a

GAO

United States Government Accountability Office

Report to Congressional Committees

July 2005 BORDER SECURITY

Actions Needed to 

Strengthen 

Management of 

Department of 

Homeland Security’s 

Visa Security Program

GAO-05-801
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-801.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Jess Ford at 

(202) 512-4128 or fordj@gao.gov. 

Highlights of GAO-05-801, a report to 

congressional committees 

July 2005

BORDER SECURITY

Actions Needed to Strengthen 

Management of Department of Homeland 

Security’s Visa Security Program 

Visa Security Officers (VSO) assigned to Saudi Arabia review all visa 

applications prior to final adjudication by consular officers, and assist 

consular officers with interviews and fraud prevention; however, no 

comprehensive data exists to demonstrate the VSOs’ impact. According to 

State Department consular officers, the deputy chief of mission, and 

Department of Homeland Security (DHS) officials in Saudi Arabia, the VSOs 

in Riyadh and Jeddah strengthen visa security because of their law 

enforcement and immigration experience, as well as their ability to access 

and use information from law enforcement databases not immediately 

available, by law, to consular officers. Furthermore, the requirement to 

review all visa applications in Saudi Arabia limits the VSOs’ ability to provide 

additional training and other services to consular officers, such as assisting 

with interviews. Moreover, security concerns in Saudi Arabia limit staffing 

levels at these posts. 

DHS has not developed a strategic plan outlining the Visa Security Program’s 

mission, activities, program goals, and intended results for operations in 

Saudi Arabia or the planned expansion posts. Chiefs of mission at the five 

posts chosen for expansion in fiscal year 2005 delayed approving DHS’s 

requests for the assignment of VSOs until DHS answered specific questions 

regarding the program’s goals and objectives, staffing requirements, and 

plans to coordinate with existing staff and law enforcement and border 

security programs at post. DHS’s development of a strategic plan may 

address outstanding questions from chiefs of mission and other embassy 

officials and help DHS expand the program. 

DHS Participation in the Visa Process in Saudi Arabia 

Applicant 

goes to 

post.

Application 

reviewed, 

fingerprints 

taken, and 

name 

check 

performed.

Applicant 

interviewed 

and 

documentation 

reviewed. 

Consular 

officer reviews 

name check 

results and 

determines if 

Security 

Advisory 

Opinion (SAO) 

is needed.

SAO 

submitted for 

interagency 

check

SAO 

needed

SAO not 

needed

Post 

receives 

SAO 

response

Applicant 

schedules 

interview 

with post.

Consular 

officer 

decides to 

issue or 

deny visa 

to 

applicant.

Visa is 

issued 

or 

denied.

DHS reviews 

and either 

affirms or 

refutes the 

consular 

officer’s 

determination.

Sources: GAO; Nova Development (clip art), MapArt (map).

DHS

DHS

DHS

SAUDI

ARABIA

The Homeland Security Act of 2002 

required that the Department of 

Homeland Security’s on-site 

personnel in Saudi Arabia review 

all visa applications. The act also 

authorized the expansion of the 

Visa Security Program to other 

embassies and consulates to 

provide expert advice and training 

to consular officers, among other 

things. Given the congressional 

interest in effective implementation 

of the Visa Security Program, we 

assessed (1) the Visa Security 

Officers’ activities in Saudi Arabia, 

and (2) DHS’s plans to expand its 

Visa Security Program to other 

consular posts overseas. 

What GAO Recommends

GAO recommends that the 

Secretary of Homeland Security (1) 

develop a strategic plan to guide 

visa security operations and (2) 

develop and maintain performance 

data that demonstrate the impact 

of the Visa Security Program. 

In addition, Congress may wish to 

consider amending section 428(i) 

of the Homeland Security Act to 

allow DHS the flexibility to 

determine the extent to which the 

VSOs in Saudi Arabia will review 

applications, based upon the 

development of a risk-assessment 

tool. 

We received comments from DHS 

and State, both of which agreed 

with our report. DHS stated it was 

developing a strategic plan and a 

system to measure program 

impact, as we recommended. 
Page i GAO-05-801 Border Security

Contents

Letter 1

Results in Brief 2

Background 4

Several Factors Have Limited the Impact of Visa Security Operations 

in Saudi Arabia 7

DHS’s Plans for Expansion of the Visa Security Program Delayed 13

Conclusions 19

Recommendations for Executive Action 19

Matter for Congressional Consideration 20

Agency Comments and Our Evaluation 20

Appendixes

Appendix I: Scope and Methodology 25

Appendix II: Comments from the Department of Homeland Security 26

GAO Comments 37

Appendix III: Comments from the Department of State 39

Appendix IV: GAO Contacts and Staff Acknowledgements 42

Table Table 1: Visa Security Program Expansion 16

Figures Figure 1: Establishment and Implementation of the Visa Security 

Program 6

Figure 2: Visa Process in Saudi Arabia 8
Contents

Page ii GAO-05-801 Border Security

Abbreviations

CLASS Consular Lookout and Support System

DHS Department of Homeland Security

ICE Immigration and Customs Enforcement

VSO Visa Security Officer

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Page 1 GAO-05-801 Border Security

United States Government Accountability Office

Washington, D.C. 20548

A

July 29, 2005 Letr

Congressional Committees:

The September 11, 2001, terrorist attacks highlighted vulnerabilities that 

existed in the visa process, particularly the lack of emphasis placed on 

using interviews and application reviews as antiterrorism tools.1

 In October 

2002, we reported that the visa process should be strengthened and that 

increased priority should be given to national security.2

 On November 25, 

2002, Congress passed the Homeland Security Act of 2002. The act 

provides, among other things, for the assignment of Department of 

Homeland Security (DHS) employees to U.S. embassies and consulates to 

provide expert advice and training to consular officers regarding visa 

security, among other things.3

 In particular, the act mandated that DHS 

personnel, referred to as Visa Security Officers (VSO), in Saudi Arabia 

review all visa applications prior to final adjudication by Department of 

State (State) consular officers. By September 2003, VSOs had assumed 

their responsibilities at U.S. posts in Riyadh and Jeddah, Saudi Arabia. DHS 

plans to expand the Visa Security Program4

 to additional posts throughout 

fiscal years 2005 and 2006.5 Congress appropriated $10 million for the 

program in fiscal year 2005, and DHS requested $15 million for fiscal year 

2006.

Due to the congressional interest in effective implementation of the Visa 

Security Program, we assessed (1) the Visa Security Officers’ activities in 

Saudi Arabia, and (2) DHS’s plans to expand the program to other consular 

1

A visa is a U.S. travel document that most foreign citizens must obtain before arriving at 

U.S. ports of entry to enter the United States temporarily for business, tourism, or other 

reasons. The United States also grants visas to people who intend to immigrate to the United 

States. In this report, we use the term “visa” to refer to nonimmigrant visas only. 

2

We reported that the visa process prior to September 11 focused primarily on screening 

applicants to determine if they intended to work or reside illegally in the United States. See 

GAO, Border Security: Visa Process Should Be Strengthened as an Antiterrorism Tool, 

GAO-03-132NI (Washington, D.C.: Oct. 21, 2002).

3

P.L. 107-296.

4

For the purpose of this report, we will refer to DHS’s program that oversees the 

implementation of the requirements in sect. 428 (e) and sect. 428 (i) of the Homeland 

Security Act of 2002 as the Visa Security Program.

