migrant adults or children long-term. By law,
DHS should refer the adult for prosecution within 48 hours8 and must transfer
children to HHS within 72 hours of apprehension, absent “exceptional
circumstances.”9 DHS transfers all UAC to HHS ORR custody through areferral and placement request. The child remains in ORR care until HHS canmake custody arrangements. ORR places most detained children in ORRfunded shelters located in different states across the country. Figure 2 depicts
the process for adults and children who have entered the country illegally.
Figure 2: Detainee Process for Illegal Entry for Family Units and UAC

Source: OIG-generated based on DHS data10

Once Border Patrol processes individuals for illegal entry, ICE ERO officers
transport them to detention facilities. Specifically, ERO transfers separated
children to HHS ORR facilities as needed, but houses single adults, along witha limited number of families awaiting immigration proceedings, at ICE
detention centers.
8 City of Riverside v. McLaughlin, 500 U.S. 56, 57 (1991), probable cause determination must

be made within 48 hours after arrest. In Jones v. Lowndes County, 678 F.3d 344, 350 (5th Cir.
2012), 48 to 72 hours is also an acceptable timeframe in which to be referred for prosecution
and have a hearing before a judge, for example, when the arrest is made over a weekend.
9 There are special rules for U A C from Mexico and Canada that may permit a different process,
8 U.S.C. § 1232(a)(2)(A). However, if UAC cannot be processed under those rules, CBP must
follow the same process established for unaccompanied alien children from other countries [8U.S.C. § 1232(a)(3)].
10 Figure 2 does not represent formal removal proceedings under Immigration Nationality Act §240.
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Separated families can be reunified either after a parent is released from
custody or prior to removal from the United States. If DHS releases parents
from custody into the United States, eligible parents can contact ORR tocoordinate reunification with their children.11 Additionally, parents may
request reunification prior to ICE removing them from the United States.
DHS’ Role in Family Separations Prior to Zero Tolerance
Before Zero Tolerance Policy implementation, DHS played a minimal role inreunifying migrant families, as separations rarely occurred. For example, when
CBP apprehended an alien family unit attempting to enter the United Statesillegally, it usually placed the adult in civil immigration proceedings without
referring him or her for criminal prosecution. CBP only separated apprehended
parents from children in limited circumstances—e.g., if the adult had acriminal history or an outstanding warrant, or if CBP could not determine
whether the adult was the child’s parent or legal guardian. Accordingly, inmost instances, family units either remained together in family detention
centers operated by ICE while their civil immigration cases were pending, orthey were released into the United States with orders to appear in immigration
court at a later date.
Border Patrol officials reported it conducted a prosecution initiative in FY 2017
in the El Paso Sector to deter illegal border crossings by increasingprosecutions, which resulted in an increase in family separations. On April 11,
2017, the U.S. Attorney General issued a memo that directed all Federal
prosecutors to renew their commitment to criminal immigration enforcement.
Border Patrol’s El Paso Sector conducted the initiative from July to November
2017 to maintain operational control of New Mexico and parts of Texas byprosecuting criminal adults who attempted to exploit the UAC crisis in order toavoid prosecution. Border Patrol ended the El Paso initiative on November 18,
2017, to further review the prosecution policy.
Systems Used to Support Detainee Processing and Tracking
Border Patrol and ICE personnel use various IT systems to track detainees andfamily separations. Border Patrol agents rely on the ENFORCE 3 (e3) system torecord detainee information throughout the process from apprehension toprosecution or release. ICE field officers use the Enforce Alien Removal Module(EARM) to process detainees. Both e3 and EARM data are stored in ICE’s
Enforcement Integrated Database (EID). CBP’s Office of Field Operations (OFO)
officers use the Secured Integrated Government Mainframe Access (SIGMA)

11 Parents ineligible for reunification with their children include those with criminal histories or

who might be considered a danger to their children.
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platform to process individuals at legal ports of entry.12 HHS maintains its
Unaccompanied Alien Children Portal (UAC Portal) to track children in HHS
custody. These systems are detailed in table 1.
Table 1: IT Systems for Managing and Tracking Detainees
CBPe3e3 has separate modules that allow Border Patrol agents tocapture detainee biographic data, apprehension information, andbiometric data (e.g., fingerprints), as well as track detention
status and prosecution referral information.13

SIGMA

SIGMA is OFO’s platform for processing adverse actions forinadmissible applicants for admission to the United States.

EARM

ERO’s case management system records custody decisions,detention, and removal specifics in a detainee’s personal record.

EID

EID is a shared repository for storing law enforcement
information from CBP’s e3 and SIGMA systems and ICE’s EARM
system on migrants apprehended and detained, as well as family
units and family separations.

ICE

HHS
UAC Portal

HHS’ database tracks information related to juveniles in ORR
custody.
Source: OIG-generated based on DHS data

Recent Reports on the Zero Tolerance Policy
DHS OIG, HHS OIG, and the Government Accountability Office (GAO) haveconducted several audits or inspections of DHS’ and HHS’ ability to track
family separations. These agencies reported on the challenges DHS faced intracking family separations during the Zero Tolerance Policy period.
x

In September 2018, DHS OIG reported initial observations from its June
26–28, 2018 visit to the Southwest Border to evaluate family separation
issues resulting from the Zero Tolerance Policy. DHS OIG reported thatthe Department was not fully prepared to implement the Administration’s
policy or deal with some of its after-effects. Additionally, DHS OIG found

12 OFO is responsible for inspecting and examining legitimate travel and trade at ports of entry,

and preventing the entry into the United States of contraband and those persons who would
harm the United States. Because OFO operates at legal ports of entry, the office played alimited role in implementing the Zero Tolerance Policy and separating families.
13 The system modules include Intake, Detention, Biometrics, Prosecution, and Processing.
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that the Department struggled to identify, track, and reunify families due
to systems limitations, including a lack of interoperability.14x

In October 2018, GAO reported that HHS and DHS did not plan forincreased numbers of children separated from their parents or legal
guardians. GAO reported that DHS and HHS officials were unaware of
the Zero Tolerance Policy until the U.S. Attorney General issued thememo directing all United States Attorney Offices along the Southwest
Border to work with DHS to adopt it. Additionally, GAO reported thatprior to April 2018, DHS and HHS did not have a consistent way toidentify in their data systems children separated from their parents atthe border. DHS and HHS made tracking system upgrades between April
and July 2018; however, it was too early for GAO to determine the extent
to which the changes would consistently identify children separated fromtheir parents or help reunify families.15

x

In January 2019, HHS OIG reported that the total number of children
separated from a parent by DHS was unknown. As of December 2018,
HHS identified 2,737 children separated by Border Patrol and transferred
to ORR custody. However, HHS OIG reported that DHS may haveseparated thousands more children since 2017 and that HHS faced
challenges identifying separated children.16

We conducted this audit to follow up on DHS OIG’s September 2018 report.
Our objective was to determine the effectiveness of DHS’ IT systems for
tracking detainees and supporting efforts to reunify UAC with their families.

Results of Audit
DHS did not have the information technology (IT) system functionality needed
to track separated migrant families during the execution of the Zero Tolerance
Policy. U.S. Customs and Border Protection (CBP) adopted various ad hoc
methods to record and track family separations, but these methods led towidespread errors. CBP officials have been aware of these IT deficiencies
since at least November 2017 when U.S. Border Patrol conducted an initiativethat mirrored the Zero Tolerance Policy. These conditions persisted because
CBP did not address its known IT deficiencies adequately before DHS
implemented Zero Tolerance in May 2018. DHS also did not provide adequate
guidance to personnel responsible for executing the Zero Tolerance Policy.
14Special Review - Initial Observations Regarding Family Separation Issues Under the Zero

Tolerance Policy, OIG-18-84, September 201815 Unaccompanied Children: Agency Efforts to Reunify Children Separated from Parents at theBorder, GAO-19-163, October 201816 Separated Children Placed in Office of Refugee Resettlement Care, HHS, OEI-BL-00511,

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Because of these IT deficiencies, we could not confirm the total number offamilies DHS separated during the Zero Tolerance period. DHS estimated that
Border Patrol agents separated 3,014 children from their families while thepolicy was in place. DHS also estimated it had completed 2,155 reunifications
in response to a court order, although this effort continued for 7 months
beyond the July 2018 deadline for reunifying children with their parents.
However, we conducted a review of DHS data during the Zero Tolerance period
and identified 136 children with potential family relationships17 who were notaccurately recorded by CBP. In a broader analysis of DHS data between thedates of October 1, 2017, to February 14, 2019, we identified an additional
1,233 children with potential family relationships not accurately recorded by
CBP.18 Without a reliable account of all family relationships, we could not
validate the total number of separations, or reunifications.
Although DHS spent thousands of hours and more than $1 million in
overtime costs, it did not achieve the original goal of deterring “Catch-andRelease” through the Zero Tolerance Policy. Instead, thousands of detainees
were released into the United States. Moreover, the surge in apprehended
families during this time resulted in children being held in CBP facilities
beyond the 72-hour legal limit.

DHS Lacked Adequate IT Functionality to Record and Track
Family Separations
DHS did not have the IT system functionality needed to accurately track andaccount for the total number of families separated during the Zero Tolerance
Policy period. Border Patrol agents adopted ad hoc techniques to work aroundthe system limitations, but these techniques introduced data errors thatfurther hindered ICE ERO officers’ ability to track migrant parents separated
from their children. DHS was aware of these IT deficiencies prior to Zero
Tolerance Policy implementation, but IT modifications implemented in
preparation for the policy did not fully resolve the problems. DHS personnel
faced equally significant IT challenges interfacing and coordinating with HHS tofacilitate the transfers of thousands of children to ORR custody.

17
The term potential family relationship is used because DHS OIG cannot confirm the family
relationship in each instance. CBP’s data suggests that there is a family relationship based on
name, age and being apprehended together. But in some circumstances CBP did not record thechild and adult as a family in their system or in case notes.
18 The audit team had access to all CBP apprehension data but did not have access to HHS or
U.S. Department of Justice data. Therefore, the review of potential family relationships did notinclude analysis of HHS or U.S. Department of Justice data.

