SENSITIVE BUT UNCLASSIFIED

REFUGEES 

Actions Needed by 

State Department and 

DHS to Further 

Strengthen Applicant 

Screening Process 

and Assess Fraud 

Risks 

Report to Congressional Addressees

July 2017

GAO-17-706

SENSITIVE BUT UNCLASSIFIED

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-706, a report to 

congressional addressees

July 2017

REFUGEES

Actions Needed by State Department and DHS to 

Further Strengthen Applicant Screening Process and 

Assess Fraud Risks

What GAO Found

From fiscal year 2011 through June 2016, the U.S. Refugee Admission Program 

(USRAP) received about 655,000 applications and referrals—with most referrals 

coming from the United Nations High Commissioner for Refugees—and 

approximately 227,000 applicants were admitted to the United States (see 

figure). More than 75 percent of the applications and referrals were from 

refugees fleeing six countries—Iraq, Burma, Syria, Somalia, the Democratic 

Republic of Congo, and Bhutan. Nine Department of State- (State) funded

Resettlement Support Centers (RSC) located abroad process applications by 

conducting prescreening interviews and initiating security checks, among other 

activities. Such information is subsequently used by the Department of 

Homeland Security’s (DHS) U.S. Citizenship and Immigration Services (USCIS), 

which conducts in-person interviews with applicants and assesses eligibility for 

refugee status to determine whether to approve or deny them for resettlement. 

Status of U.S. Refugee Admissions Program (USRAP) Applications Received from Fiscal Year 

2011 through June 2016, by Fiscal Year (as of June 2016)

a

After receiving an application, USRAP partners determine whether the applicant qualifies for a U.S. Citizenship and 

Immigration Services (USCIS) interview. b

USCIS officers may place an application on hold after their interview if they determine that additional information is 

needed to adjudicate the application.

State and RSCs have policies and procedures for processing refugee 

applications, but State has not established outcome based-performance 

measures. For example, State’s USRAP Overseas Processing Manual includes

requirements for information RSCs should collect when prescreening applicants 

and initiating national security checks, among other things. GAO observed 27 

prescreening interviews conducted by RSC caseworkers in four countries and 

found that they generally adhered to State requirements. Further, State has 

control activities in place to monitor how RSCs implement policies and 

procedures. However, State has not established outcome-based performance 

indicators for key activities—such as prescreening applicants and accurate case 

Why GAO Did This Study

Increases in the number of USRAP 

applicants approved for resettlement in 

the United States from countries where 

terrorists operate have raised 

questions about the adequacy of 

applicant screening. 

GAO was asked to review the refugee 

screening process. This report (1) 

describes what State and DHS data 

indicate about the characteristics and 

outcomes of USRAP applications, (2)

analyzes the extent to which State and 

RSCs have policies and procedures on 

refugee case processing and State 

oversees RSC activities, (3) analyzes 

the extent to which USCIS has policies 

and procedures for adjudicating 

refugee applications, and (4) analyzes 

the extent to which State and USCIS 

have mechanisms in place to detect 

and prevent applicant fraud. GAO 

reviewed State and DHS policies, 

analyzed refugee processing data and 

reports, observed a nongeneralizable 

sample of refugee screening interviews 

in four countries in 2016 (selected 

based on application data and other 

factors), and interviewed State and 

DHS officials and RSC staff.

What GAO Recommends

GAO recommends that State (1) 

develop outcome-based indicators to 

measure RSC performance and (2) 

monitor against these measures; 

USCIS (1) enhance training to 

temporary officers, (2) develop a plan 

to deploy additional officers with 

national security expertise, and (3) 

conduct regular quality assurance 

assessments; and State and DHS 

jointly conduct regular fraud risk 

assessments. State and DHS 

concurred with GAO’s 

recommendations.

View GAO-17-706. For more information, 

contact Rebecca Gambler at (202) 512-8777 

or gamblerr@gao.gov.
Highlights of GAO-17-706 (Continued) 

United States Government Accountability Office

file preparation—or monitored RSC performance consistently across such indicators. Developing outcome-based 

performance indicators, and monitoring RSC performance against such indicators on a regular basis, would better 

position State to determine whether RSCs are processing refugee applications in accordance with their responsibilities.

USCIS has policies and procedures for adjudicating applications—including how its officers are to conduct interviews, 

review case files, and make decisions on refugee applications—but could improve training, the process for adjudicating 

applicants with national security concerns, and quality assurance assessments. For example, USCIS has developed an 

assessment tool that officers are to use when interviewing applicants. GAO observed 29 USCIS interviews and found that 

officers completed all parts of the assessment. USCIS also provides specialized training to all officers who adjudicate 

applications abroad, but could provide additional training for officers who work on a temporary basis, which would better 

prepare them to adjudicate applications. In addition, USCIS provides guidance to help officers identify national security 

concerns in applications and has taken steps to address challenges with adjudicating such cases. For example, in 2016, 

USCIS completed a pilot that included sending officers with national security expertise overseas to support interviewing 

officers in some locations. USCIS determined the pilot was successful and has taken steps to formalize it. However, 

USCIS has not developed and implemented a plan for deploying these additional officers, whose expertise could help 

improve the efficiency and effectiveness of the adjudication process. Further, USCIS does not conduct regular quality 

assurance assessments of refugee adjudications, consistent with federal internal control standards. Conducting regular 

assessments of refugee adjudications would allow USCIS to target training or guidance to areas of most need. 

Key Steps in the U.S. Refugee Admissions Program (USRAP) Screening Process 

a

All persons traveling to the United States by air are subject to standard U.S. government vetting practices. 

State and USCIS have mechanisms in place to detect and prevent applicant fraud in USRAP, such as requiring DNA 

testing for certain applicants, but have not jointly assessed applicant fraud risks program-wide. Applicant fraud may 

include document and identity fraud, among other things. USCIS officers can encounter indicators of fraud while 

adjudicating refugee applications, and fraud has occurred in USRAP programs in the past. Because the management of 

USRAP involves several agencies, jointly and regularly assessing fraud risks program-wide, consistent with leading fraud 

risk management practices and federal internal control standards, could help State and USCIS ensure that fraud detection 

and prevention efforts across USRAP are targeted to those areas that are of highest risk. 

This is a public version of a sensitive report issued in June 2017. Information that the Departments of Homeland Security, 

and State deemed to be sensitive is not included in this report. 
Page i GAO-17-706 Refugee Screening Process

Letter 1 

Background 9

USRAP Applicant Characteristics Vary; About One-third of 

Applicants from Fiscal Year 2011 through June 2016 Have 

Been Admitted to the United States, as of June 2016 18

State and RSCs Have Policies and Procedures for Processing 

Refugees, but State Could Improve Efforts to Monitor RSC 

Performance 29

USCIS Has Policies and Procedures for Adjudicating Refugee 

Applications, but Could Improve Training and Quality 

Assurance 37

State and USCIS Have Mechanisms to Help Detect and Prevent 

Applicant Fraud, but Could Jointly Assess Applicant Fraud 

Risks 52

Conclusions 57

Recommendations for Executive Action 58

Agency Comments 58

Appendix I Central American Minors Program 62

Appendix II Summary of United States Refugee Admissions 

Program Priority Categories 71

Appendix III Comments from the Department of State 75

Appendix IV Comments from the Department of Homeland Security 78

Appendix V GAO Contact and Staff Acknowledgments 82

Tables

Table 1: Status of U.S. Refugee Admissions Program (USRAP) 

Applications Received from Fiscal Year 2011 through 

June 2016, by Fiscal Year (as of June 2016) 22

Contents
Page ii GAO-17-706 Refugee Screening Process

Table 2: Description of U.S. Refugee Admissions Program 

(USRAP) Priority Access Groups, as of March 2017 72

Figures

Figure 1: Refugee Admissions by Region, Fiscal Years 2011 

through 2016 12

Figure 2: Key Steps in the U.S. Refugee Admissions Program 

(USRAP) Screening Process 13

Figure 3: Refugee Applications Received by Country of Nationality 

and Year, Fiscal Year 2011 through June 2016, by Fiscal 

Year 19

Figure 4: Key Characteristics of Refugee Applications to the U.S 

Refugee Admissions Program (USRAP), Fiscal Year 

2011 through June 2016 (as of June 2016) 20

Figure 5: Percentage of Refugee Applications Approved by U.S. 

Citizenship and Immigration Services, by Resettlement 

Support Center (RSC), Fiscal Year 2011 through June 

2016 (as of June 2016) 24

Figure 6: Median Length of Time from Creation of a Case to 

Subsequent Key Phases in the U.S. Refugee Admissions 

Program (USRAP), Applications Submitted Fiscal Year 

2011 through June 2016 (as of June 2016) 28

Figure 7: U.S. Citizenship and Immigration Services (USCIS) 

Initial Training Requirements for Officers Who Adjudicate 

Refugee Applications 40

Figure 8: Overview of Key Processing Steps for U.S. Refugee 

Admissions Program’s (USRAP) Central American 

Minors (CAM) Program 65
Page iii GAO-17-706 Refugee Screening Process

Abbreviations

AOR Affidavit of Relationship

CAM Central American Minors Program

CBP U.S. Customs and Border Protection

CLASS Consular Lookout and Support System 

DHS Department of Homeland Security

FBI Federal Bureau of Investigation

GPRA Government Performance and Results Act of 1993

GPRAMA GPRA Modernization Act of 2010

INA Immigration and Nationality Act

IO International Operations

IOM International Organization for Migration

ISIS Islamic State in Iraq and Syria

MOU memorandum of understanding

NGO non-governmental organization

P1 Priority 1

P2 Priority 2

P3 Priority 3 

RAD Refugee Affairs Division

RAIO Refugee, Asylum, and International Operations Directorate

RAVU Refugee Access Verification Unit 

RSC Resettlement Support Center

State Department of State

SOP standard operating procedures

SVPI Security, Vetting, and Program Integrity unit

UNHCR United Nations High Commissioner for Refugees

USCIS U.S. Citizenship and Immigration Services

USRAP U.S. Refugee Admissions Program

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-17-706 Refugee Screening Process

441 G St. N.W.

Washington, DC 20548

July 31, 2017

Congressional Addressees

An estimated 34,000 people are forced to flee their homes each day 

because of conflict, oppression, and persecution, according to the United 

Nations High Commissioner for Refugees (UNHCR).1 U.S. immigration 

law provides that qualified foreign nationals located outside of the United 

States may be granted humanitarian protection in the form of refugee 

status and resettlement in the United States if they demonstrate that they 

are unable or unwilling to return to their home country because of past 

persecution or a well-founded fear of future persecution based on their 

race, religion, nationality, membership in a particular social group, or 

political opinion.2 UNHCR reported that there were more than 21 million 

refugees worldwide in 2015.3 In fiscal year 2016, the United States 

admitted approximately 85,000 refugees for resettlement—the largest 

yearly number in more than 15 years—through the U.S. Refugee 

Admissions Program (USRAP).

Increases in the number of USRAP applicants approved for resettlement 

in the United States—particularly from countries in the Middle East where 

terrorist groups such as the Islamic State in Iraq and Syria (ISIS) 

operate—have raised questions about the adequacy of screening for 

refugee applicants to prevent access by persons who may be threats to 

national security. There are also questions as to whether USRAP is 

vulnerable to fraud because, for example, testimonial evidence alone, 

without corroboration, may be sufficient for refugee applicants to meet the 

burden of proof for establishing eligibility for resettlement in the United 

States.4 Given the potential consequences that the outcomes of decisions 

on refugee applications can have on the safety and security of both 

1

UNHCR, Global Trends: Forced Displacement in 2015 (Geneva, Switzerland: June 

2015).

2

U.S. immigration law also provides that eligible spouses and children of such refugees 

shall also be admitted as refugees when accompanying or following-to-join the principal 

refugee, but are not required to establish a persecution claim of their own.

3

UNHCR, Global Trends: Forced Displacement in 2015.

4

See, e.g., 8 U.S.C. § 1158(b)(1)(B)(ii) (providing that the testimony of the applicant may 

be sufficient to sustain the applicant’s burden without corroboration, and that if evidence to 

corroborate otherwise credible testimony is deemed necessary, such evidence must be 

provided unless the applicant does not have the evidence and cannot reasonably obtain 

the evidence). 

Letter
Page 2 GAO-17-706 Refugee Screening Process

vulnerable refugee populations and the United States, it is important that 

the U.S. government have an effective refugee screening process to 

allow for resettlement of qualified applicants while preventing persons 

with malicious intent from using USRAP to gain entry into the country.

The Departments of State (State) and Homeland Security (DHS) have 

joint responsibility for the admission of refugees to the United States. 

Specifically, State’s Bureau of Population, Refugees, and Migration 

coordinates and manages USRAP and makes decisions on which 

individuals around the world are eligible for resettlement as refugees in 

the United States. State coordinates with DHS and other agencies in 

carrying out this responsibility. In particular, nine State-funded 

Resettlement Support Centers (RSC) that are operated by international 

and nongovernmental organizations and are located abroad with distinct 

geographic areas of responsibility communicate directly with applicants to 

process their applications, collect their information, and conduct in-person 

prescreening interviews.5 After such prescreening is complete, DHS’s 

U.S. Citizenship and Immigration Services (USCIS) has responsibility for 

adjudicating applications from these individuals. In adjudicating such 

applications, USCIS officers are to conduct individual, in-person 

interviews with applicants overseas and use the results of these 

interviews in conjunction with other relevant information, such as the 

results of applicants’ security checks, to determine whether USCIS will 

approve the applicants for resettlement in the United States as refugees. 

Federal agencies within and outside of the intelligence community, 

including the National Counterterrorism Center (NCTC), the Department 

of Defense, and the Federal Bureau of Investigation (FBI), partner with 

State and USCIS on security checks to identify and vet any potential 

national security concerns associated with an applicant.6 Further, at U.S. 

ports of entry, DHS’s U.S. Customs and Border Protection (CBP) is 

responsible for inspecting all individuals, including refugees, to determine 

if they will be admitted or otherwise permitted entry into the country. 

5

The nine RSCs and their respective headquarters locations are: Africa (Nairobi, Kenya); 

Austria (Vienna, Austria); East Asia (Bangkok, Thailand); Eurasia (Moscow, Russia); Latin 

America (Quito, Ecuador); Middle East and North Africa (Amman, Jordan); South Asia 

(Damak, Nepal); Turkey and the Middle East (Istanbul, Turkey); and Cuba (Havana, 

Cuba). RSC Cuba is operated by State. 

6

Among other missions, NCTC, within the Office of the Director of National Intelligence, 

serves as the primary organization within the U.S. government for analyzing and 

integrating all information possessed or acquired by the U.S. government pertaining to 

terrorism and counterterrorism See 50 U.S.C. § 3056 (excepting, however, intelligence

pertaining exclusively to domestic terrorist and domestic counterterrorism).
Page 3 GAO-17-706 Refugee Screening Process

Pursuant to a provision in the Joint Explanatory Statement accompanying 

the Consolidated Appropriations Act, 2016, and congressional requests, 

we were asked to review the refugee screening process.7 This report (1) 

describes what State and DHS data indicate about the characteristics and 

outcomes of USRAP applications, (2) analyzes the extent to which RSCs 

and State have policies and procedures on refugee case processing and 

State has overseen RSC activities, (3) analyzes the extent to which 

USCIS has policies and procedures for adjudicating refugee applications, 

and (4) analyzes the extent to which State and USCIS have mechanisms 

in place to detect and prevent applicant fraud in USRAP.8 You also asked 

7

See 161 Cong. Rec. H10175 (daily ed. Dec. 17, 2015) (explanatory statement 

accompanying Pub. L. No. 114-113, div. F, 129 Stat. 2242, 2493 (2015)).

8

This report does not address the impacts, if any, of Executive Order 13780, Protecting 

the Nation From Foreign Terrorist Entry into the United States, issued on March 6, 2017, 

on USRAP or the processing of refugees for admission into the United States more 

generally. See 82 Fed. Reg. 13,209 (Mar. 9, 2017). Among other things, the Executive 

Order articulates that it is the policy of the United States to improve the screening and 

vetting protocols and procedures associated with the visa-issuance process and USRAP. 

As of June 2017, certain aspects of the Executive Order had been the subject of pending 

litigation and sections 2 and 6 of the Executive Order (among other things, temporarily 

suspending the entry of nationals from countries of particular concern and the U.S. 

Refugee Admissions Program, respectively) remained the subject of a nationwide 

injunction. See Hawaii v. Trump, No. 1:17-cv-00050, ECF Doc. No. 219, 2017 U.S. Dist. 

LEXIS 36935 (D. Haw. Mar. 15, 2017) (Order Granting Motion for Temporary Restraining 

Order), aff’d in pertinent part, 2017 U.S. App. LEXIS 10356 (9th Cir. June 12, 2017) (per 

curiam). On June 26, 2017, however, the Supreme Court, granted, in part, the 

government’s application to stay the injunction and, specific to section 6, explained that 

the administration may enforce this section except with respect to an individual seeking 

admission as a refugee who can “credibly claim a bona fide relationship with a person or 

entity in the United States.” See Trump v. International Refugee Assistance Project, 2017 

U.S. LEXIS 4266 (June 26, 2017) (per curiam) (providing also that the government’s 

petitions for certiorari have been granted and that the Court will hear the cases during the 

first session of the October Term 2017). Subsequent to the Supreme Court’s June 26, 

2017, ruling, State and DHS officials stated that USRAP will be implemented in 

accordance with the Executive Order and consistent with the Supreme Court’s ruling.

Implementation of the Executive Order, however, remains the subject of ongoing litigation 

in the federal courts. See, e.g., Hawaii v. Trump, No. 1:17-cv-00050, 2017 U.S. Dist. 

LEXIS 109034 (D. Haw. July 13, 2017) and Trump v. Hawaii, 2017 U.S. LEXIS 4322 (July 

19, 2017). 
Page 4 GAO-17-706 Refugee Screening Process

us to provide specific information on the Central American Minors (CAM) 

program, which is included in appendix I.9

This report is a public version of a sensitive report that we issued in June 

2017.10 The Departments of Homeland Security and State deemed some 

of the information in our June report to be Sensitive But Unclassified or 

For Official Use Only, which must be protected from public disclosure. 

Therefore, this report omits sensitive information about USRAP security 

check processes and results, as well as specific details about prior 

incidences of fraud in the program. Although the information provided in 

this report is more limited, the report addresses the same objectives as 

the sensitive report and uses the same methodology. 

To describe what State and DHS data indicate about the characteristics 

and outcomes of USRAP applications, we analyzed record-level data 

from State’s Worldwide Refugee Admissions Processing System 

(WRAPS)—an interactive computer system that serves as a repository for 

application information and tracks the status of all individual refugee 

applications to USRAP—for all refugee applications that were received 

from fiscal years 2011 through June 2016.11 We also obtained WRAPS 

summary data on the CAM program from December 2014—when State 

and DHS began accepting applications for the program—through March 

2017. We assessed the reliability of the WRAPS data by, for example, 

reviewing them for missing data or obvious errors and interviewing State 

officials responsible for ensuring data quality. During our assessment, we 

found some inconsistencies in the data field that indicates the status of 

9

In general the CAM refugee/parole program, managed jointly by State and DHS, permits 

qualifying parents in the United States to request that their children or other eligible family 

members in El Salvador, Guatemala, or Honduras be considered for admission to the 

United States as a refugee or permitted entry on parole. In general, parole is a mechanism 

by which an individual not otherwise admitted to the United States may be permitted entry 

into the country on a temporary basis. See 8 U.S.C. § 1182(d)(5); 8 C.F.R. § 212.5. The 

CAM program began accepting applications from qualifying parents on December 1, 2014, 

and, effective November 15, 2016, the program was expanded to allow additional 

categories of eligible family members to apply for admission to the United States as 

refugees when accompanied by a qualifying child. 

10GAO, Refugees: Actions Needed by State Department and DHS to Further Strengthen 

Applicant Screening Process and Assess Fraud Risks, GAO-17-444SU (Washington, 

D.C.: June 7, 2017).

