BORDER SECURITY

Actions Needed to 

Strengthen 

Performance 

Management and 

Planning for 

Expansion of DHS’s 

Visa Security Program

Report to Congressional Requesters

March 2018

GAO-18-314

This report was revised on March 29, 2018, to correct the definition 

of “ineligible” in the sidebar on page 10.

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-314, a report to 

congressional requesters

March 2018

BORDER SECURITY

Actions Needed to Strengthen Performance 

Management and Planning for Expansion of DHS’s 

Visa Security Program

What GAO Found

The Department of Homeland Security’s (DHS) U.S. Immigration and Customs 

Enforcement (ICE) manages the Visa Security Program (VSP), which provides 

an additional layer of review to the visa adjudication process; however, VSP 

agents are not consistently providing required training to consular officers. ICE 

implemented the Pre-Adjudicated Threat Recognition and Intelligence 

Operations Team (PATRIOT) in fiscal year 2014. PATRIOT screens 100 percent 

of nonimmigrant visa applications at VSP posts against U.S. databases, and 

U.S.-based analysts manually vet applications with potential matches to 

derogatory information. VSP agents at post then make recommendations to 

Department of State (State) consular officers on whether to refuse a visa. In 

fiscal year 2016, VSP screened over 2.1 million visa applications, and 

recommended over 8,000 visa refusals. In addition, VSP agents and VSP-funded 

locally employed staff dedicated approximately 43 percent of their work hours in 

fiscal year 2016 to non-VSP activities—such as assisting ICE investigations not 

directly related to visas. ICE increased the percentage of VSP posts providing 

quarterly training from 30 percent in fiscal year 2014 to 79 percent in fiscal year 

2016. However, some trainings are not targeted to the specific post and do not 

address identified threats to the visa process, as required. Ensuring that VSP 

agents provide required training would help ensure consular officers have 

information that could assist them in adjudicating visas.

ICE developed objectives and performance measures for VSP, but its measures 

are not outcome-based and limit the agency’s ability to assess the effectiveness 

of VSP. As of fiscal year 2017, none of VSP’s 19 established performance 

measures are outcome-based. For example, ICE measures its activities, such as 

number of visa refusals VSP agents recommended, rather than the outcomes of 

those recommendations. ICE officials stated that measuring VSP’s outcomes is 

difficult due to the qualitative nature of the program’s benefits; however, solely 

tracking activities, such as number of recommended refusals, does not allow ICE 

to evaluate VSP’s effectiveness. Developing and implementing outcome-based 

performance measures, consistent with best practices for performance 

management, would help ICE determine whether VSP is achieving its objectives. 

ICE evaluated options for VSP expansion but its site selection process did not 

incorporate PATRIOT data or options for remote operations that, for example, 

use U.S.-based VSP agents. ICE has previously utilized PATRIOT to gather data 

to estimate program capacity, but ICE officials stated that they do not use 

PATRIOT to collect data on the potential number of ineligible visa applicants and 

workload for posts under consideration for VSP expansion. By incorporating 

PATRIOT data on posts under consideration into its site selection process, ICE 

could more effectively manage human capital and other resources. Further, ICE 

has implemented remote VSP operations in some posts, but does not consider 

such approaches during its annual site selection process. ICE documentation 

stated that ICE could successfully screen and vet applicants remotely through 

VSP, however the officials’ preferred approach is to deploy agents to posts 

overseas. Incorporating remote options for VSP operations could help identify 

opportunities to further expand VSP and better utilize resources. View GAO-18-314. For more information, 

contact Rebecca Gambler at (202) 512-8777

or gamblerr@gao.gov.

Why GAO Did This Study

In response to congressional concerns 

about potential vulnerabilities in the 

visa issuance process, ICE 

implemented VSP in 2003, which 

deploys officials to certain U.S. posts 

overseas to review visa applications, 

train consular officers, and conduct 

related investigations. ICE had 

expanded VSP operations to 32 posts, 

as of 2017. 

GAO was asked to review VSP. This 

report examines the extent to which: 

(1) VSP has contributed to the visa 

adjudication process, (2) ICE has 

implemented a system to assess VSP 

performance, and (3) ICE has 

identified and evaluated options to 

expand VSP to additional posts.

GAO analyzed ICE data for each VSP 

post for fiscal years 2014 through 

2016, the most current full-year data 

available at the time of GAO’s study; 

reviewed documents relating to VSP; 

and interviewed relevant agency 

officials. GAO visited 7 VSP posts 

selected on the basis of workload and 

other factors, and administered two 

surveys to consular and VSP officials, 

respectively, at all VSP posts that were 

operational at the time the survey was 

administered.

What GAO Recommends

GAO recommends that ICE ensure 

that trainings are implemented as 

required, develop and implement 

outcome-based performance 

measures, and incorporate PATRIOT 

data and remote options into its site 

selection process. DHS concurred with 

all recommendations. This is a public 

version of a sensitive report issued in 

December 2017. Information that DHS 

or State deemed sensitive has been 

omitted.
Page i GAO-18-314 Border Security

Letter 1

Background 6

ICE Provides an Additional Layer of Review to the Visa 

Adjudication Process through VSP, but VSP Agents Are Not 

Consistently Providing Required Training to Consular Officers 13

ICE Has Not Developed and Implemented Outcome-Based 

Measures to Assess Program Performance 24

ICE’s Site Selection Process for VSP Expansion Does Not 

Incorporate Information That Could Better Inform Resource 

Allocation 29

Conclusions 37

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 38

Appendix I Objectives, Scope, and Methodology 41

Appendix II Comments from the Department of Homeland Security 45

Appendix III Results of Screening and Vetting at Visa Security Posts, Fiscal Year 

2016 47

Appendix IV Work Hours at Visa Security Posts, Fiscal Year 2016 50

Appendix V GAO Contact and Staff Acknowledgments 52

Tables

Table 1: Results of Visa Security Program (VSP) Screening and 

Vetting Efforts, Fiscal Year (FY) 2014 through 2016 20

Table 2: Number of Visa Security Program (VSP) Posts That 

Provided At Least Four Quarterly Trainings to Consular 

Officers, Fiscal Years 2014 through 2016 22

Table 3: Visa Security Program’s (VSP) Performance Objectives 

and Related Measures, as of August 2017 25

Contents
Page ii GAO-18-314 Border Security

Table 4: Results of Visa Security Program (VSP) Screening and 

Vetting Efforts at VSP Posts, Fiscal Year 2016 48

Table 5: Fiscal Year 2016 Work Hours Recorded by Visa Security 

Program (VSP)-funded Staff 50

Figures

Figure 1: Annual Appropriations for U.S. Immigration and Customs 

Enforcement’s Visa Security Program (VSP), Fiscal 

Years 2009 through 2017 9

Figure 2: Visa Security Program’s (VSP) Screening and Vetting 

Process Before and After the Implementation of the Pre 

Adjudicated Threat Recognition and Intelligence 

Operations Team (PATRIOT) 14

Figure 3: Visa Security Program Applications Resulting in One or 

More Nominations or Records Enhancements to the 

Terrorist Identities Datamart Environment (TIDE), Fiscal 

Years 2014 through 2016 18

Figure 4: Status of Visa Security Program (VSP) Expansion, 

Calendar Year 2003 through September 2017 30

Figure 5: U.S. Immigration and Customs Enforcement (ICE) 

Annual Site Selection Process for Visa Security Program 

(VSP) Expansion 31
Page iii GAO-18-314 Border Security

Abbreviations

ARSO-I Assistant Regional Security Officer Investigator

CBP U.S. Customs and Border Protection

DHS Department of Homeland Security

FBI Federal Bureau of Investigation

GPRA Government Performance and Results Act of 1993

GPRAMA GPRA Modernization Act of 2010

HSI Homeland Security Investigations

ICE U.S. Immigration and Customs Enforcement

INA Immigration and Nationality Act

MOU memorandum of understanding

OIG Office of Inspector General

OMB Office of Management and Budget

PATRIOT Pre-Adjudicated Threat Recognition and Intelligence

Operations Team

State Department of State

TIDE Terrorist Identities Datamart Environment

TSDB Terrorist Screening Database

VSP Visa Security Program

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Page 1 GAO-18-314 Border Security

441 G St. N.W.

Washington, DC 20548

March 20, 2018

Congressional Requesters

In response to congressional questions about potential vulnerabilities in 

the visa issuance process, U.S. Immigration and Customs Enforcement

(ICE), a component within the Department of Homeland Security (DHS), 

implemented the Visa Security Program (VSP) in 2003.1 ICE has since 

deployed officials to certain U.S. embassies and consulates overseas to 

strengthen the visa review process by working with Department of State 

(State) consular officers in reviewing applications.2 In fiscal year 2014, 

ICE, in collaboration with U.S. Customs and Border Protection (CBP), 

implemented the Pre-Adjudicated Threat Recognition and Intelligence 

Operations Team (PATRIOT), which significantly changed VSP 

operations by automating parts of this review process at VSP posts, 

among other changes.3 Since 2003, ICE has gradually expanded VSP 

operations to additional locations overseas, from 3 posts in 2003 to 32 

posts in 2017, and Congress has directed DHS to further expand the 

program. Specifically, the explanatory statement accompanying the 

Consolidated Appropriations Act, 2017, directed ICE to continue planning 

 1

The Homeland Security Act of 2002 established DHS and gave the Secretary of 

Homeland Security authority to issue regulations with respect to the issuance and refusal 

of visas, and to assign DHS employees to consular posts overseas to support the visa 

process. Pub. L. No. 107-296, tit. I, IV, §§ 101, 428, 116 Stat. 2135, 2142, 2187-88 

(classified at 6 U.S.C. §§ 111, 236).

2

Unless otherwise noted, this report generally focuses on nonimmigrant visas, which are 

those issued to foreign nationals seeking temporary admission into the United States 

under a specific nonimmigrant category (8 U.S.C. § 1101(a)(15); 8 C.F.R. § 214.1(a)(1)-

(2)), for an authorized period of stay delineated by a particular timeframe or duration-ofstatus (i.e., admission for duration of a specific program or activity, which may be 

variable). Nonimmigrant visa holders include tourists, business visitors, or students, 

among others. Immigrant visas are issued to eligible “immigrants” (foreign nationals who 

do not fall within one of the classes of nonimmigrants) seeking lawful permanent resident 

status in the United States with a path to citizenship. See 8 U.S.C. § 1101(a)(16). Certain 

nonimmigrants—for example, recipients of K visas for the fiancé(e) or spouse of a U.S. 

citizen or their children, and T and U visas for victims of severe forms of trafficking in 

persons or other qualifying crimes—are also eligible for lawful permanent residence, 

provided they satisfy the applicable statutory criteria. 

3

For the purposes of this report, posts refer to U.S. embassies, consulates, and other 

types of diplomatic and consular posts, such as multilateral missions or American 

presence posts. We use the term VSP post to refer to posts for which VSP conducts visa 

screening, vetting, training, and consular-related investigative activities. 

Letter
Page 2 GAO-18-314 Border Security

and budgeting for VSP expansion to at least two high-threat locations per 

year in future budget requests.4

We have previously reported on VSP.5 In 2011, we found that ICE could 

not accurately assess progress toward meeting program objectives 

because it did not collect comprehensive data on VSP activities, and 

some of the data it collected were not reliable.6 We also reported that 

VSP agents were not consistently providing required advice and training 

to consular officers across all posts, and at some posts, consular officers 

received no training. Further, we reported that ICE did not track 

information on its non-VSP activities—that is, investigative and 

administrative functions beyond visa security responsibilities—and it was 

unable to identify the time VSP agents spent on these activities. We 

made several recommendations to help address these weaknesses. DHS 

concurred with and took actions to address our recommendation 

regarding training for consular officers; however, DHS did not concur with 

our recommendation that ICE collect comprehensive data on all 

performance measures and track the time VSP agents spent on visa 

security versus other activities.

 4

See Explanatory Statement (163 Cong. Rec. H3327, H3811 (daily ed. May 3, 2017)) 

accompanying the DHS Appropriations Act, 2017, Pub. L. No. 115-31, div. F, 131 Stat. 

135. See also Explanatory Statement (161 Cong. Rec. H10161, H10168 (daily ed. Dec. 

17, 2015)) accompanying DHS Appropriations Act, 2016, Pub. L. No. 114-113, div. F, 129 

Stat. 2242 (2015).

5

See GAO, Border Security: DHS’s Visa Security Program Needs to Improve Performance 

Evaluation and Better Address Visa Risk Worldwide, GAO-11-315 (Washington, D.C.: 

Mar. 31, 2011), and Border Security: Actions Needed to Strengthen Management of 

Department of Homeland Security’s Visa Security Program, GAO-05-801 (Washington, 

D.C.: Jul. 29, 2005).

6

In 2014, DHS’s Office of Inspector General also concluded that ICE could not assess 

VSP’s performance, in part because of data limitations, and recommended that ICE 

develop performance measures to determine the success of VSP in meeting its 

objectives. In response, ICE officials updated VSP’s performance measures by removing 

measures for investigations and training and adding new measures for data that could 

readily be collected via PATRIOT, which had not been implemented at the time of the 

DHS Office of the Inspector General’s review. See DHS’ Office of Inspector General, The 

DHS Visa Security Program, OIG-14-137 (Washington, D.C.: Sept. 10, 2014).
Page 3 GAO-18-314 Border Security

In light of continued questions about the security of the visa process, you 

asked us to review ICE’s management of VSP.7 This report examines the 

extent to which: (1) VSP has contributed to the visa adjudication process, 

(2) ICE has developed and implemented a system to assess VSP 

performance, and (3) ICE has identified and evaluated options to expand 

VSP to additional posts.