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DHS IT Systems Lacked the Functionality Needed to Effectively Record
and Track Family Units
Border Patrol and ICE ERO share a joint responsibility for processing
individuals apprehended between ports of entry. On average, Border Patrol
apprehended approximately 1,200 individuals per day during Zero Tolerance.
Although Federal law requires the Chief Information Officer of each agency todevelop and maintain a sound IT environment to ensure integration across IT
capabilities used for mission operations,19 DHS’ IT systems did not have thefunctionality during Zero Tolerance to track and share data on family
separations and reunifications. Specifically, Border Patrol agents document
apprehensions, family status, and prosecutions in the e3 system for eachillegal entry. Next, ICE officers process adults for detention, removal, or
release, and facilitate UAC transfers to HHS, using the EARM system. Both
Border Patrol’s e3 and ICE’s EARM systems store and share data through aback-end database, EID. This end-to-end process is depicted in figure 3.
Figure 3: Systems Processing from Apprehension to Release

Source: OIG-generated from DHS data

The e3 system lacked critical capabilities to (1) separate grouped family
members, (2) track separations once a family unit was deleted from the e3
system, and (3) reunite family members.

National Defense Authorization Act for Fiscal Year 1996, Pub. L. No. 104–106, § 5125 (1996);
Office of Management and Budget (OMB) Memorandum 15-14, Management and Oversight ofFederal Information Technology, June 10, 201519www.oig.dhs.gov

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Separating Family Members
The e3 system did not have built-in functionality to separate adults referred forprosecution from a family unit. Instead, a Border Patrol agent had to delete
the entire family unit from e3 in order to process the family members as single
adult(s) and UAC. Once the family unit was deleted from the system, the agent
could no longer view or retrieve the family unit tracking number from e3. That
information remained stored separately in the back-end database, EID, but
was retrievable only by IT specialists at CBP headquarters. Figure 4 illustrates
how Border Patrol agents deleted family units in the e3 system.
Figure 4: Deleting a Family Unit in e3

Source: Screenshot from CBP documentation following the e3 April 2018 update

Tracking Separations
Prior to April 2018, the e3 system did not provide Border Patrol field users theability to track separations once a family unit was deleted from e3, or identify
for headquarters personnel the reason why the family members wereseparated. In addition, e3 did not have a search capability to match a childand an adult by last name, age range, or apprehension date. In April 2018,
Border Patrol updated e3 to add 11 possible separation codes for agents toselect as distinct reasons why family members were separated. However, noneof the 11 separation codes were specifically tied to the Zero Tolerance Policy.
That is, agents did not have an option to select “Zero Tolerance” as a reason forseparating families. To compensate, Border Patrol agents used ad hoc
workarounds to capture the reasons for family separations by simply selecting“Criminal History” or “Other Reasons,” as highlighted in table 2.

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Table 2: Family Separation Reasons Added to e3 on April 19, 2018
Separation
Code
ERR
FCCO
FCNR
FCNFRP
FMEW
FMGA
FMH
FMPC
FMPO
FMPIV
FMT

Separation Reason
FMUA made in error
Fraudulent Claim – Child determined to be over 18
Fraudulent Claim – No Family Relation (No prosecution)
Fraudulent Claim – No family relation (prosecution of adult)
Family Member – Extraditable Warrant
Family Member – Gang Affiliation
Family Member Hospitalized
Family Member Prosecuted – Criminal History
Family Member Prosecuted – Other Reasons
Family Member – Prior Immigration Violation(s) and order of removal
Family Member – Terrorist

Source: OIG-generated from DHS data

Border Patrol then typed case notes, in narrative text form, into the e3 systemat the top of detainee case files, creating the only accessible record of separated
family members. CBP headquarters instructed Border Patrol agents across theSouthwest Border to use case notes to record information on separated family
members. Ideally, case notes typically included summaries on the individuals
apprehended, where and when they were apprehended, and with whom.
The downstream effect of ad hoc typing in case notes became apparent when
CBP headquarters began efforts to identify separated families needingreunification after the policy ended in June 2018. To locate and reunify family
members, Border Patrol headquarters personnel had to review all separations
coded as “Criminal History” or “Other Reasons” in the system, as well as all theaccompanying case notes. This process was neither easy nor accurate.
Lacking critical IT tracking capability, Border Patrol immediately struggled tokeep pace with the high volume of migrant apprehensions and separations
resulting from Zero Tolerance. They also could not determine how many
children in Border Patrol custody were separated from parent(s) at any giventime.
Reuniting Family Members
DHS’ IT systems could not electronically rejoin previously deleted family
members. Specifically, Border Patrol’s e3 system did not have automatedcapability to restore the families previously deleted if the individual members
were eventually reunited at CBP facilities. Instead, Border Patrol agents had toprocess the parents and their children together again in e3, assign new family
unit numbers (potentially duplicating records), and further annotate the casefiles to state that family members were reunified. Similarly, when ICE ERO
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release and noted the reunifications in EARM case comments and on Microsoft
Excel spreadsheets.
Manual, Ad Hoc Family Tracking Introduced Widespread Data Errors
Border Patrol personnel inadvertently entered incorrect codes to indicate
reasons for family separations, or incorrectly assigned children and adults tofamily units. Data errors were so extensive that a Border Patrol Chief
expressed embarrassment at the number of inaccuracies documented by field
personnel. The following are examples of the various challenges stemmingfrom CBP’s inability to account for separations consistently in e3:xCreating family units: Upon initial apprehension processing, Border
Patrol agents incorrectly created family units for individuals who were
not parent/child. Our review of DHS data disclosed 270 instances wherefamily units were created in error.

x

Recording family separations: Border Patrol personnel incorrectly entered
the codes indicating the reason for separation. In other instances,
agents separately processed parents as single adults and their children
as UAC at initial intake, never recognizing them in the system asmembers of the same family, making it exceedingly difficult to track andreunify them afterward. We identified nearly 300 individuals whom
Border Patrol incorrectly processed in this manner.

x

Separating family members using multiple codes: Border Patrol
personnel selected multiple separation codes when deleting a single
family unit, causing confusion for ICE headquarters personnel who later
attempted to track the separations by specific, individual codes. Border
Patrol’s list of separations from e3 contained 62 detainees with multiple
separation reason codes. But, only one separation reason code wasneeded to identify each detainee to avoid conflicting information.

In instances when DHS had no data at all on family separations, DHS only
discovered these separations when HHS or nonprofit entities advocating on
behalf of the UAC notified the Department. For example, in one case, an
Arizona-based nonprofit organization contacted DHS about a deaf minor who
had been separated from his father by Border Patrol. Upon ICE’s review, thechild’s official case record discussed neither the separation nor the child’s
disability. In other instances, UAC records in the ICE system had incomplete
or inaccurate information on separated family members.
These tracking challenges worsened when Border Patrol field personnel atvarious locations used different ad hoc methods to track detainees. For
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example, Border Patrol agents in a Texas sector with one of the highest
volumes of apprehensions in the country opted to create separation lists using
Microsoft Excel spreadsheets. However, local Border Patrol leadership noted
this approach created additional problems, as they were not able to use thespreadsheets easily to report on separation statistics when headquarters
requested they do so. The spreadsheets also contained inaccuracies as they
were not designed for large-scale processing.
Staff at another Texas Border Patrol sector contacted IT support at
headquarters for assistance with tracking and reporting on family separations
during Zero Tolerance. At the time, field staff were unable to identify adults
held for prosecution who were separated from accompanying children.
However, headquarters also did not have centralized information on thenumber of family separations occurring in each sector to assist the field.
Instead, headquarters personnel had to create a specific report based on the
sector’s requests for family separation data and distribute it daily.
Headquarters staff acknowledged that they had received similar requests forassistance in tracking separations from other sectors.
Inability to Properly Record Family Units Hindered Detainee Tracking
Border Patrol’s lack of uniform processing of apprehended migrants andnumerous data entry errors had a significant downstream effect on ICE, which
was responsible for tracking individuals detained, released, or transferred to
HHS. ICE’s challenges stemmed from (1) a lack of understanding of theseparation codes Border Patrol used, and (2) inadequate information provided
by Border Patrol in some e3 case records.
1) The family separation data recorded in e3 by Border Patrol was often
indecipherable for ERO headquarters personnel responsible forgenerating reports from system data. Specifically, ICE did notunderstand the 11 new codes, described in table 2, that Border Patrol
began using in April 2018 when separating family members. Without
this information, ICE ERO personnel were unable to identify which
adults in their custody had actually been separated from their children.
2) ICE was also hindered from properly tracking separated families because
Border Patrol did not always include in its e3 documentation thenecessary information on family separations. At a detention center in
Texas, ICE officers said the majority of the official records they reviewed
had no information on parents separated from their children. Officers
said that often they only became aware of separated family members
when a parent in custody asked about his or her separated child.
Officers said they typically determined family members had been
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separated by searching through records for lists of individuals
apprehended together.
To address these concerns, ICE personnel asked Border Patrol to note eachfamily separation at the top of the official narrative case record in e3. However,Border Patrol did not consistently capture this information as requested. We
reviewed a random sample of Border Patrol records on 339 adult parents
separated from children during Zero Tolerance enforcement. Of the records
reviewed, only 139 (41 percent) of the 339 contained family separation
information at the top of the case files. Further, 208 (61 percent) contained
partial biographical information about separated children and 71 (21 percent)
had no information at all on separated children.20 To compensate, some ICE
field officers established local procedures to track family separations during
Zero Tolerance. These tracking methods included adding narrative text
comments to migrant case files or flagging files in the EARM system.
ICE’s office responsible for processing UAC and families requested
headquarters make changes to the EARM system to track separations in early
2018, before Zero Tolerance. Discussions concerning system upgrades toaddress tracking needs continued for months. During Zero Tolerance, ICE
officers escalated concerns to headquarters about a lack of data consistency
and stated that the EARM system did not include a place to note family
separations. However, ICE system upgrades to aid in tracking family
separations were not completed until August 2018, after the Zero Tolerance
Policy ended.
IT Deficiencies Pre-dated Zero Tolerance Policy Implementation
CBP headquarters personnel had been aware of the various system deficiencies
related to tracking family separations since at least the El Paso initiative in2017 that mirrored Zero Tolerance. During this initiative DHS and theDepartment of Justice coordinated to increase prosecutions of illegal entry in
the El Paso Sector, including individuals entering with their families. We could
not determine the origin of the initiative. Through increased prosecutions,
Border Patrol separated nearly 280 families — an increase from prosecuting 0
percent of adults with a family the month before the initiative began toprosecuting15 percent during the initiative.
However, Border Patrol’s e3 system did not have the functionality to track
family separations at that time. El Paso Sector agents requested assistancefrom CBP headquarters, but the necessary system changes were not made.
According to Border Patrol headquarters personnel, El Paso Sector’s request for
20 The numbers and percentages do not add here because some cases had more than one error.