11We selected October 2010 through June 24, 2016—fiscal year 2011 through about 

three quarters of fiscal year 2016—because this was the most recent complete 5-year 

period and fiscal year for which data were available when we were conducting our work.
Page 5 GAO-17-706 Refugee Screening Process

the application in USRAP when conducting our internal data checks. We 

rounded the counts for the categories in this field to the nearest thousand 

for the purposes of reporting USRAP summary data and to the nearest 

hundred for the purposes of reporting CAM summary data. We found the 

WRAPS data to be sufficiently reliable for the purposes of this report, 

including determining the number of applications, their outcomes 

(approved, closed or denied, or pending), the results of security checks, 

timeframes associated with processing applications, and various 

applicant characteristics such as gender and nationality.

To analyze the extent to which State and RSCs have policies and 

procedures on refugee case processing and State’s oversight of RSC 

activities, we analyzed State’s standard operating procedures (SOP) and 

guidance to RSCs, including State’s USRAP Overseas Processing 

Manual and SOPs pertaining to different phases of the refugee 

application process.12 We also reviewed local SOPs developed by each 

RSC. Additionally, we observed refugee processing and RSC 

caseworkers conducting in-person prescreening interviews (27 interviews 

in total) by visiting RSC offices in four locations—San Salvador, El 

Salvador; Vienna, Austria; Amman, Jordan; and Nairobi, Kenya—from 

June through September 2016.13 We selected these locations based on 

various factors, including variations in the number of refugee applications 

received, geographic variability (i.e., RSC locations), and the types of 

applications processed at each office. The results from our visits are 

specific to the processing and interviews observed at these locations 

when we visited and cannot be generalized; however, we believe the site 

visit results still provide important context and insights into how RSCs 

implement USRAP policies and procedures. For the five RSCs we did not 

visit in person, we conducted telephone interviews with RSC 

management. In addition, we analyzed 107 summary reports USCIS team 

supervisors completed following officers’ trips overseas to interview 

USRAP applicants from the fourth quarter of 2014 through the third 

quarter of 2016 (the most recent reports available at the time of our 

 12Department of State, USRAP Overseas Processing Manual (Washington, D.C.: October 

2015).

13We selected RSC caseworkers to observe on the basis of who was processing refugee 

applications and prescreening USRAP applicants during our planned site visits. 
Page 6 GAO-17-706 Refugee Screening Process

review).14 We also spoke with 6 USCIS officers who conducted the 

applicant interviews we observed during our site visits to obtain their 

perspectives on RSC case processing, as well as 4 supervisory officers.15

To assess the controls State has in place to monitor RSCs, we reviewed 

RSC cooperative agreements and a memorandum of understanding 

(MOU), and the most recent monitoring report State completed for each 

RSC; questionnaires completed by RSC directors in advance of State 

monitoring visits; and fiscal year 2015 quarterly reports RSCs submitted 

to State—the most recent completed fiscal year for which data were 

available when we were conducting our work.16 We obtained additional 

information on how State monitors RSCs during our interviews with State 

officials who manage the program. We compared State’s monitoring 

efforts with requirements in State’s Performance Management 

Guidebook,17 Federal Assistance Policy Directive,18 and the Government 

Performance and Results Act of 1993 (GPRA), as updated by the GPRA 

Modernization Act of 2010 (GPRAMA).19

 14We analyzed all available USCIS summary reports from July 2014 through June 2016. 

USCIS officials told us that some summary reports were not available for a number of 

reasons, including: reports lost during the migration of technology, reports in progress and 

pending completion, and trips with a single officer who communicated regularly with 

USCIS headquarters officials during the trip about any relevant issues or trends.

According to USCIS officials, trip reports are required yet informal reporting mechanisms

to ensure continuity between circuit rides and to provide team leaders with the opportunity 

to communicate case processing trends and issues. Although written by supervisors, they 

do not go through a formal clearance process. USCIS officials stated that trends and 

issues described in the reports may only be reflective of that particular case composition 

and team composition on a single circuit ride. These officials further stated that the reports

do not necessarily reflect the ongoing processing and take into account the totality of 

processing in that location.

15We selected USCIS officers and supervisory officers to interview based on their 

availability either during or after our site visits.

16Nongovernmental organizations operate four RSCs through cooperative agreements 

with State—Africa, Austria, East Asia, and Turkey and the Middle East. In addition, State 

funds four other RSCs managed by the International Organization for Migration —Eurasia, 

Latin America, South Asia, and Middle East and North Africa—through voluntary 

contributions. State operates RSC Cuba.

17Department of State, Performance Management Guidebook: Resources, Tips, and 

Tools (Washington, D.C.: December 2011).

18Department of State, Federal Assistance Policy Directive (Washington, D.C.: January 

2016).

19See generally Pub. L. No. 103-62, 107 Stat. 285 (1993) (GPRA) and Pub. L. No. 111-

352, 124 Stat. 3866 (2011) (updating GPRA); 31 U.S.C. § 1115.
Page 7 GAO-17-706 Refugee Screening Process

To analyze the extent to which USCIS has developed and implemented 

policies and procedures for adjudicating refugee applications, we 

analyzed USCIS SOPs on the refugee adjudication process, including 

USCIS’s I-590 Refugee Application Assessment—the primary tool 

refugee officers use to interview and screen refugees and document the 

resulting adjudication decisions. Further, we observed 29 USCIS 

interviews at the four RSCs we visited.20 Although these observations are 

not generalizable across all USCIS interviews, they provided first-hand 

observations on how USCIS officers adjudicate refugee applications and 

insights into the implementation of USCIS’s policies and procedures. In 

addition, we analyzed the aforementioned USCIS summary reports to 

better understand how USCIS adjudicates applications overseas and any 

associated challenges. We also reviewed USCIS training materials and 

attended trainings that USCIS officers receive prior to traveling overseas 

to interview a specific population of refugees. We also discussed USCIS 

training and guidance with USCIS’s Refugee Affairs Division (RAD) and 

International Operations (IO) Division and the 10 USCIS officers, 

mentioned above, who we interviewed. In addition, we reviewed USCIS 

workforce planning information and training requirements. We compared 

all of this information to Standards for Internal Control in the Federal 

Government and leading practices in federal strategic planning.21 Further, 

we reviewed USCIS quality assurance policy documents, quality 

assurance assessments from fiscal year 2015—the most recent year in 

which USCIS assessed refugee adjudications—and spoke with USCIS 

officials about quality assurance mechanisms for USRAP. We compared 

USCIS’s quality assurance practices to USCIS’s memorandum on roles 

and responsibilities with respect to refugee processing and federal 

internal control standards22 and standard practices for program 

management.23

 20In Kenya, we observed USCIS interviews at the Kakuma refugee camp. In all other 

locations, we observed USCIS interviews at the RSC offices. We selected USCIS officers 

to observe on the basis of who was interviewing USRAP applicants during our planned 

site visits. 

21GAO, Standards for Control in the Federal Government, GAO-14-704G (Washington, 

D.C.: September 2014).

22GAO-14-704G.

23Project Management Institute, Inc., The Standard for Program Management ®, Third 

Edition, 2013.
Page 8 GAO-17-706 Refugee Screening Process

To analyze the extent to which State and USCIS have mechanisms in 

place to detect and prevent applicant fraud in USRAP, we compared 

State’s and USCIS’s fraud-related policies and procedures with standards 

for federal internal control and leading practices in GAO’s A Framework 

for Managing Fraud Risks in Federal Programs (Fraud Risk 

Framework).24 For the purposes of this report, we define refugee fraud as 

the willful misrepresentation of material facts, such as making false 

statements, submitting forged or falsified documents, or conspiring to do 

so, in support of a refugee claim with the United States.25 Regarding 

USCIS, we reviewed policies and procedures on how to identify and 

prevent fraud in USRAP, such as USCIS’s draft refugee fraud process 

SOPs and fraud training materials that USCIS provides to its officers. 

Regarding State, we reviewed memoranda on previously identified fraud 

in USRAP programs as well as SOPs State developed to help RSCs 

identify fraudulent applications. Further, we interviewed USCIS and State 

headquarters officials and officials at all 9 RSCs about applicant fraud in 

USRAP and their fraud identification and prevention procedures. In 

addition, we analyzed WRAPS data on steps RSCs take to prevent 

fraudulent applications. We also reviewed the 107 USCIS trip reports, 

which contain information on fraud trends that officers encountered while 

adjudicating cases in a particular location.

The performance audit upon which this report is based was conducted 

from February 2016 to June 2017 in accordance with generally accepted 

government auditing standards. Those standards require that we plan 

 24GAO-14-704G, and A Framework for Managing Fraud Risks in Federal Programs, 

GAO-15-593SP (Washington, D.C.: July 28, 2015). This framework is a comprehensive 

set of leading practices that serves as a guide for program managers to use when 

developing efforts to combat fraud in a strategic, risk-based manner. GAO identified these 

leading practices through focus groups with antifraud professionals; interviews with 

government, private sector, and nonprofit antifraud experts; and a review of literature. We 

used the leading practices in this framework to assess USCIS efforts because, as the 

framework states, it encompasses control activities to prevent, detect, and respond to 

fraud, as well as structures and environmental factors that influence or help managers 

achieve their objective to mitigate fraud risks; thus, this framework is applicable to USCIS 

efforts to address fraud risks in the refugee admissions program. Pursuant to the Fraud 

Reduction and Data Analytics Act of 2015, the Director of the Office of Management and 

Budget is to establish, in consultation with the Comptroller General, guidelines for 

agencies to establish financial and administrative controls to identify and assess fraud 

risks and design and implement control activities to prevent, detect, and respond to fraud, 

including improper payments, and which are to incorporate the leading practices identified 

in GAO’s Fraud Risk Framework. See Pub. L. No. 114-186, 130 Stat. 546 (2016).

25We developed this definition on the basis of an analysis of documentation from USCIS, 

as well as through interviews with USCIS officials who investigate fraud in USRAP.
Page 9 GAO-17-706 Refugee Screening Process

and perform the audit to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

subsequently worked with State, DHS, and the Department of Defense 

from June to July 2017 to prepare this nonsensitive version of the original 

sensitive report for public release. This public version was also prepared 

in accordance with generally accepted government auditing standards.

The United States has a long history of refugee resettlement, but there 

was no formal program for the resettlement and admission of refugees 

until the Refugee Act of 1980 (Refugee Act) amended the Immigration 

and Nationality Act (INA) to, among other purposes, establish a more 

uniform basis for the provision of assistance to refugees.26 Under the INA, 

as amended, an applicant seeking admission to the United States as a 

refugee must (1) not be firmly resettled in any foreign country, (2) be 

determined by the President to be of special humanitarian concern to the 

United States, (3) meet the definition of refugee established in U.S. 

immigration law, and (4) be otherwise admissible to the United States as 

an immigrant under U.S. immigration law.27 Under USRAP, USCIS 

officers determine an applicant’s eligibility for refugee status by assessing 

whether the applicant has, among other things, credibly established that 

he or she suffered past persecution, or has a well-founded fear of future 

persecution, and that he or she is not otherwise statutorily barred from 

 26See Pub. L. No. 82-414, tit. I, § 101(a)(42), tit. II, ch. 1, §§ 207-09, 66 Stat. 163 (1952) 

(INA), as added by Pub. L. No. 96-212, tit. II, § 201, 94 Stat. 102, 102-06 (1980) (Refugee 

Act); 8 U.S.C. §§ 1101(a)(42), 1157-59. For example, prior to enactment of the INA and its 

subsequent amendments, the United States, pursuant to the Displaced Persons Act of 

1948, Pub. L. No. 80-774, 62 Stat. 1009, which was enacted in response to the migration 

crisis in Europe resulting from World War II, admitted over 400,000 displaced persons by 

the end of 1952.

27See 8 U.S.C. §§ 1101(a)(42) (defining “refugee” under U.S. immigration law), 1157 

(authorizing, and establishing the criteria for, the admission of refugees to the United 

States). 

Background

Refugee Eligibility 

Requirements and 

Admissions
Page 10 GAO-17-706 Refugee Screening Process

being granted refugee status or admission to the United States.28 Among 

other things, USCIS officers may not classify an applicant as a refugee or 

approve an applicant for refugee resettlement in the United States if he or 

she: has participated in the persecution of any person on account of race, 

religion, nationality, membership in a particular social group or political 

opinion; is inadmissible for having engaged in terrorist activity or 

associating with terrorist organizations; is inadmissible on certain nonwaivable criminal or security grounds; or is firmly resettled in a foreign 

country.29 Under USRAP, cases may be presented for USCIS 

adjudication with a single applicant or may include a principle applicant 

with certain family members.30 All applicants on a case must be deemed 

 28Specifically, under the INA a refugee is any person who is outside any country of his or 

her nationality or, in the case of a person having no nationality, is outside any country in 

which he or she last habitually resided, and who is unable or unwilling to return to, and is 

unable or unwilling to avail himself or herself of the protection of that country because of 

persecution or a well-founded fear of persecution on account of race, religion, nationality, 

membership in a particular social group, or political opinion. See 8 U.S.C. § 1101(a)(42) 

(providing further that in such special circumstances as the President, after appropriate 

consultation, may specify, persons within their country of nationality or, if having no 

nationality, within the country in which he or she habitually resides, may also be deemed a 

refugee if he or she is persecuted or has a well-founded fear of persecution on account of 

the same factors, and also describing particular circumstances that will be deemed to 

constitute persecution or a well-founded fear of persecution on account of political opinion, 

such as being forced to abort a pregnancy or undergo involuntary sterilization).

29See generally 8 U.S.C. §§ 1101(a)(42) (establishing the persecutor bar); 

1182(a)(2)(establishing criminal and related grounds of inadmissibility) and (a)(3) 

(establishing security and related grounds of inadmissibility, including terrorism-related 

grounds); and 8 U.S.C. § 1157(c) (establishing that firm resettlement in any foreign 

country is a bar to admission as a refugee). See also 8 C.F.R. § 207.1(b) (establishing the 

standard for determining whether a refugee is considered to be “firmly resettled”). 

Derivative spouses and children of the principal refugee are not subject to the firm 

resettlement bar, certain grounds of inadmissibility, such as the public charge, labor 

certification and immigrant document requirement grounds, do not apply to refugees by 

statute, and the statute recognizes certain other grounds of inadmissibility for which a 

discretionary waiver may or may not be granted based for humanitarian, family unity, or

public interest reasons. See 8 U.S.C. § 1157(c)(2)-(3); 8 C.F.R. § 207.1(b), 207.3. There 

is no explicit exception to the persecutor bar—see Negusie v. Holder, 555 U.S. 511 

(2009)—but according to USCIS officials the application of a person who would otherwise 

fall within the persecutor bar but who has established that his or her conduct may have 

been the result of duress will be placed on hold. 

30Under USRAP, the principal applicant’s spouse and unmarried children under the age of 

21 may apply together while they are overseas. The principal applicant may also petition 

for his or her derivative spouse and children to “follow-to-join” him or her as refugees 

within two years after the principal has been admitted to the United States as a refugee, 

unless the deadline is waived for humanitarian reasons. See 8 U.S.C. § 1157(c)(2); 8 

C.F.R. § 207.7.
Page 11 GAO-17-706 Refugee Screening Process

admissible, but only the principal applicant must prove his or her past 

persecution or fear of future persecution.

Before the beginning of each fiscal year and after consultation with 

Congress, the President is to establish the number of refugees who may 

be admitted to the United States in the ensuing fiscal year (i.e., a 

“ceiling”), with such admissions allocated among refugees of special 

humanitarian concern to the United States (e.g., by region or country of 

nationality).31 For example, for fiscal year 2016, the administration 

proposed and met a ceiling of 85,000 refugees in fiscal year 2016 

(including a goal of admitting 10,000 Syrian refugees) and established a 

ceiling of 110,000 for fiscal year 2017.

32 Since 2001, annual ceilings for 

refugee admission have generally been between 70,000 and 80,000 

admissions; in the early 1990s, the ceilings were at more than 100,000 

admissions. Actual admissions of refugees into the country have been at 

or below the ceiling in recent years. For example, the combined ceiling for 

 31See 8 U.S.C. § 1157(a) (providing that the number of refugees who may be admitted in 

any fiscal year shall be the number as the President determines, before the beginning of 

the fiscal year and after appropriate consultation, is justified by humanitarian concerns or 

is otherwise in the national interest), (b) (authorizing the President, after appropriate 

consultation, to allocate additional refugee numbers for unforeseen emergency 

circumstances), and (e) (defining what constitutes appropriate consultation with 

Congress).

32According to State officials, a refugee counts towards the ceiling in the year for which 

they were admitted to the United States. Section 6(b) of President’s March 6, 2017, 

executive order provides that the entry of more than 50,000 refugees in fiscal year 2017 

would be detrimental to the interests of the United States and suspends the entry of 

refugees beyond that number until such time as the President determines that additional 

admissions would be in the national interest. See Exec. Order No. 13,780, 82 Fed. Reg. at 

13,216. As of June 2017, State and DHS officials had stated that USRAP was being 

implemented in a manner compliant with the District Court of Hawaii’s nationwide

injunction and thus with a ceiling of 110,000 refugee admissions for fiscal year 2017 (the 

program had been operating under the 50,000 ceiling established in the Executive Order 

prior to the District Court’s injunction). The Supreme Court, through its June 26, 2017, 

ruling, however, granted, in part, the government’s application to stay the injunction and, 

with respect to section 6(b), permitted the administration to proceed with the 50,000 

refugee ceiling provided that the section is not enforced against an individual seeking 

admission as a refugee who can credibly claim a bona fide relationship with a person or 

entity in the United States, “even if the 50,000-person cap has been reached or 

exceeded.” See 2017 U.S. LEXIS 4266, at *17-18. Subsequent to the Supreme Court’s 

ruling, State and DHS officials stated that section 6(b) of the Executive Order will be 

implemented in a manner consistent with the Supreme Court’s ruling. Implementation of 

the Executive Order, however, remains the subject of ongoing litigation in the federal 

courts. See, e.g., Hawaii v. Trump, No. 1:17-cv-00050, 2017 U.S. Dist. LEXIS 109034 (D. 

Haw. July 13, 2017) and Trump v. Hawaii, 2017 U.S. LEXIS 4322 (July 19, 2017). As June 

23, 2017, about 49,000 refugees had been admitted to the United States in fiscal year 

2017, according to State. 
Page 12 GAO-17-706 Refugee Screening Process

fiscal years 2011 through 2016 was 451,000, during which the United 

States admitted about 410,000 refugees. Figure 1 shows refugee 

admissions by region during this time period.

Figure 1: Refugee Admissions by Region, Fiscal Years 2011 through 2016

Note: The Department of State (State) determines “region” by nationality of the applicant, not the 

location of the State-funded Resettlement Support Center that processed the application. 

Wrapsnet.org is a public website operated by State that provides information and data on the U.S. 

Refugee Admissions Program.
Page 13 GAO-17-706 Refugee Screening Process

There are a number of steps in the USRAP screening process for 

applicants. Figure 2 provides an overview of the refugee screening 

process.

Figure 2: Key Steps in the U.S. Refugee Admissions Program (USRAP) Screening Process

a

Biometrics is the automated recognition of individuals based on their biological and behavioral 

characteristics. USCIS staff collect applicants’ fingerprints and check them against the Federal 

Bureau of Investigation, DHS, and Department of Defense databases.

b

All persons traveling to the United States by air are subject to standard U.S. government vetting 

practices. For example, CBP is to electronically vet all travelers, including persons seeking 

resettlement in the United States as refugees, before they board U.S.-bound flights and is to continue 

vetting the travelers until they land at a U.S. port of entry. Such travelers are also be subject to 

Transportation Security Administration prescreening, as well as physical screening prior to boarding 

commercial aircraft destined for the United States, in accordance with the agency’s policies and 

procedures.

c

According to State’s USRAP Overseas Processing Manual , if a USCIS officer denies a case and the 

RSC presents the applicant with the denial letter, the applicant has 90 days to file a Request for 

Screening Process for 

Refugees Seeking to 

Resettle in the United 

States
Page 14 GAO-17-706 Refugee Screening Process

Review. Such reviews are divided into two categories: requests that allege an error in the adjudication 

and requests that introduce new evidence; and, in general, the applicant may only file one request for 

review. A review may result in USCIS overturning the denial, upholding the denial or requesting 

another interview with the applicant. 

