Testimony Before the Subcommittee on 

Immigration, Border Security, and Claims, 

Committee on the Judiciary, House of 

Representatives

United States Government Accountability Office

GAO

For Release on Delivery 

Expected at 2:30 p.m. EDT 

Thursday, May 5, 2005 DEPARTMENT OF 

HOMELAND SECURITY 

Addressing Management 

Challenges That Face 

Immigration Enforcement 

Agencies 

Statement of Richard M. Stana, Director, 

Homeland Security and Justice Issues 

GAO-05-664T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-664T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Richard Stana 

at (202) 512-8777 or stanar@gao.gov. 

Highlights of GAO-05-664T, a testimony 

before the Subcommittee on Immigration, 

Border Security, and Claims, Committee 

on the Judiciary, House of 

Representatives 

May 5, 2005

DEPARTMENT OF HOMELAND SECURITY

Addressing Management Challenges That 

Face Immigration Enforcement Agencies 

A number of similar management challenges that had been experienced by 

INS have continued in the new organizations now responsible for 

immigration enforcement functions. In 2001, GAO testified that, while 

restructuring may help address certain management challenges, INS faced 

significant challenges in assembling the basic systems and processes that 

any organization needs to accomplish its mission. These include clearly 

delineated roles and responsibilities, policies and procedures that effectively 

balance competing priorities, effective internal and external 

communications and coordination, and automation systems that provide 

accurate and timely information. In March 2003, the functions of the INS 

were transferred to the new DHS and placed in the newly-created ICE and 

CBP. In 2004, we reported that many similar management challenges we 

found at INS were still in existence in the new bureaus. 

In evaluating solutions to ICE and CBP management challenges, including 

potential structural changes, several factors might be considered. The first 

factor is whether ICE and CBP currently have good management 

frameworks in place. Such a management framework, among other items, 

would include a clear mission, a strategic planning process, good 

organizational alignment, performance measures, and leadership and 

accountability mechanisms. The second factor is whether ICE and CBP have 

developed systems and processes to support the management frameworks 

they may have in place. The third factor is that the management challenges 

in these two bureaus exist in the larger context of the creation and evolution 

of DHS. The transformation and integration activities at DHS can take 

5-7 years to accomplish, and some management challenges might be 

resolved in this process. 

Reorganization of INS into DHS 

The Department of Homeland 

Security (DHS) assumed 

responsibility for the immigration 

programs of the former 

Immigration and Naturalization 

Service (INS) in 2003. The three 

DHS bureaus with primary 

responsibility for immigration 

functions are U.S. Customs and 

Border Protection (CBP), U.S. 

Immigration and Customs 

Enforcement (ICE), and U.S. 

Citizenship and Immigration 

Services (CIS). This testimony 

focuses on CBP and ICE, which 

took over the immigration 

enforcement function. CBP is 

responsible for functions related to 

inspections and border patrol, and 

ICE is responsible for functions 

related to investigations, 

intelligence, detention, and 

removal. 

The Subcommittee on Immigration, 

Border Security, and Claims, House 

Committee on the Judiciary, held a 

hearing to discuss management 

challenges and potential structural 

changes. Some research 

organizations have suggested 

structural changes to address 

management challenges, including 

a merger of CBP and ICE. 

This testimony addresses the 

following questions: (1) Have ICE 

and CBP encountered similar 

management challenges to those 

encountered at INS? 

 (2) What factors might be 

considered in addressing some of 

the management challenges that 

exist at ICE and CBP? 
Page 1 GAO-05-664T 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to share our views on management 

challenges relating to the Department of Homeland Security’s (DHS) U.S. 

Immigration and Customs Enforcement (ICE) and U.S. Customs and 

Border Protection (CBP), whose functions were formerly under the 

Immigration and Naturalization Service (INS) and the Customs Service, as 

this committee considers potential structural changes to enhance the 

enforcement of immigration laws. We have conducted numerous reviews 

of both specific programs and overall management in these components, 

and at the legacy agencies that preceded them. In my testimony today, I 

will discuss the following topics: 

• Have ICE and CBP encountered similar management challenges to 

those encountered at INS? 

• What factors might be considered in addressing some of the 

management challenges that exist at ICE and CBP? 