5

In this report, we do not name the exact locations DHS plans to expand to because the 

department stated this is sensitive information.
Page 2 GAO-05-801 Border Security

posts overseas. To assess DHS operations in Saudi Arabia, we reviewed 

documentation on and observed visa operations at the U.S. Embassy in 

Riyadh and the U.S. Consulate in Jeddah. In Saudi Arabia and Washington, 

D.C., we interviewed DHS officials who manage the Visa Security Program, 

as well as State consular officials. To assess DHS’s plans for expansion of 

the Visa Security Program, we visited two of the five posts to which DHS 

plans to expand the program and interviewed consular and embassy 

officials, including the chiefs and deputy chiefs of mission, at these 

locations to discuss the posts’ plans for the VSOs. We also spoke with the 

consuls general from the other three posts initially chosen for expansion in 

fiscal year 2005. In addition to our review of the DHS Visa Security 

Program, we will report later this year on (State) changes to the visa 

process since our 2002 report. We conducted our evaluation from August 

2004 to June 2005 in accordance with generally accepted government 

auditing standards. 

Results in Brief VSOs assigned to consular posts in Riyadh and Jeddah, Saudi Arabia, are 

required to review all visa applications prior to final adjudication by 

consular officers and assist consular officers with interviews and fraud 

prevention. According to DHS, State’s consular officials, and the deputy 

chief of mission in Saudi Arabia, the VSOs strengthen visa security at these 

posts. VSOs offer law enforcement and immigration experience and have 

access to and experience using information from law enforcement 

databases, which are not readily available to consular officers. The VSOs in 

Saudi Arabia provided anecdotal evidence of their contributions to the visa 

process; however, DHS does not maintain comprehensive data on the 

results of their activities, such as the number of cases for which VSOs 

recommended refusal, and thus is unable to fully demonstrate the 

program’s overall impact on visa operations. Further, additional factors 

have limited the impact of the VSOs. Since the initial deployment of VSOs 

in August 2003 until June 2005, DHS assigned temporary officers to the 

posts in Saudi Arabia for tours that lasted between 2 and 15 months, which 

initially hindered continuity in operations. In June 2005, DHS hired and 

deployed permanent VSOs to Saudi Arabia. Additionally, the mandate 

requiring that VSOs review all visa applications in Saudi Arabia, including 

visas preliminarily refused by consular officers and low-risk applicants, 

limits their ability to perform other tasks that would further benefit 

consular officers, such as providing additional fraud prevention and 

detection training. Moreover, security concerns at consular posts in Saudi 

Arabia limit the number of personnel from DHS, as well as other agencies, 

that can be stationed at these posts.
Page 3 GAO-05-801 Border Security

DHS planned to expand the Visa Security Program to five locations in fiscal 

year 2005 and intends further expansion in future years; however, chiefs of 

mission at the posts chosen for expansion in fiscal year 2005 delayed 

approval of DHS’s National Security Decision Directive (NSDD) 386

requests. Embassy and State officials attributed the delays to questions 

about the program’s goals, objectives, and staffing requirements, as well as 

DHS’s plans to coordinate with existing law enforcement and border 

security staff and programs at post. According to DHS officials, the 

department provided sufficient responses throughout 2004 and 2005 to 

answer the concerns raised by chiefs of mission. However, DHS has not 

developed a strategic plan for visa security operations in Saudi Arabia or 

the future expansion posts in fiscal year 2005 and beyond. The 

development of a plan may address questions from chiefs of mission and 

prevent delays in approving the assignment of VSOs during future 

expansion of the Visa Security Program.

In this report, we are recommending that DHS, in consultation with State, 

develop a strategic plan to guide the operations of the Visa Security 

Program in Saudi Arabia and the program’s expansion to other embassies 

and consulates. This plan should define mission priorities and long-term 

goals and identify the outcomes expected at each post. In addition, the 

strategic plan and supporting documents should include the criteria used to 

select the locations for expansion, justification for the number of VSOs at 

each post, costs associated with assigning VSOs overseas, and the roles and 

responsibilities of the VSOs in relation to other agencies at post. We are 

also recommending that DHS develop and maintain comprehensive 

performance data that track the results of VSO activities to demonstrate 

the Visa Security Program’s impact at each location.

We are also including a matter for congressional consideration. Congress 

may wish to consider amending section 428(i) of the Homeland Security 

Act 2002, which requires the review of all visa applications in Saudi Arabia, 

to allow DHS the flexibility to determine which applications VSOs will 

review prior to final adjudication by consular officers. This would give 

VSOs greater discretion to prioritize their review of applicants to focus on 

those who may pose a risk to national security and would provide them 

time to perform other tasks that could benefit consular officers. 

6

The National Security Decision Directive-38 process requires non-State agencies to seek 

approval of chiefs of missions on any proposed changes in the size, composition, or 

mandate of their staff.
Page 4 GAO-05-801 Border Security

We received written comments from DHS and State, which we have 

reprinted in appendixes II and III, respectively. DHS and State agreed with 

our report. DHS stated it was developing a strategic plan and a system to 

measure program impact, as we recommended. State agreed with the 

conclusions of the report. Both DHS and State agreed that amending the 

requirement for DHS to review all visa applications in Saudi Arabia would 

allow time for other high-priority activities.

Background The Homeland Security Act of 2002 established the Department of 

Homeland Security (DHS) and gave it responsibility for visa policy. Section 

428 of the act also authorized DHS to immediately assign personnel to 

Saudi Arabia to review all visa applications prior to final adjudication, as 

well as the future assignment of officers to other locations overseas to 

review visa applications.7

 In August 2003, DHS created the Office of 

International Enforcement within the Border and Transportation Security 

Directorate,8

 to implement these requirements. In the same month, four 

temporary DHS officers were deployed to Saudi Arabia to begin reviewing 

all visa applications. In September 2003, DHS and State signed a 

Memorandum of Understanding to govern the implementation of section 

428. This agreement broadly defines the DHS officers’ responsibilities in 

reviewing visa applications, indicating, in particular, that they will 

• provide expert advice to consular officers regarding specific security 

threats relating to visa adjudication, specifically by gathering and 

reviewing intelligence relevant to visa adjudication and providing 

training to consular officers on terrorist threats and detecting applicant 

fraud;

7

P.L. 107-296, Sec. 428(e) and Sec. 428(i).

8

Border and Transportation Security is responsible for, among other things, (1) preventing 

the entry of terrorists and the instruments of terrorism to the United States, while ensuring 

the efficient flow of lawful traffic and commerce; (2) securing U.S. transportation systems; 

and (3) enforcing U.S. immigration laws.
Page 5 GAO-05-801 Border Security

• review applications on their own initiative or at the request of consular 

officers, and provide input on or recommend security advisory opinion 

requests;9

 and

• conduct investigations on consular matters under the jurisdiction of the 

Secretary of Homeland Security.

Several other agencies stationed overseas have roles in the visa 

adjudication process. For example, the State Department Diplomatic 

Security Bureau’s regional security officers assist the consular section by 

investigating passport and visa fraud detected through the consular 

officers’ reviews of visa applications and supporting documents.10 In 

addition, officials from the Federal Bureau of Investigation overseas can 

assist consular officers when questions about an applicant’s potential 

criminal history arise during adjudication. DHS’s Bureaus of Citizenship 

and Immigration Services and Customs and Border Protection have 

responsibility for some immigration and border security programs 

overseas. For example, consular officers may seek advice from these 

officials on issues such as DHS procedures at U.S. ports of entry. 