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

December 2017.8 DHS and State deemed some of the information in that 

report to be Sensitive But Unclassified or Law Enforcement Sensitive, 

which must be protected from public disclosure. Therefore, this report 

omits sensitive information about the visa screening and vetting process, 

as well as the specific locations of VSP posts. Although the information 

provided in this report is more limited, the report addresses the same 

objectives as the sensitive report and uses the same methodology.

To determine the extent to which VSP has contributed to the visa 

adjudication process, we analyzed ICE data for each VSP post for fiscal 

years 2014—the year PATRIOT was implemented—through 2016—the 

most recently available full year data on the results of VSP operations. To 

assess the reliability of these data, we interviewed ICE officials who use 

and maintain the data and checked the data for missing information, 

outliers, and obvious errors, among other actions. On the basis of these 

steps, we determined that the data were sufficiently reliable for the 

purposes of our reporting objectives, including providing summary 

statistics on VSP operations. We also reviewed program documentation, 

memoranda of understanding (MOU), standard operating procedures, 

and relevant legislation, such as the Homeland Security Act of 2002 and 

Immigration and Nationality Act (INA), and we interviewed ICE and State 

headquarters officials on VSP operations. We conducted site visits to 

seven VSP posts to observe VSP operations, and interviewed ICE and 

 7

This report does not address individuals who are allowed to seek admission to the United 

States without a visa, such as citizens of Canada and the British Overseas Territory of 

Bermuda (and certain residents of other adjacent islands, such as the Bahamas) under 

certain circumstances, as well as Visa Waiver Program participants. The Visa Waiver 

Program allows nationals from certain countries to apply for admission to the United 

States as temporary visitors for business or pleasure without first obtaining a visa from a 

U.S. embassy or consulate abroad. See 8 U.S.C. § 1187; 8 C.F.R. §§ 212.1, 214.6(d), 

217.1-217.7; 22 C.F.R. §§ 41.0-41.3.

8

GAO, Border Security: Actions Needed to Strengthen Performance Management and 

Planning for Expansion of DHS’s Visa Security Program, GAO-18-104SU (Washington, 

D.C.: Dec. 19, 2017).
Page 4 GAO-18-314 Border Security

State consular officials on VSP in each location.9 We selected these 

posts out of the 29 VSP posts that were operational as of January 2017 

on the basis of their relatively high visa workloads; ICE data on the 

percentage of applicants that potentially matched to derogatory 

information in fiscal year 2016; and, geographic distribution to help 

account for variations in visa applicant pools that VSP agents encounter 

at different locations. Our observations from these site visits are 

illustrative and provide insights about VSP operations, but are not 

generalizable to all VSP posts. We also administered two separate 

surveys—one to consular managers who oversee the consular officers 

who adjudicate visas, and another to VSP agents—at all 29 VSP posts to 

gather information and insights on VSP and PATRIOT, among other 

things. We administered these instruments from March through May 2017 

in person at the 7 posts we visited, and by email to the remaining 22. We 

received responses from all 29 posts.

To determine the extent to which ICE has developed and implemented a 

system to assess VSP performance, we gathered information on VSP 

performance measurement practices and reviewed annual reports to 

Congress.10 We also reviewed our prior work and DHS Office of Inspector 

General (OIG) reports on VSP’s performance management.11 We 

analyzed relevant information in light of principles outlined in the 

Government Performance and Results Act (GPRA) Modernization Act of 

2010 and best practices for performance management.12 We also 

gathered documentation from State to better understand other potential 

data on the outcomes of visa applications that were reviewed by VSP 

agents (see appendix I for more information about these data and our 

analysis).

 9

Specific VSP locations we visited are omitted from this report because DHS deemed 

VSP locations to be sensitive. 

106 U.S.C. § 236(e)(4).

11For example, see GAO-11-315 and OIG-14-137.

12GPRA Modernization Act of 2010 (GPRAMA), Pub. L. No. 111-352, 124 Stat. 3866 

(2011) (updating GPRA of 1993, Pub. L. No. 103-62, 107 Stat. 285). In particular, see 

GPRAMA § 3, 124 Stat. at 3867-71 (codified at 31 U.S.C. § 1115) (relating to agency 

performance plans and performance measurement). For best practices for performance 

management, see GAO, Designing Evaluations: 2012 Revision, GAO-12-208G 

(Washington, D.C.: Jan. 2012); Performance Measurement Definitions and Relationships, 

GAO-11-646SP (Washington, D.C.: May 2, 2011).

Key Visa Adjudication Process Term

Derogatory information: Information on a 

visa applicant that makes him or her 

potentially inadmissible to the United States or 

otherwise ineligible for a visa.

Source: GAO. | GAO-18-314
Page 5 GAO-18-314 Border Security

To determine the extent to which ICE has identified and evaluated options 

to expand VSP to additional posts, we obtained information from ICE on 

VSP’s expansion to new posts since 2003, such as start dates and 

staffing levels. We also reviewed information on the extent to which ICE 

has assessed the potential to expand VSP using remote operations—that 

is, by using U.S.- or other non-on site VSP agents to review visa 

applications and conduct other VSP-related activities. For example, we 

reviewed ICE’s evaluation of its 2016 pilot on remote VSP operations, 

interviewed ICE and State officials who participated in the pilot, and 

analyzed performance data from the pilot posts. We reviewed ICE’s 

methodology for site selection, which it updated in 2017 for future years’

site selection, including lists of posts that were prioritized for future 

expansion. We also reviewed prior methodologies that ICE used to 

expand the program from 2003 through fiscal year 2017. We assessed 

these methodologies against internal control standards, best practices for 

making resource allocation decisions and estimating cost, and Office of 

Management and Budget (OMB) guidance for making program expansion 

decisions.13 Additional information about our scope and methodology for 

all three objectives is included in appendix I.

We conducted this performance audit from November 2016 through 

December 2017 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

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

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. We subsequently 

worked with DHS and State from December 2017 to March 2018 to 

prepare this nonsensitive version of the original sensitive report for public 

release. This public version was also prepared in accordance with 

generally accepted government auditing standards.

 13GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014); GAO Cost Estimating and Assessment Guide: Best 

Practices for Developing and Managing Capital Program Costs, GAO-09-3SP 

(Washington, D.C.: March 2009). Also see OMB, OMB Circular No. A-94, Guidelines and 

Discount Rates for Benefit-Cost Analysis of Federal Programs (Washington, D.C.: Oct. 29, 

1992). OMB Circular A-94 provides guidance for any analysis used to support government 

decisions to initiate, renew, or expand programs or projects that would result in 

measurable benefits or costs extending for three or more years into the future.
Page 6 GAO-18-314 Border Security

Various statutes, memoranda of understanding (MOU), and other 

guidance documents have established roles and responsibilities for VSP.

Homeland Security Act of 2002 and 2003 MOU. Since its 

establishment, DHS has had exclusive authority, pursuant to section 428 

of the Homeland Security Act, to issue regulations with respect to, 

administer, and enforce provisions of U.S. immigration and nationality 

laws relating to the functions of consular officers in connection with the 

granting or refusal of visas; and DHS is authorized to assign officers to 

each diplomatic and consular post at which visas are issued.14 In 2003, 

DHS and State signed a MOU to govern the implementation of section 

428 and, in accordance with the statute, the memorandum broadly 

outlines DHS officers’ responsibilities in reviewing visa applications, 

indicating 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;

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

officers; and

• conduct investigations on consular matters under the jurisdiction of 

the Secretary of Homeland Security.

Further, the MOU notes that DHS has final responsibility over visa 

guidance, except for those matters that are specifically within the 

Secretary of State’s responsibility in existing statutes related to the 

management of the visa process and foreign policy, and in future 

statutes, presidential proclamations and executive orders.

2011 MOU. On January 11, 2011, ICE and State’s Bureau of Consular 

Affairs signed an additional MOU to further explain the roles, 

 14Pub. L. No. 107-296, tit. IV, subtit. C, § 428(b), (e), 116 Stat. at 2187-89 (classified at 6 

U.S.C. § 236(b), (e)). At post, DHS officers are to review visa applications, conduct related 

investigations, and provide expert advice and training to State consular officers who 

adjudicate such applications. Id. at § 428(e), 116 Stat. at 2189.

Background

Authorities Governing VSP
Page 7 GAO-18-314 Border Security

responsibilities, and collaboration of VSP agents and State officials in 

daily operations of VSP at posts overseas.15 The MOU does the following, 

among other things:

• describes general collaboration between ICE and State for VSP 

operations as well as for visa and passport fraud investigations;

• establishes roles and responsibilities of VSP agents and consular 

officers; and

• calls for the development of formal, targeted training and briefings to 

inform consular officers and other U.S. government personnel at 

consular posts of identified threats relating to the visa process.

The 2011 MOU also states that the primary responsibility of VSP agents 

is visa security. However, the MOU acknowledges that ICE personnel 

perform functions of regional or worldwide scope related to the post 

where they are assigned, and that VSP agents may be called upon to 

perform other functions in support of the post.

VSP is managed by ICE’s Homeland Security Investigations (HSI), which 

is responsible for investigating a wide range of domestic and international 

activities arising from the illegal movement of people and goods into, 

within, and out of the United States. Within HSI, management of VSP is 

divided between International Operations and the National Security 

Investigations Division. International Operations manages ICE’s attaché 

offices in U.S. embassies and consulates, including offices with VSP 

agents. According to ICE, these offices coordinate domestic ICE 

operations with foreign counterparts, investigate and disrupt criminal 

efforts to smuggle people and materials into the United States, and build 

international partnerships through outreach and training. Generally, ICE 

has deployed one or two VSP agents to each VSP post, and some offices 

also employ locally hired staff who help with VSP operations.16 ICE’s 

National Security Investigations Division administers VSP’s PATRIOT, 

which aims to identify national security, public safety, and other eligibility 

concerns related to visa applicants prior to their in-person consular 

 15According to ICE officials, as of March 2018, ICE and State are in the process of 

updating this MOU. 

16As of January 2017, most VSP posts (25 of 29) had one or two VSP agents, according 

to ICE staffing data. Further, in addition to the agents, most VSP posts (18 of 29) have 

local staff who help review visa applications and interview applicants to support VSP 

screening and vetting, among other activities.

VSP Management and 

Funding
Page 8 GAO-18-314 Border Security

interview at VSP posts. PATRIOT was implemented in September 2014 

in partnership with CBP’s National Targeting Center, which manages the 

computer systems off which PATRIOT is based, among other 

responsibilities.17

From fiscal years 2009 through 2017, ICE received more than $300 

million in appropriated funds for VSP, as shown in figure 1. Since fiscal 

year 2010, ICE has generally received between $30 and $35 million 

annually for the program, except for fiscal years 2015 and 2017. 

Specifically, in both fiscal years 2015 and 2017, ICE received 

approximately $50 million to implement VSP.18 According to the 

explanatory statements accompanying the appropriations acts for these 

fiscal years, funding was provided above the requested amounts in order 

to annualize costs of previously funded program expansion and to further 

expand VSP to high-threat countries, among other reasons.19

 17The National Targeting Center is a 24/7 operations entity responsible for providing 

advance information and research about high-risk travelers and cargo and facilitating 

coordination between law enforcement and intelligence agencies in support of CBP’s antiterrorism mission and efforts to keep high-risk individuals and cargo from boarding U.S.-

bound flights and vessels. PATRIOT uses CBP’s Automated Targeting System, which is a 

computer-based enforcement and support system that compares traveler information 

against intelligence and law enforcement data to identify high-risk travelers. We discuss 

this system in more detail later in this report.

18See 163 Cong. Rec. at H3811, accompanying Pub. L. No. 115-31, div. F, 131 Stat. 135 

(2017) (“$18,000,000 is provided above the request for VSP to annualize the costs of 

previously funded program expansion and for further expansion to additional high priority 

locations.”); see also Explanatory Statement (161 Cong. Rec. H227, H280 (daily ed. Jan. 

13, 2015)), accompanying the DHS Appropriations Act, 2015, Pub. L. No. 114-4, 129 Stat. 

39 (“$12,000,000 is provided to expand the Visa Security Program to high-threat 

countries; and an increase of $3,500,000 is provided to support enhancement to the 

PATRIOT information technology system for visa vetting.”).

