Report to Congressional Committees

United States Government Accountability Office

GAO

October 2004 HOMELAND 

SECURITY 

Management 

Challenges Remain in 

Transforming 

Immigration Programs

GAO-05-81 
www.gao.gov/cgi-bin/getrpt?GAO-05-81.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Richard M. 

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

Highlights of GAO-05-81, a report to 

congressional committees 

October 2004

HOMELAND SECURITY

Management Challenges Remain in 

Transforming Immigration Programs 

The Department of Homeland 

Security (DHS) assumed 

responsibility for the immigration 

enforcement and services 

programs of the former 

Immigration and Naturalization 

Service (INS) in 2003. The three 

DHS bureaus with primary 

responsibility for immigration 

functions are U.S. Customs and 

Border Protection (CBP), U.S. 

Citizenship and Immigration 

Services (CIS), and U.S. 

Immigration and Customs 

Enforcement (ICE). This transfer 

creates a great opportunity for DHS to 

address long-standing management 

and operational problems within INS. 

The Homeland Security Act 

requires GAO to review the transfer 

of immigration functions to DHS. In 

response, this report assesses the 

status of (1) communication and 

coordination of roles and 

responsibilities, (2) integration of 

immigration and customs 

investigators in ICE, and 

(3) administrative services and 

systems in CBP, CIS, and ICE. 

GAO recommends that DHS use 

key practices to create a 

mechanism for periodically 

obtaining and considering 

employee feedback on their ideas 

and concerns and provides specific 

guidance on roles and 

responsibilities and administrative 

services. DHS commented on a 

draft of this report and generally 

agreed with our findings and 

recommendations. 

Most of the field officials with whom GAO spoke generally characterized 

communication and coordination with other DHS immigration programs in 

their geographic area as good or excellent. Other officials noted, that in 

some areas related to investigative techniques and other operations, 

unresolved issues regarding the roles and responsibilities of CBP, CIS, and 

ICE give rise to disagreements and confusion, with the potential for serious 

consequences. According to headquarters and field officials, some guidance 

has been made available to the field, and there are plans to provide more. 

Most ICE field officials GAO contacted said they have taken initial steps 

toward integrating the former immigration and customs investigators, such 

as establishing cross-training and pay parity. Most of these officials said, 

however, that additional important steps remained to be completed to fully 

integrate investigators. They reported that the lack of uniform policies and 

procedures for some ICE operations has caused confusion and hindered the 

creation of a new integrated culture. Headquarters officials said they were 

responding to these challenges. 

Officials in CBP, CIS, and ICE expressed confusion about a new shared 

services system for mission support when interviewed 3 to 4 months after 

the system was instituted. They also expressed frustration with problems 

they have encountered with travel, budget, and payroll systems, which are 

not a part of the shared services system. Additionally, the realignment of 

staff for shared services, along with other events, has resulted in some 

mission staff being assigned administrative work as a collateral duty, which 

may affect mission productivity. 

Key practices used by other public and private organizations that have 

undergone successful mergers and transformations may be helpful to DHS in 

addressing the challenges raised in this report and in transforming 

immigration enforcement and services. These key practices include 

establishing communication strategies to create shared expectations and 

involving employees to gain ownership for changes. 

Reorganization of INS into DHS 
Page i GAO-05-81 Homeland Security 

Letter 1

Results in Brief 3 

Background 7 

Communication and Coordination Generally Considered Good or 

Excellent by Program Officials, yet Some Cite a Need for Clearer 

Guidance on Roles and Responsibilities 12 

Some Steps Taken and Some Steps Remain to be Completed in 

Integrating Immigration and Customs Investigators into ICE 21 

Many Officials Expressed Difficulty Understanding Administrative 

Services 28 

Key Practices for Successful Mergers and Transformations 38 

Conclusions 41 

Recommendations 42 

Agency Comments 43 

Appendix I Objectives, Scope, and Methodology 46 

Appendix II Comments from the Department of Homeland 

Security 49 

Appendix III GAO Contacts and Staff Acknowledgments 56 

GAO Contacts 56 

Staff Acknowledgments 56 

Tables 

Table 1: Summary of Interview Responses by ICE’s SACs and 

ASACs Regarding Communication and Coordination with 

CBP, CIS, and other ICE Programs 13 

Figures 

Figure 1: Immigration Programs in DHS 10 

Figure 2: Division of CBP, CIS, and ICE Roles Under DHS’s Shared 

Services 30 

Contents 
Page ii GAO-05-81 Homeland Security 

Figure 3: Key Practices for Successful Mergers and Organizational 

Transformations 39 

Abbreviations 

ASAC associate special agent in charge 

CBP U.S. Customs and Border Protection 

CIS U.S. Citizenship and Immigration Services 

COSS Customs Overtime Scheduling System 

DHS Department of Homeland Security 

FBI Federal Bureau of Investigation 

FFMS Federal Financial Management System 

FLETC Federal Law Enforcement Training Center 

ICE U.S. Immigration and Customs Enforcement 

INS Immigration and Naturalization Service 

RAC resident agent in charge 

SAC special agent in charge 

TECS Treasury Enforcement Communications System 

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reproduce this material separately. 
Page 1 GAO-05-81 Homeland Security 

October 14, 2004 

Congressional Committees 

The Homeland Security Act of 2002 established the Department of 

Homeland Security (DHS) and led to the most substantial reorganization 

of the federal government since the 1940s.1

 The duties and responsibilities 

of several former agencies were transferred to DHS, including 

responsibility for immigration enforcement and services. These functions 

were transferred from the Immigration and Naturalization Service (INS), 

which was abolished in 2003. Transfer of the immigration functions 

creates a great opportunity for DHS to successfully address long-standing 

management and operational problems within INS that we have reported 

over the years. 

Our past work on transformations has shown that it is unrealistic to 

expect DHS to have fully resolved these difficult and long-standing 

problems after just one and a half years in operation. As we have 

reported,2

 successful organizational transformations can take 5 to 7 years 

to implement, and the three DHS bureaus with primary responsibility for 

immigration functions—U.S. Customs and Border Protection (CBP), U.S. 

Citizenship and Immigration Services (CIS), and U.S. Immigration and 

Customs Enforcement (ICE)—are in the process of transformation as they 

develop new ways of dealing with each other and managing their 

performance. We have also reported that in the short term, the experience 

of private sector mergers is that productivity and effectiveness, for 

example, decline as attention is concentrated on critical and immediate 

issues. Given the gravity of DHS’s mission, a focus on critical and 

immediate issues is understandable. Nevertheless, because any failure by 

DHS to effectively carry out its mission could expose the nation to very 

serious consequences, it is important that DHS start immediately to take 

advantage of its unique opportunity to transform immigration management 

and program operations and provide the immigration enforcement and 

services that the American people need. 

 1

P.L. 107-296 (2002). 

2

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

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

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-81 Homeland Security 

The Homeland Security Act requires us to review the transfer of functions 

from INS to DHS, and identify issues associated with the transition.3

 This 

report is intended to satisfy the requirements of the mandate. To help 

formulate the objectives to respond to this mandate, we spoke with 

immigration experts in the public and private sectors and representatives 

of pro- and anti-immigration advocacy groups in the Washington, D.C., 

area, and reviewed prior reports that we and others have issued. From 

these efforts, we identified three issues that, early in the transition, 

appeared to represent significant management challenges and that we 

believed related to a range of mission and mission support activities. Thus, 

this report assesses the status of (1) communication and coordination 

among immigration programs in DHS, (2) integration of immigration and 

customs investigators in ICE, and (3) administrative services and systems 

used following the transition into DHS. We did not assess program 

performance or DHS’s overall response to long-standing problems in this 

review. Additionally, our analysis was based on a snapshot in time, 

primarily during the first half of fiscal year 2004, and it is possible our 

results may be different if our interviews were conducted today. 