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e3 functionality to track family separations was not a high enough priority to
warrant the time and resources required for system modifications.
As during Zero Tolerance, Border Patrol personnel relied on local spreadsheets
to document family separations during the El Paso initiative. However, having
to input information manually into spreadsheets increased the likelihood oferrors, which in turn complicated efforts to match and reunite separated
families after Zero Tolerance ended. For example, of the nearly 280 families
separated during the El Paso initiative, at least 7 adults had incorrect aliencase file numbers21 on the tracking spreadsheets and 33 others recorded no
information at all on family separations. The use of spreadsheets in the field,
rather than recording information in department-wide systems, prevented ICE
and CBP personnel in other locations from seeing where El Paso Sector Border
Patrol agents had separated family members.
CBP leadership noted the sensitivity of family separations and recommended
improved coordination among CBP, ICE, and HHS officials during the El Paso
initiative to mitigate issues associated with family separations and placementof separated children. In November 2017, in an email to CBP’s Acting
Commissioner and ICE’s Acting Director, a senior HHS ORR official identified
an increased number of detained migrant children needing placement. The
Acting Commissioner responded that CBP would coordinate with HHS on
future plans for family separations. Around the same time, CBP headquarters
instructed the El Paso Sector to halt the initiative. After it did so, the El Paso
Sector provided an after-action report to Border Patrol’s Acting Chief ofOperations calling for greater coordination among the various stakeholders.
The following year, the same Acting Chief assisted in implementing Zero
Tolerance and was aware of the need for improved coordination among CBP,
ICE, and HHS ORR to address the known challenges encountered in separating
migrant families.
DHS Faced Additional Challenges Interfacing with HHS to Track Transfersof Unaccompanied Children
DHS personnel faced equally significant challenges interfacing andcoordinating with HHS to facilitate transfers of thousands of UAC to ORR
custody during Zero Tolerance. The Homeland Security Act of 2002 assigned
responsibility for care and custody of unaccompanied children to HHS.
However, DHS did not have an automated process to request transfer of a childin CBP custody to HHS. Instead, Border Patrol agents pressed a referral
request button in e3 that transmitted an encrypted email to HHS’ UAC Portal
requesting transfer for each separated child. All subsequent communication
An alien number is a unique DHS-generated identification number for non-citizens applying
for immigration benefits or subject to law enforcement actions.

21

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after the initial system request had to be communicated directly between DHS
juvenile coordinators22 and HHS personnel by email. For a routine case,coordinators typically send and receive five or more emails to place just one
child in ORR custody. To illustrate:
1. Border Patrol sends an email requesting transfer of a UAC to ORR.
2. ORR sends an email confirming that placement is arranged.
3. The transportation contractor sends an email facilitating travel details forthe transfer.
4. The transportation contractor sends another email including the travel
itinerary.
5. Border Patrol emails back, acknowledging receipt of the child’s travel
information. ICE ERO is copied on the emails so it can track the UAC.
6. ICE ERO directly inputs Placement Requests.
The process, end-to-end, is depicted in figure 5.
Figure 5: Manual Processes for Requesting UAC Placement with HHS

Source: OIG-generated from DHS data

Monitoring multiple emails for each child was labor intensive, and emails werereceived at all hours of the day. One Border Patrol agent estimated that in a 1week period, she received 1,700 emails regarding UAC placement. At one field
22 Juvenile coordinators are CBP and ICE personnel whose responsibilities include UAC

transfers.

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site we visited, Border Patrol had a team of five agents monitoring email
exchanges between HHS and a transportation contractor regarding theplacement of UAC. Border Patrol staff expressed concerns that reliance on
email to share travel details further complicated tracking of UAC transfers andresulted in errors, such as Border Patrol receiving incorrect travel itineraries
for some children. To compensate, Border Patrol had to manually compare
emails against information in the HHS UAC Portal and then manually input thecorrect travel data into e3. More concerning, because referral requests were
not automated, requests never reached HHS when the encrypted email transferfrom e3 to the UAC portal went down, adding to the backlog of UAC in Border
Patrol’s custody.
ICE ERO field offices also became overwhelmed with the manual work
associated with facilitating UAC placement and updating EARM to track UAC
placement. During Zero Tolerance, ICE officers estimated that they received up
to 300 emails per day. Multiple ICE ERO field office juvenile coordinators weinterviewed in Texas during our November 2018 fieldwork stated their full-timejobs entailed monitoring placement of children in different HHS facilities andconducting multiple manual processes to update ICE systems. Specifically,
after receiving transfer email notifications, officers manually transferredjuveniles using the following steps:
1. copying the information from transfer emails manually into a Microsoft
Excel spreadsheet;
2. using the Microsoft Excel spreadsheets to update UAC location
information in EARM; and3. generating a report in Microsoft Excel from EARM to manually crosscheck against the UAC Portal.
Without automated transfer capability or electronic tracking of UAC transferred
to HHS, DHS had to employ various mechanisms to manage this process. Both
Border Patrol and ICE personnel relied on spreadsheets as their primarymethod to track UAC awaiting placement with HHS and to share information
with headquarters about children in custody at any given time. To supplement
manual logs, one Border Patrol station also used a basic whiteboard, which
could accidentally be erased. These methods were susceptible to error andwere inadequate to keep pace with the high volume of transfers taking place
during the Zero Tolerance Policy, averaging more than 64 per day.

DHS Did Not Address IT Deficiencies or Provide Guidance andStandard Procedures Prior to Zero Tolerance Implementation
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September 2018 because of Zero Tolerance. However, prior to policy
implementation, DHS did not address deficiencies recognized and documented
in 2017 that could potentially hamper the ability to track separated families.
Border Patrol and ICE guidance to field personnel charged with executing thepolicy was deficient. DHS also did not address several procedural challenges
that would make the family reunification process difficult. Figure 6 showsmajor milestones surrounding the Zero Tolerance period.
Figure 6: Major Zero Tolerance Policy Milestones

Source: OIG-Generated based on data provided by DHS

DHS Did Not Address IT Deficiencies Prior to the Zero Tolerance Policy
On May 4, 2018, the DHS Secretary approved the adoption of the Zero
Tolerance Policy based on the outcome of the 2017 El Paso initiative, which
CBP claimed had reduced family apprehensions by 64 percent.23 However, DHS
did not first confirm whether the various technology-related challenges
documented and reported from the El Paso initiative had been resolved. In
fact, on May 4, 2018, the same day the Secretary signed the memorandum
implementing the Zero Tolerance Policy, Border Patrol instructed field personnel
to use spreadsheets to track separations because e3 system changes were still
pending. One senior CBP official who participated in Zero Tolerance Policy
planning meetings stated that key stakeholders had pressured DHS to

The Zero Tolerance Policy was signed on May 4, 2018, and officially went into effect on May 5,
2018.
23

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implement the policy in early May 2018 before identified deficiencies in e3 wereresolved.24
Federal law and departmental guidance require effective planning to ensure thesuccess of IT development efforts.25 System enhancements to implement new
functionality, such as adding capability to track family separations in e3,
typically take months to develop, test, and deploy. However, DHS implemented
Zero Tolerance 3 months before deploying needed system enhancements inAugust 2018. Specifically, Border Patrol restructured e3 to add new features
for recording the separation and reunification of family members, as well as
tracking UAC time in custody, but the new features were not implemented until
August 2018, nearly 2 months after the Zero Tolerance Policy was terminated.
Figure 7 depicts the new functionality added to e3.
Figure 7: Updates to e3 to Track Separation and Reunificationof Migrant Family Units (FMUA)

Source: Screenshot from CBP documentation

Similarly, ICE did not deploy updates to track family separations until August
2018, almost 2 months after Zero Tolerance ended. ICE updated EARM toallow its data analysts access to Border Patrol separation reasons codes and toenable ICE headquarters to run reports on Border Patrol separations.
The new functionality added to e3 and EARM in August 2018, after Zero
Tolerance ended, provided CBP and ICE personnel with better visibility of
24 A DHS participant provided meeting invitations for the Principals Coordination Committee,

which included representatives of the U.S. Department of Defense, HHS, DHS, U.S.
Department of Justice, OMB, and the Executive Office of the President.
25 National Defense Authorization Act for Fiscal Year 1996, Pub. L. No. 104–106 (1996) Div. E,
Clinger-Cohen Act; and DHS 102-01, Acquisition Management Directive, Revision 3, Instruction
Appendix B, July 28, 2015
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family separations as they occurred.26 The separations were indicated in both
systems through flags that alerted agents and officers that a detainee was partof a separated family. For example, when Border Patrol separated a family unit
in e3, a flag appeared in the shared database, EID. At the same time, thisindicator was transmitted to ICE ERO’s system where it provided a yellow
banner alert in an alien’s file. The banner alerted ICE officers that anindividual in custody was separated from his or her family, as shown infigure 8.
Figure 8: Family Separation Banner in EARM

Source: Screenshot from ICE documentation

While the system flag increased awareness of family separations, it did notprovide any supporting details or give ICE officers the ability to update or
remove the flag if detainees were reunified with family members. For example,
a senior ERO official in the field noted that a detainee previously deported withhis family was apprehended a second time for attempting to illegally re-enter
the country alone. The banner on his case file remained from the previous
family separation. As a result, ICE officers had to conduct additional research
to confirm whether the detainee was currently part of a separated family unit
and thus eligible for reunification through HHS. The senior ERO official was
unaware of how a banner might be removed, or whether that was permitted.
DHS and HHS Did Not Address Data Sharing Challenges
DHS did not begin discussing with HHS its approach for sharing information
on family separations until April 2018 when a working group meeting wasconvened among policy stakeholders from various Federal agencies.27 On April
13, 2018, DHS and HHS signed a Memorandum of Agreement on consultationand information sharing practices between the two departments, including anagreement to share documentation to assist HHS ORR with UAC placement
decisions. However, DHS and HHS staff disagreed on what information, such
CBP may still separate a family if a determination is made that the parent is unfit or presents
a danger to the child.
27
Participants in the April 2018 working group meetings included U.S. Department of Defense,
U.S. Department of Justice, HHS, and the Executive Office of the President.
26

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as criminal history, should be shared on parents of children needing placementwith ORR. DHS and HHS made only limited progress in finding an automatedapproach to sharing separation data after the policy ended. In July 2018, after
Zero Tolerance ended, HHS added more fields to annotate in juvenile referral
requests on its UAC Portal that a child had been separated from his or her
parents. The system change included the addition of a checkbox showing achild separated from a parent as illustrated in figure 9. HHS also added a field
to the juvenile referral request allowing Border Patrol personnel to include theseparated parent’s alien number.
Figure 9: Separation Checkbox Added to UAC Portal