Program access. First, State and USCIS make initial determinations 

about whether an individual will be accepted into or excluded from 

USRAP (referred to as program access) for subsequent screening and 

interview by USCIS officers. There are multiple mechanisms by which 

State and its partners receive USRAP applications. For example, most 

applicants are referred to USRAP by UNHCR, but applicants who meet 

certain criteria can apply directly. State has identified three categories of 

individuals who are of special humanitarian concern and, therefore, can 

qualify for access to USRAP:

• Priority 1 (P1), or individuals specifically referred to USRAP generally 

because they have a compelling need for protection;33

• Priority 2 (P2), or specific groups, often within certain nationalities or 

ethnic groups in specified locations, whose members State and its 

partners have identified as being in need of resettlement; and

• Priority 3 (P3), or individuals from designated nationalities who have 

immediate family members in the United States who initially entered 

as refugees or who were granted asylum.34

Prescreening and biographic checks. Second, RSCs, funded by State 

and operated by international and nongovernment organizations, 

communicate directly with USRAP applicants and prepare their case files. 

RSC staff are to create a case file for applicants and record all of the 

applicants’ information into WRAPS. RSCs are to conduct prescreening 

interviews to record key information, such as applicants’ persecution 

stories and information about their extended family, and submit 

biographic security checks based on the information collected during the 

interview to U.S. agencies, including DHS, State, and the FBI, among 

others. According to State’s USRAP Overseas Processing Manual, every 

applicant in USRAP is required to undergo security checks that must be 

cleared before a refugee can be resettled in the United States, and 

 33To be considered by USRAP, P1 applicants must be referred by UNHCR, a Stateapproved non-governmental organization, or a U.S. Embassy.

34See app. II for a description of the priority categories and how applicants associated with 

each priority gain access to USRAP. The priority classifications only indicate the source of 

the referral, not the urgency with which they are adjudicated. 
Page 15 GAO-17-706 Refugee Screening Process

USCIS officers are not to approve the applicant until all required security 

checks are cleared. Specifically, State SOPs require RSCs to initiate, as 

applicable, three biographic checks:

• Consular Lookout and Support System (CLASS) Check. CLASS is a 

State Department name check process. The system contains records 

provided by numerous agencies and includes information on persons 

with prior visa applications, immigration violations, and terrorism 

concerns. State conducts the check against multiple sources, 

including the U.S. government’s consolidated watchlist of known or 

suspected terrorists, using a USRAP applicant’s primary name and 

name variants, among other data.35

• Security Advisory Opinion. The FBI and intelligence community 

partners conduct biographic checks of certain applicants who are 

members of groups or nationalities designated by the U.S. 

government as requiring more thorough vetting.36

• Interagency Check. Partners, including NCTC and elements of the 

intelligence community, screen biographic data of all refugee 

applicants within a designated age range against intelligence and law 

enforcement information within their databases and security holdings. 

Specifically, all refugee applicants within certain ages are required to 

undergo an Interagency Check. Further, security vetting partners are 

to continuously check interagency refugee applicant data against their 

security holdings through a refugee’s admission to the United States

and, in some instances, after an applicant’s arrival and admission to 

the United States.

Through these checks, applications are screened for indicators that they 

might pose a national security or fraud concern or have immigration or 

criminal violations, among other things. USCIS and FBI officials have 

testified at congressional hearings that security checks are limited to the 

records available in U.S. government databases (which may include 

information provided by foreign governments and other information on 

foreign nationals). According to State SOPs, security check responses 

are communicated through WRAPS, and RSC staff include them in the 

case file provided to the USCIS officer adjudicating the application. If at 

 35The Terrorist Screening Center, a multi-agency organization administered by the FBI, 

maintains the Terrorist Screening Database—the U.S. government’s consolidated 

watchlist of known or suspected terrorists.

36State SOPs also provide that a Security Advisory Opinion may be required as a result of 

the CLASS Check. 

Key Refugee Processing Terms

Access: Determination by the Department of 

State and its U.S. Refugee Admissions 

Program (USRAP) partners of whether the 

applicant qualifies for the U.S. Citizenship and 

Immigration Services (USCIS) adjudication

based on if he/she is of special humanitarian 

concern (i.e., if he/she is within a Priority 1, 

Priority 2, or Priority 3 category), among other 

things. 

Adjudication: USCIS’s process for deciding 

whether to approve or deny an applicant for 

refugee status. The adjudication process 

includes, among other things, at least one inperson interview; security checks; and, in 

some instances, additional review of the 

applicant’s case to address national security 

concerns.

Approved application: Determination by 

USCIS officer that the applicant meets the 

refugee definition and is otherwise eligible for 

resettlement in the United States, and will 

subsequently be processed for travel to the 

United States.

Admitted: U.S. Customs and Border 

Protection (CBP) admits applicant to the 

United States as a refugee.
Page 16 GAO-17-706 Refugee Screening Process

any time an applicant is identified as having a match for the Security 

Advisory Opinion or Interagency Check, the case is to be placed on hold.

For Security Advisory Opinion results that are completed before the 

USCIS interview, State officers are to review any matches to determine if 

they relate to the applicant and should preclude the applicant from access 

to the USRAP. USCIS is responsible for reviewing security check results 

that are completed after the USCIS interview. Further, the CLASS check 

may require a Security Advisory Opinion or additional DHS review. Once 

prescreening is complete and RSC staff have received the results of 

certain security checks, they are to notify State and USCIS that the 

applicant is ready for interview and adjudication.37 DHS is to, based on 

policy, conduct an additional review of Syrian and certain other applicants 

prior to adjudication as part of prescreening.

USCIS Adjudication. Third, USCIS adjudicates applications. USCIS 

coordinates with State to develop a schedule for refugee interviews each 

quarter of the fiscal year. USCIS officers conduct individual, in-person 

interviews overseas with applicants to help determine their eligibility for 

refugee status. RAD and IO—within USCIS’s Refugee, Asylum, and 

International Operations (RAIO) Directorate—share responsibility for 

adjudicating USRAP cases. In 2005, USCIS created the Refugee Corps, 

a cadre of USCIS officers within RAD who, according to USCIS officials, 

are to adjudicate the majority of applications for refugee status. These 

officers are based in Washington, D.C., but they travel to multiple 

locations for 6 to 8 weeks at a time (called circuit rides), generally making 

four trips per year, according to RAD officials. In addition, IO officers 

posted at U.S. embassies overseas can conduct circuit rides and 

interviews in embassies to adjudicate refugee applications, among other 

responsibilities.38 Before or during the circuit ride, USCIS officials are to 

take the applicants’ fingerprints, which are screened against DHS, 

Department of Defense, and FBI biometric databases, and if new 

information from the biometric check raises questions, USCIS officers 

may ask additional questions at the interview, require additional 

interviews, or deny the case. In addition, if USCIS officers identify new 

biographic information during the interview, such as an alias that was 

 37According to State SOPs, the CLASS check must be completed prior to RSC staff 

requesting that USCIS interview the applicant. RSC staff are to have submitted the 

Security Advisory Opinion and Interagency Checks prior to requesting the interview, but 

they may receive the results after the USCIS interview. 

38IO is the component of USCIS, within RAIO, that is charged with advancing the USCIS 

mission in the international arena. IO has 24 offices around the world.
Page 17 GAO-17-706 Refugee Screening Process

previously unknown or not disclosed to RSC staff, that information is 

vetted through the biographic security checks described above, per State 

and DHS policy. The officers are to place these applications on hold, 

pending the outcome of these checks. Further, consistent with USCIS 

policy, officers are required to place a case on hold to do additional 

research or investigation if, for example, the officer determines during the 

interview that the applicant may pose a national security concern. Based 

on the interviews and security checks conducted, USCIS officers will 

either approve or deny an applicant’s case.39 USCIS supervisory officers 

are to review 100 percent of officers’ adjudications, according to USCIS 

policy.

Final processing and travel to the United States. If USCIS approves 

an applicant’s refugee application, RSCs are to generally provide the 

applicant with cultural orientation classes on adjusting to life in the United 

States, facilitate medical checks, and prepare the applicant to travel. Prior 

to admission to the United States, applicants are subject to the standard 

CBP and Transportation Security Administration vetting and screening 

processes applied to all travelers destined for the United States by air.40

CBP is to inspect all refugees upon their arrival at one of seven U.S. 

 39According to State’s USRAP Overseas Processing Manual, if a USCIS officer denies a 

case and the RSC presents the applicant with the denial letter, the applicant has 90 days 

to file a Request for Review. Such reviews are divided into two categories: requests that 

allege an error in the adjudication and requests that introduce new evidence. An applicant 

for refugee resettlement who receives a Notice of Ineligibility for Resettlement may file 

only one request for review, although USCIS may, in its discretion, establish exceptions 

concerning subsequent requests for review. A review may result in USCIS overturning the 

denial, upholding the denial or requesting another interview with the applicant. State or 

USCIS can also close an applicant’s case for a variety of reasons, including the outcome 

of a security check, if State determines that the applicant does not meet USRAP criteria, 

or an applicant request to withdraw from the program. 

40All persons traveling to the United States by air are subject to standard U.S. government 

vetting practices. For example, CBP is to electronically vet all travelers, including persons 

seeking resettlement in the United States as refugees, before they board U.S.-bound 

flights and is to continue vetting the travelers until they land at a U.S. port of entry. Such 

travelers are also subject to Transportation Security Administration prescreening, as well 

as physical screening prior to boarding commercial aircraft destined for the United States 

in accordance with the agency’s policies and procedures. 
Page 18 GAO-17-706 Refugee Screening Process

airports designated for refugee arrivals and make the final determination 

about whether to admit the individual as a refugee to the United States.41

From fiscal year 2011 through June 2016, WRAPS data indicate that 

USRAP received about 655,000 referrals and applications, associated 

with about 288,000 cases. As figure 3 indicates, during this time frame, 

more than 75 percent of applications were from refugees fleeing 6 

countries—Iraq, Burma, Syria, Somalia, the Democratic Republic of 

Congo, and Bhutan—and the number of applicants from certain countries 

has changed over time. For example, the number of Bhutanese and 

Burmese applications decreased, but the number of Syrian and 

Congolese applications increased. State officials said that UNHCR 

submitted a large number of P1 Syrian referrals to USRAP in fiscal year 

2016 because more people were fleeing that country due to conflict and 

the goal of admitting 10,000 Syrian refugees. From October 2015 through 

June 2016, WRAPS data indicate that more than one-third of USRAP 

applicants were Syrian.

 41See 8 C.F.R. § 207.4. The seven U.S. airports designated for refugee arrivals are, 

according to CBP officials: Miami International Airport; Chicago O’Hare International 

Airport; Washington Dulles International Airport; John F. Kennedy International Airport 

(New York); Los Angeles International Airport; George Bush Intercontinental Airport 

(Houston); and Newark International Airport.

USRAP Applicant 

Characteristics Vary; 

About One-third of 

Applicants from Fiscal 

Year 2011 through 

June 2016 Have 

Been Admitted to the 

United States, as of 

June 2016

USRAP Applicant 

Characteristics Vary by 

Country of Nationality, 

Processing Location, and 

Case Size
Page 19 GAO-17-706 Refugee Screening Process

Figure 3: Refugee Applications Received by Country of Nationality and Year, Fiscal Year 2011 through June 2016, by Fiscal 

Year

Note: Not all U.S. Refugee Admissions Program applicants are ultimately admitted to the United 

States as refugees.

a

Fiscal year 2016 data includes applications received from October 2015 through June 2016.

In addition to nationality, USRAP applicants’ characteristics varied in 

other ways. For example, as shown in figure 4, applications to USRAP 

from fiscal year 2011 through June 2016 were largely split between the 

P1 or P2 categories and about two-thirds were processed in one of three 

RSCs (Middle East and North Africa, Africa, and East Asia). Further, 75 

percent of applicants were associated with cases that included immediate 
Page 20 GAO-17-706 Refugee Screening Process

family members (which includes a spouse and unmarried children under 

the age of 21), while 25 percent of cases included only 1 individual.42

Figure 4: Key Characteristics of Refugee Applications to the U.S Refugee Admissions Program (USRAP), Fiscal Year 2011 

through June 2016 (as of June 2016)

Note: Percentages may not sum to 100 due to rounding.

a

The USRAP priority system provides guidelines for managing and processing refugee applications. 

The three priority categories are: Priority 1, or individuals specifically referred to USRAP generally 

because they have a compelling need for protection; Priority 2, or specific groups, often within certain 

nationalities or ethnic groups in specified locations, whose members Department of State (State) and 

its partners have identified as being in need of resettlement; and Priority 3, or individuals from 

designated nationalities who have immediate family members in the United States who initially 

entered as refugees or who were granted asylum.

b

Family members who can be included on the same case include the principal applicant, his or her 

spouse, and unmarried children under the age of 21. Any additional members other than spouse or 

children must have their own cases. According to State officials, many applicants on their own cases 

have family members on another case.

 42According to State and DHS officials, many applicants with their own case have family 

members on another case. For example, a young adult son or daughter over the age of 21 

cannot be included on a parent’s case but may be cross-referenced.
Page 21 GAO-17-706 Refugee Screening Process

At any given time, there are a number of applicants at different stages of 

the USRAP process. According to State and RSC officials, State and 

USCIS process applications in the general order they were received. For 

example, table 1 shows that, of the applications received in fiscal year 

2011, 56 percent were approved and admitted to the United States as of 

June 2016, 13 percent were still in process (pending access to USRAP, 

actively being processed, or on hold), and 31 percent of applications were 

closed before the applicant completed the USRAP process, as of June 

2016.43 By comparison, as of June 2016, almost 70 percent of 

applications received in fiscal year 2015 were in process.

 43State or USCIS can close an applicant’s case for a variety of reasons, including the 

outcome of a security check, the applicant requested to withdraw from the program, or if 

the applicant is found otherwise not to be qualified for the program.

United States Admitted 35 

Percent of Applicants from 

Fiscal Year 2011 to June 

2016, and the Remaining 

Applications Were Closed 

or In Process, as of June 

2016
Page 22 GAO-17-706 Refugee Screening Process

Table 1: Status of U.S. Refugee Admissions Program (USRAP) Applications Received from Fiscal Year 2011 through June 

2016, by Fiscal Year (as of June 2016)

Fiscal year 

application 

received

Pending 

access to 

USRAPa Active On holdb

Closed or denied 

before USRAP process 

completedc

Admitted to 

the United 

States Total

2011 Less than 100

Less than 1%

8,000

6%

8,000

7%

37,000

31%

67,000

56%

120,000

2012 Less than 100

Less than 1%

4,000

5%

5,000

6%

22,000

27%

49,000

62%

80,000

2013 1,000

1%

8,000

9%

10,000

11%

25,000

27%

48,000

52%

92,000

2014 7,000

7%

23,000

22%

12,000

12%

25,000

23%

39,000

37%

106,000

2015 12,000

10%

43,000

36%

25,000

22%

16,000

14%

22,000

18%

119,000

2016

(as of June)

45,000

32%

62,000

44%

20,000

15%

10,000

7%

2,000

2%

139,000

Total 66,000

10%

147,000

22%

81,000

12%

134,000

20%

227,000

35%

655,000

Source: GAO analysis of USRAP data. | GAO-17-706.

Note: Data are rounded to the nearest thousand, and, as a result, the sum of the number of 

applicants across all fiscal years may be different than the rounded total.

a

After receiving an application, USRAP partners determine whether the applicant qualifies for an 

interview with U.S. Citizenship and Immigration Services (USCIS).

b

USCIS officers may place an application on hold after their in-person interview if they determine that 

additional information is needed to adjudicate an application.

c

Applicants with closed or denied applications did not complete the USRAP process because, for 

example, USCIS officers denied the application or the applicant withdrew from the program.

Program Access. Of the total number of applications received from fiscal 

years 2011 through June 2016 (about 655,000), State and its USRAP 

partners made access determinations for about 590,000 of that amount—

569,000 (or 96 percent) of which they accepted, as of June 2016.44 As 

described earlier, State and its USRAP partners makes the initial 

determination on whether to grant an applicant access (accept) to 

USRAP for subsequent screening and interview by USCIS officers.45

According to State officials, one reason the acceptance rate is high is 

because State Refugee Coordinators stationed overseas provide 

 44About 66,000 applications were pending an access determination.

45See app. II for additional information on which USRAP partners grant access for specific 

USRAP programs.
Page 23 GAO-17-706 Refugee Screening Process

feedback to UNHCR on the types of P1 applications that are not likely to 

be accepted or ultimately approved by USCIS officers. Further, according 

to State officials, State coordinates with UNHCR and USCIS to develop 

predefined eligibility criteria for certain P2 groups and applicants meeting 

those criteria may access USRAP once UNHCR submits the application 

to State. For example, State and UNHCR created a new P2 group in 

2015 for Congolese who fled to Tanzania. To be part of the P2 group, 

applicants must have registered with UNHCR and verified their residence 

in the Nyaragusu refugee camp.

From fiscal year 2011 through June 2016, acceptance of applications to 

USRAP for adjudication varied by nationality of the applicants. For 

example, excluding pending applications, USRAP partners did not accept 

8 percent of Iraqi applicants. USRAP partners also did not accept 4 

percent of Syrian applicants, and did not accept less than 1 percent of 

Burmese and Somali applicants. According to State officials, the most 

common reason why applicants are not accepted is that they fail to meet 

criteria to access USRAP. For example, according to State officials, 

acceptance rates were lower for Iraqi applicants because some Iraqis 

could not prove their association with the United States—a requirement 

under various P2 programs. As part of the adjudication process, USCIS 

officers are to confirm that applicants were appropriately granted access 

to USRAP. WRAPS data from fiscal year 2011 through June 2016 show 

that USCIS officers confirmed that over 99 percent (all but about 1,000 

out of 351,000) of the applicants interviewed were appropriately granted 

access to USRAP (i.e., qualify for adjudication by USCIS), as of June 

2016.

USCIS Adjudications. According to WRAPS data, as of June 2016, 

USCIS officers interviewed about 62 percent (351,000) of the applicants 

who were granted access to USRAP from fiscal year 2011 through June 

2016. USCIS officers approved 89 percent (314,000 of 351,000) and 

denied 7 percent (24,000) of these applications.46 Approval rates varied 

by RSC (see fig. 5).

 46Four percent of applications received a determination other than approved or denied, 

including that the applicant was not qualified for USRAP. USCIS officers can also make no 

determination at the time of the interview and place the application on hold.
Page 24 GAO-17-706 Refugee Screening Process

Figure 5: Percentage of Refugee Applications Approved by U.S. Citizenship and 

Immigration Services, by Resettlement Support Center (RSC), Fiscal Year 2011 

through June 2016 (as of June 2016)

Applications may also be put on hold for a number of reasons. For 

example, holds may occur because of security check results, a USCIS 

officer did not have sufficient information at the time of the interview to 

approve or deny the applications associated with the case, or as a result 

of new information that came to light after the interview. For applications 

in our time period of analysis, WRAPS data indicate that 12 percent 

(about 81,000) were on hold as of June 2016. USCIS officials stated that 

they would make a final decision on these cases after receiving additional 

information, which could include outstanding or additional security checks 

results, information from family members’ cases, and conducting 

additional interviews.
Page 25 GAO-17-706 Refugee Screening Process

About 24 percent (138,000) of the applicants who were granted access to 

USRAP from fiscal year 2011 through June 2016 were awaiting 

interviews with USCIS (i.e., the applicant had an active case or a case 

that was on hold but had not received an interview), as of June 2016.47

RSC Middle East and North Africa (58,000) and RSC Africa (40,000) had 

the largest number of applications awaiting interviews. Some applicants 

have waited years to receive a USCIS interview. For example, according 

to WRAPS data, about 9,000 applications submitted in fiscal years 2011 

or 2012 were active in June 2016 and the applicants had not yet received 

a USCIS interview. About 87 percent of these applications were 

applicants from Iraq or Somalia. In addition, there were about 6,000 

applications received in fiscal years 2011 and 2012 that were on hold and 

had not received a USCIS interview, 93 percent of whom were from Iraq, 

Somalia, or Burma. According to State officials, the security situations in 

Iraq and a refugee camp on the border of Kenya and Somalia where 

many Somali applicants are located have made it difficult to schedule 

USCIS interviews at certain times in these locations, among other 

reasons.

For applications received from fiscal year 2011 through June 2016 with 

security check results noted in WRAPS, the Interagency Check was the 

one that most often resulted in a result of “not clear” based on thresholds 

set by an interagency process including the intelligence community and 

law enforcement agencies.