In assessing the integration of immigration and customs investigators in 

ICE, we briefly discuss the former U.S. Customs Service (Customs), which 

transferred from the Department of the Treasury. Customs was 

responsible for enforcing customs laws in regulating legitimate 

commercial activity and for safeguarding U.S. borders against the illegal 

entry of goods. Before September 11, 2001, Customs’ enforcement 

activities focused primarily on preventing the smuggling of drugs into the 

United States. 

To address the objectives, we reviewed laws; CBP, CIS, and ICE transition 

documents; policies; and other relevant documents. We also interviewed 

officials at headquarters who were responsible for managing ICE’s 

detention and removal, intelligence, and investigations programs; CIS’s 

adjudications program; and CBP’s Border Patrol and inspections programs 

between September 2003 and August 2004. We interviewed ICE, CIS, and 

CBP officials responsible for developing plans for the transition in 

September 2003. We interviewed officials in CBP, CIS, and ICE field 

offices between December 2003 and March 2004 in the following cities: 

Arlington, Virginia; Baltimore, Maryland; New York, New York; Miami, 

Florida; Detroit, Michigan; and San Diego, California, and with the U.S. 

 3

P.L. 107-296, Sec. 477(d)(1). 
Page 3 GAO-05-81 Homeland Security 

Border Patrol field offices in Miami, Detroit, and San Diego. We selected 

these locations because of their geographic dispersion, their proximity to 

major ports of entry, and the relative proximity of ICE, CBP, and CIS 

offices to one another. In these locations, we talked with officials 

responsible for inspections, the Border Patrol, and inspectors in CBP; 

officials responsible for adjudications and adjudicators in CIS; and 

managers, supervisory investigators, and investigators in ICE. Baltimore 

and Arlington were used as preliminary site visits to form our interview 

questions. In the remaining four cities and all remaining ICE field offices, 

we used a structured interview to obtain information and opinions 

relevant to our objectives from the two most senior ICE officials.4

 In total, 

this meant interviewing 49 SACs and ASACs in ICE’s field offices. Many of 

these officials provided specific examples to help explain their arguments, 

which we did not verify. 

We conducted our review between August 2003 and August 2004 in 

accordance with generally accepted government auditing standards. A 

more detailed discussion of our scope and methodology appears in 

appendix I. 

Most of the field officials in the CBP, CIS, and ICE offices with whom we 

spoke generally characterized communication and coordination with other 

DHS immigration programs in their geographic area as good or excellent. 

They attributed their positive views mainly to working relationships that 

existed before the transition of INS to DHS—particularly with inspections 

(in CBP), adjudications (in CIS), and detention and removal (in ICE). 

While CBP, CIS, and ICE headquarters offices have issued guidance on the 

various programs’ roles and responsibilities, some field officials in all 

three bureaus said they would like additional guidance to provide a clearer 

understanding of such roles and responsibilities. Officials noted that in 

some cases, unresolved disagreements and confusion regarding the roles 

and responsibilities of the DHS immigration bureaus related to various 

investigative techniques and other operational issues has the potential for 

serious consequences. As one example, field officials told us that 

 4

Special agents in charge (commonly referred to as SACs) are law enforcement officers 

responsible for directing ICE investigation operations and resources in a specific 

geographic area. SACs are the most senior managers in the field offices of ICE’s 

investigations program. Associate special agents in charge (commonly referred to as 

ASACs) are the second most senior managers in the field offices of ICE’s investigations 

program. During our review the title ASAC was changed to deputy special agent in charge. 

Results in Brief 
Page 4 GAO-05-81 Homeland Security 

conflicting positions by ICE and the Border Patrol over an investigative 

technique known as controlled deliveries has hampered communication 

and coordination and can not only hinder the accomplishment of ICE’s 

mission but potentially put ICE investigators at risk.5

 According to 

headquarters and field officials, there are plans to issue more guidance on 

operational roles and responsibilities. Specifically, CBP and ICE plan to 

issue more guidance clarifying the roles and responsibilities of Border 

Patrol agents and investigators (in such areas as investigative techniques 

used in border operations, asset forfeiture, and information sharing), 

although they could not provide a specific date when the guidance would 

be issued to the field. 

Top officials in ICE’s special agent in charge (SAC) offices said that, 

although they had taken initial steps toward integrating the former 

immigration and customs investigative workforces at the time of our 

review, additional important steps remained to be completed at many 

offices to fully integrate investigators. The initial steps most SACs said 

their offices have taken include (1) assigning investigators from the former 

INS and Customs offices to work in new investigative groups that are in 

the same physical location, (2) providing classroom-based cross-training 

and on-the-job–training so former INS investigators know the laws and 

perform the functions of legacy Customs investigators and vice versa; and 

(3) resolving the pay disparity between former INS and Customs 

investigators. However, many of these officials reported that the 

continuation of former INS and Customs investigators working in separate 

locations has been an obstacle to integration. A headquarters official told 

us that ICE has begun to co-locate some SAC offices and that other offices 

would be co-located as existing leases expire. ICE officials currently 

estimate that it would cost $150 million to co-locate all SAC offices 

immediately. Field officials also reported that the lack of uniform policies 

and procedures for some ICE operations has caused confusion and 

hindered the creation of a new integrated culture. ICE headquarters 

officials told us that they are prioritizing the establishment of uniform 

policies and that until a new ICE policy is established, SAC offices are 

required to use the policies of the former agencies. In addition, many field 

officials said that the lack of unique public identifiers such as badges, 

credentials, and uniforms has held up creation of a unified ICE agency and 

 5

Controlled delivery is an ICE investigative method that involves allowing a known group 

of illegal aliens or contraband to enter the country so they can be followed to their 

destination and arrested by ICE investigators. 
Page 5 GAO-05-81 Homeland Security 

caused frustration and embarrassment. In August 2004, ICE headquarters 

officials confirmed there had been a delay in issuing symbols such as 

badges and raid jackets and that such symbols were either already 

available or were in the final stages of development. 

In an attempt to provide more efficient administrative mission support 

services, DHS is in the process of developing and implementing systems 

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

a shared service system in which certain mission support services—such 

as human resources—are provided by one bureau to the other bureaus. 

Certain mission support services were not incorporated into the shared 

services system. Officials in CBP, CIS, and ICE expressed confusion about 

shared services when we interviewed them 3 to 4 months after the system 

was instituted. Many field officials said they did not know what constitutes 

shared services, what processes they should use for receiving assistance 

from a shared service provider, or how many of their staff administrative 

positions would be reassigned to positions in other offices as shared 

service providers. DHS headquarters officials acknowledged in June 2004 

(6 months after the initiation of shared services) that although a 

communication strategy was in place, communicating information about 

shared services was a “work in progress” and that it was the responsibility 

of the individual bureaus (both those providing and those receiving 

services) to communicate to their field staff about how the shared services 

process worked. CBP, CIS, and ICE officials also expressed frustration 

with problems they have encountered with travel, budget, and payroll—

which are administrative systems managed within the agencies and not a 

part of shared services. At least in part because of problems with funding 

codes in the travel software, some ICE staff have waited for months to be 

reimbursed for government travel. Some ICE field officials also expressed 

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

because of the systems used for these functions. Some mission staff in 

CBP, CIS, and ICE field offices also told us that inspectors, investigators, 

and adjudicators have been assigned administrative functions full-time or 

as a collateral duty because (1) some administrative staff from their office 

were reassigned to other offices to serve as shared service providers, 

(2) the increase in staff because of mergers in inspections and 

investigations and, (3) hiring freezes. One effect of assigning mission staff 

to administrative work is that because they are not spending all of their 

time on duties needed to accomplish the program’s mission, they are not 

reaching the full potential of the program position. 