The purpose of my comments is to provide the Subcommittee with 

oversight information as potential changes to the structure of ICE and 

CBP are considered. My comments are based on our wide-ranging, 

completed work, and our institutional knowledge of homeland security 

and various government organizational and management issues. We 

conducted our work in accordance with generally accepted government 

auditing standards. 

A number of management challenges similar to those found at INS have 

continued in the new organizations now responsible for immigration 

enforcement functions. These INS management challenges included a lack 

of clearly defined priorities and goals; difficulty determining whom to 

coordinate with, when to coordinate, and how to communicate; and 

inadequately defined roles resulting in overlapping responsibilities, 

inconsistent program implementation, and ineffective use of resources. In 

1999 and 2001, we testified on these management challenges before this 

subcommittee. Our 2001 testimony concluded that, while restructuring 

may help address certain management challenges, the new organization 

would still face significant challenges in assembling the basic systems and 

processes that any organization needs to accomplish its mission. These 

systems and processes include clearly delineated roles and 

responsibilities, policies and procedures that effectively balance 

Summary 
Page 2 GAO-05-664T 

competing priorities, effective internal and external communications and 

coordination, and automation systems that provide accurate and timely 

information. We noted that unless these elements were established, 

enforcing our immigration laws, providing services to eligible aliens, and 

effectively participating in the government wide efforts to combat 

terrorism would be problematic regardless of how the immigration 

function was organized. In March 2003, the enforcement functions of the 

INS were transferred to the new DHS and placed in the newly-created ICE 

and CBP. In 2004, we reported that many similar management challenges 

we found at INS were in existence in the new bureaus. 

In evaluating solutions to ICE and CBP management challenges, including 

potential structural changes, several factors may be considered. The first 

factor is whether ICE and CBP currently have a good management 

framework in place. Such a management framework, among other items, 

would include a clearly defined and articulated mission, a comprehensive 

strategic planning process for achieving the mission, an organizational 

alignment that supports the mission and strategy, performance measures 

to gauge their progress, and leadership and accountability mechanisms. 

The second factor is whether ICE and CBP have developed systems and 

processes to support such a management framework which assists 

management in resolving management challenges. For example, we have 

noted problems with ICE’s disseminating guidance related to operational 

activities. The third factor involves recognizing that the management 

challenges in these two bureaus exist in the broader context of the 

creation and evolution of DHS—the largest reorganization of the federal 

government in over 50 years. The experience of successful 

transformations and change management initiatives in large public and 

private organizations suggests that it can take 5-7 years until such 

initiatives are fully implemented and cultures are transformed in a 

substantial manner. Further, some management challenges at ICE and 

CBP might be affected by department-wide management initiatives. We 

designated DHS’s transformation as a high-risk area in 2003.

Immigration enforcement includes, among other things, patrolling 8,000 

miles of international boundaries to prevent illegal entry into the United 

States; inspecting over 500 million travelers each year to determine their 

admissibility; apprehending, detaining, and removing criminal and illegal 

aliens; disrupting and dismantling organized smuggling of humans and 

contraband as well as human trafficking; investigating and prosecuting 

those who engage in benefit and document fraud; blocking and removing 

employers’ access to undocumented workers; and enforcing compliance 

with programs to monitor visitors. 

Background 
Page 3 GAO-05-664T 

Immigration functions also include providing services or benefits to 

facilitate entry, residence, employment, and naturalization of legal 

immigrants; processing millions of applications each year; making the 

right adjudicative decision in approving or denying the applications; and 

rendering decisions in a timely manner. 

When INS was abolished in 2003 by the Homeland Security Act of 2002,1

 its 

enforcement functions were transferred to two bureaus within the DHS. 

First, INS’s interior enforcement programs—investigations, intelligence, 

and detention and removal—were placed in ICE. Within ICE, investigators 

and intelligence analysts from former INS and the U.S. Customs Service 

were merged into the investigations and intelligence offices, while staff 

from former INS’s detention and removal program were placed in the 

detention and removal office. Second, inspectors from former INS, 

Customs, and Agriculture and Plant Health Inspection Service, as well as 

former INS’s Border Patrol agents were incorporated into CBP. Both CBP 

and ICE report to the Undersecretary for Border and Transportation 

Security, who in turn reports to the Deputy Secretary of the DHS. For 

service functions, INS’s Immigration Services Division, responsible for 

processing applications for immigration benefits, was placed in 

Citizenship and Immigration Services (CIS), which reports directly to the 

Deputy Secretary of DHS. Figure 1 shows the transition of INS functions 

into DHS. 