Source: Screenshot from CBP Documentation

Despite these system enhancements, efforts to fully automate data exchange
between DHS and HHS were unsuccessful. In October 2018, Border Patrol IT
staff attempted to work with HHS to implement a direct exchange of separation
data from e3 to the UAC Portal; however, HHS system maintenance prevented
the update. As of February 2019, e3 still did not automatically notify HHS offamily separations, and HHS staff had to select the checkbox manually in its
system based on Border Patrol’s emailed notes. ICE ERO also continued to
input information manually to the UAC Portal and use text fields to add
detailed information. As recently as March 2019, CBP’s Commissioner statedin congressional testimony that CBP IT systems still needed improvements totrack separated children effectively.28
Insufficient Guidance to the Field on Tracking Family Separations
Border Patrol and ICE headquarters did not provide adequate guidance to field
personnel to ensure successful implementation of the Zero Tolerance Policy.
OMB requires that users of Federal IT resources have the skills, knowledge,

28 United States Congress.

Senate Judiciary Committee, Hearing on Oversight of Customs andBorder Protection’s Response to the Smuggling of Persons at the Southern Border, March 6, 2019www.oig.dhs.gov

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and training needed to be effective.29 However, CBP provided guidance toBorder Patrol field personnel after separations had already begun. Specifically,on May 7, 2018, Border Patrol sent a memo and a 14-page presentation to field
personnel instructing them on how to document family separations in Border
Patrol IT systems. The presentation included steps on how to create,
temporarily separate, or delete a family unit in e3. However, no accompanying
system-based training was provided. The guidance also was not consistently
communicated to staff responsible for carrying out these job duties. Some staff
did not receive the guidance until several days after the policy was
implemented. Meanwhile, Border Patrol agents made a number of errors
within the first few days of Zero Tolerance Policy implementation, such asincorrectly entering eight separated children into the system without indicating
they were from a family unit.
Border Patrol headquarters also did not distribute procedural guidance andguidelines for achieving 100-percent prosecutions for all illegal migrants until
the night before Zero Tolerance began. On May 4, 2018, a Border Patrol Chiefat headquarters sent a memo to each sector with estimates on Border Patrol’sability to meet 100-percent prosecutions as the policy intended. The memo
listed which sectors should reach 100-percent prosecutions immediately andwhich ones should slowly ramp up to prosecuting all detainees. The memo
instructed sectors to prioritize referring single adults with criminal histories
over adults in family units. Lastly, the memo required weekly reporting on
detainee prosecution statistics. However, Border Patrol headquarters
personnel admitted they did not consistently track reporting metrics from thesectors, and had no way of validating that sectors adhered to the prioritization
guidelines.
In addition, Border Patrol did not effectively provide sectors with instruction onwhich children should be separated from their parents. On June 4, 2018,
Border Patrol headquarters instructed Southwest Border sectors to stop
separating children 12 years old and younger from their parents because of
ORR capacity issues. However, some sectors continued to separate children
younger than 12 through the end of Zero Tolerance on June 20, 2018.
Following the June 4, 2018 instructions, Border Patrol separated almost 400
additional children 12 years old and younger, 15 of whom were 4 years of age
or younger, risking detaining them longer than allowed in temporary holding
facilities unsuited for children.
Border Patrol headquarters personnel stated that various factors may havehindered dissemination of family separation guidance. For example, Border
Patrol agents did not always have the computer access they needed in the field
29 OMB Circular A-130, Managing Information as a Strategic Resource, Section 5(c)(3), July 28,

2016
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to review headquarters guidance. One Border Patrol Chief at headquarters
stated that it was common for Border Patrol field personnel to hold different job
responsibilities for weeks at a time. As a result, they might not be aware of e3
processing updates because they did not consistently use the system. The
same Border Patrol Chief attributed some of the UAC tracking challenges to alack of a training. This official expressed concern that, despite having 21,000
personnel, Border Patrol lacked a central office at headquarters to provide IT
training to the field.
Like Border Patrol, ICE also did not provide adequate communication toprepare field personnel prior to Zero Tolerance Policy implementation. ICE
personnel had direct responsibility for detaining and removing parents andtracking UAC. Yet many ICE headquarters and field personnel we interviewed
stated they first learned through unofficial channels the policy was in place.
Most ICE personnel stated they received no direct communication prior topolicy implementation, either through ICE’s chain of command or throughformal Department communication. ICE headquarters confirmed it did not
broadcast information on Zero Tolerance Policy implementation to the field
because it believed the policy would only affect CBP operations. One ICE ERO
manager at headquarters said she would have provided prepared messaging on
Zero Tolerance if she had been aware beforehand that the policy would be
implemented.
DHS Lacked Standard Procedures for Reunifications
Prior to Zero Tolerance implementation, the Department did not establish aplan for how CBP, ICE, and HHS would successfully reunify separated family
members. As a result, ICE ERO personnel were not prepared to deal with the
myriad of nuanced circumstances surrounding family separations. For
example, personnel at one field office complained to ICE and CBP headquartersthat they lacked guidance on how to address instances when a parent awaiting
deportation did not want to be reunited with his or her child prior todeportation. Personnel at a different ICE field office were unaware of a policy
on reuniting a parent with a child already placed with a sponsor. Some ICE
personnel put the onus on the parents, stating the plan was for parents torequest reunification with their children prior to deportation. Alternatively, if aparent was released from ICE custody into the United States, the parent was
expected to contact ORR to coordinate reunification independently.
DHS’ process for reunifying migrant families evolved over time. For example,
on June 8, 2018, CBP began distributing informational flyers to detainedparents on how to reunite with their children. However, as the OIG reported inwww.oig.dhs.gov

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September 2018,30 these flyers were not consistently distributed or properly
displayed. Moreover, in mid-June 2018, a week before the Zero Tolerance
Policy ended, the CBP Commissioner instructed field personnel to update theflyer to provide additional information to parents on how to contact separated
family members in ORR custody.
Issues with tracking separated children and reunification procedures prompted
the creation of a joint ICE-HHS working group in early June 2018. The
working group met to share information among ICE juvenile coordinators andHHS ORR personnel responsible for custody and care of UAC. Although
Federal courts ordered family reunifications in late June 2018 for completion inlate July, DHS and HHS did not develop a reunification plan to support efforts
to meet this timeframe. As of March 2019, the working group still did not havea formal reunification plan in place.
This poor family reunification planning mirrored what occurred during the2017 El Paso initiative. In a July 2017 draft memo, El Paso Sector
management acknowledged concerns from local judges that Border Patrol,
ERO, and ORR needed a coordinated reunification plan for rejoining andrepatriating families. However, they never developed a plan and children
separated under the El Paso initiative could have remained separated fromtheir parents for long periods. One HHS official stated he first became aware offamily separations in August 2017 during the El Paso initiative when CBPtransferred an infant to ORR. The infant was not reunited with her mother forat least six months.

DHS Could Not Accurately Account for Separated Families or
Accomplish Reunifications as Mandated
In light of DHS’ IT systems deficiencies, CBP’s official system of record31
contained incomplete data and too many errors to reach a conclusive or
accurate count of all families separated during Zero Tolerance. We tried, but
could not confirm the accuracy of Border Patrol’s reported estimate that 3,014
children were separated during the policy period. We conducted a review of
DHS’ data during the Zero Tolerance period and identified 136 children withpotential family relationships that were not accurately recorded by CBP, which
could result in unrecorded family separations. In a broader analysis of DHS
data between October 1, 2017, and February 14, 2019, we identified an
additional 1,233 children with potential family relationships not accurately
recorded by CBP. DHS also estimated it had completed 2,155 reunifications in
30 Special Review – Initial Observations Regarding Family Separation Issues Under the Zero

Tolerance Policy, OIG-18-84, September 2018
31 A system of record is an information system that is the authoritative source for a particular

data element in a system containing multiple sources of the same element.
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response to Ms. L. v. ICE, although this effort continued for 7 months beyond
the July 2018 deadline for reunifying children with their parents. Without areliable account of all family relationships, we cannot confirm that DHS has
identified all family separations, and therefore, we cannot determine whether
DHS and HHS have reunified these families.
Inability to Accurately Identify Total Number of Children Separated from
Their Families
Border Patrol’s official system of record, e3, contained too many incomplete
records and errors to enable CBP to reach a conclusive or accurate count of all
families separated during Zero Tolerance. From June to July 2018, Border
Patrol conducted detailed reviews of the e3 system data in attempts todetermine the total number of separations that occurred during the Zero
Tolerance period. To separate a family apprehended during the Zero Tolerance
policy, as noted earlier, Border Patrol agents would first create a family unit,
then delete the family unit. When deleting the family unit number, agentsadded a “FMPO” or “FMPC” separation code (as described in table 2) to notate aseparation due to the policy. However, family separations could not always be
identified because agents did not consistently record family units in the system
prior to separation, as discussed earlier in this report.
Without accurate system data to track family separations, DHS and HHS wereforced to attempt manual counts to confirm the familial status of hundreds ofdetainees and children. Starting in June 2018, DHS and HHS established ajoint operation center staffed with DHS and HHS personnel working together toreview data to account for separations. Using this approach, the joint
operations center attempted to compare and reconcile all individuals for whom
Border Patrol had no records as belonging to families. Specifically, Border
Patrol provided to HHS a list of 5,657 adults and children recorded as
separated during Zero Tolerance. HHS analysts then reviewed HHS’ and CBP’s
raw data to identify children in ORR custody who should have been identified
as members of family units, based on adults with consecutive alien numbers,same last names, and same dates of entry to the United States. HHS personnel
told us they also interviewed or reviewed files for all 11,800 children in theircustody at that time to further identify family separations.
After DHS and HHS completed their reviews, Border Patrol estimates ofseparated families increased from 5,657 to 5,855. By July 2018, Border Patrol
had added 291 previously unaccounted for adults and children to its originallist of 5,657 family separations. Of the 291, 225 were identified by HHS
because Border Patrol had not originally recorded these 225 detainees as
members of family units (as discussed previously in this report), so there were
no deleted family unit numbers to track. Border Patrol also identified 93
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detainees on its initial June 2018 separation list who were either incorrectlyclassified as members of family units, or who were never actually separated. In
some instances, HHS recorded family separations based on its own analysis,
but Border Patrol could not confirm the separations due to a lack of
information in the e3 system and case notes.
Border Patrol and HHS Discrepancies
In addition to data errors, we found discrepancies between Border Patrol and
HHS family separation counts. As of July 2018, Border Patrol’s final count of
separated children was 3,014, but the tally in August 2018 from HHS and DHS
combined was 12 percent lower, at 2,654.32 These numbers did not match for
two reasons:
1. Border Patrol’s final count of 3,014 children, as of July 2018, included
an additional 530 children who had been reunified with their families in
CBP facilities and never transferred to HHS.
2. Border Patrol and HHS timeframes for tracking separated children
differed. Specifically, while CBP included all family separations that
occurred during Zero Tolerance (May 5 to June 20, 2018,) HHS looked forany separated child in ORR custody as of June 26, 2018.
To illustrate, we were able to identify an additional 43 children that
Border Patrol separated from before Zero Tolerance (April 19 to May 4,2018) that were not included in Border Patrols’ list provided to HHS. We
were also able to identify an additional 26 children from after Zero
Tolerance (June 20 to August 30, 2018) that were not included in Border
Patrols’ list provided to HHS.33
By looking for any separated child in ORR custody as of June 26, 2018, HHS
identified additional potential separations that occurred before and during Zero
Tolerance. Table 3 depicts the total number of family separations identified by
HHS, but not included in Border Patrol’s final count.