Carrying out this transformation will not be an easy or quickly realized 

task, so it is understandable that challenges have arisen. In July 2003, to 
Page 6 GAO-05-81 Homeland Security 

help agencies like DHS in such transformations, we reported on nine key 

practices that have been found at the center of successful mergers and 

transformations.6

 While all nine key practices are important in this 

transformation, we believe two would be particularly helpful to DHS in 

addressing the longstanding and new challenges identified in this report 

relating to the transformation of immigration programs in DHS: 

(1) establishing a communication strategy to create shared expectations 

and report related progress and (2) involving employees to obtain their 

ideas and gain their ownership of the transformation. While we did not 

assess in this review the degree to which these practices are being used, 

we did identify certain parts of the key practices that have not been fully 

integrated into immigration strategies, such as establishing a feedback 

mechanism to identify and address employee concerns. 

To help DHS address the challenges to the overall transformation of 

immigration programs, we recommend that the Secretary of Homeland 

Security help ensure that all parts of the key practices we identified are 

used to address the new and pre-existing challenges related to 

immigration enforcement and services. In particular, DHS should create a 

mechanism to periodically obtain employee feedback, clarify roles and 

responsibilities for field staff in the three bureaus with immigration 

responsibilities, and provide additional detailed guidance on processes 

and procedures to follow for the provision of shared administrative 

services. 

We provided a draft of this report to DHS for comment. In its response, 

DHS generally agreed with our overall findings and recommendations and 

requested that we add more context in some areas, such as the 

department’s communication and employee feedback efforts. We discuss 

some of these efforts in the relevant portions of this report but note that 

many of these efforts were ongoing at the time the concerns were raised 

during our fieldwork. DHS also said that our fieldwork coincided with the 

implementation of the shared services initiative and, as such, it did not 

believe the field managers views expressed in this report accurately 

portray the initiative or the current level of comprehension of the 

initiative. While things change over time, we believe that the views 

expressed at the time of our interviews indicate a need in the field for 

 6

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

Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003). 
Page 7 GAO-05-81 Homeland Security 

additional detailed guidance on the shared administrative services 

initiative. 

The primary mission of DHS is, among other things, to prevent terrorist 

attacks within the United States in the aftermath of the September 11, 

2001, attacks on the World Trade Center and the Pentagon. The creation of 

DHS brought together 22 agencies with responsibility for securing the 

borders and coastal waters, transportation sector, ports, and critical 

infrastructure (such as telecommunications systems), among other things. 

In addition, DHS consolidated some nonsecurity agencies such as the 

Federal Emergency Management Agency’s natural disaster response 

functions and maritime safety and drug interdiction by the Coast Guard. 

The creation of DHS was also intended to coordinate the sharing of 

homeland security information and foster closer coordination with federal 

agencies that were not incorporated into DHS, such as the Federal Bureau 

of Investigation (FBI) and the Department of State. 

Under INS, and now within DHS, immigration enforcement and service are 

complex, multifaceted functions. Immigration enforcement includes, 

among other things, patrolling 8,000 miles of international boundaries to 

prevent illegal entry into the United States; inspecting over 500 million 

travelers each year to determine their admissibility; apprehending, 

detaining, and removing criminal and illegal aliens; disrupting and 

dismantling organized smuggling of humans and contraband as well as 

human trafficking; investigating and prosecuting those who engage in 

benefit and document fraud; and enforcing compliance with programs 

such as the Student and Exchange Visitor Information System (SEVIS) and 

the United States Visitor and Immigrant Status Indication Technology (USVISIT). Immigration service includes providing services or benefits to 

facilitate entry, residence, employment, and naturalization of legal 

immigrants; processing millions of applications each year; making the 

right adjudicative decision in approving or denying the applications; and 

rendering decisions in a timely manner. 

Some background about the long-standing management problems at INS is 

useful to set the stage for the transformation task DHS inherited. In this 

respect, over the years, we have written numerous reports that identified 

management challenges INS experienced in its efforts to achieve both 

effective immigration law enforcement and service delivery. In assuming 

the responsibility for immigration enforcement and services, DHS inherits 

Background 
Page 8 GAO-05-81 Homeland Security 

many of these management challenges. For example, in 1997 we reported 

that INS lacked clearly defined priorities and goals and that its 

organizational structure was fragmented both programmatically and 

geographically. Additionally, after a reorganization in 1994, field managers 

still had difficulty determining whom to coordinate with, when to 

coordinate, and how to communicate with one another because they were 

unclear about headquarters offices’ responsibilities and authority. We also 

reported that INS had not adequately defined the roles of its two key 

enforcement programs—Border Patrol and investigations—which resulted 

in overlapping responsibilities, inconsistent program implementation, and 

ineffective use of resources. INS’s poor communication led to weaknesses 

in policies and procedures. In later reports, we reported that broader 

management challenges affected efforts to implement programs to control 

the border, deter alien smuggling, reduce immigration benefit fraud, 

reduce unauthorized alien employment, remove criminal aliens, and 

manage the immigration benefit application workload and reduce the 

backlog.7

INS was abolished, effective in 2003, by the Homeland Security Act of 

2002,8

 and its functions were transferred to three agencies within the 

Department of Homeland Security. INS’s Immigration Services Division, 

responsible for processing applications for immigration benefits, was 

placed in CIS, which reports directly to the Deputy Secretary of DHS. INS’s 

interior enforcement programs—investigations, intelligence, and detention 

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

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

merged into the investigations and intelligence offices, while staff from 

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

 7

GAO, INS’s Southwest Border Strategy: Resource and Impact Issues Remain after Seven 

Years, GAO-01-842 (Washington, D.C.: August 2, 2001); GAO, Alien Smuggling: 

Management and Operational Improvements Needed to Address Growing Problem, 

GAO/GGD-00-103 (Washington, D.C.: May 1, 2000); GAO; GAO, Immigration Benefit 

Fraud: Focused Approach Is Needed to Address Problems, GAO-02-66 (Washington, D.C.: 

January 31, 2002); GAO, Immigration Enforcement: Challenges to Implementing the INS 

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

Criminal Aliens: INS’ Efforts to Identify and Remove Imprisoned Aliens Need to be 

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

INS’s Efforts to Identify and Remove Imprisoned Aliens Continue to Need Improvement, 

GAO/T-GGD-99-47 (Washington, D.C.: Feb., 25, 1999); GAO, Immigration Benefits: Several 

Factors Impede Timeliness of Application Processing, GAO-01-488 (Washington, D.C.: 

May 4, 2001). 

8

P.L. 107-296, Sec. 471(a). 
Page 9 GAO-05-81 Homeland Security 

and removal office. CBP incorporated inspectors from former INS, 

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

former INS’s Border Patrol agents. CBP and ICE both report to the 

Undersecretary for Border and Transportation Security, who in turn 

reports to the Deputy Secretary of the DHS. See figure 1 for the 

organizational position of immigration programs in DHS. 
Page 10 GAO-05-81 Homeland Security 

Figure 1: Immigration Programs in DHS 

Information Analysis 

and Infrastructure

Development Directorate

Border and 

Transportation 

Security Directorate

Transportation 

Security 

Administration

U.S. Customs and 

Border Protection

(CBP)

Federal Law 

Enforcement Training 

Center

Office for

Domestic 

Preparedness

U.S. Immigration

and Customs 

Enforcement (ICE)

Emergency 

Preparedness and 

Response Directorate

Science and 

Technology 

Directorate

Management

Directorate

Coast

Guard

Secret

Service

Office for State

and Local 

Government 

Coordinator

Office of

International

Affairs

Special Liaison

for Private

Sector

 U.S. Citizenship and 

Immigration Service (CIS)

Shared services

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

Immigration and Naturalization Service (INS)

Services Investigations, Intelligence,

Detention and Removal

Inspections

and Border Patrol

Deputy Secretary

Department of Homeland Security 

(Secretary)