19See 163 Cong. Rec. at H3811; see also 161 Cong. Rec. at H280. For other examples 

where ICE has received funding above the administration’s request for VSP-related 

purposes, see, e.g., Explanatory Statement (161 Cong. Rec. at H10168), accompanying 

the DHS Appropriations Act, 2016, Pub. L. No. 114-113, div. F, 129 Stat. 2242 (2015) 

(providing $2,000,000 above the request for VSP to annualize the costs of previously 

funded program expansion); Conference Report, H.R. Rep. No. 112-331, at 964 (Dec. 15, 

2011), accompanying the Consolidated Appropriations Act, 2012, Pub. L. No. 112-74, 125 

Stat. 786 (2011) (providing $4,400,000 above the request to support VSP expansion); and 

Explanatory Statement (159 Cong. Rec. S1275, S1551 (daily ed. March 11, 2013)), 

accompanying the Consolidated and Further Continuing Appropriations Act, 2013, Pub. L 

.No. 113-6, 127 Stat. 198 (providing an additional $2,000,000 to support pre-adjudication 

vetting of visa applicants).
Page 9 GAO-18-314 Border Security

Figure 1: Annual Appropriations for U.S. Immigration and Customs Enforcement’s 

Visa Security Program (VSP), Fiscal Years 2009 through 2017

Note: Figure 1 shows amounts made available for VSP each fiscal year pursuant to that year’s 

Department of Homeland Security appropriations act or other statute appropriating funds and does 

not reflect any reprogrammings, transfers, rescissions, or other adjustments that may have altered 

total funding available to the program in a particular fiscal year.
Page 10 GAO-18-314 Border Security

At the posts where the program is located, VSP is part of a larger visa 

screening, adjudicating, and issuance process. State is responsible for 

the issuance of immigrant and nonimmigrant visas, and manages the visa 

application and adjudication process, as well as the consular officer corps 

and its functions at over 220 visa-issuing posts overseas.20 Foreign 

nationals who wish to come to the United States on a temporary basis 

and are not citizens or nationals of countries that participate in the Visa 

Waiver Program must generally obtain a nonimmigrant visa allowing them 

to travel to the United States and apply for admission into the country at a 

U.S. port of entry.21 State’s consular officers adjudicate visa applications 

and are charged with facilitating legitimate travel while preventing 

applicants ineligible for a visa or U.S. admission, including potential 

terrorists, from obtaining a visa authorizing their travel to the United 

States. The process for determining who will be issued or refused a visa 

contains several steps, including:

• review of the visa application and related documentation, as 

appropriate;

• collection of biometrics (fingerprints and full-face photographs);

• security checks that cross-reference an applicant’s name, biometrics, 

and other information against multiple databases maintained by the 

U.S. government; and

 20See 6 U.S.C. § 236(c), (d); 8 U.S.C. §§ 1201, 1202.

21Ports of entry are facilities that provide for the controlled entry into or departure from the 

United States. Specifically, a port of entry is any officially designated location (seaport, 

airport, or land border location) where CBP officers are assigned to clear travelers, 

merchandise, cargo, and other items; collect duties; enforce customs laws; and inspect 

persons entering or applying for admission into, or departing the United States pursuant to 

U.S. travel controls and immigration law.

Key Visa Adjudication Process Terms

Inadmissible: Individuals are inadmissible to 

the United States if they fall within the classes 

of foreign nationals defined as such under the 

Immigration and Nationality Act (INA), as 

amended, Pub. L. No. 82-414, tit. II, ch. 2, § 

212(a), 66 Stat. 163, 182-87 (1952) 

(classified, as amended, at 8 U.S.C. § 

1182(a)), such as foreign nationals who have 

engaged in terrorist or criminal activities or 

previously violated U.S. immigration law. If a 

visa applicant is found inadmissible, and has 

not obtained a waiver from the Department of 

Homeland Security, the applicant would be 

statutorily ineligible for a visa.

Ineligible: An individual is ineligible for a visa 

if it appears to the Department of State 

consular officer, based on the application or 

supporting documentation, that the applicant 

is not legally qualified to receive the visa 

being sought. If the consular officer decides, 

at his or her discretion, that an applicant is 

ineligible for visa issuance, the refusal may be 

based on statutory grounds of inadmissibility 

under INA § 212(a), or may be due to the 

individual’s failure to otherwise satisfy the 

applicable eligibility requirements for the 

particular visa, as defined in the INA. For 

example, a consular officer may refuse a J-1 

exchange visitor visa to an applicant coming 

to the United States to perform services as a 

member of the medical profession if such 

person does not either demonstrate 

competency in oral and written English or hold 

a degree from an accredited school of 

medicine, as required of such visa applicants 

under INA § 212(j).

Source: GAO. | GAO-18-314

Visa Adjudication Process
Page 11 GAO-18-314 Border Security

• in-person interviews, as required.22

From 2003 until the implementation of PATRIOT beginning in fiscal year 

2014, agents at VSP posts manually screened visa applications after the 

consular officer had already made a preliminary decision to either refuse 

or issue the visa. Prior to the implementation of PATRIOT’s automated 

screening process, consular officers interviewed applicants and reviewed 

relevant supporting documentation and security check results, and then 

made a preliminary determination to issue the visa or refuse the visa. 

After the consular officer made an initial determination, VSP agents at 

post then screened the applicant’s biographic information against DHS’s 

TECS database—DHS’s principal law enforcement and antiterrorism 

database that includes enforcement, inspection, and operational 

records—to identify applicants that potentially matched records of 

individuals who were known threats to the United States or matched to 

other derogatory information that could make them ineligible for a visa.23

The VSP agent then vetted a smaller number of applications based upon 

a threat-based targeting plan specific to each post. On the basis of these 

reviews, VSP agents submitted a recommendation to the consular officer 

either agreeing with the preliminary decision or recommending that the 

visa be refused. The consular officer then decided whether to issue or 

refuse the visa.24 PATRIOT automated parts of this screening and vetting 

process, as discussed later in this report.

 22See 8 U.S.C. § 1202(a), (c), (h); 22 C.F.R. §§ 41.102, 42.62. Prior to March 2017, 

applicants who qualified for State’s Interview Waiver Program were not required to 

schedule or appear at post for an interview for their nonimmigrant visa application to be 

adjudicated by a consular officer. For example, State reported that 332,980 nonimmigrant 

visas were issued in fiscal year 2016 under the Interview Waiver Program, which is about 

3.2 percent of the 10,381,159 nonimmigrant visas issued that fiscal year. Executive Order 

13780, issued in March 2017, suspended this program and directed State to ensure 

compliance with 8 U.S.C. § 1202, requiring that all those seeking nonimmigrant visas 

undergo an in-person interview, subject to specific statutory exceptions. The Executive 

Order further identified categories of foreign nationals traveling under certain visa 

categories or for particular purposes for which the interview waiver program suspension 

does not apply, such as individuals traveling on a diplomatic or diplomatic-type visa. See 

Protecting the Nation from Foreign Terrorist Entry Into the United States, Exec. Order No. 

13780, § 9, 82 Fed. Reg. 13,209, 13,216-17 (Mar. 9, 2017).

23TECS is used for preventing terrorism, providing border security and law enforcement, 

and sharing information about people who are inadmissible or may pose a threat to the 

security of the United States. Originally developed in the 1980s, TECS provides traveler 

processing and screening, investigations, case management, and intelligence functions 

for multiple federal, state, and local agencies. TECS is not an acronym.

24If the consular manager and VSP agents disagreed on a case, a dispute resolution 

process was used to render a final determination of the application. 

Key Visa Adjudication Process Terms

Screening: Reviewing visa application 

information for matches to derogatory

information in relevant databases.

Vetting: Researching and investigating 

screened applicants with possible matches in 

those databases or based on other criteria.

Source: GAO. | GAO-18-314
Page 12 GAO-18-314 Border Security

Several other U.S. agencies with personnel stationed overseas have 

roles in the visa process. State’s Bureau of Consular Affairs’ fraud 

prevention managers investigate fraud cases, conduct fraud training for 

consular officers, and provide information on fraud trends to consular 

officers. State’s Bureau of Diplomatic Security’s Assistant Regional 

Security Officer Investigators (ARSO-I) are to assist consular officers by 

investigating suspected passport and visa fraud detected through the 

consular officers’ reviews of visa applications and supporting 

documents.25 Further, the Department of Justice’s Federal Bureau of 

Investigation’s (FBI) legal attachés can assist consular officers when 

questions about an applicant’s potential criminal history or terrorist activity 

arise during adjudication.26

 25Under State’s Bureau of Diplomatic Security, 122 ARSO-Is are assigned to 107 posts to 

protect the integrity of the visa system and disrupt criminal networks and terrorist mobility, 

as of December 2016. ARSO-Is are Diplomatic Security special agents who specialize in 

criminal investigations of visa fraud. Diplomatic Security recommends that ARSO-Is spend 

80 percent of their time working on visa fraud, and 20 percent of their time supporting 

other Diplomatic Security responsibilities, such as providing security to high-level visitors 

at post. ARSO-Is often work with local law enforcement and judicial officials to arrest and 

prosecute violators of local laws related to visa fraud, such as the fraudulent production of 

local identification documents used in applications for visas. 

26Legal attachés are the personal representatives of the FBI Director in the foreign country 

in which he or she is assigned. According to the FBI, legal attachés’ core mission is to 

establish and maintain liaison with principal law enforcement and security services in 

designated foreign countries, which enables the FBI to conduct its responsibilities in 

combating international terrorism, organized crime, cybercrime, and general criminal 

matters. 
Page 13 GAO-18-314 Border Security

Through PATRIOT, ICE contributes to the visa adjudication process by 

screening, vetting, and, in certain cases, investigating visa applicants at 

VSP posts. In fiscal year 2014, ICE, in collaboration with CBP, began 

implementing PATRIOT on a rolling basis to existing VSP posts. As of 

September 2016, ICE had implemented PATRIOT at all 29 existing VSP 

posts.27 PATRIOT includes (1) an automated screening system, (2) U.S.-

based ICE and CBP analysts (referred to hereafter as U.S.-based 

analysts) who manually vet potential matches resulting from the 

automated screening, and (3) agents stationed abroad.28 As shown in 

figure 2, the introduction of PATRIOT automated ICE’s role in visa 

screening and created the opportunity for VSP agents to provide 

recommendations to consular officers prior to their initial adjudication of 

the visa.

 27VSP agents also screen and vet applicants for immigrant visas using a process similar 

to the pre-PATRIOT process used to screen nonimmigrant visa applicants. In March 2017, 

DHS implemented a pilot program that used PATRIOT to also screen immigrant visas 

applicants at 6 VSP posts. As of August 2017, State notified ICE that it planned on 

implementing PATRIOT for immigrant visas at all VSP posts in November 2017.

28As of January 2017, ICE analysts conduct manual vetting for 22 VSP posts and CBP 

analysts conduct vetting for the remaining 7 posts. CBP also conducts manual vetting for 

two additional posts, for which it screens and vets applicants remotely. Remote VSP 

operations are discussed later in this report.

ICE Provides an 

Additional Layer of 

Review to the Visa 

Adjudication Process 

through VSP, but VSP 

Agents Are Not 

Consistently 

Providing Required 

Training to Consular 

Officers
Page 14 GAO-18-314 Border Security

Figure 2: Visa Security Program’s (VSP) Screening and Vetting Process Before and After the Implementation of the PreAdjudicated Threat Recognition and Intelligence Operations Team (PATRIOT)

Note: Prior to fiscal year 2010, State used a paper-based nonimmigrant visa application form, the DS156. State began rolling out the new online DS-160 form worldwide in December 2009, and 

completed rolling out the new form by March 2010.
Page 15 GAO-18-314 Border Security

PATRIOT screens all visa applications submitted to VSP posts. Once a 

foreign national submits a visa application online to a VSP post, 

PATRIOT automatically screens various data points from the visa 

application (such as name, date of birth, and passport number) against 

U.S. government holdings of derogatory information using CBP’s 

Automated Targeting System.29 The Automated Targeting System 

includes data from various U.S. government systems, including TECS, 

the FBI’s Terrorist Screening Database (TSDB), and State’s Consular 

Consolidated Database, among others.30 According to ICE data, in fiscal 

year 2016, most visa applications screened through PATRIOT’s 

automated system did not match to derogatory information. Such 

applications are automatically returned to consular officers with a 

recommendation from PATRIOT of “no objection,” which means that ICE 

does not object to the consular officer potentially issuing a visa to the 

applicant (barring the subsequent identification of any other derogatory 

information). According to State officials, PATRIOT’s automated system is 

valuable as part of the layered approach to homeland security. In 

addition, consular managers from 7 of the 29 VSP posts we surveyed 

reported to us that PATRIOT is helpful as another layer of security checks 

to ensure that consular officers are not missing any derogatory 

information that would inform their adjudication.

However, consular managers we surveyed had mixed views on the extent 

to which PATRIOT has enhanced the ability of consular officers to 

adjudicate visas. Specifically, consular managers at 15 of 29 VSP posts 

reported that PATRIOT enhanced the ability of consular officers to 

adjudicate visas a great deal or a moderate amount. The remaining 14 

consular managers reported that PATRIOT enhanced the ability of 

 29CBP’s Automated Targeting System is a computer based-enforcement and support 

system that compares traveler information against intelligence and law enforcement data 

to identify high-risk travelers. Information on additional data points that PATRIOT screens, 

as well as the number of data points used, are omitted from this report because DHS 

deemed the information to be sensitive.

30TSDB is the U.S. government’s consolidated terrorist watch list of known and suspected 

terrorists. Information in the TSDB comes from two sources: National Counterterrorism 

Center’s Terrorist Identities Datamart Environment, which provides information on known 

or suspected international terrorists, and the FBI, which provides information about known 

or suspected domestic terrorists. The FBI’s Terrorist Screening Center manages the 

TSDB. The Consular Consolidated Database contains data from the Bureau of Consular 

Affairs on current and former visa applicants, such as names, addresses, birthdates, 

biometric data, identification numbers, and country of origin, and also links to other U.S. 

government systems, including FBI’s fingerprint database.