This is the final count of family separations cited in Ms. L. v. ICE, 18-cv-428 (S.D. Cal. August30, 2018).
33
Of the total 69 additional children we found separated, 25 children were included on the Ms.
L. Class list. However, we could not confirm the total number of children included on the Ms.
L. Class list due to missing Alien numbers.
32

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Table 3: HHS Identified Potential Family Separations Not Included
in Border Patrol’s Final Count

Potential Separations Before Zero
Tolerance

July 22, 2013 – May 4,
2018

394

Included in
the Ms. L.
class list
285

Potential Separations During Zero
Tolerance

May 5 – June 20, 2018

302

129

Total

696

414

Potential Separations
Discovered by HHS

Dates ofPotential Separation

Count

Source: OIG-generated from DHS data

The 302 children HHS identified may have been separated by Border Patrol,
OFO, or ICE ERO. CBP confirmed the following points regarding the 302
potential separations:x

A 4-year-old child was a Zero Tolerance separation, but was not
identified by Border Patrol because of a user processing error. The OIG
confirmed the child was included in the Ms. L. class list.

x

A 1-year-old child was traveling with her mother who was younger than
18. Because the mother was a minor herself, CBP does not consider thisa family unit separation. The OIG confirmed this child was ultimately
included in the Ms. L. class list.

x

CBP could not confirm whether a 2-year-old child listed as separated by
HHS was a Zero Tolerance separation because Border Patrol did not
capture enough information in e3. The OIG confirmed this child was
ultimately included in the Ms. L. class list.

x

CBP could not confirm whether a 3-year-old child listed as separated by
HHS was a Zero Tolerance separation because Border Patrol did not
capture enough information in e3. The OIG confirmed this child was notincluded in the Ms. L. class list provided during fieldwork.

OIG Analysis Identified Possible Family Separations Undetected by CBP
Due to the number of errors Border Patrol made in recording family
separations, we determined that there was a high risk that DHS did notaccount for all separated children. To confirm this, the OIG’s Data Analytics
team conducted an independent analysis of DHS’ apprehension data,
disclosing hundreds of possible family relationships that CBP had not recorded
in its systems. As previously discussed, Border Patrol reported that 3,014
children were separated from their families during the Zero Tolerance Policy
period. However, our analysis determined that the number of family
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separations during the policy period may be greater than what DHS reported
because it is difficult to account for a family separation without first recording
a family relationship. Based on our analysis we found a total 1,369 potential
family relationships not recorded by Border Patrol.

During Zero
Tolerance:
May 5 - June20, 2018

To determine whether more than the reported number of
migrant family separations took place during Zero
Tolerance, we conducted a targeted search of DHS
apprehension data, pinpointing all instances from May 5,
2018, to June 20, 2018, when adults and children
apprehended together, had common last names,34 and were
between 16 to 40 years apart (suggesting possible
parent/child relationships). We found 136 children withpotential family relationships that were not recorded byBorder Patrol during this period.

We broadened the timeframes of our analysis, recognizing that someseparations occurred outside of the Zero Tolerance period. The following
children were separated from parents referred for prosecution either prior to
Zero Tolerance Policy implementation or immediately after it ended.
Expanded
Scope:
October 1,
2017 February 14,
2019:

Using the same approach, we searched for potential
separations between October 1, 2017 and February 14,
2019. We found 1,233 minors with potential family
relationships uncounted by DHS, including 584 before Zero
Tolerance, and 649 after Zero Tolerance — in addition to
the 136 minors discovered during Zero Tolerance, whom
Border Patrol apprehended, potentially with their family
members, but who were not included in DHS’ reported
numbers of family units or groups.35 Despite these
indicators in the data, we found no record in DHS’ systemthat these 1,233 minors were part of family units or groups.

Table 4 reflects the total number of potential family relationships not recordedby CBP before, during, and after Zero Tolerance Policy.

34 Of the 3,014 children Border Patrol identified as separated, 99.7 percent were from Latin

American countries. Therefore, the audit team used traditional Latin American naming
conventions to determine “common last names” among apprehensions, which consists ofmother’s maiden name-father’s surname.
35 Without reviewing the official narrative for each of these cases, this data could include false
positives or relatives who do not meet the DHS definition of a family unit, which is limited to an
adult over 18 who is the legal guardian or parent of a child under 18.
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Table 4: OIG Identified Potential Family Relationships Not Recorded
Before, During, and After the Zero Tolerance Policy
Description of OIG Finding
Potential Family Relationships Not Recorded
by Border Patrol Before Zero Tolerance

Dates ofPotential Separation
Oct. 1, 2017 – May 4, 2018

Count
584

Potential Family Relationships Not Recorded
by Border Patrol During Zero Tolerance

May 5 – June 20, 2018

136

Potential Family Relationships Not Recorded
by Border Patrol After Zero Tolerance

June 21, 2018 – Feb. 14, 2019

649

Total

1,369

Source: OIG-generated from DHS data

Methodology for OIG Analysis of Possible Family Relationships
We sent three samples of names to Border Patrol to conduct further analysis:x

In April 2019, we provided a sample list of 25 children found using thismethodology; however, we did not receive a response from CBP.

x

After the issuance of the draft report for this audit, we provided a new setof 34 children identified using this methodology. In response, CBP
confirmed that from this sample, DHS had in fact separated two children
not included on Border Patrol’s list of Zero Tolerance separations. CBP
also confirmed that the remaining 32 children were not separated fromboth parents. In many of these cases, the children remained with theirmother while separated from their father. Because CBP does notconsider a child who remains with one parent a family separation, andbecause these children were recorded as being in a family unit with atleast one parent, we refined our methodology to only include children
with no family relationship recorded at all. Based on the results of thisanalysis, we changed our methodology to eliminate instances where achild was put into a family unit with one parent, while potentially being
separated from the other parent or another family member.

x

Using this refined methodology, we sent a second sample of 39 children
to CBP for review. In response, CBP confirmed that from this sample of39, DHS had separated five children not included in Border Patrol’s listof Zero Tolerance separations. One of these five separations included achild separated immediately after Zero Tolerance ended, who had no casenotes to indicate a family separation. Working with a CBP analyst, we

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identified another five cases from the sample of 39 that were incorrectly
processed. In each of the five cases, a child was not properly recorded as
being part of a family unit or group. In these cases, the child stayed withfamily or siblings and was removed from the country. In the remaining
29 cases, we could not confirm whether the child was traveling with afamily member, or whether the family simply did not alert Border Patrol
agents that they were traveling together. In some cases, a family may
not alert CBP personnel of a family relationship.36 This methodology isreflected in Table 4.
We are concerned that if DHS did not properly record all family information in
its IT systems, it may have underestimated and may not be able to determine
accurately the number of family separations that occurred from October 2017
to February 2019. OIG’s ability to identify almost 1,400 instances of potential
family relationships not properly recorded or accounted for by DHS indicatesthat the Department may not have properly analyzed its own e3 data from the
Zero Tolerance Policy period. For example, DHS may have missed separations if
it only reviewed records identified as deleted family units, rather than reviewing
all apprehensions to identify individuals not properly recorded as family units,
or individuals misclassified as family groups. As discussed previously in thereport, such errors were common. In a follow-up meeting post-fieldwork, aBorder Patrol Chief stated that Border Patrol was already reviewing thousandsof additional potential separations provided by HHS due to the expansion of the
Ms. L. case. The Chief stated that Border Patrol was using a process similar to
OIG’s methodology to find potential separations, then reviewing case notes toconfirm these separations.
In addition to our analysis of Border Patrol data, DHS OIG also reviewed OFO’s
family separation data. OFO reported 74 family separations for all of FY 2018.
However, our review of its data from October 2017 to February 2019 revealed
additional potential unrecorded family relationships. Similar to our analysis of
the Border Patrol data, we matched minors against adults applying for asylum,
or who crossed a port of entry without legal documents on the same date, withshared last names and an age difference between 16 and 40 years. Our review
disclosed possible cases of minors who had the same last names andapprehension dates as accompanying adults, but who were not listed by OFO
as family units.37 It should be noted that OFO does not record family groups;
36 Cases of parental omission are not errors introduced by CBP.

The potential OFO cases include individuals applying for asylum or those who did not havedocuments when entering the United States through a legal port of entry. These potential
cases did not include individuals who entered legal ports of entry under other categories suchas those who were United States citizens, legal permanent residents, or who had a bordercrossing card. The OIG may conduct follow-up work to determine the nature of OFO’s
potential underreporting.

37

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so, many of these potential family relations not recorded in SIGMA may beminors traveling with extended family members.
DHS Did Not Meet Court-Mandated Reunification Deadlines
DHS did not fulfill a June 26, 2018 court order to identify and reunify all
children in ORR custody by July 26, 2018. In response to the court order,
HHS immediately began a concerted data-sharing effort with DHS to reunite
children younger than age 5 with their families within 14 days, and children 5
years old and older within 30 days as specified.38 However, hundreds ofchildren could not be successfully reunified with their families by the deadline.
More than 300 children remained separated as late as August 2018, 1 monthafter the court-mandated deadline, because their parents were no longer in the
United States. Of the more than 300 separated children, 6 were younger thanage 5. Additionally, DHS and HHS could not reunify 17 children because theirparents were in Federal, state, or local custody. Table 5 provides data on
family reunification efforts as of August 30, 2018.
Table 5: Status of Reunification Efforts, as reported by DHS and HHS as ofAugust 30, 2018
5 Years orYounger
103

5 to 17
Years Old
2,551

2,654

Children Reunified with a Parent

61

1,876

1,937

Children Released to Sponsor or Turned 18

20

200

220

Children Not Reunified Because Parent Is No Longer
in the United States.