 1

P.L. 107-296, Sec. 471(a). 
Page 4 GAO-05-664T 

Figure 1. Transfer of Immigration Functions from INS into DHS 

Transition efforts for CBP posed fewer challenges than for ICE. 

Specifically, CBP brought together INS and Customs inspections programs 

Information Analysis 

and Infrastructure

Development Directorate

Border and 

Transportation 

Security Directorate

Transportation 

Security 

Administration

U.S. Customs and 

Border Protection

(CBP)

Federal Law 

Enforcement Training 

Center

Office for

Domestic 

Preparedness

U.S. Immigration

and Customs 

Enforcement (ICE)

Emergency 

Preparedness and 

Response Directorate

Science and 

Technology 

Directorate

Management

Directorate

Coast

Guard

Secret

Service

Office for State

and Local 

Government 

Coordinator

Office of

International

Affairs

Special Liaison

for Private

Sector

 U.S. Citizenship and 

Immigration Service (CIS)

Shared services

Source: GAO analysis of President’s fiscal year budget, PL. 107-286.

Immigration and Naturalization Service (INS)

Services Investigations, Intelligence,

Detention and Removal

Inspections

and Border Patrol

Deputy Secretary

Department of Homeland Security 

(Secretary)

Under CIS

in DHS

Under CBP

in DHS

Under ICE

in DHS

Former agency

New department
Page 5 GAO-05-664T 

that, prior to the transition, largely worked side by side in many land ports 

of entry around the country and that shared similar missions. In contrast, 

ICE is a patchwork of agencies and programs that includes INS’s 

investigations and intelligence programs, Customs’ investigations and 

intelligence programs, the Federal Protective Service, and the Federal Air 

Marshals. In combining the investigations programs, ICE has been tasked 

with merging former INS investigators who specialized in immigration 

enforcement (e.g., criminal aliens) with former Customs investigators who 

specialized in customs enforcement (e.g., drug smuggling). 

The integration of INS and Customs investigators into a single 

investigative program has involved the blending of two vastly different 

workforces, each with its own culture, policies, procedures, and mission 

priorities. Both programs were in agencies with dual missions that prior to 

the merger had differences in investigative priorities. For example, INS 

primarily looked for illegal aliens and Customs primarily looked for illegal 

drugs. In addition, INS investigators typically pursued administrative 

violations, while Customs investigators typically pursued criminal 

violations. 

Whether further structural changes are warranted is one of the topics that 

this hearing is to address. Some observers have proposed merging ICE and 

CBP. For example, the Heritage Foundation and the Center for Strategic 

and International Studies (CSIS), in a report on DHS management, 

suggested a possible merger of ICE and CBP to address some of these 

management problems. A Senior Research Fellow at The Heritage 

Foundation stated in a March 2005 congressional testimony, “DHS needs 

to be organized not to accommodate the present, but to build toward the 

ideal organization of the future. Therefore, the department needs to 

articulate how it envisions conducting its missions five to ten years from 

now and let this vision drive the organizational design, particularly the 

structure of border security operations.”2

 Another witness stated, 

“Whether the decision is ultimately made to merge ICE and CBP or not, 

 2

Statement of Dr. James Jay Carafano, Senior Research Fellow, The Heritage Foundation, 

Before the Subcommittee on Management, Integration, and Oversight, House Committee 