In October 2003, DHS designated its Bureau of Immigration and Customs 

Enforcement (ICE) to handle the operational and policy-making 

responsibilities outlined in section 428 (e) and (i). Subsequently, ICE 

created an office to oversee the Visa Security Program. Since the 

assignment of VSOs to Saudi Arabia in 2003 until May 2005, DHS has spent 

about $4 million for Visa Security Program operations at headquarters and 

overseas, of which approximately $2 million was spent on operations in 

Saudi Arabia. Figure 1 provides a timeline for the establishment and 

implementation of the visa security program.

9

In some cases, the consular officer is required to submit an application for a Security 

Advisory Opinion, or decides that one is needed. A Security Advisory Opinion provides an 

opinion or clearance from Washington on whether to issue a visa to an applicant. These 

clearances are required for a number of reasons, including when an applicant’s name 

appears as a “hit” in the name-check system, or if the applicant’s country of origin is a state 

sponsor of terrorism. 

10State’s Bureau of Diplomatic Security is mainly responsible for providing a safe and secure 

environment for the conduct of U.S. foreign policy. Overseas, bureau personnel develop and 

implement security programs to safeguard all personnel who work in every U.S. diplomatic 

mission around the world.
Page 6 GAO-05-801 Border Security

Figure 1: Establishment and Implementation of the Visa Security Program

In August 2004, the DHS Office of Inspector General reported on the 

planning and implementation of the VSOs’ activities in Saudi Arabia. The 

report was based on observations beginning in July 2003, at which time 

DHS was in the early stages of designing the Visa Security Program.11 (DHS 

officers did not arrive in Saudi Arabia until August 31, 2003.) According to 

the Inspector General, DHS operations at the time of the review were not 

as efficient or effective as they could be due to the use of temporary 

officers in Saudi Arabia, a lack of specialized training and foreign language 

proficiency, and the lack of a clear plan for the VSOs. The Inspector 

General recommended that DHS hire permanent officers, develop a visa 

security training program, and establish criteria for selecting VSOs. 

According to the Inspector General’s office, DHS has taken steps to 

implement these recommendations, but as of July 8, 2005, six remain open.

August 31, 2003 -

VSOs assigned to 

Saudi Arabia.

October 2003 to 

November 2003 - 

Site visits for 

expansion posts.

August 2004 - 

Approval of NSDD-38 

request for VSOs at 

first expansion post.

March 2005 - 

Approval of NSDD-38 

request for VSOs at 

second expansion post.

November 25, 2002 - 

Homeland Security 

Act of 2002.

September 26, 2003 - 

Memorandum of 

Understanding on 

section 428 between 

DHS and State signed.

March 1, 2003 - 

DHS begins 

operations.

June 2004 - 

DHS submits NSDD-38 

requests for 5 expansion 

posts.

September 11, 2001 2002 2003 2004 2005

June 2005 - 

Approval of NSDD-38 

requests for VSOs at third 

and fourth expansion 

posts.

October 2003 - 

Responsibility for the 

Visa Security Program 

transferred to ICE.

August 2004 - 

DHS Inspector General 

report on section 428 

requirements.

Source: GAO.

11DHS Office of Inspector General, An Evaluation of DHS Activities to Implement Section 

428 of the Homeland Security Act of 2002, OIG-04-33 (Washington, D.C.: Aug. 2004).
Page 7 GAO-05-801 Border Security

Several Factors Have 

Limited the Impact of 

Visa Security 

Operations in Saudi 

Arabia

According to embassy officials in Saudi Arabia and DHS officials, the VSOs 

enhance homeland security through their review of visa applications at 

posts in Saudi Arabia. However, several factors have hindered the program, 

including a lack of comprehensive data on the VSOs’ activities and results 

in Riyadh and Jeddah to demonstrate the program’s overall impact at these 

posts. 

VSOs Provide Additional 

Law Enforcement 

Capability to the Visa 

Process in Saudi Arabia

VSOs in Saudi Arabia provide an additional law enforcement capability to 

the visa adjudication process. VSOs have access to and experience using 

important law enforcement information not readily available to consular 

officers. Moreover, VSOs’ border security and immigration experience can 

assist consular officers during the visa process. 

VSOs Provide Additional Review 

to Visa Adjudication Process

According to State Department consular officers, the deputy chief of 

mission, and DHS officials, VSOs in Saudi Arabia enhance the security of 

the visa adjudication process at these consular posts. In particular, the 

consular sections in Riyadh and Jeddah have incorporated the VSOs’ 

review of all visa applications into the adjudication process (see fig. 2). 

After consular officers interview an applicant and review the relevant 

supporting documentation, they make a preliminary determination about 

whether to issue or refuse the visa or refer the case to Washington for 

additional security clearances. Consular officers may consult with VSOs 

during this initial determination. According to the VSOs, within 24 hours of 

this initial determination by consular officers, they review the application 

and inspect the applicant’s documentation for evidence of fraud or 

misrepresentation, indicators of potential national security risks, criminal 

activity, and potential illegal immigration risks. VSOs may also query the 

applicant’s information against a number of law enforcement, immigration, 

and other databases, which may contain more detail than the consular 

officers’ name check results. Based on these reviews, the VSOs will either 

affirm or oppose the consular officer’s original decision, and the consular 

officer then decides to issue or deny the visa. If the consular section chief 

and the VSOs disagree on a case, it is sent to DHS, where the Secretary of 

Homeland Security, in consultation with State officials, will render a final 

determination. According to a consular official in Saudi Arabia at the time 

of our visit in February 2005, no case has ever been sent back to 

Washington for such a decision.
Page 8 GAO-05-801 Border Security

Figure 2: Visa Process in Saudi Arabia

In addition to reviewing applications, the VSOs may conduct secondary 

interviews with some visa applicants based either on findings from their 

application reviews or a consular officer’s request. For example, DHS 

officials in Riyadh reported that the VSOs, in cooperation with intelligence 

Applicant 

goes to post.

Application 

reviewed, 

fingerprints taken, 

and name check 

performed.

Applicant 

interviewed and 

documentation 

reviewed. 

Consular officer 

reviews name 

check results 

and determines 

if Security 

Advisory 

Opinion (SAO) 

is needed.

SAO 

submitted 

for 

interagency 

check

SAO 

needed

SAO not 

needed

Post 

receives 

SAO 

response

Applicant 

schedules 

interview with 

post.

Consular 

officer 

decides to 

issue or deny 

visa to 

applicant.

Visa is 

issued 

or 

denied

DHS reviews 

and either 

affirms or 

refutes the 

consular 

officer’s 

determination.

SAUDI ARABIA

Source: GAO; Nova Development (clip art), MapArt (map).

DHS officers in consular posts 

in Saudi Arabia participate in 

the visa process at three points:

1. VSOs in Riyadh conduct some name checks 

 and investigative research in criminal and 

immigration databases to assist consular 

officers' interviews of applicants.