PATRIOT Automatically 

Screens 100 Percent of 

Visa Applications 

Submitted to VSP Posts 

and Provides an Additional 

Layer of Review Against 

Derogatory Information in 

U.S. Databases
Page 16 GAO-18-314 Border Security

consular officers to adjudicate visas very little or not at all. In general, 

consular managers told us that there are similarities between PATRIOT’s 

automated screening and the required checks conducted through State’s 

consular name check systems. Of the 14 consular managers that 

reported that PATRIOT enhanced the ability of consular officers to 

adjudicate visas very little or not at all, 10 reported that derogatory 

information identified through PATRIOT is sometimes not helpful because 

it is the same or similar to information pulled from other systems 

accessible to consular officers. For example, two of State’s main consular 

systems screen against systems that are also screened by PATRIOT.31

However, State officials stated that PATRIOT is useful to consular officers 

because it corroborates derogatory information found in consular 

systems, which can make consular officers feel more confident in their 

adjudications. For example, consular managers from 4 of the 29 VSP 

posts told us that PATRIOT helps to corroborate derogatory information 

found from other systems to which consular officers have access.

State officials noted that PATRIOT enhances the screening and vetting of 

visa applications in other ways, as well. Consular officers do not have 

access to some kinds of law enforcement sensitive information that are 

available to VSP agents, such as information on ongoing law enforcement 

investigations.

 31We have omitted more detailed information comparing the systems against which 

State’s consular systems and PATRIOT are screened because DHS deemed the 

information to be sensitive.
Page 17 GAO-18-314 Border Security

Once the PATRIOT automated screening process is complete, U.S.-

based analysts review the relatively small percentage of visa applications 

in which the applicant’s information potentially matched to derogatory 

information, referred to as “hits.”32 According to ICE data, 2.91 percent of 

visa applications screened by PATRIOT in fiscal year 2016 had a 

potential match to derogatory information that required U.S.-based 

analysts to review the application.33 These analysts use various 

government systems to vet the applicant, including classified databases. 

If needed, U.S.-based analysts contact VSP agents at post to obtain 

information from the visa applicant to help determine if the applicant is a 

match to derogatory information. If not a match, analysts are to clear the 

potential hit, which automatically returns the application back to State with 

a recommendation of “no objection.” According to State and VSP officials, 

clearing such “false matches” helps facilitate legitimate travel. However, if 

the applicant is a match, the analysts are to summarize their findings, 

provide an opinion on whether the applicant is potentially ineligible for the 

visa or otherwise inadmissible into the United States, cite applicable 

federal statutes if relevant, and electronically send the information to the 

VSP agents at post. Although U.S.-based analysts provide their opinion, 

VSP agents at post make a final recommendation to the consular officer 

on whether to refuse the visa.

U.S.-based analysts also use information gathered during their vetting 

efforts to expand or enhance records in U.S. databases on terrorist 

identities. For example, terrorism-related information may be discovered 

by analysts during vetting that could be used to support a nomination or 

record enhancement to the Terrorist Identities Datamart Environment 

 32According to ICE and CBP, U.S.-based manual vetting for PATRIOT is conducted by 

ICE analysts and a combination of CBP security specialists and officers, respectively. For 

the purposes of this report, we refer to the officials performing PATRIOT’s manual vetting 

from both agencies as analysts. 

33ICE data indicates that 1.58 percent and 1.18 percent of visa applications screened by 

PATRIOT in fiscal years 2014 and 2015, respectively, had a potential match to derogatory 

information; however, this data may not be reliable. For fiscal years 2014 and 2015, ICE 

defined applications vetted as the number of applications for which an analyst clicked a 

button in VSP’s internal tracking system to indicate that he or she had manually vetted the 

application. For fiscal year 2016, ICE improved the reliability of this data by defining 

applications vetted as the number of applications that identified a hit to derogatory 

information. Because all applications with hits are forwarded to analysts for manual 

vetting, this definition more accurately identifies the number of applications vetted by U.S.-

based analysts. 

Relatively Few Visa 

Applications Screened 

through PATRIOT Require 

Manual Vetting By U.S.-

Based Analysts, Who Also 

Gather Information to 

Expand Records on 

Terrorists
Page 18 GAO-18-314 Border Security

(TIDE).34 In coordination with the VSP agents, the U.S.-based analysts 

may submit nominations to the National Counterterrorism Center, which 

provides information on known or suspected international terrorists in 

TIDE. From fiscal year 2014 through 2016, ICE made nominations or 

record enhancements to TIDE based upon 2,203 visa applications, as 

shown in figure 3.35

Figure 3: Visa Security Program Applications Resulting in One or More 

Nominations or Records Enhancements to the Terrorist Identities Datamart 

Environment (TIDE), Fiscal Years 2014 through 2016

Note: The National Counterterrorism Center’s TIDE contains information pertaining to or on known or 

suspected international terrorists. These data do not correspond to the U.S. Immigration and 

Customs Enforcement data on the total number of nominations or record enhancements presented in 

its annual report to the Congress.

Out of the 5.7 million visa applications screened at VSP posts from fiscal 

years 2014 through 2016, VSP agents recommended that consular 

officers refuse over 21,000 applications. To determine what 

recommendations they will make to consular officers on visa applications, 

VSP agents conduct various activities at post, including:

• Reviewing visa applications. VSP agents review applications and 

information provided by U.S.-based analysts, and conduct additional 

vetting activities, including researching government databases. VSP 

agents at 18 of 29 posts reported that each VSP agent reviews 1 to 

10 applications per day. Further, VSP agents at 8 posts reported that 

each VSP agent reviews 11 to 15 applications per day, and agents 

 34The National Counterterrorism Center’s TIDE contains information pertaining to or on 

known or suspected international terrorists.

35This also includes enhancements made to existing records on known or suspected 

terrorists, such as adding or updating information. Further, one application may contain 

information on multiple known or suspected terrorists. 

VSP Agents at Post 

Recommended Refusal to 

Consular Officers for 

Fewer Than Half of One 

Percent of Visa 

Applications
Page 19 GAO-18-314 Border Security

from the remaining 3 posts reported that each VSP agent reviews 

more than 15 applications per day.

• Interviewing visa applicants. When needed, VSP agents interview 

visa applicants independently or with consular officers and other 

officials at post. If requested, VSP agents provide additional 

information to the U.S.-based analysts to assist in vetting potential 

matches to derogatory information. Some of the agents stated that, 

instead of attending interviews in person, they send questions to 

consular officers to ask during their interview with the applicant. About 

half of the VSP posts (15 of 29) reported that each agent participates 

in 0 to 4 interviews with applicants per month. Of the remaining 14 

VSP posts, 7 posts reported that each VSP agent participates in 5 to 

8 interviews with applicants per month, and 7 posts reported that each 

VSP agent participates in more than 8 interviews per month.

• Conducting investigations related to consular matters. VSP 

agents conduct investigations related to consular matters, such as 

visa fraud and drug trafficking. As needed, VSP agents coordinate 

investigations with various U.S. entities at post, including FBI, State, 

and the intelligence community, as well as international organizations 

and host nation law enforcement. According to ICE data, VSP agents 

at 11 VSP posts opened 2 to 3 VSP-related cases, 10 posts opened 4 

to 9 VSP-related cases, and 3 posts opened more than 10 VSPrelated cases in fiscal year 2016.36

• Coordinating with other U.S. officials. As needed, VSP agents may 

coordinate with other U.S. government officials on visa-related issues. 

Based on the results of our survey and observations, VSP agents at 

post generally enjoy positive working relationships with other staff at 

post. Consular managers from most of the VSP posts (27 of 29) 

described their working relationship with the VSP agents at their post 

as good or very good.37 Similarly, other officials we interviewed on our 

site visits who occasionally interact with the VSP agents on issues 

related to visas, such as the FBI legal attachés and State’s ARSO-Is, 

generally stated that they have positive working relationships with the 

VSP agents.

 36VSP agents at the remaining 5 posts opened less than 2 cases; however, VSP 

operations at all 5 of these posts had not been initiated until September 2016, near the 

end of the fiscal year. 

37The consular manager at 1 VSP post described the working relationship between 

consular officers and VSP agents as neither good nor poor, and a consular manager at 

the remaining VSP post described the working relationship as poor.
Page 20 GAO-18-314 Border Security

VSP agents make the final recommendation to State consular officers as 

either no objection (green light), no objection with information for the 

consular officer (green light with comments),38 or recommended refusal 

(red light). As VSP has expanded to additional posts from fiscal year 2014 

through 2016, the percentage of recommended refusals has remained 

relatively consistent, as shown in table 1 (see appendix III for an analysis 

of the results of VSP screening and vetting, broken out by VSP post for 

fiscal year 2016).

Table 1: Results of Visa Security Program (VSP) Screening and Vetting Efforts, Fiscal Year (FY) 2014 through 2016

FY

Applications 

screeneda

Results of screening and vetting

(percent of applications screened)

No objection No objection with information Recommend refusal

2014 1,578,985 1,567,432

(99.27%)

6,212

(0.39%)

5,341

(0.34%)

2015 1,977,223 1,959,914

(99.12%)

9,134

(0.46%)

8,175

(0.41%)

2016 2,183,100 2,165,283

(99.18%)

9,721

(0.45%)

8,096

(0.37%)

Source: GAO analysis of U.S. Immigration and Customs Enforcement (ICE) data. I GAO-18-314

Note: Percentages may not add to 100 percent due to rounding. Not all of the applicants that ICE 

screens and vets will eventually appear for an interview and have their visa adjudicated by a consular 

officer. For example, ICE data indicates that VSP screened 2,183,100 applications in fiscal year 2016 

and State data for that time period indicate that consular officers adjudicated 1,625,601 applications 

at VSP posts.

a

There were 20 operational VSP posts in FY 2014; 26 in FY 2015, and 30 in FY 2016. ICE data for 

FYs 2015 and 2016 also includes one post for which VSP operations are conducted by VSP agents 

at a remote location.

Visa applications are screened by PATRIOT prior to the applicant’s 

interview, but during our site visits VSP agents identified three reasons 

their recommendations may not be available prior to the applicant’s 

interview with a consular officer. First, VSP agents reported that they are 

sometimes unable to provide recommendations to consular officers prior 

to the interview because they need additional information on the applicant 

before making their recommendation, which the agent can obtain during 

the applicant’s upcoming interview. Second, VSP agents explained the 

 38In cases where the VSP agent determines that there is no inadmissibility or ineligibility, 

the agent may provide information uncovered by the VSP screening and vetting process 

to potentially help the consular officer make his or her adjudication decision.
Page 21 GAO-18-314 Border Security

wait time between submitting a visa application and being able to 

schedule an interview can sometimes be short, making it sometimes 

difficult for U.S.-based analysts—some of whom work during U.S. 

business hours—to complete their manual vetting. For example, a VSP 

agent at a post reported that he rarely provides recommendations prior to 

the consular officer’s interview because the wait time at his post is 

typically 3 days, which may not be enough time to fully vet some 

applicants. Finally, PATRIOT responses may not be available at the time 

of the interview for cases in which the applicant provided additional or 

corrected biographic information to State on the day of the interview. Any 

new information is run through automatic PATRIOT screening again, and 

U.S.-based analysts will conduct manual vetting on any newly identified 

matches to derogatory information. State officials noted that, although 

PATRIOT responses are not always available prior to the consular 

officer’s interview, consular systems at VSP posts prevent a visa from 

being printed until the officer has reviewed a final PATRIOT response.

ICE data on the number of trainings recorded by VSP agents indicates 

that the program has increased the percentage of VSP posts meeting the 

program’s training requirement since fiscal year 2014, but some posts 

have not fully met this requirement. The 2011 MOU between ICE and 

State notes that VSP personnel are to develop formal, targeted training 

and briefings to inform consular officers and other U.S. government 

personnel at consular posts of identified threats relating to the visa 

process. ICE guidance to implement this requirement specifies that VSP 

agents are to provide such training quarterly. According to ICE officials, 

they communicate the quarterly training requirements during predeployment training for VSP agents. Further, headquarters-based 

program managers reinforce the requirement during monthly phone calls 

with each post. As shown in table 2, the percentage of VSP posts 

meeting the training requirement increased from 30 percent (6 of 20) in 

fiscal year 2014 to 84 percent (16 of 19) in fiscal year 2015; 79 percent 

(19 of 24) of posts met the training requirement in fiscal year 2016. In 

fiscal year 2016, the number of recorded trainings provided per post 

ranged from as low as 0 to as high as 18.

VSP Agents Are Not 

Consistently Providing 

Training to Consular 

Officers, As Required
Page 22 GAO-18-314 Border Security

Table 2: Number of Visa Security Program (VSP) Posts That Provided At Least Four 

Quarterly Trainings to Consular Officers, Fiscal Years 2014 through 2016

Fiscal year Number of VSP postsa

2014 6 of 20 (30 percent)

2015 16 of 19 (84 percent)

2016 19 of 24 (79 percent)

Source: GAO analysis of U.S. Immigration and Customs Enforcement data. I GAO-18-314

a

These data exclude posts that were not open for the full fiscal year.