on Homeland Security (Washington, D.C.: Mar. 9, 2005). 
Page 6 GAO-05-664T 

the real issues will remain unless the underlying mission, vision, and 

planning occur in a unified manner.”3

Over the years, we have issued numerous reports that identified 

management challenges INS experienced in its efforts to achieve both 

effective immigration law enforcement and service delivery. For example, 

in 1997 we reported that INS lacked clearly defined priorities and goals 

and that its organizational structure was fragmented both 

programmatically and geographically. Additionally, after reorganization in 

1994, field managers still had difficulty determining whom to coordinate 

with, when to coordinate, and how to communicate with one another 

because they were unclear about headquarters offices’ responsibilities and 

authority. We also reported that INS had not adequately defined the roles 

of its two key enforcement programs—Border Patrol and investigations—

which resulted in overlapping responsibilities, inconsistent program 

implementation, and ineffective use of resources. INS’s poor 

communication led to weaknesses in policies and procedures. In later 

reports, we showed that broader management challenges affected INS’s 

efforts to implement programs to control the border, deter alien 

smuggling, reduce immigration benefit fraud, reduce unauthorized alien 

employment, remove criminal aliens, and manage the immigration benefit 

application workload and reduce the backlog.4

In 1999 and 2001, we testified on these management challenges before this 

subcommittee. Our 2001 testimony was delivered at the time when 

 3

Statement of David Venturella, Former Acting Director of the Office of Detention and 

Removal Operations, Department of Homeland Security, Before the Subcommittee on 

Management, Integration, and Oversight, House Committee on Homeland Security 

(Washington, D.C.: Mar. 9, 2005). 

4

GAO, Immigration Enforcement: Challenges to Implementing the INS Interior 

Enforcement Strategy, GAO-02-861T (Washington, D.C.: June 19, 2002); GAO, Immigration 

Benefit Fraud: Focused Approach Is Needed to Address Problems, GAO-02-66

(Washington, D.C.: Jan. 31, 2002); GAO, INS’s Southwest Border Strategy: Resource and 

Impact Issues Remain after Seven Years, GAO-01-842 (Washington, D.C.: Aug. 2, 2001); 

GAO, Immigration Benefits: Several Factors Impede Timeliness of Application 

Processing, GAO-01-488 (Washington, D.C.: May 4, 2001).GAO, Alien Smuggling: 

Management and Operational Improvements Needed to Address Growing Problem, 

GAO/GGD-00-103 (Washington, D.C.: May 1, 2000); and Criminal Aliens: INS’s Efforts to 

Identify and Remove Imprisoned Aliens Continue to Need Improvement, 

GAO/T-GGD-99-47 (Washington, D.C.: Feb., 25, 1999); and GAO, Criminal Aliens: INS’ 

Efforts to Identify and Remove Imprisoned Aliens Need to be Improved, 

GAO/T-GGD-97-154 (Washington, D.C.: July 15, 1997). 

Similar Management 

Challenges Continue 
Page 7 GAO-05-664T 

Congress, the Administration, and others had offered various options for 

restructuring the INS to deal with its management challenges. We testified 

that while restructuring may help address certain management challenges, 

we saw an organization (INS) that faced significant challenges in 

assembling the basic building blocks that any organization needs: clearly 

delineated roles and responsibilities, policies and procedures that 

effectively balance competing priorities, effective internal and external 

communications and coordination, and automation systems that provide 

accurate and timely information. We noted that unless these elements 

were established, enforcing our immigration laws, providing services to 

eligible aliens, and effectively participating in the government-wide efforts 

to combat terrorism would be problematic regardless of how INS was 

organized. 

In 2004, we reported DHS experienced management challenges similar to 

those we had found at INS. For example, some officials noted that in some 

areas related to investigative techniques and other operations, unresolved 

issues regarding the roles and responsibilities of CBP and ICE give rise to 

disagreements and confusion, with the potential for serious consequences. 

As in 1999 and 2001, we reported in 2004 that selected operations had 

reportedly been hampered by the absence of communication and 

coordination between CBP and ICE. Further, we reported in 2004 that CBP 

and ICE lacked formal guidance for addressing some overlapping 

responsibilities. 

As this Subcommittee, DHS officials, and other stakeholders consider 

potential structural changes to ICE and CBP, we have identified three 

factors to consider for resolving management challenges including (1) a 

management framework for ICE and CBP, (2) systems and processes to 

support this framework, and (3) the context of the larger DHS 

transformation. These factors are important to help identify the most 

suitable and appropriate course of action to address management 

challenges. 