Under CIS

in DHS

Under CBP

in DHS

Under ICE

in DHS

Former agency

New department
Page 11 GAO-05-81 Homeland Security 

CBP, CIS, and ICE each have a separate chain of command and field 

structure. Under former INS, there were 33 district offices, each headed by 

a district director, who had responsibility for adjudications, detention and 

removal, inspections, intelligence, and investigations. In DHS, the 

responsibilities of the 33 district offices under the former INS were 

distributed among 33 CIS district offices, 27 Special Agent in Charge 

investigations field offices, 22 detention and removal field offices, 20 CBP 

offices for field operations (that oversee about 300 land, sea, and air ports 

of entry), and 6 field intelligence units. The former INS’s 20 border patrol 

sectors remained intact.9

CBP brought together INS and Customs inspections programs that, prior 

to the transition, largely worked side by side in many land ports of entry 

around the country and that shared similar missions. CIS was a direct 

transfer of the Immigration Services Division within INS, and the program 

remained largely intact. In contrast, ICE is a patchwork of agencies and 

programs that includes INS’s investigations and intelligence programs, 

Customs’ investigations and intelligence programs, Customs’ air and 

marine interdiction division, the Federal Protective Service, and the 

Federal Air Marshals. In combining the investigations programs, ICE has 

been tasked with merging INS investigators who specialized in 

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

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

integration of INS and Customs investigators into a single investigative 

program has involved blending of two vastly different workforces, each 

with its own culture, policies, procedures, and mission priorities. Both 

programs were in agencies with dual missions that prior to the merger had 

differences in investigative priorities. For example, INS primarily looked 

for illegal aliens and Customs primarily looked for illegal drugs. In 

addition, INS investigators typically pursued administrative violations, 

while Customs investigators typically pursued criminal violations. 

 9

In addition to the 33 district offices, CIS also runs four Service Centers, three regional 

offices, eight asylum offices, and a number of application support centers, and sub-offices. 

The SAC offices also have subordinate and smaller Resident Agent in Charge (RAC) offices 

that report to them. Each of the 20 Border Patrol sectors has subsector stations within its 

geographical area. 
Page 12 GAO-05-81 Homeland Security 

Most field officials with whom we spoke in CBP, CIS, and ICE 

characterized communication and coordination with their local 

counterparts as good or excellent. Officials also said that positive 

relationships were primarily based on previous working relationships built 

while the programs— particularly inspections, detention and removal, and 

adjudications—were all within one agency, INS or Customs. About a 

quarter of the officials we interviewed across the immigration programs in 

CBP, CIS, and ICE also said that they would like a clearer understanding 

of the roles and responsibilities of each program. Those ICE officials who 

characterized communication and coordination as fair to poor attributed 

the inability to resolve their problems to various reasons, depending on 

the program; these included a lack of communication or conflicts in roles 

with the Border Patrol and the intelligence program’s distance from, and 

production of useful work for, the SAC offices. Near the end of our work, 

some headquarters and field officials in CBP, CIS, and ICE told us efforts 

were under way, and agreed upon, to clarify issues related to roles and 

responsibilities that have arisen. 

Communication among CBP, CIS, and ICE occurs at the headquarters and 

field level in different ways. All three bureaus have liaisons at the 

headquarters level. For example, ICE has liaisons to CBP and CIS that 

serve as points of contact and facilitators in convening the appropriate 

officials for discussions on cross-cutting issues, and ICE’s liaisons are to 

contact those agencies’ liaisons should ICE initiate discussions. In the 

field, officials in CBP, CIS, and ICE said they typically used meetings to 

maintain contact with one another, although the frequency of meetings 

varied—from not at all to bimonthly—and there are no requirements for 

field officials to meet regularly. Officials who said that they met regularly 

also said that they found these meetings to be useful in sharing 

information and addressing issues that cut across programs. 

Overall, most field officials we contacted who responded to this question 

in CBP, CIS, and ICE characterized communication and coordination 

among their programs as good or excellent. Most SACs and ASACs said 

that communication and coordination with CBP’s inspections, CIS’s 

adjudications, and ICE’s detention and removal programs were good or 

excellent. On the other hand, about one-third of SACs and ASACs who 

responded to this question believed that communication and coordination 

with CBP’s Border Patrol and ICE’s intelligence programs were fair to 

poor. Some officials said they expressed this view concerning 

communication and coordination with the Border Patrol because there 

were conflicts or overlaps in roles and responsibilities or a lack of 

Communication and 

Coordination 

Generally Considered 

Good or Excellent by 

Program Officials, yet 

Some Cite a Need for 

Clearer Guidance on 

Roles and 

Responsibilities 

Most Officials Reported 

Positive Communication 

and Coordination among 

Programs 
Page 13 GAO-05-81 Homeland Security 

communication. SACs and ASACs who characterized communication and 

coordination with ICE’s intelligence program as fair or poor said they did 

so for such reasons as the intelligence office was not in close proximity to 

the SAC office or they did not feel that intelligence analysts were 

producing analyses useful to the SAC office. Table 1 presents the 

responses by ICE’s SACs and ASACs regarding communication and 

coordination with CBP, CIS, and other ICE programs. 

Table 1: Summary of Interview Responses by ICE’s SACs and ASACs Regarding Communication and Coordination with CBP, 

CIS, and other ICE Programs 

 Communication between ICE field offices and 

Rating CBP: Border Patrol CBP: Inspections

CIS: 

Adjudications

ICE: Detention and 

removal ICE: Intelligence

Good or 

excellent 21 (70%) 41 (91%) 36 (88%) 35 (83%) 28 (68%)

Fair or poor 9 (30%) 4 (9%) 5 (12%) 7 (17%) 13 (32%)

Total 30 (100%) 45 (100%) 41 (100%) 42 (100%) 41 (100%)

Source: GAO survey. 

Note: Data are based on 40 telephone interviews and 9 face-to-face interviews with SACs and 

ASACs. We did not include responses from the 2 SACs and 2 ASACs in the Baltimore and Arlington 

SAC offices, as our interviews with them were preliminary and the questions were not close ended. 

The total number of SAC and ASAC interview responses varies for several reasons: (1) One SAC 

office had two ASACs; (2) we did not interview one SAC who was new to his position; and we did not 

interview an ASAC who was also new to his position. Additionally, the total responses for each 

category varied because not all SACs and ASACs responded to all of our questions. 

Many SACs and ASACs indicated that their positive views of 

communication and coordination with staff from other programs were 

primarily based on previous working relationships built while the 

programs were all in INS or Customs. In addition, officials we contacted in 

CIS and CBP, and other officials in ICE, said that they also relied on 

working relationships that existed before the transfer to facilitate 

communication and coordination on cross-cutting issues. Those SACs and 

ASACs who responded that they relied to a little or no extent on preexisting working relationships said that they provided such a response 

because they did not have a prior relationship to rely upon. In addition, 

such informal means of maintaining communication and coordination 

among program officials, while helpful, can be short-lived as personnel 

retire or resign. For the long term, processes that provide a systematic way 

of building and maintaining such relationships among program staff 

provide better assurance of effective communication and coordination. 

Providing guidance that outlines roles and responsibilities among the 

programs is one way of helping to achieve systematic maintenance of such 
Page 14 GAO-05-81 Homeland Security 

relationships. In this respect, the headquarters offices for CBP, CIS, and 

ICE have issued some guidance on roles and responsibilities of certain 

aspects of the immigration programs. For example, 

• CBP and ICE issued general guidelines on each bureau’s roles and 

responsibilities regarding how they would transfer the assets of 

antismuggling investigators from the Border Patrol to ICE, and how they 

would handle antismuggling investigations after the transfer of these 

investigators to ICE. A memorandum jointly issued by CBP and ICE in 

April 2004 for SACs and Border Patrol sector chiefs in field locations 

outlined each program’s basic responsibilities. ICE would assume 

responsibility for administrative support; funding of the antismuggling 

investigators; and all investigations and complex cases such as 

international in nature or related to organizations or national security. The 

Border Patrol would have lead responsibility for cross-border and borderrelated interdiction activities, such as surveillance to interdict illegal 

border crossings. According to CBP officials, the intent of the 

memorandum was in part to provide each program with a basic 

framework for working together. 