On the basis of our analysis, the training provided by VSP agents to 

consular officers at some VSP posts does not align with the 2011 MOU 

directive that ICE develop formal, targeted trainings and briefings at 

consular posts. For example, consular managers at 4 of the 7 posts we 

visited stated that the trainings VSP agents provide to consular officers 

generally consist of an overview of VSP and PATRIOT.39 Although such 

information is useful to consular officers, particularly those who are new, 

such general training is not targeted to the specific post, nor does it 

address identified threats relating to the visa process. Further, VSP 

agents at 3 posts stated that they considered the training required by the 

MOU to include answering questions from consular officers on DHSrelated topics or initial consultations with the agent when a new consular 

officer arrived at post. However, responding to questions from consular 

officers outside the context of a formal, targeted training or briefing is not 

consistent with the 2011 MOU.

ICE officials stated that their intention for the quarterly training 

requirement, per the guidance, is for agents to monitor the threat 

environment and trends in the visa applicant pool at their post. Further, 

consular managers at 3 of the 7 posts we visited said that that they would 

like VSP to provide more training to consular officers, including training on 

the threat environment at their post. For example, one consular manager 

stated that she would like more information or training from VSP on 

worldwide and regional trends, patterns of concern, and threat streams.

Although ICE’s headquarters-based program managers reinforce the 

quarterly training requirement in their monthly phone calls with VSP 

 39Consular managers at the other 3 posts we visited stated that agents provided training 

on various topics that were of interest to the post, such as human smuggling.
Page 23 GAO-18-314 Border Security

agents, ICE program managers generally do not monitor the content of 

these trainings to determine if they meet the intention of the 2011 MOU. 

ICE requires VSP agents to record their quarterly trainings by developing 

a training record in ICE’s Investigative Case Management System, which 

is reviewed by local ICE supervisors at post. However, ICE officials stated 

that such reviews have generally not focused on whether the content of 

the training met the intention of the 2011 MOU. Standards for Internal 

Control in the Federal Government states that program management 

should establish monitoring activities to monitor the internal control 

system, and take corrective actions as needed.40 Ensuring that VSP 

agents develop and provide training as required would help provide 

consular officers with additional information on threats that could assist 

them in conducting visa adjudications.

Per the 2011 MOU, VSP agents and local staff can work on other 

activities in addition to their VSP responsibilities, including providing 

assistance for ICE international investigations not directly related to visa 

issuance. VSP-funded staff, which includes VSP agents and locally 

employed staff funded by VSP, dedicated approximately 57 percent of 

their work hours to VSP activities on average, and the remainder to nonVSP activities, according to ICE’s fiscal year 2016 staff hours data (see 

appendix IV for an analysis of VSP work hours broken out by VSP post 

for fiscal year 2016).41 The percentage of staff hours dedicated to VSP 

activities varied among posts, ranging from less than 15 percent to more 

than 90 percent. For example, 9 of the 24 posts that were operational the 

full fiscal year dedicated less than 50 percent of staff hours to VSP 

activities.

VSP agents at the 7 posts we visited stated that such non-VSP 

responsibilities include addressing requests from ICE domestic field 

offices in need of assistance, known as collateral case requests. For 

example, ICE agents at a domestic field office that are investigating a 

drug smuggling case may request that the VSP agent overseas 

coordinate with host nation law enforcement to gather additional 

information to support the investigation. VSP agents also stated that they 

may be required to respond to collateral case requests across multiple 

 40GAO-14-704G.

41This percentage excludes the five new VSP posts that were not operational the entire 

fiscal year.

VSP-Funded Staff Also 

Work on Non-VSP 

Activities
Page 24 GAO-18-314 Border Security

countries overseas—in addition to their VSP posts—if they have regional 

areas of responsibility. For example, one VSP agent stated that he covers 

such requests for 10 other countries in addition to his VSP duties at post. 

Further, according to ICE officials, VSP-funded agents at some of the 

posts also serve as the ICE or DHS attaché for the post, and as a result 

may have other responsibilities related to coordinating DHS or ICE 

activities at post. As of September 2017, ICE reported that one of the 

VSP-funded agents at 9 of 33 VSP posts is also serving as the post’s ICE 

attaché.

ICE has developed objectives for VSP and a number of performance 

measures to assess the program’s performance; however, ICE’s 

measures are not outcome-based and thus do not position the agency to 

be able to assess the effectiveness of VSP in meeting its objectives.42

ICE officials told us that the objectives for VSP are to (1) identify and 

counteract known threats before they reach the United States, (2) 

maximize law enforcement and counterterrorism value to identify and 

disrupt unknown threats to homeland security, and (3) increase the U.S. 

government’s capacity to address threats. Other program-specific 

documentation we reviewed articulates similar program objectives, which 

are primarily focused on enhancing national security and counterterrorism 

activities. Over time, ICE has modified or developed a number of new 

performance measures for the program. For example, in 2014, ICE 

officials removed 5 of its 6 existing measures and added 8 new 

measures, for which ICE determined that data could readily be collected 

via PATRIOT. ICE added 6 new measures in fiscal year 2016 and 4 new 

measures in August 2017, for a total of 19 performance measures (see 

table 3).

 42We have previously reported on VSP’s performance management challenges and made 

recommendations to address these weaknesses. In March 2011, for example, we reported 

that ICE was unable to assess VSP’s progress toward its established objectives because 

ICE had established performance measures for each of VSP’s objectives, but had not 

collected comprehensive data for half of those performance measures. We recommended 

that ICE collect reliable data on all performance measures to allow ICE to accurately 

evaluate VSP performance and report to Congress on progress toward VSP’s mission 

objectives. ICE did not concur with this recommendation, and ICE officials stated, at that 

time, that performance data had been collected for all measures. We concluded that these 

data were incomplete or unreliable. As such, we closed the recommendation as 

unimplemented. See GAO-11-315. 

ICE Has Not 

Developed and 

Implemented 

Outcome-Based 

Measures to Assess 

Program 

Performance
Page 25 GAO-18-314 Border Security

Table 3: Visa Security Program’s (VSP) Performance Objectives and Related Measures, as of August 2017

Performance objectives Performance measures 

I. Identify and counteract known 

threats before they reach the 

United States

1. Number of applications screened

2. Number of applications vetted

3. Number of applications identified with derogatory information (“hits”)

4. Number of recommended visa refusals

5. Number of recommended visa revocationsa

6. Number of applicants for whom VSP helped facilitate legitimate travel

II. Maximize law enforcement 

and counterterrorism value to 

identify and disrupt unknown 

threats to homeland security

7. Number of hours charged to VSP-related activities

8. Number of interviews conductedb

9. Number of applications that included coordination with the host government

10. Number of recommended visa refusals due to an applicant’s nexus to terrorism

11. Number of applications that resulted in at least one nomination or record enhancement to the 

Terrorist Identities Datamart Environment (TIDE)c

III. Increase the U.S. 

government’s capacity to 

address threats

12. Number of applicants that had a nexus to terrorism

13. Number of trainings conducted by VSP agents for consular officers

14. Number of recommendations of no objection, with information to the consular officerd

15. Number of investigations opened

16. Number of investigation reports developed and approved

17. Number of applications for which VSP agents developed an intelligence report

18. Number of applications for which VSP agents coordinated with other, non-U.S. Immigration 

and Customs Enforcement (ICE) personnel at post

19. Number of applications for which ICE coordinated with domestic agencies, including ICE 

domestic field offices

Source: GAO analysis of information from ICE. I GAO-18-314

Note: According to ICE officials, certain performance measures can be associated with multiple 

objectives. For example, ICE officials stated that the number of investigations opened, and number of 

investigative reports developed help to assess its second and third program objectives.

a

According to ICE, a VSP agent may recommend a visa revocation when new derogatory information 

is uncovered that would render the applicant ineligible for the issued visa. This may occur when new 

information is made available post-vetting. Under 8 U.S.C. § 1201(i), a consular officer or the 

Secretary of State may at any time, in his or her discretion, revoke a visa.

b

This performance measure includes the number of visa applications for which ICE has either 

conducted an interview of an applicant or requested that consular officers collect additional 

information during their interview with the applicant.

c

The National Counterterrorism Center’s TIDE includes information on known or suspected 

international terrorists.

d

VSP agents may provide information to the consular officer, which could be helpful to the consular 

officer’s adjudication, but itself does not render the applicant inadmissible to the United States.

With the introduction of PATRIOT, ICE has taken steps to track more 

program data related to its activities. For example, since July 2016, ICE 

has reported to Congress annually on data associated with five of its

measures—(1) number of applications screened, (2) number of 
Page 26 GAO-18-314 Border Security

applications vetted, (3) number of applications identified with derogatory 

information, (4) number of recommended visa refusals, and (5) number of 

nominations or record enhancements to TIDE.43 Further, ICE officials told 

us that they produce performance reports, or dashboards, to monitor 

performance program-wide. For example, in fiscal year 2016, ICE began 

developing program-wide dashboards for VSP data across ten of its 

performance measures. In fiscal year 2017, ICE began creating VSP 

post-specific performance reports, or placemats, which include data for 

eight of the measures.44 ICE officials responsible for managing VSP 

stated that they use these dashboards to inform ICE leadership about the 

program’s activities on a quarterly basis.

While these are positive steps, ICE has not developed and implemented 

outcome-based performance measures to assess the extent to which the 

program is achieving its stated objectives. Specifically, VSP’s 19 

performance measures and program dashboards generally measure the 

program’s outputs—or activity levels—rather than outcomes associated 

with the results of VSP’s activities. ICE officials stated that measuring 

outcomes for VSP is difficult because many of the program’s benefits are 

qualitative in nature. For example, officials stated that it is difficult to 

measure the outcomes of the investigations they opened as a result of 

VSP screening and vetting or its coordination and information sharing 

with other law enforcement agencies on visa applicants. We recognize 

that developing outcome-based performance measures can be 

challenging. However, solely tracking increases or decreases in program 

data, such as number of recommended refusals, does not allow ICE to 

fully evaluate VSP because such changes in the data may not be an 

indicator of program success or increased efficacy. For example, ICE 

tracks the number of applications that resulted in at least one nomination 

or record enhancement to TIDE. As the National Counterterrorism Center 

may not accept all nominations or enhancements, a better measure of the 

 43As previously stated, VSP separately measures the number of applications that resulted 

in at least one nomination or record enhancement to TIDE. However, ICE reports its total 

number of nominations and record enhancements to TIDE as watch list nominations in its 

annual report to the Congress. The Secretary of Homeland Security is required to report to 

the Congress annually on the basis of any determinations that the assignment of a DHS 

employee at a particular post would not promote homeland security. See 6 U.S.C. § 

236(e)(4). In 2014, a DHS OIG report recommended that ICE include its performance 

measure data in these annual reports. See OIG-14-137.

44As of August 2017, ICE had created a post-level dashboard for one VSP post, but ICE 

officials stated that they plan to do so for all VSP posts in fiscal year 2018.
Page 27 GAO-18-314 Border Security

outcome of this activity would instead be the percentage of VSP 

nominations or record enhancements to TIDE that were accepted.

Further, ICE measures the success of the program by tracking the 

number of visa applications that VSP agents have recommended 

consular officers refuse, but not the outcomes of those recommendations, 

which would better demonstrate the extent to which the program is 

achieving its objectives. For example, not all recommended refusals 

result in a visa being refused. First, some of the applications ICE screens 

and vets are never adjudicated by consular officers if, for example, 

applicants did not pay their application fee or appear for an interview. As 

previously mentioned, ICE data indicates that VSP screened and 

recommended refusal for 8,096 applications in fiscal year 2016; State 

data for that time period indicate that 942 (or 12 percent) of these 

applications were not adjudicated as of August 2017. Second, some of 

the applications for which VSP agents recommend refusal eventually 

result in an issued visa because, for example, the applicants may receive 

a waiver from DHS or on the basis of VSP agents’ consultations with 

consular officers.45 State data for fiscal year 2016 indicates that, of the 

8,096 applications for which a VSP agent recommended refusal, 1,204 

applications (or 15 percent) resulted in an issued visa with a DHS waiver, 

and 740 applications (or 9 percent) resulted in an issued visa based on 

VSP agents’ consultation with consular officers. Finally, according to 

State officials, many applications for which a VSP agent recommends 

refusal may also coincide with findings of derogatory information from one 

of State’s other security check systems, and the consular officers’

refusals may be based on a combination of the VSP agent’s 

recommendation as well as these other findings. Therefore, although the 

number of recommended refusals may be important for the program to 

collect, such data does not fully demonstrate the program’s outcomes.

 45The INA contains provisions that may allow an inadmissible nonimmigrant visa applicant 

to apply for a waiver of certain grounds of inadmissibility. See 8 U.S.C. § 1182(d)(3). DHS 

adjudicates all such waiver applications. Waivers are discretionary, meaning that even if 

the applicant satisfies any threshold requirements to waive inadmissibility set by DHS, 

approval need not occur. If the waiver is approved, the applicant can be issued a visa, 

provided that it appears to the consular officer that the applicant is otherwise eligible to 

receive a visa in light of the inadmissibility waiver. For nonimmigrant visa waivers, the 

Secretary of State or consular officer must first recommend to DHS that the applicant be 

admitted temporarily despite his or her inadmissibility. Further, per State policy, consular 

officers can issue a visa even if the VSP agent has recommended that they refuse the 

visa. In such cases, consular officers are to consult with the VSP agent.
Page 28 GAO-18-314 Border Security

We have previously reported that performance measurement should 

evaluate both processes and outcomes related to the program activities

and that outcome-based performance information should be used for 

decision-making in a results-oriented management system. According to 

our Program Evaluation Guide, it is important to select outcome-based 

performance measures that clearly represent the nature of the expected 

program benefit, cover key aspects of desired performance, and are not 

unduly influenced by factors outside the program’s control.46 Moreover, 

consistent with the GPRA Modernization Act of 2010, performance 

measurement is the ongoing monitoring and reporting of program 

accomplishments, particularly towards pre-established goals, and 

agencies are to establish performance measures to assess progress 

towards goals.47 Although it is appropriate to measure some outputs to 

manage programs, outcome-based measures are also necessary to 

address the results of the program’s activities and can help in assessing 

the status of program operations, identifying areas that need 

improvement, and ensuring accountability for end results. Developing and 

implementing a system of outcome-based performance measures for 

VSP would help ensure that the program is effective and achieving its 

intended objectives.