Based on our work on the creation and development of DHS, and 

additional work on transformation and mergers, we have identified a 

number of key success factors. Those factors that I would like to focus on 

today include clarity of mission, strategic planning, organizational 

Factors to Consider 

for Resolving 

Management 

Challenges 

Management Framework 

for ICE and CBP 
Page 8 GAO-05-664T 

alignment, performance measures, and leadership focus and 

accountability.5

• Clarity of Mission: We have previously reported on the importance of 

establishing a coherent mission that defines an organization’s culture 

and serves as a vehicle for employees to unite and rally around. As 

such, a comprehensive agency mission statement is the first GPRArequired element of a successful strategic plan.6

 In successful 

transformation efforts, developing, communicating, and constantly 

reinforcing the mission gives employees a sense of what the 

organization intends to accomplish, as well as helps employees figure 

out how their positions fit in with the new organization and what they 

need to do differently to help the new organization achieve success. 

However, as noted above, while CBP was created from programs that 

generally shared similar missions, ICE blended agencies with distinct 

mission priorities and cultures, and thus faces a greater challenge in 

creating a unified bureau. 

• Strategic Planning: Closely related to establishing a clear mission is 

strategic planning—a continuous, dynamic, and inclusive process that 

provides the foundation for the fundamental results that an 

organization seeks to achieve. The starting point for this process is the 

strategic plan that describes an organization’s mission, outcomeoriented strategic goals, strategies to achieve these goals, and key 

factors beyond the agency’s control that could impact the goals’ 

achievement, among other things. As with the mission, strategic goals 

for a transforming organization must be clear to employees, customers, 

 5

These success factors were derived from work we reported in GAO, Homeland Security: 

Management Challenges Facing Federal Leadership, GAO-03-260 (Washington, D.C.: Dec. 

20, 2002) and GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers 

and Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003). 

Additional key practices for successful mergers and organizational transformations not 

discussed in this statement include focusing on a key set of principles and priorities at the 

outset of the transformation, setting implementation goals and a timeline to build 

momentum and show progress, dedicating an implementation team to manage the 

transformation process, establishing a communication strategy to create shared 

expectations and report related progress, and involving employees to obtain their ideas and 

gain their ownership for the transformation. 

6

The Government Performance and Results Act of 1993 (GPRA) provides a strategic 

planning and management framework intended to improve federal agencies’ performance 

and hold them accountable for achieving results. Our work on management structure and 

strategic planning is based largely on GPRA. 
Page 9 GAO-05-664T 

and stakeholders to ensure they see a direct personal connection to the 

transformation. 

• Organizational Alignment: To ensure that form follows function, an 

organizational alignment that supports the mission and strategic goals 

is another component of the management framework. Leading 

organizations recognize that sound planning is not enough to ensure 

their success. An organization’s activities, core processes, and 

resources must be aligned to support its mission and help it achieve its 

goals. Such organizations start by assessing the extent to which their 

programs and activities are structured to accomplish their mission and 

desired outcomes. 

• Performance Measures: Effective implementation of this framework 

requires agencies to clearly establish results-oriented performance 

goals in strategic and annual performance plans for which they will be 

held accountable, measure progress towards those goals, determine the 

strategies and resources to effectively accomplish the goals, use 

performance information to make the programmatic decisions 

necessary to improve performance, and formally communicate results 

in performance reports. 

• Leadership Focus and Accountability: To be successful, 

transformation efforts must have leaders, managers, and employees 

who have the individual competencies to integrate and create synergy 

among the multiple organizations involved in the transformation effort. 

Leaders need to be held accountable for ensuring results, recognizing 

when management attention is required and taking corrective action. 

High-performing organizations create this clear linkage between 

individual performance and organizational success and thus transform 

their cultures to be more results-oriented, customer-focused, and 

collaborative in nature. As we have reported, a Chief Operating Officer 

(COO)/Chief Management Officer (CMO) may effectively provide the 

continuing, focused attention essential to successfully completing 

these multi-year transformations in agencies like DHS.7

 At DHS, we 

have reported that the COO/CMO concept would provide the 

department with a single organizational focus for the key management 

 7

On September 9, 2002, GAO convened a roundtable of government leaders and 

management experts to discuss the COO concept and how it might apply within selected 

federal departments and agencies. See GAO, Highlights of a GAO Roundtable: The Chief 

Operating Officer Concept: A Potential Strategy to Address Federal Governance 

Challenges, GAO-03-192SP (Washington, D.C.: Oct. 4, 2002). 
Page 10 GAO-05-664T 

functions involved in the business transformation of the department, as 

well as for other organizational transformation initiatives.8

 