• CBP and CIS convened a working group to decide who would correct 

mistakes on aliens’ arrival and departure forms. Several advocacy groups 

argued in the months following the transfer that as a result of the dispersal 

of immigration programs across DHS agencies, aliens entering the country 

did not know who to go to if an error was made on their arrival/departure 

form. The two bureaus agreed that an alien must seek an official in CBP to 

correct a CBP mistake, and a CIS official to correct a CIS mistake. 

Additionally, CBP and CIS agreed that if an alien seeking a correction 

inquires at the wrong office, then that person is to be directed to the 

appropriate authorities for making the correction. CBP and CIS officials 

provided us with this policy in written memos dated March 31, 2004, and 

March 30, 2004, respectively, that they said each bureau provided to its 

staff. 

• CIS issued guidance to its field offices in December 2003 stating that its 

Office of Fraud Detection and National Security is to serve as the focal 

point and clearinghouse for requests from law enforcement agencies for 

benefits or “cover” documents.10 The guidance outlined the procedures 

that CIS is to use in responding to law enforcement agencies outside DHS 

 10“Cover” immigration documents are those used by law enforcement confidential 

informants or cooperating witnesses, for example, in furtherance of a particular 

investigation or intelligence collection effort. These documents are not actual benefits. 
Page 15 GAO-05-81 Homeland Security 

(for example, the FBI and Drug Enforcement Agency) that want to provide 

benefits for aliens they have brought into the country as witnesses in a 

criminal case or as informants. 

Notwithstanding the above guidance, some officials we contacted across 

CBP, CIS, and ICE said that they would like a clearer understanding of the 

roles and responsibilities of each program. In addition, some difficulties 

with coordination cannot be resolved locally or by pre-existing working 

relationships because they reflect a lack of clarity in the programs’ roles 

and responsibilities and impede communication and coordination between 

them. For example, four SAC officials were unsure how the role of the 

senior inspector, inherited from INS and now in CBP, would affect ICE 

investigators’ roles in conducting investigations in the ports of entry. 11

CBP has stated that cases are not always referred to ICE by the senior 

inspectors, and there is no CBP policy to refer such cases to ICE. This is 

because some cases concern immigration violations related only to 

attempted illegal entry at a port of entry and as such are CBP matters 

regarding admissibility, not ICE interior enforcement matters. According 

to CBP headquarters officials responsible for inspections, the bureau is 

exploring the concept of expanding the senior inspector position to 

address broader types of investigations rather than only immigration 

matters, but the role of the senior inspector in relation to the role of ICE 

investigators has not yet been determined. 

Additional examples included problems (1) between ICE investigations 

and CBP’s Border Patrol in negotiating controlled deliveries, (2) between 

ICE investigations and CIS in the area of benefit fraud, and (3) among 

CBP, CIS, and ICE in the area of issuing paroles to aliens.12

 11The senior inspectors, in addition to performing the duties of the CBP officer, present 

criminal cases to the United States Attorney regarding certain potential criminal 

immigration violations that occur at ports of entry. Such criminal violations are, for 

example, re-entry after removal and alien smuggling and involve an administrative removal 

action and a potential criminal case. 

12Benefit fraud includes the willful misrepresentation of a material fact to gain an 

immigration benefit in the absence of lawful entitlement. Benefit fraud includes such 

schemes as marriage fraud and non-immigrant visa fraud. 

Some Field Officials 

Expressed a Need for 

Additional Guidance on 

Roles and Responsibilities 
Page 16 GAO-05-81 Homeland Security 

According to some of the field officials we contacted, how the Border 

Patrol and ICE should communicate and coordinate with each other on 

controlled deliveries had not been fully defined. An ICE official told us 

that prior to the transition, this technique was used by both INS and 

Customs agents and, while INS typically coordinated with the Border 

Patrol, Customs agents, because they were often dealing with narcotics, 

did not necessarily coordinate with INS unless the controlled delivery was 

going through Border Patrol checkpoints. Based on what we were told, 

since the transition, ICE and the Border Patrol have had conflicting 

positions that hamper communication and coordination about controlled 

deliveries. Border Patrol officials we contacted stated that their mission is 

to prevent and detect illegal entry of persons or contraband between ports 

of entry. Some ICE investigators we contacted said that they believe, on 

the other hand, that in order to dismantle smuggling organizations—one of 

ICE’s priorities—they need to do more than arrest the individual drivers or 

couriers. We talked with ICE officials in one field office who told us that 

there have been occasions when the Border Patrol deployed additional 

agents to an area after learning that ICE intended to conduct a controlled 

delivery. ICE investigators stated that this not only can hinder the 

accomplishment of their mission but potentially puts ICE investigators at 

risk. This is because Border Patrol agents can unsuspectingly encounter 

an undercover ICE agent in the course of interdicting persons attempting 

to cross the border, and if a gunfight ensues, the undercover ICE agent 

risks revealing his or her identity to the smugglers, or the ICE and Border 

Patrol agents risk injuring each other. A Border Patrol chief and deputy 

chief we interviewed stated that if CBP headquarters issued a formal 

memorandum stating that controlled deliveries by ICE were allowed, they 

would be willing to coordinate with local ICE managers. 

A Border Patrol official in headquarters told us that after the terrorist 

attacks on September 11, former Customs investigators began to lead 

operations on the border and between ports of entry, and saw their 

program as having authority to conduct operations on the border. When 

these investigators transitioned to ICE in March 2003, both agencies 

eventually sought to clarify their roles and responsibilities concerning 

controlled deliveries. The two bureaus formed a working group to do this 

in April 2004. 

An outcome of the working group discussions, according to CBP 

headquarters officials, is that Border Patrol and ICE plan to issue guidance 

Controlled Deliveries Have 

Reportedly Been Hampered by 

Communication and 

Coordination between Border 

Patrol and ICE 
Page 17 GAO-05-81 Homeland Security 

in the form of a memorandum of understanding concerning the general 

roles and responsibilities of their respective staffs for controlled 

deliveries.13 This new guidance, according to the Border Patrol official in 

headquarters who chaired the working group, is to state that all controlled 

deliveries between ports of entry have to be approved by the local Border 

Patrol chief, who will make a decision based on guidance from 

headquarters. Additionally, according to this same official, the guidance 

will state that the Border Patrol will have the responsibility, during 

controlled deliveries, for inspections to ensure that there are no weapons 

of mass destruction, for example, in vehicles or on persons in addition to 

the known smuggled goods or persons. Officials told us the guidance will 

also outline a process for grievances when local managers cannot agree. 

Border Patrol officials said they did not have a date when the guidance 

would be finalized, but that as of August 2004, a final draft was sent to 

CBP’s Commissioner to be signed, after which ICE’s Assistant Secretary 

would be given the draft for signature. 

At the time of our site visits, how ICE and CIS should communicate and 

coordinate with each other in cases of suspected benefit fraud has not 

been formally defined by either CIS or ICE headquarters, and the field 

officials we contacted said that this has caused disagreement among CIS 

and ICE field officials. The difficulty between CIS and ICE investigations 

regarding benefit fraud is not new. We have noted in a past report that INS 

had numerous problems related to its enforcement of benefit fraud, 

including a lack of protocols for adjudicators and others in coordinating 

benefit fraud and a lack of criteria for investigators in prioritizing benefit 

fraud cases.14 Prior to the transition, INS had begun to place a priority on 

investigating benefit fraud perpetrated by large-scale organizations or 

persons of special interest, and this priority has continued under ICE. As a 

result, some CIS field officials told us that ICE would not pursue single 

cases of benefit fraud. ICE field officials who spoke on this issue cited a 

lack of investigative resources as to why they could not respond in the 

manner CIS wanted. For example, one ASAC acknowledged that CIS 

depended on ICE to go forward with leads on benefit fraud but said that 

 13The guidance is also to cover other issues, such as Title 21 authority (covers the 

importation, distribution, manufacture, and possession of illegal narcotics), asset 

forfeiture, and sharing of intelligence and information. 