 46GAO-12-208G. 

47GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005); also, 

GAO-11-646SP.
Page 29 GAO-18-314 Border Security

ICE has generally expanded VSP to new posts by deploying VSP agents 

overseas. However, ICE has also implemented VSP remotely in some 

locations—that is, in these locations, ICE did not assign agents to these 

posts and is instead conducting VSP screening, vetting, and investigative 

activities from another (i.e., remote) location. Since fiscal year 2012, ICE 

has expanded VSP to 13 new posts with at least one deployed agent in 

each location, and closed one post, as shown in figure 5. According to 

ICE officials, ICE did not expand to new posts in fiscal years 2012 and 

2014 due to budget constraints, and closed one VSP office in 2015.

ICE’s Site Selection 

Process for VSP 

Expansion Does Not 

Incorporate 

Information That 

Could Better Inform 

Resource Allocation

ICE Has Expanded VSP to 

Some Posts by Assigning 

Agents Abroad and To 

Others With Remote 

Operations
Page 30 GAO-18-314 Border Security

Figure 4: Status of Visa Security Program (VSP) Expansion, Calendar Year 2003 through September 2017

Note: The figure excludes locations where U.S. Immigration and Customs Enforcement (ICE) has not 

assigned a dedicated VSP agent abroad. One VSP office was closed in 2006 due to security 

concerns and later reopened in 2011. ICE closed another VSP office in 2015 when the embassy 

suspended all consular services. ICE also provided visa screening and vetting services at an 

additional post from 2010 through September 2014, however, according to ICE officials, it was not 

considered a VSP post because it did not participate in Department of State visa interviews.

ICE also expanded VSP to some locations using remote operations. In 

2014, ICE closed its office at one post—which included both VSP and 

non-VSP ICE agents—due in part to budget constraints, according to ICE 

officials. To maintain VSP operations for visa applications for that 

location, ICE continued VSP operations from a different, remote location. 

In addition, in September 2015, ICE initiated remote VSP operations at 

another post by requiring VSP agents at an existing VSP location to also 

vet applicants from this new post. A VSP agent who is responsible for 

conducting the remote VSP operations stated that this additional 

workload is relatively low, but there are relatively high hit and 

recommended refusals rates. For example, whereas the hit rate and 

recommended refusal rate across all VSP posts in fiscal year 2016 were 

2.91 percent and 0.37 percent, respectively, the hit rate and 
Page 31 GAO-18-314 Border Security

recommended refusal rate for applications at this remote location were

6.08 percent and 3.05 percent, respectively.

Although ICE considers a range of information to determine how to 

expand VSP to additional posts, ICE does not incorporate PATRIOT data 

on posts it is considering for expansion into its site selection process, 

which could better inform the identification of high-priority posts and future 

resource needs. On an annual basis, ICE officials select desired posts for 

VSP expansion using a multi-step process—(1) risk-based evaluation, (2) 

capability assessment, and (3) threat and intelligence analysis (see figure 

5).48 Specifically, the risk-based evaluation analyzes several data points, 

including the number of matches of visa applicant information to the 

TSDB, percentage of third-country nationals applying for visas at a 

particular post, and the number of ICE’s open national security 

investigative cases in that country.49 This evaluation results in an annual, 

ranked list of the highest-risk posts, which ICE subsequently uses to 

complete the remaining steps of the annual site selection process.

Figure 5: U.S. Immigration and Customs Enforcement (ICE) Annual Site Selection 

Process for Visa Security Program (VSP) Expansion

Although ICE officials stated that they have generally followed this 

approach when selecting desired locations for expansion, they cited 

several challenges that ICE has faced in trying to expand to posts that are 

 48ICE officials have updated VSP’s site selection process at various points during the 

program’s existence, including in 2007, 2012, and most recently, in 2017, when they 

updated the risk-based evaluation to include new data sources. As of July 2017, ICE 

officials stated that the most recent update to the site selection methodology was in draft 

form, but had been used to inform expansion to two new locations in 2017. 

49Third-country nationals are those who apply for a visa at a post outside of their country 

of nationality.

ICE’s Process for 

Selecting Sites for VSP 

Expansion Does Not 

Incorporate PATRIOT Data 

Describing Resource 

Needs
Page 32 GAO-18-314 Border Security

ranked higher on its annual risk-based list. For example, ICE 

documentation cited lack of physical space at some posts, and delays in 

approval from State to send VSP staff to post as barriers to expansion.50

Further, ICE has expanded VSP to posts that were not among the highest 

ranked on the annual risk-based list developed during the first phase of 

the site selection process. For example, 1 of the 5 posts to which VSP 

expanded in fiscal year 2015 was among the top 30 posts on that year’s 

list of posts with the highest risk, and 4 were not.51 ICE officials stated 

that the program chose the other 4 posts based on various factors. For 

example, officials stated that the 5 posts were prioritized, in part, because 

they had an existing ICE presence.52 ICE documentation shows 3 of the 

posts as vulnerable or emerging areas of interest based on threat 

reporting or intelligence analysis, and the fourth new post was critical for 

U.S. counterterrorism activities.

When identifying posts for future VSP expansion, ICE officials stated that 

they consider PATRIOT data for staffing determinations, but do not utilize 

PATRIOT as a data source to understand the potential workload for posts 

under consideration during its annual site selection process. Although ICE 

officials stated that they look at historical PATRIOT data during the site 

selection process, ICE does not use PATRIOT to determine the volume of 

potential hits to derogatory information from visa applications at posts 

under consideration for expansion. ICE officials generally identified three 

reasons they do not use PATRIOT data during the VSP site selection 

process:

• ICE officials stated that, in absence of further manual review, 

PATRIOT data are not a good indicator of the risk or threat of 

terrorism. ICE officials explained that other data ICE uses in its risk 

analysis better identify counterterrorism concerns, including visa 

applicant matches to TSDB records. However, PATRIOT screens 

applicants against a broad spectrum of potential visa ineligibilities that 

 50National Security Decision Directive 38 (June 2, 1982) gives State’s chiefs of mission, 

typically the ambassador, authority to approve all changes to the size, composition, and 

mandate of staff assigned to overseas posts.

51For fiscal year 2015 expansion, ICE’s prioritized list for expansion was country-based 

and not visa-issuing post-based. 

52In September 2014, DHS OIG recommended that ICE continue to evaluate the feasibility 

of making all ICE overseas offices responsible for conducting visa security operations. 

OIG-14-137.
Page 33 GAO-18-314 Border Security

are not captured by such data sources, including prior immigration 

violations and criminal activities.

• ICE officials also stated that PATRIOT data includes false matches—

that is, an initial hit that analysts later determine is not associated with 

the visa applicant. However, even if hits are ultimately determined to 

be false matches, the number and percentage of hits is directly 

related to the workload for both VSP’s U.S.-based analysts and 

agents abroad because U.S.-based analysts must vet each 

application with a hit to determine if the applicant matches to any 

derogatory information, and VSP agents abroad must make 

recommendations to consular officers based on such matches.

• ICE officials explained that the program does not collect PATRIOT 

data on the number of hits at non-VSP posts because they believe 

ICE officials would be responsible for taking actions on any of the 

derogatory information that the system identifies, even during an 

exploratory or research exercise. For example, if the program 

implemented PATRIOT for a trial period at a post to which the 

program was considering expanding, ICE officials stated that they 

believe VSP would be responsible, during the trial period, to fully vet 

any applications that showed a potential match to derogatory 

information. Because the program would not have the analytical 

resources to analyze the PATRIOT data, nor yet have a VSP agent 

deployed to that post for action, any derogatory information uncovered 

by automated screening could not be vetted, according to ICE 

officials.

However, ICE officials have previously utilized PATRIOT to gather 

data to estimate program capacity without requiring that U.S.-based 

analysts and VSP agents vet the hits. For example, ICE conducted a 

systems test of automated PATRIOT screening in September 2013 to 

determine whether PATRIOT is capable of screening applications 

from all visa-issuing posts worldwide by implementing PATRIOT for a 

24-hour period without any further vetting or investigation on potential 

matches. Further, although such hits may not be vetted by VSP 

agents, applications with derogatory information exist regardless of 

whether PATRIOT screens and identifies them, and State consular 

officers are ultimately responsible for adjudicating visa applications, 

including where derogatory information may exist. ICE officials further 

stated that historical data may not provide a reasonable estimate 

because each post is unique and circumstances may vary each year. 

However, ICE officials told us that they have previously looked at 

historical PATRIOT data, such as during the site selection process.
Page 34 GAO-18-314 Border Security

Our prior work on results-oriented management has found that datadriven decision making leads to better results in setting program 

priorities and making human capital decisions.53 In addition, 

Standards for Internal Control in the Federal Government states that 

management should obtain and use relevant data to inform 

decisions.54 For VSP, such relevant data can also include information 

that would help management identify the highest priority posts for 

future program expansion. Further, OMB guidance states that 

agencies considering program expansion should conduct analyses 

that include, among other things, methods for quantifying costs, 

including an understanding of staffing needs.55 To that end, valid and 

reliable data are critical to assessing risk and an agency’s workforce 

requirements. Because PATRIOT data is a direct indicator of a broad 

spectrum of potential visa ineligibilities encountered at a post, as well 

as potential VSP agent workload, using such data to help make

expansion decisions would help position ICE to more effectively 

manage human capital and other resources.

ICE has implemented remote VSP operations in some posts and 

conducted a pilot in 2016 to evaluate the future expansion of remote 

operations, but has not considered such models during its annual site 

selection process. In February 2016, ICE implemented a 3-month pilot 

program at three posts to evaluate the effectiveness of remote operations 

for future VSP expansion. During the pilot, the PATRIOT system 

automatically screened, and U.S.-based analysts manually vetted, visa 

applications to the pilot posts. Then, a U.S.-based VSP agent made

recommendations to consular officers in these posts instead of having an 

agent being physically located at post. In the absence of an agent at post, 

the U.S.-based analysts and VSP agent coordinated with other officials at 

post—specifically, the ICE attaché at the first post, the ARSO-I at the 

second post, and consular officers at the third post—to obtain additional 

information on the applicant to verify whether the applicant is a match to 

derogatory information, or to refer potential investigative leads to other 

U.S. government agencies. According to officials, following the 3-month 

pilot, VSP continued remote operations at the second post, in 

 53For example, see GAO-14-747.

54GAO-14-704G.

55OMB, Circular A-94 (Revised 1992).

ICE Has Not Considered 

Opportunities for Remote 

Models as Part of Its 

Annual Site Selection 

Process for VSP 

Expansion
Page 35 GAO-18-314 Border Security

collaboration with the ARSO-I at that location; converted the office at the 

first post into a typical VSP post by deploying a VSP agent to that 

location; and ended all VSP operations at the third post.

After the pilot, ICE concluded that it could successfully screen and vet 

applicants remotely through VSP at certain posts, but that the pilot posts 

“failed to achieve VSP’s optimal effectiveness as an investigative 

counterterrorism tool.” According to ICE’s evaluation report, the pilot 

showed that remote operations could be sustainable under certain 

conditions, such as locations with a relatively low workload. Nonetheless, 

ICE concluded that the pilot posts were unable to fully achieve what the 

report characterized as the VSP’s core mission “to identify, investigate, 

and disrupt the travel of illicit actors” because, without a dedicated agent 

at post, the program could not investigate visa applicants, if necessary, or 

provide additional information on terrorist and criminal networks to other 

U.S. government agencies, if such information was developed during their 

screening and vetting processes.

However, ICE’s evaluation of the pilot program had weaknesses, and 

some of its conclusions were not well-supported. First, ICE did not 

evaluate how other factors may have affected performance during the 

pilot. For example, according to the U.S.-based VSP agent that provided 

recommendations to consular officers during the pilot, the consular 

section at the third post was understaffed during the course of the pilot, 

which made it difficult for them to provide robust responses to requests 

for information needed to complete VSP vetting. Second, the evaluation 

report noted that preparation prior to initiating VSP operations at the pilot 

posts was not sufficient. Specifically, the report noted that all three pilot 

sites expressed that preparation prior to the commencement of the pilot 

had not been sufficient. However, in evaluating the pilot’s performance, 

ICE did not consider how insufficient preparation may have impacted 

performance. Lastly, some of ICE’s conclusions about the performance of 

pilot posts were not supported with sufficient evidence, particularly when 

the outcomes of the pilot are compared to the performance of existing 

VSP posts. ICE concluded that pilot posts were unable to fully achieve 

VSP’s investigative mission in part because the posts did not initiate any 

standalone HSI investigations or generate any intelligence reports on the 

basis of its screening and vetting operations during the 3-month pilot. 