The second factor to consider for resolving management challenges is 

whether CBP and ICE have the systems and processes needed to support 

the management framework. While the management framework provides 

an overarching structure for an organization, systems and processes 

provide the means to implement the daily activities of running an 

organization. Some of the specific systems and processes in CBP and ICE 

that have raised concerns include: 

• Dissemination of guidance relating to operational activities, 

• Communication and coordination, 

• Information technology systems, and 

The lack of program guidance has adversely impacted ICE’s ability to 

efficiently and effectively perform its mission. In May 2004, we reported 

that ICE had not provided its deportation officers with guidance on how to 

prioritize their caseload of aliens who required supervision after release 

from detention. Consequently, ICE was unable to determine whether and 

to what extent such aliens had met the conditions of their release. We 

recommended that ICE develop and disseminate guidance to enable 

deportation officers to prioritize ICE’s caseload of aliens on orders of 

supervision so that ICE could focus its limited resources on supervising 

aliens who may be a threat to the community or who are not likely to 

comply with the conditions of their release. 

Also, in October 2004, we reported that ICE headquarters and field offices 

had a lack of uniform policies and procedures for some ICE operations 

that had caused confusion and hindered the creation of a new integrated 

culture. ICE headquarters officials told us that they were prioritizing the 

establishment of uniform policies and that until a new ICE policy is 

established, field offices are required to use the policies of the former 

agencies. 

 8

GAO, The Chief Operating Officer Concept and its Potential Use as a Strategy to 

Improve Management at the Department of Homeland Security, GAO-04-876R

(Washington, D.C.: June 28, 2004). 

Systems and Processes 

Needed to Support 

Management Framework 

Dissemination of Guidance 

Relating to Operational 

Activities 
Page 11 GAO-05-664T 

Shortfalls in communications about administrative support services were 

also a source of frustration in DHS. In October 2004, we reported that DHS 

was in the process of developing and implementing systems and processes 

called “shared services.” In December 2003, DHS instituted a shared 

service system in which certain mission support services—such as human 

resources—are provided by one bureau to the other bureaus. However, 

there were weaknesses in how the shared services program was 

communicated to employees. Officials in CBP, CIS, and ICE expressed 

confusion about shared services when we interviewed them 3 to 4 months 

after the system was instituted. Many field officials said they did not know 

what constituted shared services, what processes they should have been 

using for receiving assistance from a shared service provider, or how many 

of their staff administrative positions would be reassigned to positions in 

other offices as shared service providers. 

Further, CBP, CIS, and ICE officials also expressed frustration with 

problems they have encountered coordinating their administrative systems 

managed within the agency and not a part of shared services, including 

travel, budget, and payroll. Some ICE field officials also expressed 

concern about their ability to manage their budgets and payroll problems, 

because of the systems used for these functions. 

Information technology systems and information sharing in general are 

also an area of concern. For example, ICE did not have information that 

provides assurance that its custody reviews are timely and its custody 

determinations are consistent with the Supreme Court decision and 

implementing regulations regarding long term alien detention.9

 One reason 

ICE had difficulty providing assurance is that it lacked complete, accurate, 

and readily available information to provide to deportation officers when 

post order custody reviews are due for eligible aliens. In addition, ICE did 

not have the capability to record information on how many post order 

custody reviews had been made pursuant to regulations and what 

decisions resulted from those reviews. Therefore, ICE managers could not 

gauge overall compliance with the regulations for aliens who have been 

 9

Until 2001, aliens who were issued final orders of removal from the United States could be 

held in detention facilities indefinitely if U.S. immigration authorities determined that the 

aliens were a threat to the community or a flight risk. However, U.S. Supreme Court 

decision in Zadvydas v. Davis, 533 U.S. 678 (2001), many aliens with final orders of 

removal, including aliens determined to be a threat to the community or flight risk, could 

generally no longer be detained beyond a period of 6 months if there was no significant 

likelihood of their removal in the reasonably foreseeable future. 