14Investigators in both INS’s service centers and district offices investigated possible 

benefit fraud on the basis of information that they received from staff who processed 

benefit applications (adjudication officers), other INS investigative units, INS regional 

units, the public, and other federal and local law enforcement agencies. 

Focus of Benefit Fraud 

Investigations Reported as a 

Source of Disagreement among 

CIS and ICE Field Officials 
Page 18 GAO-05-81 Homeland Security 

his office could not commit large numbers of investigators to benefit fraud 

until more investigators were cross-trained. An ASAC and group 

supervisor in another office also cited the lack of investigators to address 

benefit fraud and acknowledged that the vast majority of the CIS cases 

referred to that ICE office we not investigated because of this lack of 

resources. 

According to CIS officials, adjudicators refer single cases of benefit fraud 

to ICE, in part because they rely on ICE to conduct database checks on 

systems CIS adjudicators cannot access. For example, ICE’s Treasury 

Enforcement Communications System (TECS) may have information on 

individuals that could help adjudicators determine whether to approve or 

deny an application for benefits.15 However, CIS officials in three cities we 

visited stated that the applicants’ files they send over to ICE are 

sometimes kept without notification of whether an investigation was 

initiated or not by ICE investigators for long periods of time. An ICE 

official in headquarters responsible for managing benefit fraud explained 

that SAC offices may investigate single cases of alleged fraud but the 

extent to which that is done depends on the assessment of the SAC office’s 

staff resources and the priorities of the local U.S. Attorney’s Office.16

Without having information from ICE that might form the basis for 

denying an application, CIS still has the responsibility to adjudicate the 

application and instead may even approve applications or take other 

temporary action when fraud is suspected. For example, in one office we 

visited, CIS officials said that they had 154 cases of alleged benefit fraud 

that they had referred to ICE since June 2003. They said they had not 

received responses from ICE on the status of these cases or whether ICE 

intended to investigate them. In the interim, CIS officials said, their office 

could not close the cases and instead had been granting the suspect 

 15TECS was developed and maintained by the Customs Service (U.S. Department of the 

Treasury), and is a mainframe-based enforcement and inspection support system that prior 

to the transition was used by Customs, INS inspectors and intelligence analysts, and other 

federal agencies. The system was developed to store information about people who are of 

interest to law enforcement agencies so that their entry into the United States may be 

monitored or, if necessary, prevented. 

16We previously reported in GAO, Immigration Benefit Fraud: Focused Approach Is 

Needed to Address Problems, GAO-02-66, (Washington, D.C., January 2002) that U.S. 

attorneys accept fraud cases under established prosecutorial priorities and resource 

availability and that the priority on fraud varies among the U.S. attorney’s offices around 

the country. 
Page 19 GAO-05-81 Homeland Security 

applicants temporary employment authorization or advance parole.17 One 

CIS manager and one ICE manager in the field indicated that while 

dismantling large-scale smuggling rings is important, single cases of 

benefit fraud can have national security implications. For example, a 

person who is allowed to remain in the country as a result of committing 

marriage fraud can become a naturalized citizen in 3 years and facilitate 

the entry of other persons into the United States who could possibly pose 

security risks. CIS and ICE officials in headquarters agreed that benefit 

fraud was important to national security as well as the integrity of the 

immigration process. CIS officials in three cities told us that ICE’s lack of 

responsiveness to some CIS referrals for benefit fraud investigations 

hindered their ability to meet their district and bureau goals for reducing 

the backlog of applications. 

While challenges were reported, there have been efforts by ICE and CIS to 

address benefit fraud. After the transition, CIS created a Fraud Detection 

and National Security office devoted to deterring fraud. ICE has 

established Benefit Fraud Units composed of investigative assistants and 

intelligence analysts who were working in CIS’s three regional offices and 

in the three of the four CIS service centers (who were working in these 

offices prior to the transition).18 CIS has Fraud Detection Units composed 

of adjudications staff in its four service centers who process applications, 

analyze applications to identify trends in fraud, and refer potential benefit 

fraud cases to ICE. ICE investigative assistants and intelligence analysts, 

in turn, are to refer cases to the local SAC investigations offices. Two CIS 

offices we visited were referring potential benefit fraud cases through this 

new process. Alternatively, in the other four offices we visited, CIS 

adjudicators were directly referring benefit fraud cases to local ICE 

investigators, who must determine whether to reject, postpone, or pursue 

the cases. 

 17Advance parole is a benefit that allows an alien residing in the United States (in other 

than lawful permanent resident status) to gain permission to travel out of and return into 

the United States when the conditions of the alien’s stay do not otherwise allow for readmission after departing the Untied States. 

18ICE has Benefit Fraud Units in the Texas, Vermont, and California Service Centers. Now 

under CIS, the former INS’s four Service Centers—California, Nebraska, Texas, and 

Vermont—were created in 1990 to help reduce application backlogs in the district offices. 

Service Centers process 35 types of applications, including petitions for permanent and 

temporary workers, petitions for admission of spouses, and applications for employmentbased adjustment of status to permanent resident. The Service centers also share 

responsibility with the District offices for processing naturalization applications. 
Page 20 GAO-05-81 Homeland Security 

Headquarters officials from CIS and ICE told us that the two bureaus were 

planning to do more to address benefit fraud. These officials told us that 

CIS and ICE are working on a memorandum of understanding that will 

document the creation of standard protocols for adjudicators to refer and 

investigators to accept, alleged cases of benefit fraud (including time 

frames for ICE in responding to CIS) and for CIS and ICE to communicate 

and coordinate in matters involving benefit fraud. Additionally, CIS 

created a new fraud position description to address single cases of fraud, 

and a CIS official told us that as of August 2004, the agency has hired 95 of 

100 newly funded staff positions to work on benefit fraud and some of 

these staff have completed one training course at the Federal Law 

Enforcement Training Center (FLETC).19 In addition, while neither official 

knew when the memo of understanding would be final, in the interim, CIS 

and ICE have established time frames for SAC offices to review fraud 

referrals for criminal investigation. 

CBP, CIS, and ICE have the authority to grant aliens parole—temporary 

admission into the United States for such reasons as humanitarian 

purposes, public benefit (e.g., participating in a legal proceeding for the 

U.S. government), or for further inspection. A CIS official told us that the 

authority to make decisions regarding parole, under former INS, rested 

with the district director, who had responsibility for all of the immigration 

programs. However, since the transition, CBP, CIS, and ICE had yet to 

make formal the roles and responsibilities for each program regarding 

who has authority to grant parole and when it is most appropriate for one 

agency rather than the other to make decisions about a parole application. 

Without this guidance on roles and responsibilities, CBP, CIS, and ICE 

officials in local areas were making determinations as to how the parole 

process will work. For example, in one city we visited, as a result of 

monthly meetings, ICE investigations, CBP inspections, and CIS 

coordinated a panel of representatives from their local offices to review 

the applications or requests for parole and, depending on the facts of each 

case, decided what program would make the decision for granting parole 

to aliens. By contrast, in another city we visited, CBP and CIS were unsure 

as to who had the authority to make decisions about parole. CBP officials 

in headquarters who are responsible for inspections told us that the 

current practice is that the bureau that has possession of the person 

 19According to a CIS official, every district office, service center, and asylum office will 

receive at least one of these positions, and large district offices will receive several 

positions. 