2. VSOs may conduct secondary interviews.

3. VSOs assist consular officers during interviews.

DHS

DHS DHS
Page 9 GAO-05-801 Border Security

officials at post, interviewed an applicant who had ties to an organization 

of national security concern to the U.S. government. This individual was 

denied a visa after the interview based upon the VSO’s determination of the 

potential threat the individual posed to the United States. We also observed 

the VSOs conduct a secondary interview with an applicant they had 

identified as a concern through their physical review of the visa 

application. 

VSOs Have Access to Law 

Enforcement Information Not 

Readily Available to Consular 

Officers 

VSOs have access to and experience using immigration and law 

enforcement databases not readily available to consular officers, who are 

not classified as criminal justice, or law enforcement, personnel. Consular 

officers rely on information contained in the Consular Lookout and 

Support System (CLASS)12 to adjudicate a visa. As law enforcement agents, 

the VSOs can access detailed criminal history records and immigration 

information not included in CLASS. For example, the VSOs have access to 

criminal history records contained in the National Crime Information 

Center’s Interstate Identification Index, which cannot be directly accessed 

by consular officers.13 The VSOs also use databases containing information 

on employers and businesses, hotel reservation information, and sponsors 

of applicants seeking temporary work visas. They can use these databases 

to verify, for instance, an applicant’s claim to be working for a particular 

business. Consular officials at headquarters and in the field believe this 

data would be useful to them in the adjudication process, particularly at the 

other posts worldwide that do not have VSOs. Indeed, consular officials in 

Washington indicated that they are working with DHS to gain access to 

these databases.

12CLASS is a State Department name check database that posts use to access critical 

information for visa adjudication. The system contains records provided by numerous 

agencies and includes information on persons with visa refusals, immigration violations, 

criminal histories, and terrorism concerns.

13Section 403 of the USA PATRIOT Act (P.L. 107-56) directs the Federal Bureau of 

Investigation to provide State with access to criminal history records contained in the 

National Crime Information Center's Interstate Identification Index (NCIC - III) files for the 

purpose of determining whether or not a visa applicant has a criminal history record. In 

accordance with this mandate, the Federal Bureau of Investigation provides extracts that 

contain biographical information such as the date of birth and height of the person with the 

criminal record. However, the extracts in CLASS do not contain details such as the charge or 

disposition of the case, which are necessary to determine if the applicant might be ineligible 

for a visa. To see this degree of detail from the records, the National Crime Prevention and 

Privacy Compact Act of 1998 (42 U.S.C. 14611 et seq.) (Compact Act) requires that consular 

officers first submit fingerprints of the visa applicant for positive identification before the 

record can be released.
Page 10 GAO-05-801 Border Security

In Riyadh, we observed a VSO assist a consular officer review a potential 

“hit” in CLASS for an applicant in Riyadh. The applicant claimed that, 

during a trip to the United States, border inspectors refused him entry to 

the country even though he had a valid visa. At the consular officer’s 

request, we observed the VSO search a database and inform the consular 

officer that the applicant at the window had been placed on the “No-Fly” 

list14—information that was not specified in CLASS—since the issuance of 

the initial visa and was therefore ineligible for another visa. In addition, the 

VSOs in Riyadh conduct searches on applicants’ names prior to their 

interviews with consular officers and provide more detailed information on 

potential matches obtained from these searches of law enforcement 

databases. Consular officers indicated that this practice helps them tailor 

their questioning of applicants.

Furthermore, the VSOs in Saudi Arabia interact with consular officers on a 

real-time basis. We observed consular officers ask the VSOs for assistance 

during interviews, for example, to clarify questions pertaining to potential 

criminal hits in CLASS. By contrast, in other embassies, consular officers 

must request additional information from other DHS overseas offices or 

from Washington. 

VSOs Provide Law Enforcement 

and Fraud Detection Knowledge 

and Training 

According to DHS, the VSOs’ law enforcement experience and training and 

knowledge of immigration law enables them to more effectively identify 

applicants who are potential threats to U.S. national security, as well as 

identify potentially fraudulent documents submitted by applicants. Since 

the Inspector General’s report in 2004, DHS has developed criteria for 

selecting VSOs, which includes certain levels of law enforcement and 

counterterrorism experience, as well as knowledge of immigration law and 

experience working overseas. In addition, VSOs have experience and 

training in detecting fraudulent documents. The Memorandum of 

Understanding between State and DHS states that VSOs at consular posts 

will provide antifraud training to consular officers, among other things. 

This training is particularly useful given that State does not have full-time 

fraud prevention officers at all of its consular posts overseas, with 

14The Transportation and Security Administration maintains the “No-Fly” list, which 

identifies individuals known or reasonably suspected to be a threat to national security and 

allows airlines to pre-screen passengers’ names before a flight.
Page 11 GAO-05-801 Border Security

antifraud duties often performed by junior officers on a part-time basis.15

Indeed, at all but one of the posts that have or plan to have VSOs, consular 

officers served as part-time fraud prevention officers in addition to their 

other duties in the consular section. Therefore, the VSOs’ experience in this 

area can be valuable to consular sections.

Impact of the Visa Security 

Program in Saudi Arabia 

Limited by Several Factors

The deputy chief of mission, consular officers, and VSOs in Saudi Arabia 

indicated that the VSOs have positively impacted visa operations; however, 

several issues raise concerns about the role and impact of these officers. 

These include (1) the use of temporary duty employees, which can limit the 

impact of the VSOs in Saudi Arabia; (2) the lack of Arabic language 

proficient officers; (3) the requirement that the officers review all visa 

applications, which limits their time to perform other valuable tasks; and 

(4) the lack of measurable data on the VSOs’ activities, which would 

demonstrate their impact on the visa process.

• From August 31, 2003, through June 2005, DHS assigned temporary duty 

VSOs to Saudi Arabia for tours that varied in length between about 2 and 

15 months, for an average assignment of about 7 months. According to 

the deputy chief of mission in Saudi Arabia, the use of temporary VSOs 

led to a lack of continuity in visa security operations, and, as a result, 

the VSOs initially were not able to significantly impact the visa process 

at post. The constant turnover of officers can hinder the development of 

institutional knowledge and overall visa security efforts. However, the 

deputy chief of mission indicated that each subsequent temporary 

officer improved operations in Saudi Arabia and enhanced security of 

the visa adjudication process. DHS acknowledged that the reliance on 

temporary detailed staff is not ideal for the continuity of operations and 

the ongoing development of the Visa Security Program. DHS officials 

believe that they have addressed the situation as DHS has hired and 

trained four permanent employees who were deployed to Saudi Arabia 

in June 2005, and will be assigned for a 12-month tour.

• Most of the VSOs stationed in Saudi Arabia since 2003 have not been 

proficient Arabic speakers and, according to DHS, two of the four new 

permanent staff assigned to Saudi Arabia speak Arabic. Additionally, 

15Consular officers who serve as fraud prevention managers are in charge of investigating 

cases of fraud, conducting fraud training for the consular section, and providing information 

on fraud relevant to the consular section at post.
Page 12 GAO-05-801 Border Security

consuls general at three of the locations chosen for expansion told us 

language proficiency would be beneficial at their posts, particularly for 

interviewing applicants and reviewing applications and documents. The 

ability to speak the host country language is a qualification for VSOs, as 

agreed to in the Memorandum of Understanding with State. DHS 

acknowledged the utility of language capability, but noted that law 

enforcement skills and expertise outweigh the limitations of a lack of 

language proficiency. According to DHS, if language training is deemed 

necessary, such courses would be offered in addition to the standard 

VSO training, which includes courses on interviewing, detection of 

deception, and national security law, as well as regional and country 

briefings. 