6

316

322

Children Not Reunified Because Parent Is In Other
Federal, State, or Local Custody

2

15

17

Description
Total Number of Children Possibly Separated from
Parents

Total

Source: OIG-generated from Ms. L. v. ICE court filings

As of February 2019, DHS and HHS attested that 2,155 children were reunified
with a parent and 580 children were discharged from ORR care underappropriate circumstances in response to Ms. L. v. ICE.39 Five children were
not reunified and remained in ORR care; four related parents were no longer in
the United States and one was incarcerated. However, we cannot confirm that

38 Ms. L. v. ICE, 18-cv-428 (S.D.

Cal. June 26, 2018)39 According to the public reporting as part of Ms. L. v.

ICE court filings, February 20, 2019.
Other appropriate circumstances include discharges to other sponsors (such as in situations
where the child’s separated parent is not eligible for reunification) or children who turned 18.
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separated children for whom CBP did not properly record a family relationshipwere reunified with a parent.40
DHS’ efforts to reconcile detainee records with UAC in HHS custody werelargely a manual process. To meet the court-ordered reunification mandates,
DHS and HHS established a joint operations center at HHS headquarters. The
center was staffed with representatives from both agencies, tasked with
conducting manual crosschecks of DHS and HHS data to confirm the total
number of separated family members. The joint effort required intensive
analysis and manual review of data housed in the e3 system and multiple
Microsoft Excel spreadsheets. HHS estimated that this effort entailed 800
hours of analysis and manual review by HHS, Border Patrol, and ICE
personnel, as well as contractors, all working together.
The process to reunify children with their families was disjointed, as DHS andHHS transferred children and parents all over the country to different facilities
in different cities and states. Specifically, for children age 4 and younger, ICE
transferred parents to meet their children in those dispersed locations.
Children 5 years and older who had parents in ICE custody travelled to one ofseveral ICE detention centers along the Southwest Border for reunification.
DHS identified several ICE detention centers where reunifications would takeplace for children ages 5 to 17. HHS personnel brought separated children to
the adult detention centers where ICE would process and reunify children with
their parents.
More concerning, reunifications were coordinated entirely by email instead ofusing a system of record to share sensitive information on actions taken. To
illustrate, HHS sent ICE field officers children’s biographical data, such as
child’s name and date of birth, which constituted personally identifiable
information, and also sent alien numbers, which constituted sensitive
personally identifiable information, through unsecured means.41 An ICE field
office director in Texas said the emails came as often as every 5 minutes andother ICE officers said that children arrived at the detention centers at all
hours of the day and night. Multiple ICE personnel supporting reunifications
described the process as chaotic. Once children arrived at detention centers,
ICE personnel had to reprocess the families for release. We visited two ICE
detention centers, and found that both used ICE systems (e.g., EARM) as well
40 The scope of this audit did not include validating information submitted by DHS as part of

the Ms. L. v ICE litigation. For more information on scope, see Appendix A.
DHS Handbook for Safeguarding Sensitive PII, Privacy Policy Directive 047-01-007, Rev. 3(Dec. 4, 2017): “Sensitive PII (SPII) is Personally Identifiable Information, which if lost,
compromised, or disclosed without authorization could result in substantial harm,
embarrassment, inconvenience, or unfairness to an individual.” Id. at 5.

41

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as Microsoft Excel spreadsheets to record the family reunifications that
occurred. This entailed reclassifying UAC and single adults as family units andthen producing notices for them to appear in court for immigration hearings.
One detention center supervisor said it could take ICE officers hours to
reprocess a single family because case information on the migrants was notalways readily available or was often in various formats (i.e., email,spreadsheets, hardcopy, or system data).
ICE was sometimes unable to transfer parents in time to meet arriving children
because ICE did not always receive adequate notice from HHS that children
were arriving. On at least one occasion, after receiving no corresponding email
notification, ICE personnel were surprised when a child arrived at a detention
center. In some cases, children had to wait hours or even stay overnight at
hotels, before their parents arrived at detention centers for reunification. One
ICE detention center supervisor said there was limited on-site space forchildren, and this space was packed with children waiting for their parents toarrive and for ICE to process their reunifications.
Parents Receiving Minimal or No Jail-time Were Denied Immediate
Reunification
During the Zero Tolerance period, many adults were only sentenced to time
served and quickly returned to CBP custody or were not referred forprosecution at all. Approximately 82 percent of all parents separated fromchildren during Zero Tolerance received minimal or no jail time. This includes
more than 15 percent of all adults separated from children during Zero
Tolerance who were not referred for prosecution. These circumstances led tomany adults returning from court to Border Patrol custody. Because adults in
CBP custody are normally referred for prosecution within 48 hours, adults
could have court hearings, be sentenced, and return to CBP facilities before
their children were transferred to ORR. Despite Border Patrol’s awareness ofincreasing numbers of parents receiving time-served sentences, separations
continued.
In light of these circumstances, CBP sought to reunify families at their own
facilities instead of transferring the children to HHS. During the Zero
Tolerance period, Border Patrol agents reportedly reunified 530 children (of2,458 total children whose parents received minimal or no jail-time) with theirparents at CBP facilities.
Border Patrol was unable to reunify 1,928 children and their parents ininstances when the parents received little or no jail time. This occurredbecause Border Patrol, as required, had already transferred the children to
ORR custody before CBP returned their parents from court. In these cases,
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migrant parents became responsible for contacting ORR to locate their children
and initiate the reunification process if they were released from DHS custody.
When parents remained in detention after their court hearings, the children
stayed in ORR custody, including placement at more than 150 locations acrossthe Nation, which made ultimate reunification much more difficult and costly.

DHS Did Not Achieve Zero Tolerance Goals Amid Ineffective IT
Tracking and Management of Separated Families
DHS spent thousands of hours and well in excess of $1 million in overtime
costs supporting Zero Tolerance. However, the policy did not achieve its
intended goal of deterring the practice of “Catch-and-Release.” Instead, thenumber of apprehensions continued to rise, and ICE was releasing thousandsof detainees into the United States almost immediately. During our site visits,
Border Patrol facilities had nearly reached full capacity, resulting in overly
crowded conditions. The increase in apprehended families also resulted inchildren being held in CBP facilities beyond the 72-hour legal limit. As aresult, CBP’s limited staff resources and facilities were strained as agents caredfor UAC rather than patrolling the border.
Reunification Efforts Strained DHS and HHS Resources While “Catch-andRelease” Continued
DHS and HHS expended significant financial and staff resources to keep pacewith the additional work required for execution of the Zero Tolerance Policy.
Border Patrol reportedly spent more than 28,000 hours and $1.2 million in
overtime to support Zero Tolerance-related activities. ICE personnel at eachdetention center we visited said they worked day and night to coordinatetransportation and detention of apprehended migrants. Some agents slept onsite for days to support reunification efforts. Additionally, a senior ICE officer
who supported the DHS and HHS joint operations center stated he worked 7days a week supporting efforts to identify separations and reunify families.
However, the number of apprehensions of family units continued to risethroughout the Zero Tolerance period. Border Patrol apprehended nearly 400
additional families along the Southwest Border during the 2 months Zero
Tolerance was in place, during May and June 2018, as compared with the 2months prior to the policy’s implementation, from March to April 2018.
The increasing number of apprehensions resulted in ICE’s release of thousandsof detainees into the United States almost immediately. This continued
throughout Zero Tolerance, even though the policy was intended to end thepractice of “Catch-and-Release.” According to CBP data, from May 5, to June20, 2018, DHS released more than 5,500 detainees from the Rio Grande Valley
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Sector Border Patrol Headquarters to the McAllen, Texas public bus station
alone, including almost 3,000 children. Further, during a November 2018 visit
to the Rio Grande Valley Sector, we witnessed ICE agents transferring busloads
of detainees from CBP facilities to the McAllen, Texas public bus station.
Figure 10 shows detainees lined up at a CBP facility.

Figure 10: Detainees at the Paso Del Norte Processing Center in El Paso, TX
Source: DHS OIG photographIn part, because of the increased apprehensions, Border Patrol facilities
reached or exceeded full capacity, resulting in overly crowded conditions, as we
observed during our site visits. For example, Border Patrol’s Central
Processing Center in McAllen, Texas, designed to hold 1,500 people, was 80
percent full during our visit in November 2018. This location is the largest
immigration-processing center in the country. Figure 11 shows living
conditions for children in the McAllen facility. During our December 2018 visit
to the Clint Border Patrol Station in Border Patrol’s El Paso Sector, agents
showed a sally port42 converted into a holding area for male adults andteenagers to alleviate crowded conditions. OIG reported on similar conditionsin May and June 2019, disclosing serious overcrowding and prolonged
detention of both adults and UAC.43 OIG reported that overcrowding and
42 A sally port is a secure entryway for a detention facility.

43 Management Alert – DHS Needs to Address Dangerous Overcrowding Among Single Adults at

El Paso Del Norte Processing Center (OIG-19-46), May 2019; and Management Alert – DHS
Needs to Address Dangerous Overcrowding and Prolonged Detention of Children and Adults in
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prolonged detention represent an immediate risk to the health and safety of
DHS agents and officers, as well as to those detained.

Figure 11: Living Conditions for Children Detained in McAllen, TX
Source: DHS OIG photograph

The increase in apprehended families also resulted in children remaining in
CBP facilities beyond the 72-hour legal limit. By May 10, 2018, only five days
after Zero Tolerance implementation, ORR reached 87 percent occupancy. As
placement space within ORR’s facilities decreased, CBP maintained custody ofchildren for longer periods. On May 29, 2018, CBP’s average custody period
for children separated from parents exceeded the 72-hour threshold for the
first time during Zero Tolerance, and exceeded the limit for 8 of the next 10days through June 7, 2018. We reviewed records for 212,935 minors from
October 1, 2017, to February 14, 2019, and determined that prior to Zero
Tolerance, approximately 16 percent of children were held in custody longer
than 72 hours. In contrast, during Zero Tolerance, we found 39 percent of
separated children were held beyond 72 hours, including 192 children who
remained in CBP facilities for more than 6 days — twice the time limit allowed.
CBP held six children in custody during Zero Tolerance for 10 days or more.