48 However, “not clear” results—meaning, the 

checks identified security or fraud concerns—represented a small 

percentage of all results for each of the three biographic checks and the 

fingerprint check, as of June 2016.49 Further, of the applicants who were 

admitted to the United States or had closed applications as of June 2016, 

the median number of days from initiation of the biographic security 

checks (at the time of the RSC prescreening interview) through the last 

 47Fourteen percent of applications were accepted for a USCIS interview but closed prior to 

an officer conducting the interview.

48According to USCIS officials, the thresholds for all security checks are established by 

interagency committees, typically at the Deputies’ level, facilitated by the National Security 

Council, and reflect the U.S. government’s collective determination for the level of security 

vetting within USRAP. Applicants may receive a “not clear” result for more than one 

security check. According to USRAP procedures, if one applicant on a case receives a 

“not clear” result, the status of all family members on the case becomes “not clear.”

49Specific details on the number of security checks conducted and the associated results 

are omitted from this report because State deemed the information to be sensitive.

A Small Percentage of 

USRAP Applicants Were 

Not Admitted to the United 

States as a Result of 

Biographic and Biometric 

Checks
Page 26 GAO-17-706 Refugee Screening Process

completed Interagency Check (which is often the last check prior to 

departure for the United States) was 247 days.

According to WRAPS data, the overwhelming majority of the about 

227,000 applicants from fiscal year 2011 through June 2016 who were 

admitted to the United States as refugees had “clear” security check 

results, as of June 2016. However, one applicant who was admitted to the 

United States in 2012 had his security check status change from “clear” to 

“not clear” days before his planned travel. The security vetting process at 

that time did not account for responses from a vetting agency that had not 

been specifically requested and, therefore, an additional check of security 

vetting responses after receipt of a final response of “clear” had not been 

conducted. According to State officials, when the RSC realized the 

applicant had a “not clear” response, it notified local USCIS officials 

immediately. USCIS data show that the refugee has since adjusted to 

legal permanent resident status.50 According to a USCIS branch chief, at 

the time of the individual’s adjustment application, the derogatory 

information (which predicated the “not clear”) had been resolved and 

there was no basis for USCIS to deny the individual’s adjustment 

application. State has since updated security SOPs to require RSCs to 

run daily reports to check if any applicants with imminent travel plans 

have received an unsolicited Interagency Check “not clear.”

 50See 8 U.S.C. § 1159(a) (establishing requirements for adjustment of status); 8 C.F.R. § 

209.1(b) (providing that upon admission to the United States, every refugee entrant will be 

notified of the requirement to submit an application for permanent residence one year after 

entry).
Page 27 GAO-17-706 Refugee Screening Process

The length of time to process a USRAP application varies. For example, 

of the applicants who applied from fiscal year 2011 through June 2016 

and had been admitted to the United States, as of June 2016, 27 percent 

were processed in less than 1 year, 47 percent between 1 and 2 years, 

and 26 percent in more than 2 years. Figure 6 shows the cumulative 

length of time (median number of days) of key phases in the USRAP 

process. The lengthiest phase was from the time USCIS approved the 

applicant through arrival in the United States (a median of 189 days).51

 51Median number of days between key processing phases may not be the same as the 

cumulative number of days in processing for the same phases because not all 

applications had recorded dates for all phases. After USCIS conditional approval, the 

applicant undergoes medical exams (the results of which are considered as part of the 

final refugee adjudication) and attends cultural orientation sessions, and the RSC 

prepares the applicant to travel. According to State officials, security checks continue 

during all of these processes and contribute to processing time before departure. Officials 

said that certain security checks will continue after an applicant arrives and is admitted to 

the United States. 

USRAP Process Took 1 

Year or Longer to 

Complete from Case 

Creation through Arrival in 

the United States for 

About Three Quarters of 

Applicants Whom USCIS 

Approved
Page 28 GAO-17-706 Refugee Screening Process

Figure 6: Median Length of Time from Creation of a Case to Subsequent Key Phases in the U.S. Refugee Admissions Program 

(USRAP), Applications Submitted Fiscal Year 2011 through June 2016 (as of June 2016)

Note: Data are rounded to the nearest thousand. Not all applications have data for all phases 

completed.

a

USCIS may interview an applicant multiple times before making a decision on his or her case. In 

addition, the decision may be pending the outcome of security checks that occur after the USCIS 

interview.
Page 29 GAO-17-706 Refugee Screening Process

State and RSCs have various policies and SOPs, trainings, and quality 

checks related to refugee case processing and prescreening.

Policies and SOPs for USRAP. State’s USRAP Overseas Processing 

Manual provides an outline of the policies and procedures involved in 

overseas processing for USRAP, including instructions for using WRAPS, 

requirements for what information RSCs should collect during 

prescreening, and instructions and requirements for initiating certain 

national security checks, among other things.52 In addition, State 

developed SOPs for processing and prescreening refugee applications at 

RSCs, which State officials indicated provide baseline standards for RSC 

operations. Further, all four of the RSCs we visited provided us with their 

own local SOPs that incorporated the topics covered in State’s SOPs. 

Directors at the remaining five RSCs also told us that they had developed 

local SOPs that covered the overarching USRAP requirements.

We observed how RSC staff implemented State’s case processing and 

prescreening policies and procedures during our site visits to four RSCs 

from June 2016 to September 2016. Specifically, we observed 27 

prescreening interviews conducted by RSC caseworkers at the four RSCs 

we visited and found that these caseworkers generally adhered to State 

requirements during these interviews. For example, RSC caseworkers we 

observed reviewed applicants’ identification documents (e.g. passport, 

 52Department of State, USRAP Overseas Processing Manual (Washington, D.C.: October 

2015). 

State and RSCs Have 

Policies and 

Procedures for 

Processing Refugees, 

but State Could 

Improve Efforts to 

Monitor RSC 

Performance

State and RSCs Have 

Policies and Procedures 

on Refugee Case 

Processing and 

Prescreening
Page 30 GAO-17-706 Refugee Screening Process

birth certificate, or marriage certificate) and recorded name variations 

(e.g. alternate spellings to confirm identity and for use in security checks); 

recorded “family tree” information (for security checks and to confirm 

family relationships for subsequent applicants); and recorded the 

applicants’ flight paths and persecution stories (to be used by USCIS 

officers in their interviews and to determine if the applicant qualifies as a 

refugee). In one location, we observed that RSC caseworkers were not 

consistently asking applicants during the prescreening interviews if they 

had any other aliases or nicknames. Further, USCIS officers identified the 

same issue in three separate RSCs, during circuit rides in fiscal years

2014, 2015, and 2016, according to RAD trip reports.53 Asking about 

aliases and nicknames is an expected practice for all RSC staff 

conducting prescreening interviews, according to State and RSC officials, 

because the information could be useful and important during an 

applicant’s biographic national security checks. Further, State officials 

said that if aliases are not identified prior to USCIS interview, it may delay 

processing because when USCIS officers identify additional names the 

RSCs must resubmit security checks. We brought the issue to the 

attention of RSC and State management, and, in response to our 

observations, the RSC revised its local SOPs to more clearly instruct 

RSC caseworkers to ask applicants if they had any aliases or nicknames, 

and State revised its prescreening SOPs and informed all other RSCs of 

the change.

In addition, we observed how RSC staff in all four locations implemented 

additional required procedures during our site visits, such as initiating 

required security checks through WRAPS and compiling case file 

information for USCIS interviewing officers, and found that these RSC 

staff were complying with SOPs. Further, all nine RSC directors we 

interviewed stated that they were familiar with State’s requirements for 

their location and reported implementing them.

Training on USRAP requirements. On the basis of our analysis of 

State’s cooperative agreements, RSC monitoring documents submitted to 

State, and interviews with State headquarters’ officials and all nine RSC 

directors, we found that these RSCs reported having various trainings for 

 53We analyzed available trip reports on circuit rides completed between July 2014 and 

June 2016. USCIS trip reports are summaries of circuit rides completed by USCIS team 

leads that include, among other things, summaries and trends in adjudications, cases that 

involved national security concerns, and suggestions on how to improve training and 

guidance for officers whom USCIS sends on future circuit rides to that location.
Page 31 GAO-17-706 Refugee Screening Process

their staff. According to State officials, they have not developed specific 

training requirements for all RSCs because each RSC has different needs 

and conditions requiring individualized training programs. All nine RSC 

directors with whom we spoke said they have training programs ranging 

from technical trainings (e.g., WRAPS or interview training) to shadowing 

programs in which newly-hired staff observe more experienced RSC 

employees performing their duties. During our September 2016 site visit 

to RSC Africa, for example, we observed new-hire training for RSC 

caseworkers, as well as more experienced caseworkers mentoring and 

coaching the newer staff. At RSC Latin America, according to the director, 

new staff receive 1 week of WRAPS training and observe more 

experienced caseworkers conduct prescreening interviews until the new 

staff member is able to conduct the interviews alone.

Quality control checks. On the basis of our analysis of RSC monitoring 

documents submitted to State, cooperative agreements, observations at 

the four RSCs we visited, and interviews with State headquarters’ officials 

and all nine RSC directors, RSCs have quality control checks to oversee 

case processing and prescreening to help ensure that RSC staff collect 

accurate and reliable information. For example, at all four RSCs we 

visited, we observed staff conducting both electronic and manual quality 

control checks of case information. Specifically, after the prescreening 

interview, RSC staff in all four locations reviewed the hard copy case file 

and ran checks in WRAPS for errors or omissions. Further, all four RSCs 

we visited had a dedicated quality control unit that is to monitor data 

quality and review regular data monitoring reports. Moreover, RSC 

directors in the other five locations stated that they have similar quality 

control checks in place, and all nine RSC directors stated that there are 

quality control checks at every stage of the USRAP process from case 

creation in WRAPS to when refugees are about to depart for the United 

States.

According to USCIS officials we interviewed at headquarters and in the 

field, RSCs generally provide the information that USCIS officers needed 

to adjudicate applications, but they also identified areas for improvement 

during some circuit rides. For example, all 10 USCIS officers that we 

interviewed who participated in the circuit rides associated with our site 

visits stated that the information gathered by RSCs during the 

prescreening process was generally accurate, complete, and useful. 

However, 4 of these officers stated that they have encountered some 

errors when RSCs provided case files with missing documents or 

information. In addition, 70 out of the 107 RAD trip reports we analyzed 

contained feedback on RSC activities. Of these 70 reports, 10 reports 
Page 32 GAO-17-706 Refugee Screening Process

stated that RSCs generally prepared the cases well, but 45 reports 

identified concerns with the quality of certain case files, including missing 

documentation.54 According to USCIS officials, missing documentation 

can lead to delays during the circuit ride while RSC staff obtain and 

provide copies of the missing documents or USCIS officers obtain the 

missing information during the interview. In addition, USCIS officers may 

need to place the application on hold until the missing documentation can 

be obtained.55 USCIS officers and State officials we interviewed stated 

that some of the missing information could only have been obtained 

during the USCIS interviews with applicants, while others stated that 

applicants can forget or neglect to give RSC staff all of their 

documentation despite repeated reminders from RSC staff. Further, five 

of the nine RSC managers stated that they request USCIS officers submit 

feedback at the end of circuit rides on the quality of the case file content 

and interpreters, and three of these RSC managers stated that they take 

action based on USCIS’s feedback.56 For example, RSC managers in two 

locations stated that they have excluded certain interpreters—who are 

hired on daily contracts—from subsequent circuit rides based on the 

feedback from USCIS officers. Additionally, USCIS officials stated that 

their supervisory officers often meet with RSC staff throughout and at the 

conclusion of a circuit ride to offer feedback on case preparation, among 

other things. USCIS headquarters officials also offer feedback to State 

headquarters officials on RSC operations after circuit ride teams return to 

Washington, D.C.

 54Twenty two of the 70 trip reports did not include information on case file quality. Seven 

of the 10 trip reports concluded that RSCs generally prepared the cases well and also 

identified concerns about RSC processing activities. 

55Some trip reports we reviewed included more than one concern about RSC processing 

activities. 

56The other two RSC managers did not comment on the actions taken based on USCIS 

feedback.
Page 33 GAO-17-706 Refugee Screening Process

State has control activities in place to monitor how RSCs implement 

policies and procedures for USRAP, but it does not have outcome-based 

performance indicators to assess whether RSCs are meeting their 

objectives under USRAP. Consistent with State’s January 2016 Federal 

Assistance Policy Directive, and according to State officials, State is 

required to monitor the RSCs it funds, whether through cooperative 

agreements or voluntary contributions.57 State funds four RSCs through 

cooperative agreements, four through a voluntary contribution to the 

International Organization for Migration (IOM), and self-operates the final 

RSC (RSC Cuba).58 On the basis of our interviews with State officials and 

as reflected in documentation from all nine RSCs, including quarterly 

reports to State, all RSCs have generally undergone the same monitoring 

regime regardless of funding mechanism. The four cooperative 

agreements and MOU with IOM establish objectives for the RSCs, which 

include interviewing applicants to obtain relevant information for the 

adjudication and ensuring the accuracy of information in WRAPS and the 

case files. State also establishes annual targets for the number of 

refugees who depart for the United States from each RSC.

In addition, the cooperative agreements between the RSCs and State 

specify that State will periodically visit and evaluate the general 

performance of RSC operations. They also require RSCs to provide State 

with regular written reports on whether performance is in compliance with 

all the terms and conditions of the agreement. Consistent with funding 

requirements, the four RSCs with cooperative agreements submitted 

quarterly reports to State in fiscal year 2015, for example, that included 

information on how each RSC is addressing USRAP objectives. The 

reports included the number of applicants prescreened each quarter, the 

number of approved applicants who received cultural orientation training, 

and how RSCs compile applicant information. In addition, the four RSCs 

operated by IOM submitted quarterly reports using the same template.59

 57Department of State, Federal Assistance Policy Directive (Washington, D.C.: January 

2016).

58The four RSCs with cooperative agreements are RSC Africa, RSC Austria, RSC East 

Asia, and RSC Turkey and the Middle East. The four RSCs run by the International 

Organization for Migration through a voluntary contribution from State are RSC Eurasia, 

RSC Latin America, RSC Middle East and North Africa, and RSC South Asia. 

59RSC Cuba does not submit quarterly reports because resettlement support operations in 

Cuba are performed directly by State‐employed U.S. Embassy staff.

State Has Controls in 

Place to Monitor RSCs, 

but Does Not Have 

Outcome-based Indicators 

to Assess RSC 

Performance across Key 

Activities
Page 34 GAO-17-706 Refugee Screening Process

Further, according to State officials, the department has dedicated 

Program Officers located in Washington, D.C., and Refugee Coordinators 

based in U.S. embassies worldwide, who are responsible for providing 

support to RSCs and monitoring their activities. State headquarters 

officials and Refugee Coordinators we met with at the four RSC locations 

we visited told us that they have daily, informal interaction—via 

telephone, e-mail, or in-person—with the RSCs. State’s Program Officers 

also stated that they coordinate regularly with RSCs and conduct annual 

monitoring visits at RSCs to assess RSCs’ performance and complete 

monitoring reports based on their visits. We reviewed monitoring reports 

from eight State site visits to RSCs completed between 2015 and 2016 

and found that some included narrative discussions of RSC case 

processing and timeframes, records management, coordination with other 

USRAP partners, and other topics.60 However, not all monitoring reports 

included consistent information on the same topics. For example, four of 

the eight monitoring reports we analyzed did not contain information on 

RSC case processing, prescreening interviews, and security check 

activities. Further, Program Officers are to complete separate monitoring 

reports for RSCs funded through cooperative agreements that assess the 

degree to which RSCs are making progress towards objectives based on 

project indicators. The indicators for RSCs, according to two fiscal year 

2016 reports we reviewed, include the number of individuals prescreened 

and presented to USCIS for interview, the number of individuals who 

received cultural orientation training, the number of refugees that 

departed from those RSCs to the United States, and whether the RSCs 

ran security checks on all applicants. According to State officials, they 

also conduct daily monitoring of RSC activities through WRAPS data, 

which may be useful for monitoring RSC workload or data quality issues.

Although State has established objectives and monitors several 

quantitative goals for RSCs—including the number of refugees that 

depart each year for the United States and the number of applicants who 

receive cultural orientation training—it has not established outcomebased performance indicators for key RSC activities such as 

prescreening applicants or accurate case file preparation, or monitored 

 60State officials said that no monitoring report was available for the South Asia RSC 

because State officials found no major deficiencies and as a result decided to provide an 

oral briefing instead of a written report.
Page 35 GAO-17-706 Refugee Screening Process

RSC performance consistently across such indicators.61 Specifically, 

neither the quarterly reports nor other monitoring reports we examined 

have or use consistent outcome-based performance indicators from 

which State Program Officers could evaluate whether RSCs were 

consistently and effectively prescreening applicants and preparing case 

files—key RSC activities that have important implications for timely and 

effective USCIS interviews and security checks. RSCs collect 

performance information from USCIS officers through surveys or inperson feedback sessions at the end of circuit rides, which could help 

inform the development of outcome-based performance indicators. For 

example, the survey asks USCIS officers to rate the quality of the RSC 

staff’s documentation of the applicants’ persecution claim. State could 

develop an indicator from this information and measure progress against 

it.

According to State’s January 2016 policy directive, all assistance awards 

made by bureaus, offices, and posts—both domestic and overseas—

within the department with assistance-awarding authority should have a 

monitoring plan that includes goals, objectives, and indicators that are 

outcome-oriented and capable of measuring the recipient’s progress in 

meeting these goals.62 In addition, according to State’s Performance 

Management Guidebook, a program requires a systematic process for 

monitoring the achievement of program activities; analyzing performance 

to track progress toward planned results; and using performance 

information and evaluations to influence program implementation and 

results.63 The guidebook states that each bureau, program, or project 

should establish goals; have specific measurable, outcome-oriented 

objectives; and develop and monitor performance indicators that focus on 

the results or effects caused. Moreover, in accordance with GPRA, as 

updated by GPRAMA, performance measurement is the ongoing 

monitoring and reporting of program accomplishments, particularly 

towards pre-established goals, and agencies are to establish 

 61Output-based performance indicators measure the direct products or services delivered 

by a program, while outcome-based indicators measures the results of those products or 

services.

62Department of State, Federal Assistance Policy Directive (Washington, D.C.: January 

2016).

63Department of State, Performance Management Guidebook: Resources, Tips, and 

Tools (Washington, D.C.: December 2011).
Page 36 GAO-17-706 Refugee Screening Process

performance measures to assess progress towards goals.64 These 

measures should link program efforts to desired outcomes. While 

GPRAMA is applicable to the department or agency level, performance 

goals and measures are important management tools to all levels of an 

agency.65

State officials said that in September 2016 they began to staff a new 

policy section within State’s Office of Admissions, and staff within this 

section are to begin standardizing the reporting of monitoring efforts, 

among other things. In addition, as of March 2017, according to State 

officials, the department and IOM were in the process of revising the 

MOU to include, among other things, new monitoring and reporting 

requirements that includes performance indicators. These officials also 

stated that, in future cooperative agreements, they plan to build on 

performance indicators developed by IOM while ensuring outcome-based 

results. However, as of March 2017, State did not have documentation or 

timelines for its plans to develop outcome-based performance indicators. 

Developing outcome-based performance indicators, as required by State 

policy and performance management guidance, and monitoring RSC 

performance against such indicators on a regular basis, would better 

position State to determine whether all RSCs are processing refugee 

applications in accordance with their responsibilities under USRAP.

 64See generally Pub. L. No. 103-62, 107 Stat. 285 (1993) (GPRA) and Pub. L. No. 111-

352, 124 Stat. 3866 (2011) (updating GPRA); 31 U.S.C. § 1115.

65GAO, Managing For Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005).
Page 37 GAO-17-706 Refugee Screening Process

USCIS has policies and procedures to determine how to assign officers—

RAD, IO, and temporary duty officers from other USCIS divisions—on 

circuit rides to adjudicate USRAP applications. According to USCIS 

officials, each fiscal year, based on State’s determination of the estimated 

number of cases that will be ready for USCIS interviews, RAD and IO 

divide responsibility for the anticipated workload. In general, RAD officers 

adjudicate refugee applications in locations where the caseload is large, 

such as Jordan and Kenya. According to USCIS officials, IO officers 

generally adjudicate refugee applications in locations where the refugee 

caseload is small, such as Pakistan, or where IO has a permanent office 

presence, such as Moscow, Russia. In fiscal year 2016, USCIS

interviewed 43,705 refugee cases comprising 120,919 individuals. RAD 

interviewed 36,706 and, IO interviewed 6,999 of these cases.