• The Memorandum of Understanding between State and DHS states that 

VSOs would provide training to consular officers on detecting 

applicants who pose a threat to homeland security and fraudulent 

documents; however, the requirement that VSOs review all visa 

applications in Saudi Arabia limits the amount of time that they can 

spend on training and other valuable services. We observed that VSOs in 

Riyadh and Jeddah must spend a significant amount of time reviewing 

all visa applications, including those of low-risk applicants or 

individuals who do not pose a threat to national security, as well as 

those that have preliminarily been refused by consular officers. For 

example, according to DHS officials, lower priority applications may 

include those from elderly applicants and very young children. 

Furthermore, the requirement has resulted in extremely long work 

hours for the VSOs. For example, to return applications to consular 

officers within 24 hours of the initial decision, the three VSOs in Riyadh 

and one VSO in Jeddah were each working 7 days per week at the time 

of our visit. Moreover, the VSOs spend considerable time—as much as 2 

hours each day, according to one officer in Jeddah—reviewing 

applications that are preliminarily refused by consular officers or from 

low-risk applicants. A Visa Security Program official noted that this 

mandate is only for visa security operations in Saudi Arabia and not 

other posts to which DHS plans to assign VSOs. At posts outside of 

Saudi Arabia, DHS proposed the use of site-specific criteria to focus the 

review of applications based on several factors, including the number of 

applications at the post and post-specific threat assessments. VSOs, 

DHS and State officials, and the deputy chief of mission all agreed that 

the mandate to review all applications was forcing the VSOs to spend 

time on lower priority tasks, limiting their ability to perform other 

activities, such as providing training or conducting additional secondary 
Page 13 GAO-05-801 Border Security

interviews of applicants. Consular officers also agreed that they would 

benefit from additional training and other interaction with the VSOs. 

According to DHS, if its VSOs were granted more flexibility to determine 

the extent of their review and were not required to review all 

applications, they could prioritize visa application reviews—a process 

which they plan to implement at other posts. DHS acknowledged that 

adding additional officers to the posts in Saudi Arabia could allow VSOs 

time to perform other tasks, but DHS would still need to prioritize these 

resources to address training and other activities in Saudi Arabia. 

However, security concerns at the U.S. embassy and consulate have 

limited the number of personnel DHS, as well as other U.S. agencies, can 

assign to these posts.16

• DHS has not maintained measurable data to fully demonstrate the 

impact of VSOs on the visa process. The VSOs that were stationed in 

Riyadh during our visit estimated that, based on their review of visa 

applications, they had recommended that visas be refused after the 

preliminary decision to issue a visa by consular officers in about 15 

cases between October 2004 and February 2005. In addition, the DHS 

officials in Saudi Arabia and in Washington, D.C., were able to provide 

anecdotal examples of assistance provided to the consular officers. 

However, DHS has not developed a system to fully track the results of 

visa security activities in Saudi Arabia. For example, DHS could not 

provide data to demonstrate the number of cases for which they have 

recommended refusal. 

DHS’s Plans for 

Expansion of the Visa 

Security Program 

Delayed 

DHS plans to expand the Visa Security Program to five additional posts in 

fiscal year 2005; however, the assignments of VSOs were delayed at four of 

the five selected expansion posts. DHS attributed the delay to resistance by 

State, as well as funding problems. State and chiefs of mission attributed 

the delays to various questions about the program, including the criteria 

used by DHS to select expansion posts and the reasoning for the number of 

VSOs requested for the posts. A strategic plan to guide operations and 

expansion of the Visa Security Program could have answered some of these 

questions and potentially prevented some delays in expanding the program 

to additional posts, but DHS has not prepared such a plan.

16Pursuant to DHS’s NSDD-38 request for Saudi Arabia, the department is authorized to have 

up to 6 personnel in Saudi Arabia.
Page 14 GAO-05-801 Border Security

DHS’s Expansion of the Visa 

Security Program in Fiscal 

Year 2005

The Homeland Security Act of 2002 authorized the assignment of DHS 

officers to each diplomatic post where visas are issued to provide expert 

advice and training to consular officers and review visa applications.17 In 

2003, a DHS working group established criteria for ranking potential posts 

for the program’s expansion. The site selection criteria considered the 

following primary factors:

• risk of terrorism in a country based on State’s threat assessments and 

intelligence of terrorist activity;

• visa workload;

• visa denial rates; and

• issuance of visas to multiple nationalities at a post.

In addition, a Visa Security Program official indicated that DHS also 

considered intelligence reports and the host nation circumstances, 

including government cooperation, corruption, immigration controls, and 

identification document controls, when selecting potential expansion 

posts. DHS conducted site assessments, in coordination with State, at six 

consular posts in October and November 2003 and April 2004 to further 

evaluate the potential for establishing the Visa Security Program at these 

posts. According to DHS, delays in expanding the program were due, in 

part, to the fact that funding was not reprogrammed for visa security 

operations until December 2004.

DHS selected five posts to expand the Visa Security Program and in June 

2004 submitted requests for the assignment of 21 VSO positions to five 

posts. One post approved the NSDD-38 request in July 2004. Another post 

approved the assignment of VSOs in March of 2005, and two posts 

approved the requests in June 2005. As of June 2005, one post has still not 

approved the NSDD-38 request. Four posts have approved the assignment 

of VSOs at their respective posts, but DHS had not yet assigned VSOs to any 

of the expansion posts.

17The Secretary of Homeland Security is authorized to assign DHS officers to consular posts 

overseas unless he determines that such an assignment at a particular post would not 

promote homeland security.
Page 15 GAO-05-801 Border Security

Questions Raised by 

Embassy Officials 

Contributed to Delays of 

DHS Expansion

Embassy officials raised questions and concerns regarding the plans to 

expand the Visa Security Program, which contributed to the delays in the 

approval of the NSDD-38 requests. State’s Office of Rightsizing the U.S. 

Overseas Presence supported the posts’ questions of DHS’s plans for 

expansion of the Visa Security Program.

Questions Raised about the Site 

Selection Criteria Used to Select 

Expansion Posts

Embassy officials at the expansion posts expressed concerns with the site 

selection process and the criteria DHS used to select the posts, which 

contributed to the delays in approving DHS’s requests for VSOs. Based on 

DHS’s quantitative evaluation criteria used to select expansion posts, visa 

issuing posts were ranked to identify priority posts for the deployment of 

VSOs. However, of the 5 posts selected for expansion of the Visa Security 

Program, 2 of the posts ranked outside of the top 10 posts identified by 

DHS’s evaluation. Moreover, embassy officials at one of these expansion 

posts that did not rank in the initial top 10 believe that DHS’s selection 

criteria does not justify the assignment of VSOs to their post. In particular 

the consular chief stated that the post had a relatively low application 

volume and a low refusal rate—two criteria that DHS used to select the 

fiscal year 2005 expansion posts. DHS stated that this particular post was 

chosen based on other qualitative data, consultation with law enforcement 

and intelligence officials, and practical considerations for expansion of the 

program. These additional factors were not included in the methodology 

DHS developed to identify priority posts for expansion of the Visa Security 

Program. Embassy officials at 2 posts chosen for expansion were unaware 

of the criteria used to select the expansion posts; however, DHS stated that 

they had explained their criteria.