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The increase in illegal crossings also strained CBP’s ability to guard the border.
Border Patrol personnel informed us that they diverted agents from guarding
the border in order to care for the rapidly increasing number of children within
their facilities. Border Patrol personnel said they had to use funds budgeted
for other mission areas to provide food and supplies for children and families
awaiting placement. CBP personnel expressed concerns regarding the time lostin carrying out their core border patrol duties because of these increased
responsibilities.
Conclusion
The Zero Tolerance Policy was in place for only 6 weeks. Although intended toreduce the practice of “Catch-and-Release,” the policy had the unexpectedconsequences of overburdening CBP and ICE resources, and over-taxing
facilities for detaining migrants at the Southwest Border. These conditions
were exacerbated by thousands of children separated from their parents and
DHS’ inability to reunify families as mandated due to poor data entry, data
tracking, information sharing, and IT systems capabilities. According to CBP,
these deficiencies alone cost Border Patrol 28,000 hours and an additional $1.2
million in staff overtime. While the Department made some improvements to
its IT systems following the policy implementation, Border Patrol, ICE, andHHS continue to use manual processes to share information about separated
children. The Department must take immediate steps to improve planning,
automation, and record keeping to minimize potentially adverse effects on
migrant detainees and their children, Border Patrol and ICE law enforcement
operations, and associated operating costs.

Recommendations
Recommendation 1: We recommend the Chief, United States Border Patrol,
institute process improvements and related training needed to improve field
personnel abilities to track separated migrant family members.
Recommendation 2: We recommend the Assistant Commissioner, CBP Officeof Information and Technology, implement necessary modifications andcontrols within the ENFORCE 3 system to limit user error and improve data
quality.
Recommendation 3: We recommend the Executive Associate Director, ICE
Enforcement and Removal Operations, coordinate with the Department of
Health and Human Services to outline roles and responsibilities, and createand distribute standard operating procedures for migrant family reunification.

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Recommendation 4: We recommend the DHS Chief Information Officer workwith ICE and CBP to ensure system interoperability to improve crosscomponent information sharing and coordination on border security
operations.
Recommendation 5: We recommend the Deputy Under Secretary forManagement coordinate with Health and Human Services to standardize
processes for collecting and sharing detainee tracking information andcommunicating those requirements to field personnel.
OIG Analysis of DHS Comments
We obtained written comments on a draft of this report from the Director of the
DHS GAO-OIG Liaison Office. The Department concurred with all five of ourrecommendations. We have included a copy of the comments in their entirety
in appendix B. Following is our evaluation and response to the comments the
Department provided in response to the draft report.
OIG Response to General Comments:
We appreciate the Department’s positive comments regarding our draft report.
The Department was pleased to note our acknowledgement that during FY
2018, DHS experienced a 35 percent increase over FY 2017 in the number offamilies and children apprehended after illegally entering at the Southwest
Border, as well as the capacity challenges this created for DHS and HHS. The
Department also noted that OIG acknowledged that CBP and ICE had madeupdates to their IT systems to facilitate tracking and reunification of separated
parents and children during FY 2018, and that the modifications had helped
improve data quality and enhance user visibility of a subject’s status. The
Department emphasized that the CBP Office of Information and Technology
continues to update the e3 system with enhancements to better support CBP
Border Patrol in processing, tracking, and managing events and subjects more
efficiently and effectively.
However, the Director also expressed concerns regarding OIG’s reported
analysis of DHS data systems and our work to confirm the number of children
DHS separated. Notably, the Director stated, “The inaccurate numbers ofpotential separations the OIG identified will create confusion and requiresignificant effort from across the Department to explain these inaccuracies andcompliance with Departmental policies and court orders resulting in asignificant burden on the agency.” Following are our responses to the specificconcerns the Director outlined.

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The Director stated that, “Despite the extensive written technicalcomments provided to the OIG and many follow-up meetings andconversations held between subject matter experts and the OIG, the draft
report included inflated numbers that will lead to misunderstandings
and misconceptions.” We disagree with this statement. As is our normal
process, OIG and the Department held a formal Exit Conference todiscuss findings and provide DHS personnel opportunity to commentand ask questions. We also held an additional meeting with personnel
from ICE’s Office of the Principal Legal Advisor to discuss their concerns
regarding the inclusion of OIG’s potential missed family relationship datain the draft report, along with our methodology that yielded thosenumbers. During this meeting, ICE personnel agreed that they were notdata experts and had struggled with data issues during the period of theZero Tolerance Policy. OIG offered to hold an additional meeting with ICE
data experts to discuss the methodology used, but ICE personnel nevercontacted the audit team to schedule the meeting.

x

The Director stated that in compliance with the Ms. L. v. ICE preliminary
injunction, HHS and DHS undertook a significant effort to identify
children in HHS ORR care who had been separated from parents and toreunify them. While we agree that DHS and HHS conducted significant
review effort, as noted in our report, this review did not include a search
for all potentially separated children. Specifically, Border Patrol only
searched for children separated during Zero Tolerance whose caserecords contained deleted family units. Border Patrol’s search excluded(1) children who were not recorded as part of a family unit, and (2)children separated before Zero Tolerance. Further, Border Patrol datacontained errors and, as a result, not all separated children were
properly recorded as being part of a family unit. These data errors
resulted in Border Patrol’s missing hundreds of detainees whom DHS
separated during Zero Tolerance. HHS later identified these separated
detainees and alerted DHS. However, HHS’ search for separated children
also was limited to include only minors who remained in ORR care as ofJune 26, 2018. Children separated from a parent, but who had beenreleased from ORR care prior to that date, were not included in theoriginal Ms. L. class list.
It should be understood that we did not attempt to verify the separations
accounted for in the Ms. L. case. Rather, we attempted to identify family
relationships that Border Patrol did not record during the intake process.
Failure to record a family relationship during initial intake increases thedifficulty in identifying family separations.

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The Director stated that the DHS, HHS, and Department of Justicenumbers had undergone rigorous double and triple checking by relevant
agencies. The Director also stated, “these agencies are still engaged in
rigorous line-by-line vetting of lists that encompass the additional
members of the expanded class as ordered by the Ms. L. court on March
8, 2019.” Despite the Director’s assertion that our report inaccurately
characterizes the level of certainty with which DHS and HHS identified
separated parents and children, the Director also concedes this is asignificant effort, which remains ongoing 15 months after Zero Tolerance
ended. Because this effort is ongoing, we question how DHS can assert
our numbers are not correct, when in fact, DHS and HHS are stillworking to validate the number of family separations that have occurredsince July 2017.

x

The Director also expressed concern that the OIG’s data analysis did notinclude the information from the full range of sources and methods usedby DHS, HHS, and the Department of Justice to identify and verify the
numbers of separated children. However, the Director does notaccurately describe the methodology used by OIG. OIG analysts
reviewed DHS’ apprehension data and identified potentially missed family
relationship data by linking adults and children whom Border Patrol
apprehended together, who shared common last names based on Latin
American naming conventions, were between 16 and 40 years apart, andwere not associated with a family unit or group in the system. In April
2019, we conducted a teleconference with a Border Patrol Chief todiscuss our methodology and obtain feedback on our data analysis
approach. Following this teleconference, we provided a sample list of 25
children found using our methodology. However, we did not receive a
response from CBP. We made a second inquiry the following week, but
did not receive a response before the draft report was provided to the
Department.
We acknowledge that not all adults and children we identified using thismethodology are separated families. Furthermore, our report does not
explicitly state, or imply, that these are families. Rather, we state thatthe data suggest potential family relationships exist that were notrecorded by Border Patrol. We also acknowledge that this data could
include false positives or relatives who do not meet the DHS definition ofa family unit, which is limited to an adult over 18 who is the legal
guardian or parent of a child under 18.

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Updates to OIG’s Data Analysis
Although we disagreed with the concerns that the Director raised, as justoutlined, we nonetheless took steps to reexamine our data methodology andmake revisions where appropriate. Specifically, in an abundance of caution to
avoid confusion and confirm our data analysis, we changed the language in ourreport from “potentially separated minors” to instances of “potential family
relationships that were not accurately recorded by CBP,” which could result in
unrecorded family separations.
Additionally, subsequent to issuing our draft report to Border Patrol for review
and comment, we provided the following two updated samples to address DHS’
concerns.
x

The first sample was a new set of names identified using our original
data methodology. This sample included a list of 34 children. In
response, CBP confirmed that from this sample, DHS had in fact
separated two children not included on Border Patrol’s list of Zero
Tolerance separations. CBP also confirmed that the remaining 32
children were not separated from both parents; in many of these cases,
the children remained with their mother while separated from theirfather. Because CBP does not consider a child who remains with one
parent a family separation, and because these children were recorded as
being in a family unit with at least one parent, we refined our
methodology to only include children with no family relationshiprecorded at all. Based on the results of this analysis, we changed our
methodology to eliminate instances where a child was put into a family
unit with one parent, while potentially being separated from the otherparent or another family member.

x

Using this refined methodology, we sent a second sample of 39 children
to CBP for review. In response, CBP confirmed that from this sample of39, DHS had separated five children not included in Border Patrol’s listof Zero Tolerance separations. One of these five separations included achild separated immediately after Zero Tolerance ended, who had no casenotes to indicate a family separation. Working with a CBP analyst, we
identified another 5 cases from the sample of 39 that were incorrectly
processed; in each of the 5 cases a child was not properly recorded as
being part of a family unit or group. In these cases, the child stayed withfamily or siblings and was removed from the country. In the remaining
29 cases, we could not confirm whether the child was traveling with afamily member, or whether the family simply did not alert Border Patrol
agents that they were traveling together. Based on this finding, we added
language to the report to clarify that, in some cases, a family may not