However, ICE data for fiscal year 2016 indicate that most VSP posts that 

were operational the full fiscal year (19 of 24) did not generate any 

intelligence reports. Further, although all VSP posts that were operational 

the full fiscal year opened at least one investigation in fiscal year 2016, 

and some posts opened more than 10, but about half of the VSP posts 
Page 36 GAO-18-314 Border Security

(11 of 24) opened three or fewer investigations during the course of the 

whole fiscal year.

DHS and State officials we interviewed identified potential opportunities to 

expand VSP using remote operations. Specifically, VSP agents at 3 of the 

7 posts we visited expressed interest in remote screening and vetting 

options for other posts in their country or area of responsibility, similar to 

the regional VSP model ICE has already employed. For example, the 

VSP agent at one post said that a full-time agent at his post could 

potentially cover the VSP workload associated with two additional visaissuing posts in that country. The VSP agent at a different post indicated 

that his post could cover another post in the region because he already 

coordinates with consular staff and other officials at the post on other 

non-VSP-related ICE investigations. Both agents indicated that they could 

coordinate with the consular sections at those posts. For example, VSP 

agents could schedule in-person interviews with applicants that exhibit 

the most investigative potential, but could also refer investigations to 

other officials at post, such as the FBI legal attaché or State ARSO-I, if 

necessary. Further, officials from State’s Bureau of Diplomatic Security—

which manages the ARSO-Is—stated that they would support expanding 

VSP’s remote operations using ARSO-Is already located at post. As of 

December 2016, ARSO-Is were serving at 107 posts—83 of these posts 

are not in VSP. Further, 8 of the 83 posts are listed among the top 30 

posts on the VSP’s risk-based ranked list for posts for fiscal year 2017 

expansion.

ICE officials stated that their site selection methodology does not include 

remote models because the officials’ preferred model of operations is to 

deploy agents to posts overseas. However, remote operations can meet 

other important parts of the program’s mission, such as reviewing visa 

applications and providing recommendations to consular officers. As 

previously noted, DHS has been directed to continue to plan and budget 

for VSP expansion to at least two high-threat locations per year.56

Standards for Internal Control in the Federal Government states that 

program officials should balance the allocation of resources in relation to 

the areas of greatest risk, complexity, or other factors relevant to 

achieving the entity’s objectives.57 Further, OMB guidance for making 

program expansion decisions indicates that agencies should evaluate 

 56See 163 Cong. Rec. at H3811; 161 Cong. Rec. at H10168.

57GAO-14-704G.
Page 37 GAO-18-314 Border Security

cost-effectiveness in a manner that presents facts and supporting details 

among competing alternatives, including relative costs, benefits, and 

performance tradeoffs.58 It should consider all possible alternatives 

without bias toward its preferred solution by presenting facts and 

supporting details for each alternative.59 By incorporating remote models 

of VSP operations in the program’s site selection process, ICE could 

identify opportunities to better utilize finite resources while still addressing 

the congressional directive to expand VSP.

Since 2003, ICE has implemented VSP at certain U.S. embassies and 

consulates to strengthen the security of the visa process and increase the 

U.S. government’s capacity to address threats to homeland security. The 

implementation of PATRIOT in fiscal year 2014 enhanced the program by 

allowing ICE to automatically screen 100 percent of nonimmigrant visa 

applications submitted to VSP posts against U.S. holdings of derogatory 

information prior to the consular officers’ adjudication on the applications. 

However, not all VSP posts have met ICE’s training requirements. 

Ensuring that VSP agents develop and provide training on threats, as 

required, would help provide consular officers with additional information 

that could assist them in conducting visa adjudications. In addition, ICE 

collects output-based data on its activities such as the number of 

applications screened and recommended refusals. However, establishing 

outcome-based performance measures would help inform management 

how much a program is accomplishing and whether its activities are 

meeting the program’s mission. Lastly, VSP has expanded from 3 posts 

in 2003 to 32 posts in 2017, and the program is to expand further in 

accordance with congressional directive, but in planning the expansion of 

the program ICE does not fully incorporate data and models that can 

better inform resource allocation. By including PATRIOT data and remote 

VSP operations among the potential models for program expansion, ICE 

would be better positioned to evaluate expansion options to better ensure 

the efficient use of program resources.

 58OMB, Circular A-94 (Revised 1992).

59GAO-09-3SP.

Conclusions
Page 38 GAO-18-314 Border Security

We are making the following four recommendations to ICE:

The Director of ICE should ensure that trainings provided by VSP agents 

to consular officers are developed and implemented with required 

frequency and content. (Recommendation 1)

The Director of ICE should develop and implement outcome-based 

performance measures to evaluate the effectiveness of the VSP and 

assess whether the program is achieving its objectives. 

(Recommendation 2)

The Director of ICE should incorporate PATRIOT data into the VSP’s site 

selection process for the posts it is considering for expansion. 

(Recommendation 3)

The Director of ICE should incorporate remote models of VSP operations 

in the program’s site selection process. (Recommendation 4)

We provided a draft of this report to DHS, State, and the Department of 

Justice, as well as the Office of the Director of National Intelligence, for 

their review and comment. DHS provided written comments, which are 

reproduced in full in appendix II. DHS, State, and the Department of 

Justice provided technical comments, which we incorporated as 

appropriate. In an email, a Legislative Liaison Officer from the Office of 

the Director of National Intelligence stated that the agency did not have 

any comments on our draft report.

DHS concurred with all four of our recommendations. Regarding our 

recommendation that ICE develop and implement outcome-based 

performance measures to evaluate the effectiveness of the VSP, ICE 

stated that it did not agree with our assessment that none of VSP’s 19 

established performance measures are outcome-based, and that the 

agency would continue to utilize some of the measures, such as 

applications screened, number of trainings conducted by VSP agents for 

consular officers, and number of investigations opened, as important 

performance measures. As we stated in this report, it is appropriate to 

measure some output-related data such as these to manage a program; 

however, solely tracking increases or decreases in program outputs does 

not allow ICE to fully evaluate VSP because such changes in the data 

may not be an indicator of program performance. Performance 

measurement should evaluate both processes and outcomes related to 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 39 GAO-18-314 Border Security

the program activities and outcome-based performance information 

should be used for decision-making in a results-oriented management 

system. Developing and implementing a system of outcome-based 

performance measures would better inform management on whether 

VSP’s activities are meeting the program’s objectives.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until seven days from the 

report date. At that time, we will send copies to the Secretaries of 

Homeland Security and State; the Attorney General of the United States; 

and the Director of National Intelligence. In addition, the report will be 

available at no charge on the GAO website at http://gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-8777 or gamblerr@gao.gov. Key contributors to this 

report are listed in appendix V.

Rebecca Gambler

Director, Homeland Security and Justice
Page 40 GAO-18-314 Border Security

List of Requesters

The Honorable Ron Johnson

Chairman

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Charles E. Grassley

Chairman

Committee on the Judiciary

United States Senate

The Honorable Bennie Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

The Honorable Martha McSally

Chairwoman

Subcommittee on Border and Maritime Security

Committee on Homeland Security

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-18-314 Border Security

This report examines the extent to which: (1) the Visa Security Program 

(VSP) contributes to the visa adjudication process, (2) U.S. Immigration 

and Customs Enforcement (ICE) has developed and implemented a 

system to assess VSP performance, and (3) ICE has identified and 

evaluated options to expand VSP to additional posts.1

To determine the extent to which VSP has contributed to the visa 

adjudication process, we reviewed program documentation, memoranda 

of understanding (MOU), standard operating procedures, and relevant 

legislation, such as the Homeland Security Act of 2002 and Immigration 

and Nationality Act (INA), and interviewed ICE and Department of State 

(State) headquarters officials on VSP operations. Further, we analyzed 

ICE data for each VSP post for fiscal years 2014—the year the PreAdjudicated Threat Recognition Intelligence Operations Team (PATRIOT) 

was implemented—through 2016—the most recently available full year 

data on the results of VSP operations. To assess the reliability of these 

data, we interviewed ICE officials who use and maintain the data; 

observed VSP agents input data during our site visits; reviewed data 

system documentation; and checked the data for missing information, 

outliers, and obvious errors. On the basis of our reporting objectives, we 

found the data sufficiently reliable for the purposes of this report, including 

providing summary statistics on VSP operations.

 1

Unless otherwise noted, this report is generally focused on nonimmigrant visas, which 

are those issued to foreign nationals seeking temporary admission into the United States 

under a specific nonimmigrant category (8 U.S.C. § 1101(a)(15); 8 C.F.R. § 214.1(a)(1)-

(2)), for an authorized period of stay delineated by a particular timeframe or duration-ofstatus (i.e., admission for duration of a specific program or activity, which may be 

variable). Nonimmigrant visa holders include tourists, business visitors, or students, 

among others. Immigrant visas are issued to eligible “immigrants” (foreign nationals who 

do not fall within one of the classes of nonimmigrants) seeking lawful permanent resident 

status in the United States with a path to citizenship. See 8 U.S.C. § 1101(a)(16). Certain 

nonimmigrants—for example, recipients of K visas for the fiancé(e) or spouse of a U.S. 

citizen or their children, and T and U visas for victims of severe forms of trafficking in 

persons or other qualifying crimes—are also eligible for lawful permanent residence, 

provided they satisfy the applicable statutory criteria. This report does not address 

individuals who are allowed to seek admission to the United States without a visa, such as 

citizens of Canada and the British Overseas Territory of Bermuda (and certain residents of 

other adjacent islands, such as the Bahamas) under certain circumstances, as well as 

Visa Waiver Program participants. The Visa Waiver Program allows nationals from certain 

countries to apply for admission to the United States as temporary visitors for business or 

pleasure without first obtaining a visa from a U.S. embassy or consulate abroad. See 8 

U.S.C. § 1187; 8 C.F.R. §§ 212.1, 214.6(d), 217.1-217.7; 22 C.F.R. §§ 41.0-41.3.

Appendix I: Objectives, Scope, and 

Methodology

Objectives

Scope and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-18-314 Border Security

We conducted site visits to seven VSP posts to observe VSP operations 

and interview ICE and consular officials on VSP. We selected these posts 

on the basis of their relatively high visa workloads; ICE data on the 

percentage of applicants that potentially matched to derogatory 

information in fiscal year 2016; and geographic distribution to help 

account for variations in visa applicant pools and potential threats that 

VSP agents encounter in different locations. Our observations from these 

site visits are illustrative and provide insights about VSP operations, but 

are not generalizable to all 29 VSP posts. Similarly, we also observed 

domestic-based ICE and U.S. Customs and Border Protection analysts 

that conduct manual vetting as part of PATRIOT.

We administered a survey to VSP agents at all 29 VSP posts to gather 

information and insights from VSP agents on PATRIOT and the VSP, 

among other things. We administered a separate survey to consular 

managers, who oversee the consular officers that adjudicate visas and 

coordinate with the VSP agents, to gather information and insights on 

PATRIOT and the VSP. For the purpose of this review, we surveyed 

posts at which VSP agents have been deployed as of January 2017. We 

also included one post, which has a dedicated agent conducting remote 

VSP operations from a non-VSP post. We did not include other posts that 

used remote operations in our survey because these posts did not have a 

dedicated VSP agent who could complete the survey. We conducted 

pretests prior to administering the survey to check that (1) the questions 

were clear and unambiguous, (2) terminology was used correctly, (3) the 

questionnaire did not place an undue burden on agency officials, (4) the 

information could feasibly be obtained, and (5) the survey was 

comprehensive and unbiased. Pretests were conducted with VSP agents 

and consular managers in two locations. We administered these 

instruments from March through May 2017 in person at the seven posts 

we visited, and by email to the remaining 22 posts. We had a 100 percent 

response rate for both instruments.

To determine the extent to which DHS has developed and implemented a 

system to assess VSP performance, we gathered information on VSP 

performance measurement practices and reviewed DHS reports and 

plans, including ICE’s annual reports to Congress on VSP for fiscal years 

2012 through 2016, DHS annual performance reports for fiscal years 

2011 through 2016, and the ICE Strategic Plan for fiscal year 2016 

through 2020.2 We also reviewed our prior work and DHS Office of 

 2

See 6 U.S.C. § 236(e)(4).
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-18-314 Border Security

Inspector General reports on VSP’s performance management.3 We 

analyzed relevant information in light of principles outlined in the 

Government Performance and Results Act (GPRA) Modernization Act of 

2010, and best practices for performance management.4

We also gathered documentation from State to better understand other 

potential data on the outcomes of visa applications that were reviewed by 

VSP agents. At our request, State analyzed fiscal year 2016 visa data on 

the 7,154 refusal recommendations made by VSP agents.5 For example, 

State officials reviewed visa records to determine the number of these 

applications that were eventually issued, either with a DHS waiver or in 

consultation with VSP agents.6 Although we did not conduct this analysis, 

we took steps to ensure that State’s analysis was reliable. We reviewed 

descriptions of State’s methodology, checked the data for missing 

information and obvious errors, and interviewed officials who conducted 

the analysis. On the basis of the steps we took, we found the analysis 

sufficiently reliable for the purpose of identifying general outcomes for the 

applications for which VSP agents recommended refusal in fiscal year 

2016.

 3

For example, see GAO, Border Security: DHS’s Visa Security Program Needs to Improve 

Performance Evaluation and Better Address Visa Risk Worldwide, GAO-11-315 

(Washington, D.C.: Mar. 31, 2011), and DHS’ Office of Inspector General, The DHS Visa 

Security Program, OIG-14-137 (Washington, D.C.: Sept. 10, 2014).