Embassy officials also questioned the reasoning behind the number of 

VSOs that DHS requested for assignment to the selected expansion posts. 

In June 2004, DHS originally requested the assignment of 21 VSO positions 

to 5 posts. According to DHS, the request for the number of VSOs at each 

post was based on the assessment of several factors including the 

workload at post. However, chiefs of mission and consular officials also 

told us that they were unclear about the number of VSOs required for visa 

security operations and requested for assignment. DHS officials stated that 

they had explained their rationale fully. As of June 2005, four posts had 

approved the assignment of 13 VSO positions. Table 1 shows the number of 

VSO positions requested compared to the number of VSO positions 

approved by chiefs of mission. 
Page 16 GAO-05-801 Border Security

Table 1: Visa Security Program Expansion

Source: Department of Homeland Security.

Note: Table 1 shows VSO positions and administrative support positions approved as of June 2005.

DHS received approval for 8 fewer VSO positions than it requested, and 

received the full complement of staff requested at one expansion post. This 

gap in approving the assignment of VSOs indicates that DHS either 

overestimated the staff it needed to conduct activities at each post or will 

not have enough staff at each post to effectively impact the visa 

adjudication process at these locations. 

DHS negotiated the final number of positions with chiefs of mission at 

several posts to help expedite the NSDD-38 requests. For example, DHS 

and embassy officials at one post agreed to reduce the number of positions 

requested from 5 to 3; subsequently, the NSDD-38 request was approved in 

March 2005. The deputy chief of mission and consul general at another 

embassy noted that DHS’s request for four VSOs appeared excessive, 

considering the low volume of visas that are processed at that post, which 

conducts about 30 to 40 applicant interviews daily, and that there are only 

four consular officers stationed at the post. Therefore, the embassy 

approved two VSOs in June 2005. The post that has not approved DHS’s 

request as of June 2005 proposed that DHS assign not four but one VSO for 

a 6-month assignment. According to the chief of mission, during this time, 

the VSO could demonstrate how the program would benefit the post, as 

well as the need for the additional positions DHS requested. DHS officials, 

however, believe that one officer would not be sufficient to meet the threat 

to visa security at the post.

Location

Date of NSDD38 requestDate of 

approval

VSO positions

requested by

DHS

VSO positions

approved by

chiefs of

mission

Post 1 June 2004 July 2004 5 4

Post 2 June 2004 March 2005 5 3

Post 3 June 2004 Not yet 

approved

4 0

Post 4 June 2004 June 2005 3 3

Post 5 June 2004 June 2005 4 3

Total 21 13
Page 17 GAO-05-801 Border Security

Office of Rightsizing the U.S. 

Overseas Presence Supports 

Questions of DHS’s Expansion 

Plans

As we have previously reported, questions related to (1) security of 

facilities and employees, (2) mission priorities and requirements, and (3) 

cost of operations should be addressed when determining the appropriate 

number of staff that should be assigned to a U.S. embassy.18 In August 2004, 

State’s Office of Rightsizing the U.S. Overseas Presence,19 which manages 

the NSDD-38 process for the U.S. government, issued interim guidance to 

chiefs of mission regarding factors to consider when approving DHS’s 

requests for VSOs. A Rightsizing Office official stated that this guidance is 

consistent with guidance that is applicable to all agencies that submit 

NSDD-38 requests. Specifically, the cable advised the five chiefs of mission 

at posts selected for VSO expansion to delay approving the DHS positions 

until State or the post had received sufficient responses to several 

outstanding issues, including

• criteria for selecting the expansion posts;

• agreement on administrative support services, such as building 

maintenance, utilities, supplies, and equipment, among others;

• the extent to which the VSOs will have regional responsibilities at other 

embassies or consulates;

• the roles and responsibilities of the VSOs in relation to State’s consular 

fraud investigators and regional security officers at post, as well as any 

other agencies at post; and

• the criteria that will be used to measure the effectiveness of the visa 

security operations.

In 2004 and 2005, DHS provided responses, through State’s Bureau of 

Consular Affairs, to the questions raised by the chiefs of mission at four of 

the expansion posts. According to DHS, the responses were sufficient to 

answer the concerns raised by the chiefs of mission. We reviewed the 

responses to the posts, and identified a number of issues that had not been 

18See GAO, Overseas Presence: Framework for Assessing Embassy Staff Levels Can 

Support Rightsizing Initiatives, GAO-02-780 (Washington, D.C.: July 26, 2002).

19State’s Office of Rightsizing the U.S. Overseas Presence is charged with aligning the 

number and location of staff assigned overseas with foreign policy priorities and security 

and other constraints. The office leads State’s efforts to coordinate and manage deployment 

of personnel of all U.S. government agencies overseas.
Page 18 GAO-05-801 Border Security

fully addressed. For example, the documentation did not specify the 

criteria that DHS will use to demonstrate the effectiveness of its officers. 

Nevertheless, the chiefs of mission at three posts approved NSDD-38 

requests in March and June 2005.

DHS Lacks a Strategic Plan 

to Guide Operations and 

Expansion of the Visa 

Security Program 

In 2003, DHS and State agreed in a Memorandum of Understanding that 

DHS would identify those diplomatic and consular posts where DHS 

considered the presence of its personnel necessary to perform visa security 

functions and would subsequently assign VSOs to those posts. DHS plans 

to expand the Visa Security Program to five additional consular posts 

throughout fiscal year 2005. Furthermore, DHS plans to expand the Visa 

Security Program beyond the posts initially selected for expansion, 

conducted a site assessment in May 2005 for a sixth expansion location, 

and plans to continue deployment of VSOs to attain worldwide coverage of 

the program. According to DHS, the Secretary of Homeland Security has 

suggested a pace of five new posts per year.

Although DHS plans to expand the Visa Security Program in fiscal year 

2005 and beyond, it does not a have a strategic plan20 that defines mission 

priorities and long-term goals and identifies the outcomes expected at each 

post to guide operations of the program. We have identified the 

development of a strategic plan as an essential component of measuring 

progress and holding agencies accountable for achieving results.21 The 

development of an overall strategic plan for the Visa Security Program 

prior to the expansion of the program may have addressed the questions 

initially raised by State and embassy officials that led to the delay of the 

assignment of VSOs. Moreover, a strategic plan would provide a framework 

for DHS to address broader questions regarding the selection criteria for 

expansion, the roles and responsibilities of VSOs, and the cost of 

establishing the program at posts. In addition, a strategic plan would guide 

rightsizing analyses to determine the appropriate number of VSOs at each 

20The Government Performance and Results Act of 1993, as amended, P.L. 103-62, provides a 

strategic planning and management framework intended to improve federal programs’ 

performance. The act outlines key elements of a strategic plan including the development of 

a mission statement, general goals and objectives that explains expected results, 

operational processes and resources needed to accomplish the program goals, daily 

performance and activities linked to program goals, external factors that affect the program, 

and performance assessments to establish and revise program goals.

21See GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).
Page 19 GAO-05-801 Border Security

post. Officials from DHS and State, as well as consular officials we 

contacted overseas, all agreed that the development of such a plan would 

be useful to guide visa security operations in Saudi Arabia and other posts. 

It would also be useful to inform the Congress, as well as State and other 

agencies who participate in the visa process at consular posts overseas.