USCIS solicits a pool of temporary duty (temporary) officers from offices 

throughout USCIS who have volunteered to adjudicate refugee 

applications on circuit rides, contingent upon receiving additional training, 

when RAD or IO do not have sufficient staff capacity to meet the workload 

demands. According to RAD headquarters officials, there are no 

restrictions on assigning temporary officers to particular circuit rides. RAD 

officials stated that they generally assign RAD and temporary officers 

based on officers’ availability and interview experience. Additionally, 

temporary officers may commit to doing one or more circuit rides over one 

USCIS Has Policies 

and Procedures for 

Adjudicating Refugee 

Applications, but 

Could Improve 

Training and Quality 

Assurance

USCIS Has Policies and 

Procedures to Assign 

Officers and Adjudicate 

Refugee Applications

Staffing USCIS Circuit Rides
Page 38 GAO-17-706 Refugee Screening Process

or more fiscal years. USCIS headquarters officials acknowledged that 

applications in some locations are more difficult to adjudicate than others 

and some temporary officers may not be as proficient or experienced at 

adjudicating applications as permanent RAD and IO officers. As a result, 

as resources permit, RAD and IO officials stated that they try to place 

temporary officers on circuit rides with caseloads that are best suited for 

their experience level. RAD headquarters officials also stated that, 

historically, they have planned for temporary officers to conduct 

approximately 15 to 25 percent of RAD’s refugee interviews and expect 

temporary officers to continue to be part of their workforce plan. When the 

refugee ceiling increased to 85,000 in fiscal year 2016, RAD increased 

the number of temporary officers on circuit rides to meet immediate 

mission needs while also working to hire additional refugee officers. RAD 

officials stated that, in fiscal year 2016, temporary staff completed 41 

percent of RAD’s interviews. As of March 2017, RAD officials stated that 

they have undertaken significant hiring efforts in the past year, reducing 

the need for temporary officers. In addition, IO officials stated that fewer 

than 25 percent of the officers who participated in IO circuit rides in fiscal 

year 2016 were temporary officers. As of March 2017, IO officials stated 

that they do not plan to use temporary officers to adjudicate refugee 

applications for the remainder of fiscal year 2017.

USCIS has developed policies and procedures for adjudicating refugee 

applications. These policies and procedures apply to RAD, IO, and

temporary officers and include policies and procedures for how officers 

are to review the case file before the interview and conduct the interview 

as well as how supervisors are to review applications to ensure they are 

legally sufficient. For example, USCIS has developed a refugee 

application assessment tool that all officers are to use when interviewing 

the applicant to determine if the applicant was appropriately granted 

access to USRAP, had past persecution or a well-founded fear of 

persecution, is credible, is not a persecutor, and is admissible to the 

United States—including whether the applicant might be inadmissible due 

to national security or terrorism-related concerns. According to the 

assessment tool, at the time of interview, the USCIS officer is responsible 

for ensuring that appropriate security checks have been completed before 

making a decision on the application. Further, after receiving a completed 

refugee case file, supervisors are to review all forms and documents in 

the file that are relevant to establishing eligibility for refugee resettlement, 

including any documents provided by UNHCR or the RSC and those 

completed by the interviewing officer. Supervisors are to review the case 

file completed by the interviewing officer to ensure that the officer’s 

decision is legally sufficient, that the officer has reviewed security check 

Adjudication Policies and 

Procedures
Page 39 GAO-17-706 Refugee Screening Process

results, and that all sections of the refugee application assessment are 

accurate and complete. In addition, USCIS has developed policies and 

procedures for determining when to place applications on hold. 

Specifically, officers may place an application on hold when the officer 

cannot make a final decision at the time of the interview—for example, if 

the outcomes of all required security checks are not yet available or if 

national security indicators requiring additional research become known 

to the officer at any point during the interview.

We observed 29 USCIS RAD refugee interviews (including interviews by 

RAD officers and temporary officers) at four RSCs that we visited from 

June 2016 to September 2016 and found that the interviewing officers 

completed all parts of the assessment tool and placed cases that had 

pending security checks on hold, as required. We also observed that the 

USCIS officers documented the questions they asked and the answers 

the applicants provided. We also observed RAD supervisors while they 

reviewed officers’ initial decisions, interview transcripts, and case file 

documentation, consistent with RAD policy, at two of the sites we 

visited.66 Further, all six of the USCIS officers that we met with stated that 

supervisors conducted the required supervisory case file review during 

their circuit rides and the four supervisory officers we met with were 

aware of the requirements and stated that they conducted the supervisory 

reviews.67

According to USCIS policy, all USCIS officers who adjudicate refugee 

applications must complete specialized training, and the training varies 

based on the USCIS division of the officer (for example, Asylum or 

Refugee Affairs). However, temporary officers receive a condensed (or 

shortened) version of the trainings received by full time refugee officers 

and do not receive infield training. Figure 7 shows the training USCIS 

officers receive depending on whether they are in RAD, IO, or another 

USCIS division (i.e., a temporary officer).

 66We did not have an opportunity to directly observe supervisory review at the remaining 

two locations. 

67Of the interviewing officers we met with, 8 were refugee officers and 2 were temporary 

officers. None of the supervisors were temporary officers. 

USCIS Provides 

Specialized Training to All 

Officers Who Adjudicate 

Refugee Applications, but 

Could Improve Training for 

Temporary Officers
Page 40 GAO-17-706 Refugee Screening Process

Figure 7: U.S. Citizenship and Immigration Services (USCIS) Initial Training 

Requirements for Officers Who Adjudicate Refugee Applications

a

According to International Operations (IO) officials, most IO circuit rides include a small number of 

staff and the predeparture briefing is less formalized than the Refugee Affairs Division (RAD) 

predeparture briefing.

b

According to IO officials, some IO officers receive in-field training from a dedicated trainer on RAD 

circuit rides, while others may receive in-field mentoring through other means, such as being paired 

with a more experienced officer on their first circuit ride.

c

Applies to individuals who have completed affirmative asylum interviews within the past year. Like 

refugee officers, asylum officers conduct interviews to assess whether an applicant has credibly 

established that he or she is a refugee.

d

Applies to individuals who have never conducted refugee or asylum interviews or whose most recent 

RAD or asylum interviewing experience was more than 5 years ago.

Protection Training. RAD training requirements for refugee officers state 

that officers are to attend a 4 week, in-person training (referred to as 

refugee basic training) that is specific to the refugee adjudication process, 

including classroom sessions, a written exam, and at least three mock 

interviews. IO headquarters officials stated that IO officers are to attend 

refugee basic training before adjudicating refugee applications. To 

adjudicate refugee applications, temporary officers are to have received 

“protection training,” the content of which varies based on the experience 
Page 41 GAO-17-706 Refugee Screening Process

and qualifications of the temporary officer.68 Specifically, RAD’s training 

requirements for temporary officers state that officers who have not 

interviewed refugees in the past year are to receive an abbreviated inperson training that is either 3 days (if the temporary officer has recent 

interviewing experience for RAIO directorates, such as an asylum officer) 

or 20 days (if the temporary officer does not have recent interviewing 

experience for RAIO directorates).69 On the basis of our review of training 

syllabi, topics in refugee basic training, and temporary officer trainings 

include, at a minimum, applicable refugee and other immigration laws, 

refugee case file review, national security concerns, bars to refugee 

admission to the United States, and credibility assessment.

Middle East Refugee Processing Training. Further, since October 

2014, all officers (including temporary officers) who adjudicate 

applications that include applicants from Iraq and Syria are required to 

take the week-long Middle East Refugee Processing training.70 This 

training provides information to officers on the region’s history, specific 

country conditions, and additional training on indicators of potential 

national security concerns—such as military service history—for refugee 

applicants from Iran, Iraq, and Syria. This training includes briefings from 

law enforcement and the intelligence community.

Predeparture briefings. In addition, prior to each RAD circuit ride, all 

officers, including temporary officers, who will adjudicate applications on 

that circuit ride are to receive a predeparture briefing that includes, 

among other things, any updated information on national security 

 68For example, RAD considers Asylum Division Officer Training, the division-specific 

training course for USCIS asylum officers, protection training. Like refugee officers, 

asylum officers conduct interviews to assess whether an applicant has credibly 

established that he or she is a refugee within the meaning of U.S. immigration law. 

However, whereas refugee officers travel overseas to interview applicants, asylum officers 

interview applicants from within the United States. RAD also utilizes USCIS attorneys from 

the Office of the Chief Counsel, especially the Refugee and Asylum Law Division and the 

Administrative Appeals Office as temporary officers on refugee circuit rides. According to 

USCIS officials, these officers have had extensive immigration and refugee-related legal 

training. 

69For example, officers who have conducted asylum interviews within the past year are to 

take the 3-day training. Officers who have not conducted refugee interviews in 5 or more 

years are to take the 20-day training.

70A previous version of this training for officers who adjudicated applications from Iraq, 

known as Iraqi training, began in June 2007. In October 2014, Iraqi training was 

lengthened and expanded to the current Middle East refugee processing training.
Page 42 GAO-17-706 Refugee Screening Process

concerns and caseload trends for the particular circuit ride population. IO 

officials stated that their circuit rides are smaller and they do not always 

have formal predeparture briefings.71 However, IO officials told us their 

officers spend time before circuit rides reviewing case files and 

researching any country conditions or policy updates that officers deem 

relevant to their cases. All 10 RAD or temporary officers we interviewed 

who adjudicated applications or reviewed cases on the RAD circuit rides 

we observed stated that the USCIS trainings—particularly the 

predeparture briefings—were valuable and helpful.

In-field training. RAD officers receive 10 days of “in-field training” from a 

dedicated trainer on their first circuit ride. According to RAD training 

requirements and circuit ride trip reports, during the in-field training 

period, new officers are to observe experienced interviewers, conduct 

interviews on a reduced schedule, receive individual guidance and 

performance feedback, and discuss case-specific issues with the trainers. 

In particular, 3 of the 107 trip reports we analyzed covered circuit rides 

with in-field training and noted that the in-field training period was 

valuable for new officers. For example, one report stated that new 

refugee officers benefited greatly from the in-field trainer’s knowledge and 

ability to be fully available for training and development. IO officials stated 

that they do not require formal in-field training for all new officers. Some 

new IO officers receive formal in-field training on RAD circuit rides, while 

others on smaller circuit rides may be paired with a more experienced 

officer and receive in-field mentoring on their first circuit ride. However, 

temporary officers do not receive in-field training.

Although temporary officers receive training prior to participating in circuit 

rides, we found that they sometimes face challenges adjudicating refugee 

applications. For example, we analyzed the 44 available trip reports 

completed from July 2014 through June 2016 from RAD circuit rides that 

included temporary officers.72 In 15 of the 44 reports (about one-third), the 

RAD circuit ride supervisors noted that temporary officers faced 

challenges adjudicating refugee applications on the circuit ride. For 

example, one report indicated that although temporary officers completed 

 71IO officials stated that IO does not necessarily hold formal pre-departure briefings 

because, in some locations, the same few IO officers may be processing the same 

refugee populations on multiple occasions. Thus, those particular IO officers may already 

be familiar with that caseload and may not require a formal pre-departure briefing.

72We analyzed all 107 available reports completed following circuit rides during this time 

frame. 
Page 43 GAO-17-706 Refugee Screening Process

the required training and predeparture briefing, they seemed not to have 

retained much information. Other reports indicated that temporary officers 

stated that they did not feel prepared to conduct some aspects of 

administrative and interview processes or that most temporary staff on 

the circuit ride only began to grasp the full range of law, policy, and 

procedures after 4 to 5 weeks on the circuit ride. One report also noted 

that temporary officers required de-facto mentoring on a daily basis. 

Further, USCIS headquarters officials and two interviewing officers we 

spoke with told us that some temporary officers make more errors than 

experienced officers, which contributes to inefficiencies, such as extra 

hours worked by supervisors. In addition, one temporary officer we 

observed stated that, despite the training she received, she felt 

unprepared to adjudicate cases on the first few days of her circuit ride. 

According to USCIS officials, all adjudications that are finalized have 

been determined by a supervisor to be legally sufficient. Consistent with 

USCIS policy, a supervisor is to review each case file and determine that 

the officer’s decision on the application is legally sufficient, among other 

things, before the decision is finalized. The supervisor may agree with the 

officer’s decision, request a reinterview for more information, or overturn 

the officer’s decision.

On the basis of their review of trip reports, USCIS headquarters officials 

stated that in 2016, they revised the Refugee Processing Overview 

training (which is required for temporary officers with recent RAIO 

interviewing experience, such as asylum officers) and the predeparture 

briefing content (up to 8 days) to include mock interviews and more 

practical exercises about the refugee adjudication process. We reviewed 

syllabi for the Refugee Processing Overview training and found that the 

training increased from 1 day, without mock interviews, in April 2015 to 3 

days, with two mock interviews and additional practical exercises about 

national security and terrorism-related concerns, in March 2016. 

However, unlike RAD officers and IO officers, USCIS has not offered infield training for temporary officers.

Standards for Internal Control in the Federal Government states that 

management should demonstrate a commitment to recruit, develop, and 

retain competent individuals. The standards also note that competence is 

the qualification to carry out assigned responsibilities, and requires 

relevant knowledge, skills, and abilities, which are gained largely from 

professional experience, training, and certifications.73 USCIS officials told 

 73GAO-14-704G.
Page 44 GAO-17-706 Refugee Screening Process

us that temporary officers receive a number of accommodations to help 

them adjudicate applications—including a reduced ramp-up schedule on 

their first days of interviewing and a compilation of frequently used 

adjudication tools and guidance—but that USCIS is unable to offer in-field 

training to temporary officers due to resource constraints. 

In March 2017, RAD officials also stated that they have undertaken 

significant hiring efforts in the past year, reducing the need for temporary 

officers. IO officials also said IO does not plan to use temporary officers 

for the remainder of fiscal year 2017. Nevertheless, interviewing officers, 

including temporary officers, play a critical role in the refugee adjudication 

process, and USCIS may use temporary officers to meet workload 

demands in the future. Some temporary officers have committed to 

working on three circuit rides in a 2-year period, and may interview 

hundreds of refugee cases over that time frame. Further, while enhancing 

training for temporary officers may require additional resources, the lack 

of experience and preparation among temporary officers has led to 

inefficiencies, as described by some USCIS supervisors. To the extent 

that USCIS uses temporary officers on future circuit rides, providing them 

with additional training, such as in-field training, would help better prepare 

them to interview refugees and adjudicate their applications, increase the 

quality and efficiency of their work, and potentially reduce the supervisory 

burden on those who oversee temporary officers.
Page 45 GAO-17-706 Refugee Screening Process

In addition to training, USCIS has developed guidance documents and 

tools to help officers identify USRAP applicants with potential national 

security concerns. However, USCIS could strengthen its efforts by 

developing and implementing a plan for deploying officers with national 

security expertise on selected circuit rides. USCIS provides a number of 

resources to officers to help them identify and address potential national 

security-related concerns in USRAP applications.

74 Further, security 

check results (provided by interagency vetting partners) may help officers 

identify security concerns before the refugee interview. In addition, 

USCIS’s national security policies and operating procedures require that 

cases with national security concerns be placed on hold by interviewing 

officers. These cases are then reviewed by USCIS headquarters staff 

who have additional specialized training and expertise in vetting national 

security issues. These headquarters staff can clear the hold, deny the 

case, or refer the case back to USCIS officers for reinterview with 

suggested lines of questioning. Further, RAD maintains training lesson 

plans, guidance on particular issues (such as terrorism-related 

inadmissibilities), and country conditions information that is accessible to 

interviewing officers overseas. As discussed above, USCIS provides the 

most up-to-date guidance to interviewing officers during its predeparture 

briefings.

While USCIS has training and guidance to adjudicate cases with national 

security-related concerns, USCIS trip reports and officers we interviewed 

indicated that it can be challenging to adjudicate such applications. About 

half of the trip reports we analyzed (52 of 107) identified national security 

concerns as a training need for future circuit rides or made policy or 

guidance requests regarding national security concerns. Of these 52 

reports, 33 were from circuit rides with no temporary officers and 19 were 

from circuit rides with a mix of temporary officers and refugee officers. For 

example, some trip reports generally noted that officers had difficulty 

identifying what applicant characteristics would be considered potential 

national security concerns among certain populations being interviewed. 

In addition, one trip report stated that officers required repeated 

reminders to elicit all of the necessary details that headquarters reviewers 

would need to determine whether an applicant posed a national security 

concern. Further, one supervisor we spoke with during a site visit stated 

 74Specific examples of resources provided to officers are omitted from this report because 

USCIS deemed the information to be sensitive.

USCIS Has Resources to 

Help Officers Identify 

Applicants with National 

Security Concerns, but 

Has Not Documented

Plans for Deploying 

Officers with National 

Security Expertise on 

Circuit Rides
Page 46 GAO-17-706 Refugee Screening Process

that guidance about identifying cases with national security indicators is 

ambiguous and, at times, contradictory. Moreover, both RAD and IO 

headquarters officials we met with stated that interviewing officers are 

hesitant to make decisions regarding cases with national security 

concerns, and, as a result, often place cases on hold that are ultimately 

determined not to have national security concerns. USCIS officials 

identified several reasons why it is challenging to provide training and 

guidance on how to adjudicate cases with potential national security 

concerns. For example, according to RAD and IO headquarters officials, 

indicators of national security concerns and the country conditions that 

give rise to them evolve and change; as a result, USCIS guidance on how 

to address those concerns also changes over time.

To further help interviewing officers adjudicate cases with national 

security concerns, RAD initiated a pilot program in the second and third

quarters of fiscal year 2016, through which it sent headquarters USCIS 

Security, Vetting, and Program Integrity (SVPI) unit officers with national 

security-related expertise to support interviewing officers on select circuit 

rides.75 During these circuit rides, according to RAD and SVPI officials, 

SVPI officers’ tasks included prescreening case files and applications for 

national security concerns, flagging those concerns, and recommending 

lines of questions for USCIS interviewing officers. During our August 2016 

visit to Amman, Jordan, we observed 16 interviews of applicants whose 

case files the SVPI officer had prescreened for potential national securityrelated issues; interviewing officers used notes that the SVPI officer 

provided to inform the questions they asked applicants. In some 

instances, the SVPI officer stated that he met with the interviewing officer 

before the interview to discuss potential questions on issues of national 

security concern that the SVPI officer anticipated might arise. Further, 

during the interview, the SVPI officer was available for real-time webchats 

to answer officers’ questions as they arose. 

The SVPI officer, circuit ride supervisor, and interviewing officers we 

spoke with in Amman all stated that having SVPI present on the circuit 

ride was valuable. For example, one temporary officer, who was on her 

 75SVPI consists of both RAD refugee officers and USCIS Fraud Detection and National 

Security Directorate immigration officers who are responsible for addressing national 

security, fraud, or other security-related issues that arise in the adjudication of 

applications. SVPI officers provide advice to refugee officers adjudicating applications with 

fraud or national security concerns, conduct additional headquarters’ checks where there 

are indicators of fraud or national security concerns, and help shape policy and operating 

procedures for national security cases.
Page 47 GAO-17-706 Refugee Screening Process

first circuit ride, stated that she could not imagine resolving cases with 

national security concerns without the in-field help of SVPI. USCIS 

headquarters officials stated sending an SVPI officer resulted in a 

decrease in cases requiring headquarters review, although other factors 

also played a role in this decrease. For example, the on-site SVPI officer 

was able to resolve some cases with potential national security concerns 

in the field and was also able to prioritize cases requiring headquarters’

review due to potential national security concerns.

In December 2016, RAIO and SVPI officials said they had determined 

that the SVPI in-field pilot was successful and that they plan to make it a 

formal part of select circuit rides in the future. These officials stated that 

they plan to continue to send SVPI officers on select circuit rides with 

caseloads high in potential national security-related issues, as resources 

permit.76 The officials stated that RAD selects which circuit rides will have 

on-site SVPI support based on several factors, including the number of 

cases placed on hold for national security-related concerns during 

previous circuit rides to certain locations and the availability of SVPI staff. 