4

GPRA Modernization Act of 2010 (GPRAMA), Pub. L. No. 111-352, 124 Stat. 3866 

(2011) (updating GPRA of 1993, Pub. L. No. 103-62, 107 Stat. 285). In particular, see 

GPRAMA § 3, 124 Stat. at 3867-71 (codified at 31 U.S.C. § 1115) (relating to agency 

performance plans and performance measurement). For best practices for performance 

management, see GAO, Designing Evaluations: 2012 Revision, GAO-12-208G 

(Washington, D.C.: Jan. 31, 2012); Performance Measurement and Evaluation: Definitions 

and Relationships, GAO-11-646SP (Washington, D.C.: May 2, 2011).

5

According to State data, in addition to 7,154 recommended refusals, 9 visa applications 

had not yet been adjudicated as of August 2017.

6

The INA contains provisions that may allow an inadmissible nonimmigrant visa applicant 

to apply for a waiver of certain grounds of inadmissibility. See 8 U.S.C. § 1182(d)(3). DHS 

adjudicates all such waiver applications. Waivers are discretionary, meaning that even if 

the applicant satisfies any threshold requirements to waive inadmissibility set by DHS, 

approval need not occur. If the waiver is approved, the applicant can be issued a visa, 

provided that it appears to the consular officer that the applicant is otherwise eligible to 

receive a visa in light of the inadmissibility waiver. For nonimmigrant visa waivers, the 

Secretary of State or consular officer must first recommend to DHS that the applicant be 

admitted temporarily despite his or her inadmissibility. Further, per State policy, consular 

officers can issue a visa even if the VSP agent has recommended that they refuse the 

visa. In such cases, consular officers are to consult with the VSP agent.
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-18-314 Border Security

To determine the extent to which DHS identified and evaluated options to 

expand VSP to additional posts, we obtained information from ICE on 

VSP’s expansion to new posts since 2003, such as start dates and 

staffing levels. We also reviewed information on the extent to which ICE 

has assessed the potential to expand the VSP using remote operations—

that is, by using U.S.- or other non-on site VSP agents to review visa 

applications and conduct other VSP-related activities. For example, we 

reviewed ICE’s evaluation of its 2016 pilot on remote VSP operations, 

interviewed ICE and State officials that participated in the pilot, and 

analyzed performance data from the pilot posts. We reviewed ICE’s 

methodology for site selection, which it updated in 2017 for future years’

site selection, including lists of post that were prioritized for future 

expansion. We also reviewed prior methodologies that ICE used to 

expand the program from 2007 through fiscal year 2017. We also 

interviewed ICE officials involved with remote VSP operations at two 

posts to gather insights on their experiences with VSP operations. We 

assessed these methodologies against internal control standards, best 

practices for making resource allocation decisions and estimating cost, 

and Office of Management and Budget (OMB) guidance for making 

program expansion decisions.7

The performance audit upon which this report is based was conducted 

from November 2016 through December 2017 in accordance with 

generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on 

our audit objectives. We subsequently worked with DHS and State from 

December 2017 to March 2018 to prepare this unclassified version of the 

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

prepared in accordance with these standards.

 7

GAO-14-704G; GAO Cost Estimating and Assessment Guide: Best Practices for 

Developing and Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: 

March 2009).Also see OMB, OMB Circular No. A-94, Guidelines and Discount Rates for 

Benefit-Cost Analysis of Federal Programs (Washington, D.C.: Oct. 29, 1992). OMB 

Circular A-94 provides guidance for any analysis used to support government decisions to 

initiate, renew, or expand programs or projects that would result in measurable benefits or 

costs extending for three or more years into the future.
Appendix II: Comments from the Department 

of Homeland Security

Page 45 GAO-18-314 Border Security

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department 

of Homeland Security

Page 46 GAO-18-314 Border Security
Appendix III: Results of Screening and Vetting 

at Visa Security Posts, Fiscal Year 2016

Page 47 GAO-18-314 Border Security

In fiscal year 2016, U.S. Immigration and Customs Enforcement (ICE), a 

component within the Department of Homeland Security (DHS), deployed 

Visa Security Program (VSP) agents to 29 U.S. embassies or consulates 

to screen and vet visa applicants, among other responsibilities. In 

addition, VSP agents vetted applicants for two posts, including the post 

where they are deployed and another post remotely. VSP agents review 

visa applications and make recommendations to Department of State 

consular officers that adjudicate the visas. VSP agents’ recommendations 

will either note that DHS (1) has no objection to the visa being issued 

(green light), (2) has no objection to the visa being issued, but has 

information that may be of interest to consular officers (green light with 

comments), or (3) recommends the consular officer refuse the visa (red 

light). The percentage of applications with a potential match to derogatory 

information—known as hits—across all VSP posts was 2.91 percent. 

Further, 99.18 percent of applications received a green light, 0.45 percent 

received a green light with comments, and 0.37 percent received a red 

light.

As show in table 4, the percentage of hits to potential derogatory 

information and recommended refusals varied among VSP posts. The 

percentage of hits varied widely among VSP posts, ranging from over 13 

percent to less than 1 percent in fiscal year 2016. ICE officials stated that 

post-specific circumstances explain some of the variation in the 

percentage of hits. Recommended refusal rates also varied among VSP 

posts, from less than 0.01 percent to more than 1.00 percent across VSP 

posts in fiscal year 2016.

Appendix III: Results of Screening and 

Vetting at Visa Security Posts, Fiscal Year 

2016
Appendix III: Results of Screening and Vetting 

at Visa Security Posts, Fiscal Year 2016

Page 48 GAO-18-314 Border Security

Table 4: Results of Visa Security Program (VSP) Screening and Vetting Efforts at VSP Posts, Fiscal Year 2016

Post Applications 

screened

Percent of 

applications 

vetteda

VSP recommendation

(percent of applications screened)

No objection No objection with 

informationb Recommend refusal

1 54,204 4.57 99.42 0.25 0.33

2 59,757 6.22 98.45 0.89 0.66

3c 607 2.80 99.18 0.00 0.82

4 86,661 0.40 99.85 0.08 0.07

5d 10,293 6.08 95.03 1.92 3.05

6 15,373 2.02 98.94 0.66 0.40

7 88,796 4.69 99.34 0.41 0.25

8d 351,837 1.45 99.46 0.33 0.21

9 27,487 3.23 99.69 0.23 0.08

10 12,699 1.76 99.17 0.31 0.52

11 36,390 6.74 98.90 0.38 0.73

12 122,906 4.18 99.19 0.48 0.33

13 58,192 1.61 99.06 0.60 0.34

14 97,666 0.79 99.72 0.14 0.15

15 80,319 13.10 98.68 0.84 0.49

16 67,917 1.10 99.66 0.21 0.13

17 60,322 6.11 98.82 0.55 0.63

18 37,696 4.12 98.19 0.79 1.02

19c 1,749 1.43 99.49 0.51 0.00

20 177,557 3.19 97.96 0.88 1.16

21 46,622 3.08 98.35 1.16 0.48

22 264,858 0.88 99.69 0.19 0.12

23 26,513 3.59 98.08 1.47 0.45

24b 605 4.30 99.83 0.17 0.00
Appendix III: Results of Screening and Vetting 

at Visa Security Posts, Fiscal Year 2016

Page 49 GAO-18-314 Border Security

Post Applications 

screened

Percent of 

applications 

vetteda

VSP recommendation

(percent of applications screened)

No objection No objection with 

informationb Recommend refusal

25 44,111 1.76 99.39 0.34 0.27

26c 56,250 1.64 99.06 0.62 0.32

27 91,315 6.43 99.22 0.40 0.39

28 16,679 2.56 98.57 0.98 0.45

29 187,719 0.70 99.61 0.21 0.18

30e n/a n/a n/a n/a n/a

Source: GAO analysis of U.S. Immigration and Customs Enforcement data. I GAO-18-314

Note: The location of each post has been substituted with a number because DHS has deemed the 

locations of VSP posts to be sensitive. The numbers for the VSP locations in this table do not 

correlate to the numbers in any other table in this report. Percentages may not add to 100 percent 

due to rounding. Not all of the applicants that ICE screens and vets will eventually appear for an 

interview and have their visa adjudicated by a consular officer. For example, ICE data indicates that 

the Pre-Adjudicated Threat Recognition Intelligence Operations Team (PATRIOT) screened 

2,183,100 applications in fiscal year 2016 and State data for that time period indicate that consular 

officers adjudicated 1,625,601 applications at VSP posts. Fiscal year 2016 data do not include a post 

that was part of a 3-month remote operations pilot beginning in February 2016, and continues to 

screen and vet visa applicants as of September 2017. According to ICE officials, they do not consider 

this post to be a VSP post because the program has not formally decided whether to continue remote 

operations at this location as of September 2017. However, ICE did provide data for another post, 

which also participated in the pilot, because this post later converted into a typical VSP post with VSP 

agents deployed abroad.

a

We also refer to this as the hit rate. For fiscal year 2016, ICE defined applications vetted as the 

number of applications that identified a hit to derogatory information, all of which are to be vetted by 

VSP analysts.

b

In cases where the agent determines that there is no admissibility or ineligibility, the agent may 

provide information uncovered by VSP screening and vetting process to potentially help the consular 

officer make his or her adjudication decision.

c

VSP operations at these posts were initiated in September 2016, and screening and vetting data for 

these posts do not represent a full fiscal year.

d

VSP operations for these posts are conducted remotely.

e

According to ICE officials, PATRIOT was activated for this post on the afternoon of September 30, 

2016, but did not return any screening or vetting results until the following day, October 1, 2016, 

which is the first day of fiscal year 2017. Therefore, there are no screening and vetting results for that 

post in fiscal year 2016.
Appendix IV: Work Hours at Visa Security 

Posts, Fiscal Year 2016

Page 50 GAO-18-314 Border Security

In fiscal year 2016, U.S. Immigration and Customs Enforcement (ICE), a 

component within the Department of Homeland Security (DHS), deployed 

Visa Security Program (VSP) agents to 29 U.S. embassies or consulates. 

In addition to screening, vetting, and training responsibilities, VSP agents 

and local staff spend portions of their work hours on ICE investigative 

activities not directly related to consular matters. VSP-funded staff, which 

includes VSP agents and local staff funded by VSP, dedicated 

approximately 57 percent of their work hours to VSP activities on 

average, and the remainder to non-VSP activities, according to ICE’s 

fiscal year 2016 staff hours data.1 As shown in table 5, the percentage of 

staff hours dedicated to VSP activities varied among posts, ranging from 

less than 15 percent to more than 90 percent. For example, 9 of the 24 

posts that were operational the full fiscal year dedicated less than 50 

percent of staff hours to VSP activities.

Table 5: Fiscal Year 2016 Work Hours Recorded by Visa Security Program (VSP)-Funded Staff

Post Total work 

hours

Percent of work hours dedicated 

to VSP activities

Percent of work hours dedicated 

to non-VSP activities

1 7,821 69 31

2 9,966 81 19

3 4,620 29 71

4 3,648 37 63

5 5,687 67 33

6a 9,719 11 89

7 4,126 43 57

8 3,785 53 47

9 4,340 80 20

10 7,908 91 9

11 4,084 67 33

12 4,848 14 86

13 12,483 70 30

14 6,967 42 58

15 3,994 94 6

16 7,297 76 24

 1

This figure does not does not include work hours data for the five posts that initiated VSP 

operations in September 2016 because these posts were operational only one month of 

the fiscal year. During this month, VSP funded staff at these posts generally recorded 

more than 90 percent of their work hours as non-VSP activities.

Appendix IV: Work Hours at Visa Security 

Posts, Fiscal Year 2016
Appendix IV: Work Hours at Visa Security 

Posts, Fiscal Year 2016

Page 51 GAO-18-314 Border Security

Post Total work 

hours

Percent of work hours dedicated 

to VSP activities

Percent of work hours dedicated 

to non-VSP activities

17b 8,868 43 57

18 6,843 59 41

19 10,960 30 70

20 3,736 38 63

21 4,359 85 15

22 12,765 55 45

23 2,309 83 17

24 4,874 78 22

Source: GAO analysis of U.S. Immigration and Customs Enforcement data. I GAO-18-314

Note: The location of each post has been substituted with a number because DHS has deemed the 

locations of VSP posts to be sensitive. The numbers for the VSP locations in this table do not 

correlate to the numbers in any other table in this report. Percentages may not add to 100 percent 

due to rounding. This table does not include work hours data for the five posts that initiated VSP 

operations in September 2016 because these posts were operational only one month or less of the 

fiscal year. During this month, VSP funded staff at these posts generally recorded more than 90 

percent of their work hours as non-VSP activities.

a

VSP operations at this post are conducted by VSP agents at another post.

b

VSP staff at this post also conduct VSP operations for another post.
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 52 GAO-18-314 Border Security

Rebecca Gambler, (202) 512-8777 or gamblerr@gao.gov

In addition to the contact named above, Kathryn Bernet (Assistant 

Director), Colleen Corcoran, Eric Hauswirth, Thomas Lombardi, Amanda 

Miller, Sasan J. “Jon” Najmi, Erin O’Brien, Garrett Riba, Dina Shorafa, 

and Adam Vogt made significant contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgements

(102473)
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