Furthermore, as a key stakeholder in the Visa Security Program, State 

should be consulted in the strategic planning process and, therefore, the 

concerns and questions raised by State’s Office of Rightsizing the U.S. 

Overseas Presence and chiefs of mission should be addressed by DHS. 

Moreover, without a strategic plan that serves as a roadmap for expansion, 

DHS may continue to experience delays in the approval of NSDD-38 

requests at future expansion posts.

Conclusions The placement of VSOs overseas has the potential to improve the security 

of the visa process at U.S. embassies and consulates. However, the 

congressional mandate requiring the VSOs in Saudi Arabia to review all 

applications prior to adjudication limits them from engaging in other 

counterterrorism activities, such as providing additional training to 

consular officers on fraud prevention and interview techniques. Moreover, 

DHS has not incorporated key features of strong program management 

essential to measuring program results and holding staff accountable for 

achieving results into its oversight of the Visa Security Program. Before 

DHS expands this program to other consular posts, it needs a plan outlining 

its goals and objectives to allow the department to measure program 

performance and determine the overall value of its visa security operations 

worldwide. Such a plan needs to address questions from the chiefs of 

mission who must approve the assignment of VSOs to U.S. embassies or 

consulates. Addressing these questions would help facilitate negotiations 

of the expansion of the Visa Security Program.

Recommendations for 

Executive Action

To help ensure that the Visa Security Program, and its expansion to other 

locations worldwide, is managed effectively, we recommend that the 

Secretary of Homeland Security:

• develop a strategic plan, in consultation with the Secretary of State, to 

guide visa security operations in Saudi Arabia and in other embassies 

and consulates overseas. This plan should incorporate the key elements 

of strategic planning, including a mission statement, program goals and 
Page 20 GAO-05-801 Border Security

objectives, approaches to achieving those goals, a connection between 

the long-term and short-term goals, and a description of how the 

effectiveness of the program will be evaluated. In addition, DHS should 

include or develop supporting documents that provide more specific 

information on the criteria used to select the locations for expansion, 

justification for the number of VSOs at each post, the roles and 

responsibilities of the VSOs in relation to other agencies located at post, 

and the resources needed to establish the Visa Security Program 

overseas. 

• develop performance data that can be used to assess the results of the 

Visa Security Program at each post. 

Matter for 

Congressional 

Consideration

Congress may wish to consider amending current legislation, which 

requires that VSOs in Saudi Arabia review all visa applications prior to 

adjudication, to provide DHS the flexibility to determine the extent to 

which VSOs review applications, based upon the development of a riskassessment tool. This flexibility will allow them to engage in other 

activities that will provide additional benefit to consular officers and the 

visa process.

Agency Comments and 

Our Evaluation

DHS and State provided written comments on a draft of this report (see 

apps. II and III). 

DHS stated it was taking actions to implement performance measurements 

and a strategic plan for the Visa Security Program, as described in our 

recommendations. DHS indicated that it is expanding the tracking and 

measurement of performance data to better reflect program results. In 

addition, DHS stated it is developing a strategic plan that will integrate the 

key elements described in our recommendation; however, DHS stated that 

it was unlikely that such a plan would have aided in the approval of the 

NSDD-38 requests at the five expansion posts. We believe that a strategic 

plan would allow DHS to better address questions about the program and 

would be useful in guiding visa security operations in Saudi Arabia and 

other consular posts. Regarding the matter for congressional consideration 

to provide DHS with the flexibility to determine the review of visa 

applications in Saudi Arabia, DHS agreed that it needed to expand some of 

the VSOs’ activities in Saudi Arabia, such as providing additional training, 

which we found were not being provided because of the volume of work 
Page 21 GAO-05-801 Border Security

that resulted from fulfilling the legislative requirement. DHS noted that a 

legislative change should maintain DHS’s authority and discretion in 

determining the scope of the VSOs’ review. DHS also provided additional 

details on the Visa Security Program, its plans to improve operations, and 

its interaction with State regarding program expansion. These comments 

are reprinted in appendix II, along with our analysis. DHS also provided 

technical comments, which we incorporated into the report, as 

appropriate.

State agreed with our conclusions, stating that the report is an accurate 

description of the implementation of the Visa Security Program. In 

addition, State agreed with our matter for congressional consideration. 

State noted that the ability of the VSOs in Saudi Arabia to access law 

enforcement and other databases not available to consular officers 

highlights the importance of shared, interoperable databases worldwide. 

With regard to the program’s expansion outside Saudi Arabia, State also 

noted that chiefs of mission and its Rightsizing Office are obligated to 

ensure that staffing overseas for all agencies is at the proper level and 

consistent with available space and resources. State’s comments are 

reprinted in appendix III.
Page 22 GAO-05-801 Border Security

We are sending copies of this report to the Secretaries of State and 

Homeland Security, and to other interested Members of Congress. We will 

also make copies available to others upon request. In addition, this report 

will be available at no charge on the GAO Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me at (202) 512-

4128 or fordj@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

GAO staff who made major contributions to this report are listed in 

appendix IV. 

Jess T. Ford

Director, International Affairs and Trade
Page 23 GAO-05-801 Border Security

List of Committees

The Honorable Susan M. Collins

Chairman

The Honorable Joseph I. Lieberman

Ranking Minority Member

Committee on Homeland Security and 

Governmental Affairs

United States Senate

The Honorable Jon Kyl

Chairman

The Honorable Dianne Feinstein

Ranking Minority Member

Subcommittee on Terrorism, Technology, 

and Homeland Security

Committee on the Judiciary

United States Senate

The Honorable Tom Davis

Chairman

Committee on Government Reform

House of Representatives

The Honorable Christopher Shays

Chairman 

The Honorable Dennis J. Kucinich

Ranking Minority Member

Subcommittee on National Security, 

Emerging Threats, and International Relations

Committee on Government Reform

House of Representatives

The Honorable Christopher Cox

Chairman

The Honorable Bennie G. Thompson

Ranking Minority Member

Committee on Homeland Security

House of Representatives
Page 24 GAO-05-801 Border Security

The Honorable F. James Sensenbrenner, Jr.

Chairman 

The Honorable John Conyers, Jr.

Ranking Minority Member 

Committee on the Judiciary

House of Representatives

The Honorable John N. Hostettler

Chairman 

The Honorable Sheila Jackson Lee

Ranking Minority Member

Subcommittee on Immigration, Border Security, and Claims

Committee on the Judiciary

House of Representatives
Page 25 GAO-05-801 Border Security

Appendix I

Scope and Methodology ApApenednxidexiIs

To assess the Visa Security Officers’ activities in Saudi Arabia, we reviewed 

the Homeland Security Act of 2002, which authorized DHS to create the 

Visa Security Program. In addition, we reviewed the subsequent September 

2003 Memorandum of Understanding between State and DHS regarding the 

implementation of the requirements set forth in section 428 of the 

Homeland Security Act. We also reviewed a prior report from August 2004 

on DHS’s implementation of section 428 requirements, conducted by the 

DHS Office of Inspector General, and spoke with the Inspector General 

officials who conducted that review. We interviewed officials from DHS 

who manage the Visa Security Program in Washington, D.C., as well as 

officials from State’s Bureau of Consular Affairs and the Office of 

Rightsizing the U.S. Overseas Presence. Moreover, we observed the VSOs’ 

activities in Riyadh and Jeddah, Saudi Arabia, and interviewed the VSOs, as 

well as consular officials and the chief of mission, regarding the impact of 

the Visa Security Program at these posts.