To increase SVPI’s ability to support circuit rides, in December 2016, 

USCIS posted an SVPI job announcement with eight potential vacancies. 

The announcement stated that the job may require travel of up to 180 

days per year on overseas circuit rides. The USCIS officials told us that, 

as of March 2017, they continue to work to fill these positions and are 

drafting an SOP that will have guidance about roles and responsibilities 

for SVPI officers providing on-site support to RAD circuit rides, which they 

intend to finalize later in 2017.77 As of April 2017, USCIS reported having 

filled five of the eight positions. Further, according to USCIS officials, 

SVPI initiated a test of the operational aspects of the draft SOP by 

deploying a supervisory SVPI officer on a RAD circuit ride in March 2017. 

USCIS officials reported in March 2017 that the draft SOP had not yet 

undergone a legal review. According to these officials, they expect to 

issue the SOP by July 2017. However, USCIS did not provide 

documentation or timelines for its plans to expand the use of SVPI 

officers on selected circuit rides.

 76As of March 2017, USCIS officials stated that SVPI officers are providing on-site support 

to select RAD circuit rides. 

77Officials stated that the hiring process for SVPI on-site circuit ride support officers was 

interrupted by the federal hiring freeze announced in January 2017, but that as of March 

2017, these positions have been exempted from the hiring freeze and the hiring process 

continues. 
Page 48 GAO-17-706 Refugee Screening Process

We have previously reported that, in developing new initiatives, agencies 

can benefit from following leading practices for strategic planning.78

Congress enacted GPRAMA to improve the efficiency and accountability 

of federal programs and, among other things, to update the requirement 

that federal agencies develop long-term strategic plans that include 

agencywide goals and strategies for achieving those goals.

79 The Office 

of Management and Budget (OMB) has provided guidance in Circular A11 to agencies on how to prepare these plans in accordance with 

GPRAMA requirements. We have reported in the past that, taken 

together, the strategic planning elements established under GPRA, as 

updated by GPRAMA, and associated OMB guidance, along with 

practices we have identified, provide a framework of leading practices 

that can be used for strategic planning at lower levels within federal 

agencies, such as planning for individual divisions, programs, or 

initiatives.80 One of these leading practices is to define strategies and 

identify resources needed to achieve goals. Strategies should be 

designed to align activities, core processes, and resources to support the 

mission. Further, strategies should include milestones as well as a 

description of the resources needed to meet established goals.

RAIO officials stated that they plan to deploy SVPI officers on additional 

circuit rides in the future. While these plans are a positive step for helping 

officers address potential national security concerns on circuit rides, 

USCIS has not yet documented these plans or completed an SOP. Given 

SVPI’s lack of documentation for future plans and challenges identified by 

USCIS staff in adjudicating cases with potential national security 

 78GAO, National Nuclear Administration: A Plan Incorporation Leading Practices Is 

Needed to Guide Cost Reporting Improvement Effort, GAO-17-141 (Washington, D.C.: 

January 2017); Environmental Protection: EPA Should Develop a Strategic Plan for Its 

New Compliance Initiative, GAO-13-115 (Washington, D.C.: Dec. 10, 2012); and 

Environmental Justice: EPA Needs to Take Additional Actions to Help Ensure Effective 

Implementation, GAO-12-77 (Washington, D.C.: Oct. 6, 2011).

79See generally Pub. L. No. 103-62, 107 Stat. 285 (1993) (GPRA) and Pub. L. No. 111-

352, 124 Stat. 3866 (2011) (updating GPRA); 5 U.S.C. § 306(a).

80For example, see GAO, Veterans Health Care: 11-12 r1, Improvements Needed in 

Operationalizing Strategic Goals and Objectives, GAO-17-50 (Washington, DC: October 

2016); Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1, 1996); Tax Administration: 

IRS Needs to Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 

(Washington, D.C.: Nov. 22, 2002); and Managing for Results: Strengthening Regulatory 

Agencies’ Performance Management Practices, GAO/GGD-00-10 (Washington, D.C.: Oct. 

28, 1999).
Page 49 GAO-17-706 Refugee Screening Process

concerns, it is unclear how or when RAIO will fulfill its plans to send 

national security experts on circuit rides to support interviewing officers. In 

light of the evolving and significant nature of national security concerns, 

developing and implementing a plan to deploy additional SVPI officers 

with national security expertise on circuit rides—including timeframes for 

deployment and how USCIS will select circuit rides for SVPI 

deployment—would better ensure that USCIS provides interviewing 

officers with the resources needed to efficiently and effectively adjudicate 

cases with national security concerns.

USCIS has not conducted quality assurance assessments of refugee 

adjudications since fiscal year 2015 and has not developed plans for 

subsequent assessments, which help ensure that case files are 

completed accurately and that decisions by RAD, IO, and temporary 

officers are well-documented and legally sufficient. The RAIO Directorate 

conducted a quality assurance review of refugee adjudications in fiscal 

year 2015.81 The RAIO Directorate’s 2015 review included a sample of 

applications adjudicated by RAD and IO during one quarter of the fiscal 

year, which was not representative of all RAD and IO applications for the 

fiscal year.82 The 2015 quality assurance review found that most cases in 

the sample were legally sufficient. 83 However, the review indicated that 

there were differences between RAD and IO adjudications. Specifically, 

the review rated 69 of 80 RAD case files (86 percent) as good or 

excellent, and rated 36 of 73 IO case files (49 percent) as good or 

excellent. Two of 80 RAD case files (less than 3 percent) in the review 

and 17 of 73 IO case files (23 percent) were rated as not legally 

 81RAIO officials stated that, prior to the fiscal year 2015 review, they made significant 

revisions to the assessment tool for refugee cases and implemented a new rating system 

for quality reviews. The purpose of these changes was to accurately reflect the quality 

level of each case and clarify whether the case was legally sufficient.

82For example, the review did not include any cases from Russia or South Africa, which 

comprised 26 percent of IO’s caseload in fiscal year 2015. 

83During RAIO quality assurance reviews, each case is assigned to one of five categories 

that reflect the quality level of the case. The categories are: legally sufficient 1 – overall, 

the quality of the adjudication is excellent; legally sufficient 2 – overall, the quality of the 

adjudication is good; legally sufficient 3 – overall, the quality of the adjudication is 

acceptable; legally sufficient 4 – overall, the quality of the adjudication is minimally 

acceptable; and not legally sufficient – the case is not legally sufficient and/or violates 

program policy. 

USCIS Has Not 

Conducted Quality 

Assurance Assessments 

of Refugee Adjudications 

since Fiscal Year 2015 

Despite Significant 

Changes to the Program 

Since That Time
Page 50 GAO-17-706 Refugee Screening Process

sufficient.84 According to the assessment, USCIS placed these cases on 

hold or requested that RSCs schedule the applicants for reinterview. 

Among cases rated not legally sufficient, the most common deficiency 

identified was that interviewing officers did not fully develop the interview 

record with respect to possible inadmissibilities. Other deficiencies 

reported included interview records not being fully developed with respect 

to well-founded fear of persecution, improper documentation and analysis 

of terrorism-related inadmissibility concerns, incorrect hold determination, 

and required sections of the assessment leading to the adjudication 

decision that were incomplete. RAIO identified issues related to training 

and guidance for IO officers as well as supervisory review that may have 

led to these deficiencies.

RAIO developed six high-priority action items to address the identified 

deficiencies in the quality assurance review and, as of November 2016, 

RAD and IO officials have made progress toward implementing them. For 

example, in 2016, IO issued a memorandum with required qualifications 

for IO officers who conduct supervisory review of refugee applications 

and provided additional guidance on which questions officers must ask 

during the interview in specific locations to ensure legal sufficiency. RAD 

and IO officials stated that they have taken steps to implement other 

action items identified in the 2015 review, such as incorporating more 

national security-related research, as appropriate, into the case file 

reviews that IO officers complete as part of their circuit ride predeparture 

preparation.

RAIO officials stated that they have not completed a quality assurance 

review since fiscal year 2015, and, as of March 2017, do not know 

whether they will do so in fiscal year 2017.85 USCIS officials stated that 

they did not conduct a review in fiscal year 2016 for two reasons. First, in 

fiscal year 2016, RAIO officials stated that they faced resource 

constraints because they were focused on hiring and training new staff, 

and training and quality assurance are handled by the same team within 

RAIO. Second, the officials stated that there was value in allowing time 

for the action steps identified after the 2015 review to be implemented 

 84The assessment rated an additional 12 IO cases (16 percent) and zero RAD cases as 

minimally acceptable.

85RAD officials stated that a variety of factors, including any changes that may occur as a 

result of executive orders in early 2017 addressing U.S. immigration policy and more 

specifically, refugee admissions, may impact whether RAIO conducts a fiscal year 2017 

quality assurance assessment.
Page 51 GAO-17-706 Refugee Screening Process

before conducting another review to identify if the action steps addressed 

the deficiencies noted in the prior review. RAIO officials also stated that 

even though they do not yet know whether they will conduct a quality 

assessment in fiscal year 2017, supervisors continue to review each 

refugee case file for legal sufficiency and completeness at the time of the 

interview. While supervisory review is an important quality control step, it 

does not position USCIS to identify systematic quality concerns, such as 

those identified in the fiscal year 2015 quality assessment results.

USCIS’s January 2015 RAD and IO Roles and Responsibilities with 

Respect to Refugee Processing memorandum states that RAD is to 

establish quality assurance criteria and design the quality assurance 

program for refugee adjudications, in consultation with IO. The 2015 

memorandum further states that RAD will conduct quality assurance 

reviews of refugee cases adjudicated by temporary officers, IO staff, and 

permanent RAD staff. Further, Standards for Internal Control in the 

Federal Government states that management should establish and 

operate monitoring activities to monitor the internal control system and 

evaluate the results.86 The scope and frequency of evaluations are to 

depend on the assessment of risks, effectiveness of ongoing monitoring, 

and rate of change within the entity and its environment. In addition, 

standard practices for program management state that program quality 

should be monitored on a regular basis to provide confidence that the 

program will comply with the relevant quality policies and standards.87

Although there have been significant changes in the refugee caseload in 

the past 2 years (such as the increase in Syrian refugees), an increased 

use of temporary staff to conduct refugee adjudications in fiscal year 

2016, and the difference in quality between RAD and IO adjudications 

noted in the 2015 quality assurance review, USCIS did not conduct 

quality reviews in 2016 and has no plans to conduct them in 2017. 

Regular quality assurance reviews could help provide USCIS reasonable 

assurance that RAD officers, IO officers, and temporary officers are 

consistently, accurately, and sufficiently documenting their adjudication 

decisions. Conducting regular quality assurance assessments of refugee 

adjudications would also provide USCIS officials with key information 

about the quality of USCIS refugee adjudications and allow them to 

 86GAO-14-704G.

87Project Management Institute, Inc., The Standard for Program Management ®, Third 

Edition, 2013.
Page 52 GAO-17-706 Refugee Screening Process

identify any areas where officers face challenges, allowing RAD and IO to 

target training or guidance to areas where it may be most needed.

Fraud can occur in the refugee process in a number of ways, and State, 

RSCs, and USCIS have implemented certain mechanisms to help detect 

and prevent fraud by USRAP applicants.88 In general, immigration benefit 

fraud often involves the willful misrepresentation of material fact for the 

purpose of obtaining an immigration benefit, such as refugee status. 

Immigration benefit fraud is often facilitated by document and identity 

fraud. Document fraud includes forging, counterfeiting, altering, or falsely 

making any document, or using, possessing, obtaining, accepting, or 

receiving such falsified documents in order to satisfy any requirement of, 

or to obtain a benefit under, U.S. law. Identity fraud refers to the 

fraudulent use of others’ valid documents. In the context of USRAP, 

applicants may attempt to apply for refugee status after having been 

denied refugee status or another immigration benefit, such as a visa, 

using another identity. Or, applicants may falsely present themselves as a 

national of a country eligible for resettlement to gain access to USRAP.

Further, applicants may present false marriage claims or attempt to 

include unrelated children on their case. USCIS officers can encounter 

indicators of fraud while adjudicating refugee applications, and State has 

 88In June 2017, we reported on how State works with UNHCR to implement integrity 

activities in the resettlement process and State and RSC activities to reduce the risk of 

staff fraud. See GAO, Refugees: State and Its Partners Have Implemented Several 

Antifraud Measures but Could Further Reduce the Risk of Staff Fraud, GAO-17-446SU 

(Washington, D.C.: June 2017). The public version of this sensitive GAO report is 

Refugees: State and Its Partners Have Implemented Several Antifraud Measures but 

Could Further Reduce Staff Fraud Risks, GAO-17-737 (Washington, D.C.: July 2017).

State and USCIS 

Have Mechanisms to 

Help Detect and 

Prevent Applicant 

Fraud, but Could 

Jointly Assess 

Applicant Fraud Risks

State, RSCs, and USCIS 

Have Implemented 

Mechanisms to Help 

Detect and Prevent Fraud 

Committed by USRAP 

Applicants
Page 53 GAO-17-706 Refugee Screening Process

suspended USRAP programs in the past because of fraud. Examples 

include the following:

• Of the 107 RAD circuit ride trip reports we analyzed, 30 reports 

identified instances in which officers denied applications for fraud or 

misrepresentation. According to an SVPI official, applications with 

indicators of fraud may also be denied on other grounds, such as 

ineligibility, inadmissibility, and security check results, among others.

• In 2008, State suspended the P3 program, a family reunification 

program between a family member in the United States and the 

refugee applicant, because of widespread fraud, as discussed below.

• In 2015, State suspended a P2 program after discovering that two 

individuals who had been approved as refugees and admitted to the 

United States had submitted fraudulent documents gain access to 

USRAP. During the suspension period from March to December 

2015, State and RSC officials reviewed all cases that they were 

processing for this P2 program. According to State officials, this 

review found additional applicants with fraudulent documents.89

State, RSCs, and USCIS have put mechanisms in place to help detect 

and prevent fraud by USRAP applicants.

State. State has guidance intended to help RSC staff identify fraudulent 

refugee applicants, and State has strengthened access controls for some 

refugee applicants. For example, State SOPs require that, when entering 

a new case into WRAPS for prescreening, RSC staff verify that a 

duplicate record does not already exist in WRAPS for the applicants. 

According to State SOPs, one of the purposes of this step is to identify 

individuals who attempt to fraudulently access USRAP. RSC officials at

all four locations we visited stated that they complete this procedure and 

our analysis of WRAPS data showed that RSCs have identified duplicate 

applicant records.90 State has also strengthened its controls for granting 

 89Specific details of the 2015 P2 fraud incident are omitted from this report because State 

determined the information to be sensitive. 

90According to our analysis of WRAPS data, from fiscal year 2011 through June 2016, 

RSCs conducting duplicate record verification found 1,396 matches to existing 

applications within their own RSC and 288 matches to existing applications submitted in 

another RSC. In these instances, RSCs may close one of the duplicative applications.

According to USCIS and State officials, as well as RSC staff, such duplicative records are 

not necessarily an indicator of fraud. For example, duplicate records could also result from 

administrative error or travel by an applicant from one RSC’s jurisdiction to another.
Page 54 GAO-17-706 Refugee Screening Process

access to USRAP for some groups of refugee applicants. For example, 

after suspending the P3 program due to fraud in 2008, State restarted the 

P3 program in 2012 with additional controls in place, including a 

requirement for DNA testing for all claimed parent and child biological 

relationships. In addition, when State initiated the P2 Central American 

Minors program in 2014—which, like the P3 program, requires a familial 

relationship between someone residing in the United States and the 

refugee applicant—State instituted a requirement for DNA testing of all

claimed biological relationships between the qualifying child and the 

qualifying parent.

91 Further, after finding fraud in 2015 in a P2 program, 

as discussed above, State strengthened the mechanism for verifying 

access to USRAP.

RSCs. RSCs have also implemented a variety of controls to help detect 

and prevent fraud among refugee applicants to USRAP. For example, 

according to all nine RSC directors, each RSC has a designated antifraud official or entity, consistent with GAO’s Fraud Risk Framework.92

Officials at all nine RSCs stated that they provide staff with training or 

information on applicant fraud trends. Further, RSC officials in two RSCs 

stated that they conduct their own research to detect potential applicant 

fraud. In addition, two of the four RSCs we visited conduct two 

prescreening interviews for each applicant rather than one. According to 

RSC officials, conducting more than one interview serves as a fraud 

deterrent because it allows the RSC staff to check for consistency across 

interviews and identify false information. Further, these RSCs require, 

where possible, that different interpreters participate in each interview to 

decrease the likelihood that applicants collude with interpreters.

USCIS. Within USCIS, SVPI and adjudicators are responsible for 

antifraud activities related to the adjudication of the refugee application. 

USCIS has implemented a number of control activities to detect and 

prevent refugee applicant fraud. Through biometric checks, USCIS may 

identify that a USRAP applicant has multiple identities. According to SVPI 

officials, SVPI analyzes the results of the checks, identifies fraud 

indicators, and may complete a fraud referral so that the applicant can be 

interviewed or re-interviewed by an officer overseas to address the fraud 

concern. SVPI also receives fraud referrals from other sources, such as 

refugee officers and the RSCs, although SVPI officials stated that the 

 91See app. I for additional information on the Central American Minors program. 

92GAO-15-593SP.
Page 55 GAO-17-706 Refugee Screening Process

number of such referrals is small. USCIS officials stated that, in many 

instances, interviewing officers deny an application with indicators of 

fraud on other grounds, which does not require the involvement of SVPI 

or a fraud referral. Interviewing officers may also place a case with 

indicators of fraud on hold for additional SVPI research. According to 

USCIS officials and training materials that we reviewed, USCIS officers 

who adjudicate refugee applications receive training in identifying fraud 

and processing cases with fraud indicators during basic training and 

predeparture briefings. We observed discussions about fraud trends at 

three of the four predeparture briefings that we attended. 

Additionally, the RAD trip report guide states that supervisors are to 

document any suspected fraud trends from the circuit ride, including how 

the fraud trend was identified, any actions taken in response to the trend, 

whether the trend was expected to continue, and examples of any 

suspected fraud. Of the 107 trip reports we analyzed, 72 contained 

information about applicant fraud or fraud trends. The information varied, 

ranging from detailed descriptions of individual cases denied due to 

misrepresentation or fraud to a more general description of potential fraud 

trends in certain populations, such as a lack of reliable marriage 

documentation. The remaining 35 reports stated that there were no fraud 

trends or left the section of the report about fraud trends blank, which 

indicates that the author of the trip report did not identify fraud trends on 

the circuit ride.

State and USCIS have not jointly assessed applicant fraud risks across 

USRAP. Our Fraud Risk Framework calls for program managers to plan 

and conduct regular fraud risk assessments. According to our Fraud Risk 

Framework, there is no universally accepted approach for conducting 

fraud risk assessments, since circumstances among programs vary; 

however, assessing fraud risks generally involves five actions: (1) 

identifying inherent fraud risks affecting the program, (2) assessing the 

likelihood and impact of those fraud risks, (3) determining fraud risk 

tolerance, (4) examining the suitability of existing fraud controls and 

prioritizing residual fraud risks, and (5) documenting the program’s fraud 

risk profile.93 The framework provides managers with flexibility in deciding 

whether to carry out this and other aspects of fraud risk management at 

the program or agency level. In addition, Standards for Internal Control in 

 93GAO-15-593SP.

State and USCIS Have 

Not Jointly Assessed 

Applicant Fraud Risks 

Across USRAP
Page 56 GAO-17-706 Refugee Screening Process

the Federal Government states that management should consider the 

potential for fraud when identifying, analyzing, and responding to risks, 

and analyze and respond to identified fraud risks, through a risk analysis 

process, so that they are effectively mitigated.94

Although State and USCIS perform a number of fraud risk management 

activities and have responded to individual instances of applicant fraud, 

these efforts do not position State and USCIS to assess fraud risks 

program-wide for USRAP or know if their controls are appropriately 

targeted to the areas of highest risk in the program. State and USCIS 

officials told us that each agency has discrete areas of responsibility in 

the refugee admissions process, and each agency’s antifraud activities 

are largely directed at their portions of the process. State is responsible 

for managing USRAP at a programmatic level and, according to State 

officials, State has responded to instances of fraud in USRAP. State 

officials said that they have not conducted an assessment of the risks 

associated with applications to USRAP because, according to these 

officials, such an assessment is USCIS’s responsibility. However, USCIS 

officials told us that SVPI—USCIS’s antifraud entity for refugee applicant 

fraud—only has authority over antifraud activities related to the 

adjudication of the refugee application, including security checks. USCIS 

officials stated that they are not responsible for, and do not have the 

authority to respond to, applicant fraud program-wide in USRAP, although 

they coordinate with State when fraud is brought to the attention of SVPI. 