Communication and 

Coordination 

Information Technology 

Systems 
Page 12 GAO-05-664T 

ordered to be removed from the United States. Although ICE was in the 

process of updating its case management system, ICE officials said that 

they did not know when the system will have the capability to capture 

information about the timeliness and results of post order custody 

reviews. In 2005, we designated information sharing mechanisms for 

homeland security as a high-risk issue, based on root causes behind 

vulnerabilities, as well as actions needed on the part of the agency 

involved.10 

In addition to considering developing a management framework and 

corresponding systems and processes, it is important to consider these 

changes in the larger context of the transformation of DHS. We designated 

DHS’s transformation as a high-risk area in 2003, based on three factors. First, 

DHS faced enormous challenges in implementing an effective 

transformation process, developing partnerships, and building 

management capacity because it had to transform 22 agencies into one 

department. Second, DHS faced a broad array of operational and 

management challenges that it inherited from its component legacy 

agencies. Finally, DHS’s failure to effectively address its management 

challenges and program risks could have serious consequences for our 

national security. Overall, DHS has made some progress, but significant 

management challenges remain to transform DHS into a more efficient 

organization while maintaining and improving its effectiveness in securing 

the homeland.

 11 

The experience of successful transformations and change management 

initiatives in large public and private organizations suggests that it can 

take 5-7 years until such initiatives are fully implemented and cultures are 

transformed in a substantial manner. Further, some management 

challenges at ICE and CBP might be affected by department-wide 

management initiatives. The management challenges of the DHS 

transformation create additional challenges for its components, including 

ICE and CBP, such as: 

• Providing focus for management efforts: Although DHS has been 

operating about 2 years, it has had two Secretaries, three Deputy 

Secretaries, and additional turnover at the Undersecretary and 

 10GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: Jan. 2005).

11GAO, Homeland Security: Overview of Department of Homeland Security Management 

Challenges, GAO-05-573T (Washington, D.C.: Apr. 20, 2005). 

Broader DHS 

Transformation and 

Management Integration 

Efforts May Affect ICE and 

CBP Management 

Challenges 
Page 13 GAO-05-664T 

Assistant Secretary levels. The recent turnover in DHS’s top leadership 

raises questions about the department’s ability to provide the 

consistent and sustained senior leadership necessary to achieve 

integration over the long term.12

• Monitoring transformation and integration: DHS’s integration of 

varied management processes, systems, and people—in areas such as 

information technology, financial management, procurement, and 

human capital------as well as administrative services is important to 

provide support for the total integration of the department. Total 

integration of the department, including its operations and programs, is 

critical to ultimately meeting its mission of protecting the homeland. 

Overall, we found that while DHS has made some progress in its 

management integration efforts, it has the opportunity to better 

leverage this progress by implementing a comprehensive and sustained 

approach to its overall integration efforts. 13

• Improving strategic planning: DHS released its first strategic plan in 

2004 that details its mission and strategic goals. DHS’s strategic plan 

addresses five of the six GPRA-required elements—a mission 

statement, long-term goals, strategies to achieve the goals, external key 

factors, and program evaluations—but does not describe the 

relationship between annual and long-term goals.14

• Managing human capital: DHS has been given significant authority to 

design a new human capital system free from many of the 

government’s existing civil service requirements, and has issued final 

regulations for this new system. Although we reported the 

department’s efforts generally reflected important elements of effective 

transformations and included many principles that are consistent with 

proven approaches to strategic human capital management, DHS has 

 12See GAO-05-573T

13GAO, Department of Homeland Security: A Comprehensive and Sustained Approach 

Needed to Achieve Management Integration, GAO-05-139 (Washington, D.C.: Mar. 16, 

2005). 

14GAO, Results-Oriented Government: Improvements to DHS’s Planning Process Would 

Enhance Usefulness and Accountability, GAO-05-300 (Washington, D.C.: Mar. 31, 2005). 
Page 14 GAO-05-664T 

considerable work ahead to define the details of the implementation of 

the system.15

• Strengthening financial management infrastructure: DHS faces 

significant financial management challenges. Specifically, it must 

address numerous internal control weaknesses, meet the mandates of 

the DHS Financial Accountability Act,16 and integrate and modernize its 

financial management systems, which individually have problems and 

collectively are not compatible with one another. In July 2004, we 

reported that DHS continues to work to reduce the number of financial 

management service providers and to acquire and deploy an integrated 

financial enterprise solution.17

• Establishing an information technology framework: DHS has 

recognized the need for a strategic management framework that 

addresses key information technology disciplines, and has made a 

significant effort to make improvements in each of these disciplines. 