CBP, CIS, and ICE Lack Formal 

Guidance for Addressing 

Overlapping Responsibilities 

for Parole 
Page 21 GAO-05-81 Homeland Security 

makes the decision about parole, and while there are ongoing discussions 

among managers in the three bureaus regarding authority, there have not 

been final decisions. In August 2004, CBP and ICE headquarters told us 

that the two bureaus have now drafted protocols regarding parole and that 

the completion of the protocols is contingent upon a decision by DHS on 

the placement and funding of the Parole and Humanitarian Assistance 

Branch. In commenting on a draft of this report, DHS said that the issues 

regarding parole operations have now been resolved. 

SAC offices have taken initial steps toward integrating the former INS and 

Customs investigative workforces. However, most SAC officials and 

investigators we spoke with said that one or more steps that are important 

for full integration remain to be completed. While officials in some SAC 

offices said they have not received enough specific guidance, such as 

performance measures from ICE headquarters on how to gauge their 

progress in merging INS and Customs investigators, many of the ones we 

contacted said there are some common initial steps SAC offices have 

completed in integrating investigators.20 These include (1) assigning former 

INS and Customs investigators to work together in mixed investigative 

groups, (2) providing formal and on-the-job cross-training to investigators 

so that former INS investigators can perform the functions of former 

Customs investigators and vice versa, and (3) establishing pay parity for all 

former INS investigators and supervising investigators. Many SAC officials 

with whom we spoke also noted that several important steps to fully 

integrate former INS and Customs investigators remain to be taken. These 

include (1) co-locating former INS and Customs investigators so their 

offices are in the same building, (2) establishing uniform ICE policies and 

procedures, and (3) issuing symbols for ICE’s Office of Investigations that 

identify all ICE investigators as being part of one agency. ICE headquarters 

officials told us in August 2004 that efforts are under way to address all of 

these steps. 

 20In an interview with ICE headquarters officials in July 2004, we were told they are just 

starting to provide guidance to SAC offices on integration and only doing so on a case-bycase basis. 

Some Steps Taken 

and Some Steps 

Remain to be 

Completed in 

Integrating 

Immigration and 

Customs Investigators 

into ICE 
Page 22 GAO-05-81 Homeland Security 

Of the 49 SACs and ASACs who responded to our question, 27 stated that 

investigators in their offices had been integrated to a great or moderate 

extent; 15 said they had been integrated to some extent, and 3 said they 

had been integrated to a little extent. SACs and ASACs who responded to 

our question indicated they had generally maintained the investigative 

focus that existed before the merger (e.g., groups continued focusing on 

money laundering, strategic investigations, and benefit fraud) but had 

mixed or intended to mix some of the former INS and Customs 

investigators into these investigative groups. An ICE official in 

headquarters said that the extent to which investigative groups would be 

integrated has been left up to individual SACs, and the characteristics of 

some geographic locations may make integration more difficult. Eleven 

SACs said they were working toward having former INS and Customs 

investigators work within mixed investigative groups. One SAC noted that 

he did not want to integrate investigators and group supervisors until they 

were formally cross-trained—training where former INS and Customs 

investigators learn the laws and regulations of each other’s discipline from 

experienced lawyers and trainers.21

Ten of 49 SACs and ASACs we spoke with indicated that former INS and 

Customs investigators in their offices were being assigned to work with 

one another on a case-by-case basis, and two of these said mixing of 

investigators in this way provided the investigators with opportunities to 

learn each other’s discipline through on-the-job-training. Such 

opportunities included having a joint duty roster where investigators from 

each former discipline responded to a call for an investigation together 

and having some investigators from former INS and Customs work in the 

same investigative groups.22 Eleven of 49 SACs and ASACs we contacted 

told us their offices had a joint duty roster such that investigators from 

different former agencies responded to cases together and learned from 

one another on the job. In one of the SAC offices, we were told that 

investigators from the former INS and Customs respond together to calls 

for investigations, but former Customs investigators process immigrationrelated cases and customs-related cases are processed by former INS 

 21Group supervisors are senior special agents responsible for overseeing an investigative 

group of 8 to 12 special agents in a particular investigative field, such as benefit fraud, 

antismuggling, or money laundering. 

22Before the transfer, both INS and Customs investigations programs rotated agents on a 

roster to serve 24-hour shifts to respond to issues that arose, for example, at the ports of 

entry or after regular business hours. 

Mixing Investigative 

Groups, Classroom-Based 

Cross-Training, and Pay 

Parity Are among the 

Initial Steps Reported in 

Integrating INS and 

Customs Investigators 
Page 23 GAO-05-81 Homeland Security 

investigators so they can learn the policies and procedures of the other 

discipline in a real-life setting. 

SACs and ASACs we spoke with said that in addition to on-the-job training, 

formal cross-training is key to eventually creating a unified workforce. ICE 

headquarters issued a cross-training curriculum to all SAC offices in 

January 2004 with a deadline for all investigators to complete crosstraining by September 30, 2004. ICE headquarters officials did not set a 

deadline for the completion of training for group supervisors or senior 

managers, although these persons could choose to participate in the 

investigator training. 

ICE officials responsible for developing the cross-training curriculum 

indicated that the intent of the cross-training was to ensure that all 

investigators from the former agencies were prepared to address all 

components of ICE’s mission. The investigators are to participate in 8 days 

of classroom training, taught by investigators and attorneys, covering both 

legal and operational issues of the other discipline. For example, former 

INS investigators receive training in areas such as commercial fraud 

investigations, financial investigations, trade compliance, and drug 

smuggling, while former Customs investigators receive training in areas 

such as determining citizenship, benefit and document fraud, initiation of 

removals, and alien detention. Investigators must pass, with a score of 70 

percent or higher, a series of nine written tests in order to be certified as 

cross-trained. As of late August 2004, ICE headquarters reported that 2,175 

out of approximately 5,400 former INS and Customs investigators had 

taken and passed at least one of the nine exams, including 1,210 former 

INS and Customs investigators who had fully completed cross-training. In 

August 2004, ICE headquarters said that they still expected most 

investigators to complete the cross-training and nine examinations by the 

September 30, 2004, deadline.23

ICE officials cited the achievement of pay parity between former INS and 

Customs investigators as one of the successes of the merger. Prior to the 

merger and for approximately a little more than a year after the transfer, 

former INS investigators and their supervisors were paid at a lower grade 

level than their counterparts from former Customs. Specifically, most 

 23There are a limited number of agents who are unable to complete cross-training as they 

are on detail assisting the United States Secret Service in carrying out protective duties 

during this election year or are assisting in training the Federal Air Marshal Service. 
Page 24 GAO-05-81 Homeland Security 

former INS investigators were paid at the GS-12 pay grade and most 

former INS group supervisors were paid at the GS-13 grade; most former 

Customs investigators were paid at the GS-13 grade and most former 

Customs group supervisors were paid at the GS-14 grade. In our site visits 

and during telephone interviews, many ICE officials, including most 

former INS investigators, said that the lack of pay parity had affected 

morale, made former INS investigators feel as if they were second class, 

and made integrating the investigative groups more difficult as the former 

INS investigators were doing the same work for less pay. In April 2004, 

DHS approved an upgrade from GS-12 to GS-13 for the majority of former 

INS investigators, and in June 2004 approved an upgrade from GS-13 to 

GS-14 for the majority of former INS group supervisors. Investigators and 

group supervisors we spoke with after pay parity went into effect said they 

believed morale had increased since pay parity was implemented, and 

former INS investigators felt they are now equal to their former Customs 

counterparts. 

Twenty-one SACs and ASACs we spoke with stated that other efforts 

important to integration — such as co-locating all ICE investigators in a 

given field location so they are in one building, establishing uniform 

operational policies and procedures, and “branding” ICE’s Office of 

Investigations with symbols that identify investigators as belonging to one 

agency — have been delayed. 

According to 19 of 49 SACs and ASACs we contacted, one of the obstacles 

to integration has been the fact that numerous investigators from former 

INS and Customs have continued to work in separate locations. Although 

INS’s and Customs’ investigations programs were merged into ICE, former 

INS investigators generally continued to work in former INS buildings, and 

former Customs investigators generally continued to work in former 

Customs buildings. Eight SACs and ASACs with whom we spoke noted 

that the lack of co-location of former INS and Customs investigators 

perpetuated the view among investigators that ICE is not yet integrated. 