As of March 2017, SVPI has a draft Fraud Process SOP, which identifies 

three main types of applicant fraud in USRAP—individuals who are using 

multiple identities; individuals who are claiming false family composition, 

such as marriage fraud; and individuals who are claiming a false country 

of nationality. In addition, the draft SOP identifies the main sources by 

which USCIS detects fraud in the USRAP application process—results 

from biometric checks and testimony and evidence from the USRAP 

applicant. However, USCIS and State have not jointly conducted a fraud 

risk assessment of the risks associated with applications to USRAP or 

determined a fraud risk tolerance for the program.

Because the management of USRAP involves several agencies, without 

jointly and regularly assessing applicant fraud risks and determining the 

fraud risk tolerance of the entirety of USRAP, in accordance with leading 

practices, State and USCIS do not have comprehensive information on 

 94GAO-14-704G.
Page 57 GAO-17-706 Refugee Screening Process

the inherent fraud risks that may affect the integrity of the refugee 

application process and therefore do not have reasonable assurance that 

State, USCIS, and other program partners have implemented controls to 

mitigate those risks. Moreover, regularly assessing applicant fraud risks 

program-wide could help State and USCIS ensure that fraud prevention 

and detection efforts across USRAP are targeted to those areas that are 

of highest risk, in accordance with the program’s fraud risk tolerance.

Screening and adjudicating refugee applicants and applications are 

challenging tasks that involve entities across the U.S. government. RSCs 

have an important role in the refugee admissions process because they 

collect applicants’ information and conduct in-person prescreening 

interviews that USCIS officers use to help determine applicants’ eligibility 

and credibility. Developing outcome-based performance indicators, as 

required by State policy and performance management guidance, and 

monitoring RSC performance against such indicators on a regular basis, 

would better position State to determine whether RSCs are processing 

refugee applications in accordance with their responsibilities under 

USRAP.

In addition, adjudicating refugee applications can be challenging. During a 

face-to-face interview, USCIS officers must, among other things, 

determine if the applicant meets the definition of a refugee; is 

inadmissible because of, for example, national security concerns or 

criminal activities; and is credible. Further, indicators of national security 

concerns (and the country conditions that give rise to them) evolve and 

change. To the extent that USCIS uses temporary officers on future 

circuit rides, providing them with additional training, such as in-field 

training, would help better prepare them to interview refugees and 

adjudicate their applications, increase the quality and efficiency of their 

work, and potentially reduce the supervisory burden on those who 

oversee temporary officers. Moreover, developing and implementing a 

plan to deploy additional USCIS SVPI officers with national security 

expertise on select circuit rides would better ensure that USCIS provides 

interviewing officers with the resources needed to efficiently and 

effectively adjudicate cases with national security concerns. In addition, 

conducting regular quality assurance assessments of refugee 

adjudications would also provide USCIS officials with key information 

about the quality of USCIS refugee adjudications and allow them to 

identify any areas where officers face challenges, allowing RAD and IO to 

target training or guidance to areas where it may be most needed.

Conclusions
Page 58 GAO-17-706 Refugee Screening Process

Given that USCIS officers encounter indicators of fraud while adjudicating 

refugee applications and fraud has occurred in USRAP programs in the 

past, it is important that USCIS and State implement leading practices to 

combat fraud. Without jointly and regularly assessing applicant fraud risks 

and determining the fraud risk tolerance of USRAP, in accordance with 

leading practices, State and USCIS do not have comprehensive 

information on the inherent fraud risks that may affect the integrity of the 

refugee application process. Moreover, regularly assessing applicant 

fraud risks program-wide could help State and USCIS ensure that fraud 

prevention and detection efforts across USRAP are targeted to those 

areas that are of highest risk.

To better assess whether RSCs are meeting USRAP objectives, the 

Assistant Secretary of State for Population, Refugees, and Migration 

should take the following two actions:

• develop outcome-based indicators, as required by State policy; and

• monitor RSC performance against such indicators on a regular basis.

To better ensure that USCIS officers effectively adjudicate applications for 

refugee status, the Director of USCIS should take the following three 

actions:

• provide additional training, such as infield training, for any temporary 

officers who adjudicate refugee applications on future circuit rides;

• develop and implement a plan to deploy officers with national security 

expertise on circuit rides; and

• conduct regular quality assurance assessments of refugee application 

adjudications across RAD and IO.

To provide reasonable assurance that USRAP applicant fraud prevention 

and detection controls are adequate and effectively implemented, we 

recommend that the Secretaries of Homeland Security and State conduct 

regular joint assessments of applicant fraud risk across USRAP.

We provided a draft of the sensitive version of this report to the 

Departments of Homeland Security, State, Defense, and Justice, as well 

as the Office of Director of National Intelligence, for their review and 

comment. State and DHS provided written comments stating that they 

concurred with our recommendations, which are reproduced in full in 

appendixes III and IV, respectively. In emails, a Director in the Office of 

Recommendations for 

Executive Action

Agency Comments 
Page 59 GAO-17-706 Refugee Screening Process

the Under Secretary of Defense for Policy at the Departments of Defense 

and the Legislative Liaison Officer at the Office of Director of National 

Intelligence stated that these agencies did not have any written 

comments on our draft report. State, DHS, the Department of Justice, and 

the FBI provided technical comments, which we incorporated as 

appropriate.

We are sending copies of this report to interested congressional 

committees; the Secretaries of Homeland Security, State, and Defense;

the Attorney General of the United States; and, the Director for National 

Intelligence. In addition, the report is available at no charge on the GAO 

website at http://gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-8777 or gamblerr@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix V.

Rebecca Gambler

Director, Homeland Security and Justice
Page 60 GAO-17-706 Refugee Screening Process

List of Addressees

The Honorable John Boozman

Chairman

The Honorable Jon Tester

Ranking Member

Subcommittee on Homeland Security

Committee on Appropriations

United States Senate

The Honorable Lindsey Graham

Chairman

The Honorable Patrick Leahy

Ranking Member

Subcommittee on State, Foreign Operations, and Related Programs

Committee on Appropriations

United States Senate

The Honorable Charles E. Grassley

Chairman

Committee on the Judiciary 

United States Senate

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable John R. Carter

Chairman

The Honorable Lucille Roybal-Allard

Ranking Member

Subcommittee on Homeland Security

Committee on Appropriations

House of Representatives
Page 61 GAO-17-706 Refugee Screening Process

The Honorable Hal Rogers

Chairman

The Honorable Nita Lowey

Ranking Member

Subcommittee on State, Foreign Operations, and Related Programs

Committee on Appropriations

House of Representatives

The Honorable Michael McCaul

Chairman

Committee on Homeland Security

House of Representatives

The Honorable Bob Goodlatte

Chairman

Committee on the Judiciary

House of Representatives

The Honorable Jeff Duncan

Chairman

Subcommittee on the Western Hemisphere

Committee on Foreign Affairs

House of Representatives
Appendix I: Central American Minors Program

Page 62 GAO-17-706 Refugee Screening Process

The Central American Minors (CAM) Program was established in 

November 2014 to promote safe, legal, and orderly migration of certain 

vulnerable children to the United States and began accepting applications 

on December 1, 2014. This family reunification program aims to deter 

children from El Salvador, Guatemala, and Honduras from undertaking a 

risky journey in an attempt to be reunited with a parent residing in the 

United States.1 CAM allows certain parents to request access to the U.S. 

Refugee Admissions Program (USRAP) for their children who are 

nationals of one of these three countries and are outside of the United 

States. Children who are found ineligible for admission as a refugee 

under USRAP but still at risk of harm may be considered for parole—in 

general a mechanism by which an individual not otherwise admitted to the 

United States may be permitted entry into the country on a temporary 

basis.2 CAM is jointly run by the Department of State’s (State) Bureau of 

Population, Refugees, and Migration and the Department of Homeland 

Security’s (DHS) U.S. Citizenship and Immigration Services (USCIS).

To participate in CAM, both parent and child must meet certain qualifying 

criteria. Among other criteria, a qualifying parent must be 18 years of age 

and lawfully present within the United States at the time of application and 

at the time of admission or parole of the beneficiary (e.g., a qualifying 

 1

From fiscal years 2009 through 2014, the Department of Homeland Security (DHS) 

apprehended about 100,000 unaccompanied children at the U.S. border from El Salvador, 

Guatemala, and Honduras. See GAO, Unaccompanied Alien Children: Actions Needed to 

Ensure Children Receive Required Care in DHS Custody, GAO-15-521 (Washington, 

D.C.: July 14, 2015).

2

See 8 U.S.C. § 1182(d)(5); 8 C.F.R. § 212.5. According to State and USCIS officials, as 

of June 2017 the use of parole within the context of CAM is under review in light of 

Executive Order 13767, Border Security and Immigration Enforcement Improvements, 

issued on January 25, 2017, and DHS’s February 20, 2017, memorandum on 

Implementing Border Security and Immigration Improvement Policies, both of which 

address the federal government’s use of parole authority. See 82 Fed. Reg. 8793 (Jan. 

30, 2017).

Appendix I: Central American Minors 

Program

Requirements for Program 

Access
Appendix I: Central American Minors Program

Page 63 GAO-17-706 Refugee Screening Process

child) to the United States.3 The qualifying child must be a biological, 

step, or legally adopted child of the qualifying parent; unmarried; under 

the age of 21 at the time the qualifying parent initiates the process; and a 

national of El Salvador, Guatemala, or Honduras. Other family members 

of the child who meet certain criteria are also eligible to be part of the 

qualifying child’s application. For example, an accompanying parent who 

is the legal spouse of the U.S.-based qualifying parent may be eligible to 

travel with the qualifying child. However, the accompanying parent cannot 

derive his or her refugee status from the qualifying child and therefore 

must independently establish that he or she qualifies as a refugee. In July 

2016 State and DHS announced that CAM would expand to include 

additional eligible family members, when accompanied by a qualifying 

child—(1) the children, regardless of age or marital status, of a U.S.-

based qualifying parent; (2) the biological parent of a qualifying child who 

is not legally married to the U.S.-based lawfully present parent; and (3) 

the caregiver of a qualifying child who is related to either the U.S.-based 

lawfully present parent or the qualifying child. 4 State began accepting 

applications that included these additional family members in November 

2016. 

 3

The qualifying parent must be lawfully present in the United States under one of the 

following categories: Permanent Resident Status, Temporary Protected Status, Parolee, 

Deferred Action, Deferred Enforced Departure, or Withholding of Removal. Parolees and 

persons granted deferred action must have been issued parole or deferred action for a 

minimum of 1 year. A beneficiary that enters the United States as a refugee is deemed 

admitted, has lawful immigration status, and a path towards citizenship (i.e., a refugee 

must apply for lawful permanent resident status within 1 year of arrival in the United States 

as a refugee). See 8 U.S.C. §§ 1101(a)(42) (defining refugee), 1157 (authorizing and 

establishing criteria for the admission of refugees to the United States), 1159 (authorizing 

adjustment of status for a refugee); see also 8 C.F.R. §§ 207.1-207.9, 209.1. A beneficiary 

paroled into the United States—that is, authorized to enter for urgent humanitarian 

reasons or significant public benefit—is lawfully present in the country temporarily but has 

not been deemed admitted to the country and parole is neither a lawful immigration status 

nor itself a pathway to citizenship. See 8 U.S.C. § 1182(d)(5) (authorizing discretionary 

parole); 8 C.F.R. § 212.5. According to USCIS officials, parole under CAM is analyzed 

using the significant public benefit standard; it is not analyzed using the urgent 

humanitarian reasons standard.

4

The caregiver must be a part of the same household and economic unit as the qualifying 

child, In addition, children of the qualifying child and unmarried children under age 21 of 

the accompanying in-country caregiver could be included on the qualifying child’s 

application. 
Appendix I: Central American Minors Program

Page 64 GAO-17-706 Refugee Screening Process

As shown in figure 8, a qualifying parent initiates the CAM application 

process in the United States by completing a form (DS-7699, or “Affidavit 

of Relationship” (AOR)) with the help of a resettlement agency—a Statefunded entity that provides support services to refugees once they arrive 

within the United States.5

 5

There are currently nine resettlement agencies that, through cooperative agreements 

with State, receive federal funding to perform a range of activities supporting refugee 

resettlement, including filing paperwork to have in-country relatives join family members 

currently residing within the United States. 

Application, Interview, and 

Screening Process
Appendix I: Central American Minors Program

Page 65 GAO-17-706 Refugee Screening Process

Figure 8: Overview of Key Processing Steps for U.S. Refugee Admissions Program’s (USRAP) Central American Minors

(CAM) Program

a

The CAM AOR contains pertinent identifying information about the U.S.-based parent, in-country 

child, and other qualifying relatives who will receive the refugee interview. Resettlement agencies are 

entities that provide support services to refugees once they arrive within the United States.

b

At this point, State makes an initial determination on whether the U.S.-based parent is lawfully 

present. For a small number of cases, if State cannot determine lawful presence at time of 

submission of the AOR, State may send them to USCIS for review. State may reject an AOR at this 

point due to a lack of lawful presence or qualifying relationship. RSC Latin America—the RSC 

responsible for CAM—is operated by the International Organization for Migration and communicates 

directly with CAM applicants to process their applications, collect their information, and conduct inperson prescreening interviews. For cases in which the U.S.-based parent is filing for an adopted or 

step-child, USCIS requires that the parent submit documentation to substantiate the relationship, 

such as legal paperwork required for adoption or a marriage certificate.

c

Receipt of DNA results must occur prior to USCIS’s final decision.
Appendix I: Central American Minors Program

Page 66 GAO-17-706 Refugee Screening Process

d

Every USRAP applicant is required to undergo security checks that must be cleared before a refugee 

can be resettled in the United States. Information for the checks is initially collected during 

prescreening. If State receives negative security check results before the USCIS interview, State may 

administratively close the case based on the information, or USCIS may interview the case and 

subsequently issue a denial if the security check information merits. If security check results are not 

complete by the time of the USCIS review, USCIS will place an otherwise approved case on hold, 

pending the security check final outcome.

e

According to State’s USRAP Overseas Processing Manual, if a USCIS officer denies a case and the 

RSC presents the applicant with the denial letter, the applicant has 90 days to file a Request for 

Review. Such reviews are divided into two categories: requests that allege an error in the adjudication 

and requests that introduce new evidence; and, in general, the applicant may only file one request for 

review. A review may result in USCIS overturning the denial, upholding the denial or requesting 

another interview with the applicant. 

The qualifying parent files an AOR with the assistance of a designated

resettlement agency, which forwards the AOR to State. State is to 

conduct a preliminary review of the AOR for completeness, including a 

check that the qualifying parent has provided proof of his or her lawful 

status, and then provide the case to Resettlement Support Center (RSC) 

staff. RSC staff are to prescreen the qualifying children according to the 

standard operating procedures for all USRAP applicants.6 Shortly after 

prescreening, RSCs are to collect the child’s DNA to confirm biological 

relationships between the parent and the qualifying child. State has 

established policies and procedures specifically for the collection and 

processing of DNA samples from the qualifying child.7 We observed RSC 

staff taking 5 separate DNA samples at the RSC Latin America San 

Salvador office, during which staff adhered to the established standard 

operating procedures for DNA collection. Separately, within the United 

States, State is to notify the parent in the United States to provide DNA 

samples to a U.S.-based, accredited lab to confirm the biological 

relationship with his or her claimed child or children. The parent must also 

cover the costs associated with the DNA testing, but State is to reimburse 

the costs of the tests if all the claimed biological relationships are 

supported by the DNA evidence, even if the beneficiary is not ultimately 

admitted as a refugee or paroled to the United States. The U.S.-based lab 

 6

In a small number of cases where sufficient proof of lawful presence is not submitted with 

the AOR, State is to submit the case to USCIS for confirmation before further processing 

occurs and before RSC prescreening.

7

For example, these procedures include requirements that DNA tests received by RSCs 

abroad must be received, inspected, and securely stored by a U.S. citizen; a DNA Test Kit 

Log be kept to record and track the location of all test kits while at the RSC; and the RSC 

verify the applicant’s name and date of birth at the appointment to collect the DNA sample 

by asking the applicant to state the information and by comparing a copy of the applicant’s 

photo identification presented at the appointment with that provided at the prescreening 

interview.
Appendix I: Central American Minors Program

Page 67 GAO-17-706 Refugee Screening Process

reports the results of DNA testing for all cases to State, which then 

uploads the results into the Worldwide Refugee Admissions Processing 

System for viewing by USCIS.8 Although USCIS does not require DNA 

testing for other eligible family members included on applications (e.g., 

the children of the qualifying child or the siblings of the qualifying child 

who are not biologically related to the U.S.-based parent)—citing, among 

other factors, concerns over the reliability of such testing between, for 

example, siblings—USCIS officials stated that additional DNA testing will 

occur for new CAM categories announced in July 2016.9

After prescreening, but before USCIS interviews the child, USCIS’s 

Refugee Access Verification Unit (RAVU) is to, among other things, take 

steps to confirm the parent’s lawful status and to review the results of 

DNA testing, if available.10 According to USCIS procedures, if RAVU 

cannot confirm the parent’s status or DNA testing results do not confirm 

the relationship, USCIS will generally reject the application.11 According to 

State data, USCIS rejected or disqualified about 600 (5 percent) of the 

approximate 12,000 CAM AORs submitted from December 2014 through 

March 2017. USCIS generally adjudicates CAM applicants as they do all 

other USRAP applicants. However, according to USCIS policy, and 

consistent with characteristics of the targeted populations and stated 

objectives of the program, USCIS officials stated that CAM applicants 

undergo additional vetting for potential gang affiliations in cases with such 

 8

The Worldwide Refugee Admissions Processing System is an interactive computer 

system that serves as a repository for application information and tracks the status of all 

individual refugee applications to USRAP. 

9

According to USCIS officials, USRAP will require additional DNA testing for the new CAM 

categories announced in July 2016, including DNA testing between (1) the qualifying 

parent and their children who are married or over age 21; (2) the qualifying child and the 

in-country biological parent of the qualifying child who is not legally married to the U.S.-

based lawfully present parent; and (3) the qualifying parent and caregiver of the qualifying 

child or in country parent and caregiver if it is a DNA-testable relationship (e.g., the 

grandmother of the qualifying child).

10The purpose of RAVU is to track and manage the review of AORs filed by immediate 

family members in the United States on behalf of overseas family members who seek 

consideration for refugee resettlement. RAVU is to review the qualifying parent’s 

immigration record (and other records or information) for (1) a qualifying form of lawful 

presence, (2) proof of the claimed relationship, and (3) derogatory information about the 

qualifying parent. If DNA testing results are not available at the time RAVU conducts its 

review, the USCIS officer will review them as part of the adjudication.

11In some cases where DNA results are negative the case may still be forwarded to 

USCIS interview if there is sufficient evidence of a valid step relationship between the 

qualifying parent and the qualifying child.
Appendix I: Central American Minors Program

Page 68 GAO-17-706 Refugee Screening Process

indicators. If USCIS concludes that such an applicant is not eligible for 

admission as a refugee, the applicant may be considered for parole.

Vetting CAM applicants for potential gang affiliation. USCIS policy 

requires that officers place CAM applications on hold if gang affiliation 

indicators exist. As with all USRAP applicants, CAM program applicants 

are inadmissible to the United States as refugees if USCIS officers find 

them to be persecutors of others, have committed certain crimes, or be a 

threat to the security of the United States, among other things. Consistent 

with USCIS policy, USCIS officers may place a case on hold to do 

additional research or investigation if the officer determines that the 

applicant or other case members may be inadmissible due to information 

provided during the interview (e.g., the applicant has a known or 

suspected gang affiliation). For example, to further review CAM 

applications from Salvadoran applicants identified by USCIS interviewers 

as having indicators of possible gang affiliation during the USCIS 

interview, USCIS staff are to contact the Federal Bureau of Investigation 

(FBI). For CAM applicants in El Salvador, FBI agents stationed in San 

Salvador are to coordinate with the government of El Salvador in sharing 

investigative information on gangs.12 According to FBI officials, if the FBI 

has any information on the CAM program applicant and potential gang 

affiliations, they are to forward the information to USCIS officials, who 

determine whether the information renders the applicant ineligible for the

program. FBI officials in San Salvador said that they receive 6 to 10 

requests per month from USCIS for any available information related to 

CAM program applicants. From December 2014 through March 2017, 

USCIS officers had placed about 14 percent of CAM applicants they 

interviewed on hold, and in most cases, according to State data, the hold 

was for USCIS’s headquarters’ review of possible gang affiliations.