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alert CBP personnel of a family relationship. These cases of parental
omission are not errors introduced by CBP.
We use the refined methodology just described in our final report. This refined
methodology has resulted in our reducing the number of children potentiallytraveling with a family member, but not recorded as part of a family unit orgroup in CBP’s systems. We provided DHS with these updated numbers.
Response to Report Recommendations:
In the formal written comments, DHS concurred with all five recommendations.
Recommendation 1: We recommend the Chief, United States Border
Patrol, institute process improvements and related training needed to
improve field personnel abilities to track separated migrant family
members.
Management Comments
DHS concurred and stated that, in April 2019, Border Patrol provided an
updated PowerPoint to the field to assist agents in improving their method for
tracking family separations. In addition, Border Patrol began a family
separation working group comprising multiple levels of Border Patrol
employees from the field. The sole function of the working group is to review
every family separation and ensure all are within CBP’s establishedparameters. Border Patrol also instructed the field to ensure two levels ofsupervisors review every separation on a case-by-case basis. DHS further
noted that Border Patrol had no problems reuniting families in CBP custody
after receiving the Executive Order to do so.
OIG Analysis
We acknowledge the Department’s efforts to improve training on tracking
separated family members. The updated PowerPoint helps meet the intent of
this recommendation; however, we received no documentation on the
Department distributing the PowerPoint to the field, or on its instruction to
field personnel to ensure two-step level supervisory review for all separations.
We also recognize Border Patrol’s establishment of a working group as apositive step toward implementing process improvements for tracking
separated migrant family members; however, we still require documentation inthis regard. We consider this recommendation resolved and open.
Recommendation 2: We recommend the Assistant Commissioner, CBP
Office of Information and Technology, implement necessary modifications
and controls within the ENFORCE 3 system to limit user error andimprove data quality.
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Management Comments
The Department concurred and stated CBP’s Office of Information Technology
collaborated with Border Patrol to identify enhancements via additional edit
check controls within the e3 system, to further limit user error and improvedata quality. The Office of Information Technology is in the process ofmodifying e3 to include additional data entry checks to further enhance theidentity and accuracy of family associations. CBP expects to complete these
efforts by February 28, 2020.
OIG Analysis
We appreciate CBP’s efforts to limit user error and improve CBP’s data quality
by working with Border Patrol personnel and adding additional data entry
checks in the e3 system. We consider these actions positive steps toward
addressing this recommendation. We suggest conducting similar work with
Office of Field Operations personnel to determine whether similar controls areneeded in their SIGMA system. We look forward to receiving status updates,
along with documentary evidence, as these controls are implemented. This
recommendation is open and resolved.
Recommendation 3: We recommend the Executive Associate Director, ICE
Enforcement and Removal Operations, coordinate with the Department of
Health and Human Services to outline roles and responsibilities, andcreate and distribute standard operating procedures for migrant family
reunification.
Management Comments
The Department concurred and stated ICE Enforcement and Removal
Operations (ERO) will work with the DHS Office of Civil Rights and Civil
Liberties, CBP, and HHS to better document the family separation andreunification roles and responsibilities of each agency. It is important to notethat this work will ultimately be dependent on how the legal landscape isdefined based on the outcome of Ms. L. v. ICE and other litigation related tofamily separations. In the meantime, ERO will continue to seek to improve
communication and coordination with HHS on migrant family reunification
procedures. The Department did not have a date for when thisrecommendation would be completed.
OIG Analysis
We recognize that reunification roles and responsibilities might change basedon the outcome of Ms. L. v. ICE, and support ICE’s plan to continue to work toboth better document family separation and reunification roles andresponsibilities and seek to improve communication and coordination with
HHS on procedures for family reunification. We look forward to receiving
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updates, along with documentary evidence, as these plans are completed andimplemented. This recommendation is open, but unresolved until the
Department provides an estimated date for its completion.
Recommendation 4: We recommend the DHS Chief Information Officer
work with ICE and CBP to ensure system interoperability to improve crosscomponent information sharing and coordination on border security
operations.
Management Comments
The Department concurred and stated the DHS Management Directorate,
through its Office of the Chief Information Officer, will support both ICE and
CBP in their efforts regarding governance of data interoperability andinformation exchanges. Specifically, the DHS Chief Data Officer will work with
the Data Governance sections of ICE and CBP to strengthen the Master
Reference Data Management processes between the two components. The
Department plans to complete these efforts by July 31, 2020.
OIG Analysis
We appreciate the Office of the Chief Information Officer’s efforts to work withICE and CBP to improve integration of their governance of data interoperability
and information exchanges. This is a positive step toward addressing thisrecommendation. We look forward to receiving future status updates, alongwith documentary evidence, as these efforts are completed. This
recommendation is open and resolved.
Recommendation 5: We recommend the Deputy Under Secretary forManagement coordinate with Health and Human Services to standardize
processes for collecting and sharing detainee tracking information andcommunicating those requirements to field personnel.
Management Comments
The Department concurred with the recommendation. In accordance with
DHS’ practice of addressing issues at the lowest organizational level possible,
the DHS Deputy Under Secretary for Management will monitor and facilitate
work by CBP and others across the Department to ensure that a standard
process for collecting and sharing detainee tracking information is developed
and adopted by field personnel, and coordinated with HHS, as appropriate.
The Director noted several steps already taken by CBP to improve
communication with HHS. These steps include changes in both Border Patrol
and OFO systems to provide additional information, improve data andcommunication, and establish a Memorandum of Agreement related to transfer
packets for ensuring better placement of children.

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The Director also highlighted how DHS and HHS currently work together tofacilitate reunification of separated families. The Director stated that as
separation cases are identified, the information is shared between appropriate
DHS and HHS personnel to promote an interagency effort for reunification.
Both ICE and HHS ensure that separation data are disseminated to field
personnel for further processing and coordination. The Director stated that
there are also plans in place for ICE’s Juvenile and Family Residential
Management Unit and the Statistical Tracking Unit to work with the DHS
Management Directorate and HHS’ ORR staff to improve the current practices.
Finally, the Department discussed CBP Office of Information and Technology’s
work to develop a Unified Immigration Portal to serve as an integrated solution
for ensuring visibility of complete and real-time information across immigration
agencies. CBP is working with ICE, U.S. Citizenship and Immigration Services,and ORR on this cross-agency portal. The Department estimates finishing its
work on this recommendation by September 30, 2020.
OIG Analysis
We recognize the Department’s efforts to coordinate with HHS to improve theprocess of sharing detainee information between the two agencies. We lookforward to learning more and receiving documented evidence on DHS’ efforts tostandardize processes for increased information sharing with HHS, including
the development of the Unified Immigration Portal. This recommendation is
open and resolved.

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Appendix A
Objective, Scope, and Methodology
The DHS OIG was established by the Homeland Security Act of 2002 (Public
Law 107−296) by amendment to the Inspector General Act of 1978. This is oneof a series of audit, inspection, and special reports prepared as part of ouroversight responsibilities to promote economy, efficiency, and effectivenesswithin the Department.
We conducted this audit to assess the effectiveness of DHS systems to track
detainees and support efforts to reunify unaccompanied alien children
separated from their families. As part of this audit, we also examined how
tracking and managing separated families impacted DHS’ ability to accomplish
goals of the Zero Tolerance Policy. As background for our audit, we researched
and reviewed federal laws, executive orders, agency guidelines, policies, andprocedures related to detainee tracking and the Zero Tolerance Policy. We
obtained documents, congressional testimony, raw data, and media articles
regarding the policy. Additionally, we reviewed published GAO and DHS OIG
reports to identify prior findings and recommendations. We used thisinformation to establish a data collection approach that consisted of interviews
with relevant stakeholders, focused information gathering, documentation
analysis, and targeted site visits to accomplish our audit objectives.
We obtained more than 250 documents, held more than 40 meetings,
participated in teleconferences with CBP and ICE staff at headquarters and in
the field, received demonstrations of multiple IT systems, and met with DHS
and HHS officials to assess detainee tracking and efforts to reunify UAC with
their families. At ICE headquarters, we interviewed representatives of ICE’s
Office of Enforcement and Removal Operations, Office of the Principal Legal
Advisor, and Office of the Chief Information Officer. Within ICE, we met withpersonnel from the Juvenile and Family Residential Management Unit. We
interviewed representatives from CBP’s Border Patrol, Office of Field
Operations, and Office of Information and Technology. Finally, we interviewed
personnel from HHS’ Office of Refugee Resettlement.
In November 2018, we visited OFO’s Port of Entry in Hidalgo, Texas, to observe
detainee processing and IT systems used for data intake, migrant tracking, andtransfer of detainees. We visited locations within CBP’s Rio Grande Valley
Sector, including the McAllen Central Processing Center, to observe CBP’ssystem and processes to record and track data about detainees, UAC transfer
to ICE and HHS, and information sharing between OFO, Border Patrol, andICE. In December, we visited Border Patrol and ICE facilities in El Paso, Clint,
and Tornillo, Texas. During site visits, we observed processing procedures inIT systems and the transfer of detainees. We also observed ICE’s ability to use
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its IT systems for tracking detainees reunifying UAC with their families. We did
not compile or review classified documents to conduct this audit.
We used the work of specialists from the OIG-wide Analytics and Support andData Audits and Infrastructure Divisions to acquire and analyze CBP data from
October 2017 through February 2019, to identify instances of potential family
relationships not accurately recorded by CBP in their IT systems during thistimeframe, including Zero Tolerance. We also reviewed separation data frombefore and after Zero Tolerance to identify trends. We obtained complete tablesfrom the production Enforcement Integrated Database (EID) and complete
backup file copies of the Border Patrol Enforcement Tracking System (BPETS)
and EID-Snapshot (EID-SNAP) operational data stores, which maintain copiesof tables from production EID, as well as derived tables produced by CBP and
ICE. We assessed the reliability of data by (1) interviewing agency officials
knowledgeable about the data, (2) reviewing existing information about thedata and the systems that produced them, and (3) performing electronic testingof data used for our analysis. For example, we received demonstrations of how
system users record data in McAllen, Texas, and El Paso, Texas, andinterviewed knowledgeable DHS officials in DC. We reviewed a Privacy Impact
Assessment for EID that describes functionality and the data contained in thesystem, as well as system documentation obtained from DHS to understandthe primary keys and unique identifiers in the system. We confirmed that the
totals of DHS-provided table extracts matched the number of records in ourcopies of operational data stores containing tables from EID. We performed
tests on key data elements to ensure there were no duplicate records or
unexpected values. We also traced a random sample of apprehension records
to underlying case notes to confirm existence. We determined that the data
were sufficiently reliable for the purposes of this report.
Lastly, we reviewed internal controls that pertain to the effectiveness of DHS’ IT
systems in supporting detainee tracking and efforts to reunify children
separated from their families. We determined these internal controls were
inadequate and required significant improvements. Controls only partiallyachieved the objectives intended to mitigate risks related to business
operations and governance under the Zero Tolerance Policy.
We conducted this performance audit between October 2018 and March 2019
pursuant to the Inspector General Act of 1978, as amended, and according toGenerally Accepted Government Auditing Standards. Those standards requirethat we plan and perform the audit to obtain sufficient, appropriate evidence toprovide a reasonable basis for our findings and conclusions based upon our
audit objectives. We believe the evidence obtained provides a reasonable basis
for our findings and conclusions based upon our audit objectives.

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Appendix B
DHS Comments to the Draft Reportwww.oig.dhs.gov

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Appendix C
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Policy
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Senior Official Performing the Duties of the Deputy Under Secretary forManagement, MGMT
Chief Operating Officer and Senior Official Performing the Duties of theCommissioner, CBP
Acting Director, ICE
Audit Liaison, MGMT
Audit Liaison, CBP
Audit Liaison, ICE
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner

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Additional Information and Copies
To view this and any of our other reports, please visit our website at:www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General
Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov.
Follow us on Twitter at: @dhsoig.

OIG Hotline
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Department of Homeland Security
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Washington, DC 20528-0305