To assess DHS’s plans to expand the Visa Security Program to consular 

posts outside Saudi Arabia, we reviewed documentation on the 

department’s requests to establish new positions at 5 additional posts and 

spoke with DHS officials regarding the planned expansion. In addition, we 

reviewed DHS’s criteria for selecting VSOs and the criteria and 

methodology for selecting expansion posts. We also compared DHS’s 

management strategy for the Visa Security Program and its expansion with 

criteria from the Government Performance and Results Act and associated 

GAO reports on performance-based, strategic planning. In addition, we 

visited two of the five posts to which DHS plans to expand the Visa Security 

Program and interviewed consular and embassy officials, including the 

chiefs and deputy chiefs of mission, at these locations to discuss these 

posts’ plans for the VSOs. We also spoke with officials from other law 

enforcement agencies at post who work with the consular section. Further, 

we spoke with the consuls general from the other three posts initially 

chosen for expansion in fiscal year 2005 to discuss the status of DHS plans 

to expand to these locations. We conducted our evaluation from August 

2004 to June 2005 in accordance with generally accepted government 

auditing standards.
Page 26 GAO-05-801 Border Security

Appendix II

Comments from the Department of Homeland 

Security ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix II

Comments from the Department of Homeland 

Security

Page 27 GAO-05-801 Border Security
Appendix II

Comments from the Department of Homeland 

Security

Page 28 GAO-05-801 Border Security
Appendix II

Comments from the Department of Homeland 

Security

Page 29 GAO-05-801 Border Security

See comment 1.

See comment 2.

See comment 3.

See comment 4.

Now on Highlights Page.

Now on page 2.

Now on page 2.

Now on page 13.

Now on page 11.
Appendix II

Comments from the Department of Homeland 

Security

Page 30 GAO-05-801 Border Security

Now on page 4.

Now on page 5.

Now on page 7.

Now on page 7.

Now on page 2. 

Now on page 13.

Now on page 12.
Appendix II

Comments from the Department of Homeland 

Security

Page 31 GAO-05-801 Border Security

See comment 5.

Now on page 2.

Now on page 3.

Now on page 13.

Now on page 3.

Now on page 15.

Now on page 15.

Now on page 15.

Now on page 17.
Appendix II

Comments from the Department of Homeland 

Security

Page 32 GAO-05-801 Border Security
Appendix II

Comments from the Department of Homeland 

Security

Page 33 GAO-05-801 Border Security

Now on page 15.

Now on page 16.

Now on page 16.

Now on page 16.

Now on page 3.

Now on page 20.

Now on page 20.
Appendix II

Comments from the Department of Homeland 

Security

Page 34 GAO-05-801 Border Security

See comment 6.

See comment 6.

Now on page 6.

Now on page 7.

Now on page 9.

Now on page 10.

Now on page 8.
Appendix II

Comments from the Department of Homeland 

Security

Page 35 GAO-05-801 Border Security

See comment 7.

See comment 8.

Now on page 15.

Now on page 15.

Now on page 18. 

Now on page 18.

Now on page 19.

Now on page 19.
Appendix II

Comments from the Department of Homeland 

Security

Page 36 GAO-05-801 Border Security
Appendix II

Comments from the Department of Homeland 

Security

Page 37 GAO-05-801 Border Security

The following are GAO’s comments on the Department of Homeland 

Security’s letter dated July 15, 2005.

GAO Comments 1. We revised the highlights page to reflect that no comprehensive data 

exists to demonstrate the impact of the VSOs in Saudi Arabia.

2. We requested documentation from DHS on the visa application reviews 

conducted by VSOs in Saudi Arabia. DHS provided weekly operational 

reports that contained descriptive examples of the reviews of visa 

applications and the outcomes of those reviews. DHS did not provide 

systematic data on the operations of the VSOs, and VSOs in Saudi 

Arabia stated that they did not have a system in place to track the 

activities of the program. The steps DHS describes appear to be 

positive steps to incorporate performance measurement into the Visa 

Security Program, and to implement a workload tracking database. We 

believe these actions should allow DHS to better demonstrate program 

results and are consistent with our recommendation.

3. We revise the report to clarify that VSOs may recommend a refusal after 

a preliminary determination to issue the visa by a consular officer. We 

agree that there might be additional cases where VSOs may influence 

the decision of consular officers. We believe it is important to measure 

other outcomes that demonstrate the impact of the Visa Security 

Program. Furthermore, we believe that it is not difficult to track 

additional data, and such performance measures should be 

incorporated into the tracking system for VSO activities.

4. We do not agree that the statement was an error in syntax. We believe 

that performance measurement is an integral part of effective program 

management, and the lack of comprehensive data on program impact 

has hindered the Visa Security Program. Performance data could be 

used to demonstrate the effectiveness of operations in Saudi Arabia, as 

well as to illustrate the benefits of the program when presenting the 

benefits of the program to interested parties, including chiefs of 

mission at future expansion posts and the Congress.

5. In August 2004, the DHS Office of Inspector General found that the 

continued use of temporary officers to fill VSO positions was not 

conducive to developing an effective or efficient long-term visa security 

operation. In addition, in February 2005, the deputy chief of mission in 

Saudi Arabia told us that the use of temporary VSOs led to a lack of 
Appendix II

Comments from the Department of Homeland 

Security

Page 38 GAO-05-801 Border Security

continuity in operations, and that the VSOs initially were not able to 

significantly impact the visa process at post. Our report recognized that 

DHS assigned permanent officers to Saudi Arabia in June 2005.

6. We revised the figure to reflect that VSOs also conduct investigative 

research on visa applicants in addition to conducting name checks.

7. Our report noted that, in addition to the quantitative data used as 

preliminary selection criteria, DHS stated it used qualitative data and 

other practical considerations in choosing the posts. DHS did not 

provide this qualitative data nor the additional considerations used to 

select expansion posts to GAO, and thus we were unable to assess the 

additional criteria. We made an assessment based on the information 

and data provided by DHS.

8. We believe that the development of a strategic plan would assist DHS 

by providing stakeholders, such as State and chiefs of mission, with 

information regarding the mission, goals and operations of the Visa 

Security Program. A strategic plan may have helped to address the 

questions raised by State and embassy officials that led to the delays in 

the approvals of the NSDD-38 requests. In addition, we believe that a 

strategic plan would expedite the approval of future NSDD-38 requests 

for assignment of VSOs to consular posts. State officials support this 

view. DHS is taking positive steps by working towards the development 

of a strategic plan as we recommend.
Page 39 GAO-05-801 Border Security

Appendix III

Comments from the Department of State ApendxiI
Appendix III

Comments from the Department of State

Page 40 GAO-05-801 Border Security
Appendix III

Comments from the Department of State

Page 41 GAO-05-801 Border Security
Page 42 GAO-05-801 Border Security

Appendix IV

GAO Contact and Staff Acknowledgments ApendxiIV

GAO Contact Jess Ford (202) 512-4128

Acknowledgments In addition, John Brummet, Daniel Chen, Katie Hartsburg, Jeff Miller, Mary 

Moutsos, Joseph Carney, and Etana Finkler made key contributions to this 

report.

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