However, much remains to be accomplished before it will have fully 

established a department-wide information technology management 

framework. To fully develop and institutionalize the management 

framework, DHS will need to strengthen strategic planning, develop the 

enterprise architecture, improve management of systems development 

and acquisition, and strengthen security.18

 15GAO, Human Capital: Preliminary Observations on Final Department of Homeland 

Security Human Capital Regulations, GAO-05-320T (Washington, D.C.: Feb. 10, 2005). For 

more information on DHS’s human capital issues, see GAO, Human Capital: Preliminary 

Observations on Proposed DHS Human Capital Regulations, GAO-04-479T (Washington, 

D.C.: Feb. 25, 2003); Posthearing Questions Related to Proposed Department of Homeland 

Security (DHS) Human Capital Regulations, GAO-04-570R (Washington, D.C.: Mar. 22, 

2004); Additional Posthearing Questions Related to Proposed Department of Homeland 

Security (DHS) Human Capital Regulations, GAO-04-617R (Washington, D.C.: Apr. 30, 

2004); Human Capital: DHS Faces Challenges in Implementing Its New Personnel 

System, GAO-04-790 (Washington, D.C.: June 18, 2004); and Human Capital: DHS 

Personnel System Design Effort Provides for Collaboration and Employee Participation, 

GAO-03-1099 (Washington, D.C.: Sept. 30, 2003). 

16Pub. L. No. 108-330 (Oct. 16, 2004). 

17GAO, Financial Management: Department of Homeland Security Faces Significant 

Financial Management Challenges, GAO-04-774 (Washington: D.C.: July 19, 2004). 

18GAO, Department of Homeland Security: Formidable Information and Technology 

Management Challenge Requires Institutional Approach, GAO-05-702 (Washington, D.C.: 

Aug. 27, 2004). 
Page 15 GAO-05-664T 

• Managing acquisitions: DHS faces the challenge of structuring its 

acquisition organization so that its various procurement organizations 

are held accountable for complying with procurement policies and 

regulations and ensuring that taxpayer dollars are well-spent.19

• Coordinating research and development: DHS has not yet completed a 

strategic plan to identify priorities, goals, objectives, and policies for 

the research and development of homeland security technologies, and 

additional challenges remain in its coordination with other federal 

agencies.20

Despite real and hard-earned progress, DHS still has significant challenges 

to overcome in all of its management areas. Resolving these challenges at 

the top levels could help address similar management challenges in DHS’s 

component organizations including ICE and CBP. 

In closing, it is important to understand the expectations and limitations of 

various proposals to address management challenges at ICE and CBP that 

we and others have identified. With respect to potential restructuring, 

reorganizing an agency or function to better align it with the mission and 

strategic planning process is desirable, whereas reorganizing mainly to 

address underlying weaknesses in supporting systems and processes, such 

as a lack of coordination and cooperation among units or a lack of 

guidance relating to operational activities, might not be productive. As we 

have seen to date, reorganizing immigration and customs functions, 

without fixing existing problems with underlying systems and processes, 

has not resolved long-standing management issues. In addition, ICE and 

CBP may not be able to resolve some of these challenges alone if they are 

affected by DHS department-wide management initiatives and 

developments. To assist the Congress in its oversight and in ensuring 

accountability in homeland security programs, we will continue to monitor 

and evaluate ICE and CBP programs as they meet, and hopefully 

overcome, their management challenges. 

 19 See GAO-05-179

20GAO, Homeland Security: DHS Needs a Strategy to Use DOE’s Laboratories for 

Research on Nuclear, Biological, and Chemical Detection and Response Technologies, 

GAO-04-653 (Washington, D.C.: May 24, 2004). 

Concluding 

Observations 
Page 16 GAO-05-664T 

Mr. Chairman, this concludes my statement. I would be pleased to respond 

to any questions that you or other members of the Subcommittee may 

have at this time. 

For further information about this testimony, please contact Richard Stana 

at 202-512-8777. 

Other key contributors to this statement were Stephen L. Caldwell, 

Lisa Brown, Mary Catherine Hult, Lori Kmetz, Sarah E. Veale, and 

Katherine Davis. 

GAO Contacts and 

Staff 

Acknowledgments 

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