Parole. CAM program applicants found by USCIS to be ineligible for 

refugee status in the United States are to be considered on a case-bycase basis for parole, which is a mechanism to allow someone who is 

otherwise inadmissible to enter the United States on a temporary basis 

 12The FBI agents in El Salvador are part of the FBI’s Transnational Anti-Gang Initiative.

Announced in 2007, the FBI established the Initiative to help combat extremely violent 

Central American street gangs. See GAO, Combating Gangs: Federal Agencies Have 

Implemented a Central American Gang Strategy, but Could Strengthen Oversight and 

Measurement of Efforts, GAO-10-395 (Washington, D.C.: Apr. 23, 2010). FBI agents also 

assist with gang vetting for applicants in Guatemala, and U.S. Immigration and Customs 

Enforcement agents assist with gang vetting for applicants in Honduras.
Appendix I: Central American Minors Program

Page 69 GAO-17-706 Refugee Screening Process

for urgent humanitarian reasons or significant public benefit.13 USCIS 

procedures require that, to support an authorization of parole, the 

qualifying child must assert to the USCIS officer during the interview that 

he or she has a fear of being harmed, and the objective evidence must 

demonstrate that the child would face a reasonable possibility of harm if 

he or she remains in their home country.14 The interviewing officer has 

discretion to conditionally approve parole, after consideration of the entire 

record, and several factors—such as the outcome of the security checks 

or derogatory information (which may include involvement in gangs or 

other criminal activity)—could lead to a denial of parole. The final decision 

regarding parole is made by a USCIS officer after review of medical exam 

results and an additional review of security checks. Once in the United 

States a parolee, unlike a refugee, is not considered to have been 

admitted into the country, has not been conferred a lawful immigration 

status, and does not have the benefit of a pathway to U.S. citizenship.

Parole under CAM may be authorized for a period of up to 2 years and 

parolees are to file their request for re-parole no later than 90 days before 

the expiration of their authorized parole. Parolees may also apply for 

employment authorization but the extent to which they may be eligible for 

other public benefits is determined in accordance with U.S. law.

 13See 8 U.S.C. § 1182(d)(5); 8 C.F.R. § 212.5. Although the basis for parole in statute and 

regulation is for “urgent humanitarian reasons or significant public benefit,” USCIS officials 

explained that parole under the CAM program is based on a determination of significant 

public benefit and not urgent humanitarian reasons. In accordance with USCIS policy, if 

an officer determines that the applicant does not meet the refugee definition, consistent 

with U.S. immigration law, the applicant will be considered for parole. If a qualifying child is 

found to be a refugee or is paroled, USCIS policy also provides that any additional eligible 

family member on the case or eligible family members cross-referenced on other cases 

will also be considered for parole.

14According to USCIS policy, the level of harm required for parole under the CAM program 

is less severe than the persecution standard established under U.S. immigration law and 

applicants seeking parole are not required to establish a connection between the harm he 

or she may experience and one of the five protected grounds used to determine refugee 

status. See 8 U.S.C. § 1101(a)(42) (defining “refugee”). USCIS policy further provides that 

the standard of harm by which a qualifying child is authorized parole (or granted refugee 

status) is not applied to other eligible family members on the case who will also be 

considered for parole, and such individuals will generally be conditionally approved for 

parole in the interest of family unity unless there are negative factors such as criminality or 

gang affiliation that outweigh that interest. For further information on the factors driving the 

migration of unaccompanied children to the United States from Central America, see 

GAO, Central America: Information on Migration of Unaccompanied Children from El 

Salvador, Guatemala, and Honduras, GAO-15-362 (Washington, D.C.: February 2015).
Appendix I: Central American Minors Program

Page 70 GAO-17-706 Refugee Screening Process

Parole has been the most common outcome of CAM program 

applications, but a lower percentage of parolees have arrived in the 

United States than those granted refugee status through the program. 

From December 2014, when the program began accepting AORs, 

through March 2017, USCIS received AORs for about 12,100 individuals. 

Most of the AORs submitted were for applicants from El Salvador (86 

percent).15 USCIS had made final decisions on half (6,300) of these 

applicants, approving 70 percent for parole and granting 29 percent 

refugee status. According to USCIS officials, more CAM cases receive 

parole because the generalized violence that applicants experience does 

not rise to the level of persecution or is not on account of a protected 

characteristic required to support a refugee determination. However, the 

officials noted that the conditions in El Salvador, Guatemala, and 

Honduras, and the fact that the children are living without at least one 

parent in their country of origin are generally sufficient to demonstrate the 

fear of harm required to support a parole determination. USCIS officers 

determined that the remaining 1 percent of applicants did not qualify for 

refugee status or parole and denied the associated cases. However, a 

higher percentage of CAM applicants who had received refugee status 

had arrived in the United States, as of March 2017. Program data on 

applications submitted from December 2014 through March 2017 show 

that 63 percent (about 1,100) of all CAM-approved refugees and 33 

percent (about 1,500) of CAM approved parolees had traveled to the 

United States. Parolees must finance their travel to the United States and 

do not receive benefits upon arrival, circumstances that, according to 

State officials, most likely account for the difference in CAM refugee and 

parolee arrivals. Refugees have access to travel loans, and must sign a 

promissory note to assume responsibility for repaying the cost of travel to 

the United States. Parolees are also responsible for paying for the costs 

of medical exams.

 15According to State officials, most applications submitted are for applicants from El 

Salvador because there are more qualifying parents within the United States from El 

Salvador than Guatemala or Honduras. 

Outcomes for CAM 

Program Applications 

Submitted from December 

2014 through March 2017
Appendix II: Summary of United States 

Refugee Admissions Program Priority 

Categories

Page 71 GAO-17-706 Refugee Screening Process

The U.S. Refugee Admissions Program (USRAP) provides refugees who 

are of special humanitarian concern from around the world with 

opportunities for resettlement in the United States.1 The Departments of 

State (State) and Homeland Security (DHS) have joint responsibility for 

the admission of refugees to the United States. Specifically, State’s 

Bureau of Population, Refugees, and Migration coordinates and manages 

USRAP and makes decisions, along with DHS’s U.S. Citizenship and 

Immigration Services (USCIS), on which individuals around the world are 

eligible to apply for refugee status in the United States. Nine State-funded 

Resettlement Support Centers (RSCs) with distinct geographic areas of 

responsibility communicate directly with applicants to process their 

applications, collect their information, conduct a prescreening interview, 

and prepare applications for adjudication by USCIS. State and its 

partners—including USCIS—make initial determinations about whether 

an individual will be accepted into or excluded from USRAP (referred to 

as program “access”) for subsequent screening and interview by USCIS 

officers. State has identified three categories of individuals who are of 

special humanitarian concern and, therefore, can qualify for access to 

USRAP—Priority 1, Priority 2, and Priority 3.2 Table 2 describes these 

priority categories—including the multiple programs that comprise the 

Priority 2 category—and how State applicants within these priorities gain 

access to USRAP.

 1

The resettlement and admission of refugees to the United States are authorized by the 

Immigration and Nationality Act (INA), as amended by the Refugee Act of 1980. See 8 

U.S.C. §§ 1101(a)(42) (defining “refugee”) and 1157 (authorizing, and establishing the 

criteria for, the admission of refugees to the United States). Pursuant to the INA, as 

amended, before the beginning of each fiscal year and after consultation with Congress, 

the President is to establish the number of refugees that may be admitted to the United 

States in the ensuing fiscal year (i.e., a ceiling), with such admissions being allocated 

among refugees of special humanitarian concern to the United States (e.g., by region or 

country of nationality). See 8 U.S.C. § 1157(a). 

2

In addition to the three priorities, USRAP also allows the principal applicant’s spouse and 

unmarried children under the age of 21 to apply together while they are overseas. The 

principal applicant may also petition for his or her derivative spouse and children to 

“follow-to-join” him or her as refugees within 2 years after the principal has been admitted 

to the United States as a refugee, unless the deadline is waived for humanitarian reasons. 

See 8 U.S.C. § 1157(c)(2); 8 C.F.R. § 207.7.

Appendix II: Summary of United States 

Refugee Admissions Program Priority 

Categories
Appendix II: Summary of United States 

Refugee Admissions Program Priority 

Categories

Page 72 GAO-17-706 Refugee Screening Process

Table 2: Description of U.S. Refugee Admissions Program (USRAP) Priority Access Groups, as of March 2017

Priority 1 (P1) refugee categorya

Priority description Program access

The P1 category includes refugee claims from persons of any nationality, in any location, 

often with compelling protection needs, for whom resettlement appears the only durable 

long-term solution. To be considered under USRAP, applicants must be referred by the 

United Nations High Commissioner for Refugees (UNHCR), a Department of State (State)-

approved non-governmental organization (NGO), or a U.S. embassy.

According to State policy, State 

officials are required to review a 

selection of P1 UNHCR referrals and 

all NGO and U.S. embassy referrals to 

ensure access to USRAP is consistent 

with U.S. policies and that there are no 

glaring inconsistencies or grounds for 

inadmissibility, among other things.b 

Priority 2 (P2) refugee category

Open access programs allow individuals to seek access to USRAP on the basis of meeting designated criteria (e.g., specific 

nationality, a U.S.-based family member, etc.). State establishes these criteria in consultation with U.S. Citizenship and Immigration 

Services (USCIS), and with UNHCR and others, as appropriate. To gain access to USRAP under a P2 open access program, 

applicants must apply at a Resettlement Support Center (RSC) designated for processing a particular program and show how they

meet criteria specified for access. Some programs allow or require applicants to apply from within their country of nationality.

Program General Description Program access 

Central American Minors 

Program (CAM)

Children in El Salvador, Guatemala, and Honduras with a 

parent who lawfully resides within the United States; other 

family members may be eligible in accordance with program 

policy. The U.S.-based parent must file for program access 

on behalf of the qualifying child, and DNA testing must 

confirm the relationship between the parent and child. 

USCIS grants access once it confirms 

that the parent lawfully resides within 

the United States and relationship to 

child qualifies under program 

parameters.

Cuba Cuban human rights activists, members of persecuted 

religious minorities, former political prisoners, forced-labor 

conscripts, and persons deprived of their professional 

credentials or subjected to other disproportionately harsh 

or discriminatory treatment resulting from their perceived 

or actual political or religious beliefs. Applicants apply 

from within Cuba.

State grants access following 

review of the application.

Lautenberg Programc Certain religious adherents living in countries that made up 

the former Soviet Union and who have close family in the 

United States. In 2004, the program was expanded to 

include certain Iranian religious minorities. Applicants can 

apply from within or outside their country of nationality. 

Generally, cases are accepted once a 

U.S.-based family member petitions 

for their relatives to have access. 

Iraqis Associated with the 

United States—Employment 

Verificationd

Iraqis who were interpreters or translators for the U.S. 

government or Multi-National Forces in Iraq; Iraqis who 

are or were employed by the U.S. government, or an 

organization or entity closely associated with the U.S. 

Mission in Iraq, that received funding through an official 

and documented contract; and, Iraqis who worked for a 

U.S.-based media organization or non-governmental 

organization. In addition, the spouses, children, parents 

and siblings of the eligible individuals are also eligible, 

provided the relationships can be verified. Individuals 

can apply directly and processing takes place within Iraq 

or (if applicant has fled Iraq) in Egypt or Jordan.

Cases are accepted once RSC Middle 

East and North Africa confirms that the 

applicant meets the necessary 

employment criteria and a State 

official authorizes the application. 
Appendix II: Summary of United States 

Refugee Admissions Program Priority 

Categories

Page 73 GAO-17-706 Refugee Screening Process

Priority 2 (P2) refugee category

Open access programs allow individuals to seek access to USRAP on the basis of meeting designated criteria (e.g., specific 

nationality, a U.S.-based family member, etc.). State establishes these criteria in consultation with U.S. Citizenship and Immigration 

Services (USCIS), and with UNHCR and others, as appropriate. To gain access to USRAP under a P2 open access program, 

applicants must apply at a Resettlement Support Center (RSC) designated for processing a particular program and show how they

meet criteria specified for access. Some programs allow or require applicants to apply from within their country of nationality.

Program General Description Program access 

Iraqis Associated with the 

United States—Form I-130 

Petition for Alien Relativee

Iraqis within the United States who have filed a USCIS 

Form I-130, which allows a U.S. citizen or lawful permanent 

resident in the United States to petition for relatives living 

abroad to immigrate to the United States, provided that 

USCIS can verify the relationship. Under this program, 

U.S.-based Iraqis who are citizens or lawful permanent 

residents may petition on behalf of their spouses, unmarried 

children, parents, brothers, and sisters. Processing can take 

place within Iraq or (if applicants have fled Iraq) in Egypt or 

Jordan. 

Once USCIS receives the I-130 

petitions and verifies family 

relationships between U.S.-based 

petitioner and the Iraqis to be 

resettled, the Iraqis gain access to the 

program.

Syrian Beneficiaries of 

Approved Form I-130 Petition 

for Alien Relativef

Syrians within the United States who have filed a USCIS 

Form I-130, provided that USCIS can verify the relationship 

and immigrant visas have not yet been issued. U.S.-based 

Syrians who are citizens may petition on behalf of their 

spouses, children (regardless of age or marital status), 

siblings, and parents. If U.S.-based Syrians are permanent 

resident aliens, they may petition on behalf of their spouses 

and unmarried children. Processing can take place in 

Jordan, Lebanon, United Arab Emirates, Saudi Arabia, 

Kuwait, Egypt, Qatar, Iraq, Israel, Bahrain, Oman, Morocco, 

and Algeria. 

Once USCIS receives the I-130 

petitions and verifies family 

relationships between U.S.-based 

petitioner and the Syrians to be 

resettled, the Syrian beneficiaries gain 

access to the program.

Closed access programs allow State to grant groups of individuals (typically, who share a common nationality or history of 

persecution) access to USRAP. State, in consultation with USCIS, designates the groups and identifies criteria for inclusion in the 

group, based on a referring entity’s (usually the UNHCR) recommendation.

Program General description Program access

Ethnic minorities and others from 

Burma in camps in Thailand

Individuals who fled Burma, are registered in one of 

nine refugee camps along the Thai-Burma border, 

were identified by UNHCR as in need of resettlement, 

and who expressed interest prior to January 2014.

The referring entity (usually UNHCR) 

provides the biographical data of 

eligible refugee applicants to USRAP 

for access.

Ethnic minorities from Burma in 

Malaysia

Members of ethnic minorities from Burma, recognized 

by the UNHCR as refugees in Malaysia, and identified 

as being in need of resettlement.

Bhutanese in Nepal Bhutanese refugees registered by UNHCR in camps in 

Nepal, identified as in need of resettlement, and 

expressing interest prior to June 30, 2014.

Congolese in Rwanda Congolese refugees in Rwanda who were survivors of 

massacres in 1997, verifiably registered by the 

government of Rwanda and UNHCR in 2011, and 

identified as in need of resettlement.

Congolese in Tanzania Congolese refugees registered by UNHCR in Tanzania 

whose residence in the Nyaragusu refugee camp was 

confirmed in a 2013-2014 UNHCR verification 

exercise.
Appendix II: Summary of United States 

Refugee Admissions Program Priority 

Categories

Page 74 GAO-17-706 Refugee Screening Process

Priority 3 (P3) refugee category

Priority description Program access

Provides for USRAP access to family members (i.e., the spouse, unmarried children under 

21, and parents) of persons residing in the United States who were initially admitted into the 

country as refugees or who were granted asylum. Only certain nationalities of family 

members may apply, and the U.S.-based family member must be 18 years of age and must 

file within 5 years of arriving in the United States.g In addition, DNA testing is required to 

verify all claimed family relationships.

Applicants gain access after USCIS 

completes a review of the immigration 

files of the U.S.-based petitioner to 

verify all claimed relationships and 

their eligibility. Applicants and their 

family members must also submit to 

DNA testing, which USCIS verifies. 

Source: GAO analysis of Department of State and USCIS information | GAO-17-706.

a

The USRAP priority system provides guidelines for managing and processing refugee applications. 

The three priority categories are: Priority 1 , or individuals specifically referred to USRAP generally 

because they have a compelling need for protection; Priority 2, or specific groups, often within certain 

nationalities or ethnic groups in specified locations, whose members State and its partners have 

identified as being in need of resettlement; and Priority 3, or individuals from designated nationalities 

who have immediate family members in the United States who initially entered as refugees or who 

were granted asylum.

b

In addition to State’s review of P1 referrals, North Koreans and Palestinians referrals require DHS 

concurrence before they may be granted access.

c

See Pub. L. No. 101-167, § 599D, 103 Stat. 1195, 1261-63 (1989) (codified at 8 U.S.C. § 1157 note 

as amended). As subsequently amended, this provision, referred to as the “Lautenberg Amendment,”

establishes a presumption of refugee status of certain categories of people from the former Soviet 

Union and Southeast Asia as well as certain Iranian religious minorities. See also Pub. L. No. 108-

199, § 213, tit. II, 118 Stat. 3, 253 (2004) (adding certain Iranian populations). The Lautenberg 

Amendment must be reauthorized each fiscal year, and for fiscal year 2016 was reauthorized as part 

of the Consolidated Appropriations Act, 2016. See, e.g., Pub. L. No. 114-113, § 7034(k)(8), div. K, 

129 Stat. 2242, 2765 (2015).

d

See Refugee Crisis in Iraq Act of 2007, Pub. L. No. 110-181, tit. XII, 122 Stat. 3, 395-401 (2008) 

(authorizing this Iraqi direct access program).

e

Accepting Iraqi I-130 applications as a P2 category may allow USRAP to expedite processing for 

these petitions.

f

Accepting Syrian I-130 applications as a P2 category may allow USRAP to expedite processing for 

these petitions.

g

Nationalities permitted to submit P3 applications in fiscal years 2016 and 2017 are Afghanistan, 

Bhutan, Burma, Burundi, Central African Republic, Colombia, Cuba, Democratic People’s Republic of 

Korea, Democratic Republic of Congo, El Salvador, Eritrea, Ethiopia, Guatemala, Haiti, Honduras, 

Iran, Iraq, Mali, Somalia, South Sudan, Sudan, Sri Lanka, Syria, and Uzbekistan.
Appendix III: Comments from the Department 

of State

Page 75 GAO-17-706 Refugees

Appendix III: Comments from the 

Department of State

July 6, 2017
Appendix III: Comments from the Department 

of State

Page 76 GAO-17-706 Refugees
Appendix III: Comments from the Department 

of State

Page 77 GAO-17-706 Refugees
Appendix IV: Comments from the Department 

of Homeland Security

Page 78 GAO-17-706 Refugee Screening Process

Appendix IV: Comments from the 

Department of Homeland Security
Appendix IV: Comments from the Department 

of Homeland Security

Page 79 GAO-17-706 Refugee Screening Process
Appendix IV: Comments from the Department 

of Homeland Security

Page 80 GAO-17-706 Refugee Screening Process
Appendix IV: Comments from the Department 

of Homeland Security

Page 81 GAO-17-706 Refugee Screening Process
Appendix V: GAO Contact and 

Staff Acknowledgments

Page 82 GAO-17-706 Refugee Screening Process

Rebecca Gambler, (202) 512-8777 or gamblerr@gao.gov

In addition to the contact named above, Kathryn Bernet (Assistant 

Director), David Alexander, Mona Nichols Blake, Eric Erdman, Cynthia 

Grant, Brian Hackney, Paul Hobart, Eric Hauswirth, Susan Hsu, Thomas 

Lombardi, Mike McKemey, Erin McLaughlin, Thomas Melito, Clair 

Peachey, Mary Pitts, Elizabeth Repko, Judith Williams, and Su Jin Yon 

made significant contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102095)
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