For example, 3 officials said that creating a unified organization is difficult 

when members of a work group—8 to 12 investigators—are dispersed in 

different offices, sometimes miles apart. Some SAC officials reported they 

have moved some investigative groups, such as the benefit fraud and 

criminal aliens, to the same buildings in an effort to better co-mingle 

former INS and Customs investigators. Officials in some other locations 

told us this has not been possible because of lack of space. Fourteen of 20 

SACs we spoke with by phone noted that their offices have been unable to 

co-locate former INS and Customs investigators because space in their 

Many Officials Stated That 

Important Steps to Fully 

Integrate Investigators 

Remain to Be Completed 

Complete Co-Location Has Not 

Yet Been Achieved 
Page 25 GAO-05-81 Homeland Security 

current buildings was limited and building leases were signed before the 

transfer or because they could not secure additional funding from DHS to 

lease new buildings before existing leases expire. An ICE headquarters 

official said there are a few SAC offices that are completely co-located and 

there are additional SAC offices that have submitted co-location plans to 

ICE headquarters and requested additional space. This official also said 

that ICE will begin to co-locate offices that have had Occupational Safety 

and Health Administration violations or where leases will soon expire, and 

the goal is to have all SAC offices co-located in the next 5 to 7 years. ICE 

headquarters officials recently estimated that complete co-location 

immediately would cost about $150 million. 

Some officials told us that ICE has been slow to establish uniform 

operational policies and procedures, causing confusion and some delay in 

the creation of a new unified ICE culture. Policies and procedures on such 

things as the use of firearms or the steps to take when investigators are 

involved in car accidents while working in an official capacity vary 

between former INS and Customs investigators. In the absence of uniform 

policies and procedures, ICE headquarters officials said they directed SAC 

offices to continue to use former policies from both INS and Customs, 

applying the policy from the former agency to the agent from that agency. 

SAC officials from some offices said they have created new local office 

policies for all ICE investigators. 

One SAC official said that a lack of unified operational policies and 

procedures has in some cases resulted in confusion or the establishment 

of local policies. Other SAC officials told us this can be problematic if 

investigators working together are relying upon different policies and 

procedures to carry out their investigative work. In one city, we were told 

that two investigators—one from the former INS and one from the former 

Customs—were involved in an auto accident. The former agencies had 

different procedures for filing paperwork on an accident, and no one knew 

which policy to follow. The SAC made a local decision to use the policy of 

the driver’s former agency. In another city, the SAC decided to adopt a 

former Customs policy concerning making an arrest at a residence. 

Customs policy had called for a minimum of four investigators in making 

an arrest, while INS did not have a policy on the minimum number of 

investigators required for an arrest. The former INS investigators and 

supervisors said they did not understand the rationale for this policy, given 

the volume of arrests they typically had in a day. Officials in ICE 

headquarters explained the rationale to us, stating that under INS 

investigators often engaged in administrative arrests of individuals for 

administrative crimes, such as visa overstays or document fraud. Under 

Lack of Uniform Policies and 

Procedures for Some 

Operations Reportedly Causes 

Confusion and Hinders the 

Creation of a New Culture 
Page 26 GAO-05-81 Homeland Security 

ICE, they said investigators are often engaging in criminal law 

enforcement arrests and possibly arresting more dangerous suspects. As a 

matter of officer safety, ICE requires that investigators work in groups of 

four when making an arrest. Knowing this rationale may have helped the 

former INS staff avoid confusion over this change. Additionally, ICE 

headquarters officials told us that the investigations program prioritized 

the establishment of uniform policies, for example, focusing on a unified 

policy for undercover operations. These headquarters officials also said 

that, in the interim, SAC offices were instructed by ICE headquarters to 

use the policy of the former agencies. 

After more than a year as ICE, field officials said that investigators and 

managers were continuing to use their former agency badges and 

credentials, and ICE headquarters officials had spent months waiting on a 

request for a name change.24 Some SACs we spoke with said that at the 

time we contacted them, ICE still did not have the public identifiers that 

separate it from the former agencies of which it is composed. We were 

told that incomplete branding of the agency with a unique logo has at 

times contributed to frustration and embarrassment.25 Some of the former 

INS investigators and managers we spoke with said that the delay in 

branding ICE has held up the creation of a unified ICE agency. 

According to officials at ICE headquarters, one element in the process of 

establishing ICE is to brand it with a unique identity by creating badges, 

raid jackets, business cards, and other identifying materials or symbols. 

When DHS was created, INS staff were directed to retire all emblems and 

paraphernalia. However, Customs was not given the same orders. In some 

ICE offices, we observed Customs emblems and paraphernalia on display. 

In another example of the divide between INS and Customs, in one city we 

visited, former Customs investigators had created a mock-up of the new 

 24For a number of months ICE delayed issuing new badges, credentials, name signs, 

business cards, and other printed material because of a pending request for a name change. 

ICE formally requested a name change—to Investigations and Criminal Enforcement—to 

more accurately reflect the work of all ICE divisions, as well as to further remove the 

agency from the legacy immigration and customs brands. In late June 2004, the Assistant 

Secretary for ICE announced that it was clear the name change would not be approved in 

the near future and ICE would go forward with the procurement of new badges and 

credentials. 

25DHS defines branding as all the things and symbols that create the recognition for an 

agency. Branding provides an organization with an identity and provides information to 

others about what that agency is. 

Pending Name Change Caused 

Delay in Creating a Unified ICE 
Page 27 GAO-05-81 Homeland Security 

ICE badge that they said was for former INS investigators, which referred 

to the INS investigators as “Junior Officers” of the U.S. Customs Service. 

During one site visit, a group of former INS investigators we spoke with 

questioned why headquarters had been so slow to implement branding, 

and one investigators said the branding should have been completed prior 

to the transition or shortly thereafter. In another site visit, one investigator 

said this lack of an identity has proven to be frustrating and embarrassing 

when acting in an official capacity, such as testifying in court. One ASAC 

we spoke with said that he tried to board a plane with his weapon and was 

questioned by airline officials when he showed his INS badge to verify that 

he was law enforcement. Airline officials said that INS had been abolished, 

and the ASAC had to explain that ICE did not yet have its own badges. The 

ASAC was eventually allowed to proceed but said he knew this problem 

had plagued other investigators as well. In another example, an agent in 

one city said that he went out and purchased his own ICE raid jacket 

because he did not like having his authority questioned when he wore an 

INS raid jacket. 

Most of the decisions about branding were made at the DHS level, and 

there are written guidelines for the use of the DHS seal and agency 

signatures for such things as business cards, letterhead, and flags.26

According to an official in ICE headquarters who is responsible for 

branding, certain branding activities that are particular to ICE are in the 

final stages. At the time of our interview in July 2004 and confirmed in 

August 2004, ICE headquarters officials acknowledged the delay and said 

that raid jackets were made available for purchase locally in January 2004, 

badges will be issued beginning in September 2004, and uniforms were in 

the final stages of production. 

Many of those we spoke with from both the former INS and Customs 

noted that there have been benefits to merging the INS and Customs 

investigations programs. They noted that combining the expertise of 

former INS and Customs investigators has provided expanded authority in 

conducting investigations and could contribute to more thorough 

investigations. Other SAC officials said that expanded authority has been 

beneficial in investigating money laundering in alien smuggling cases and 

 26All agencies, with the exception of the U.S. Coast Guard and the Secret Service, are 

required to use the DHS seal and the agency’s name as their logos. 

Many See Positive Aspects 

of the Transition 
Page 28 GAO-05-81 Homeland Security 

going after the assets of foreign-born persons running prostitution rings as 

they can now prosecute someone for multiple offenses. Four SACs and 

ASACs said they expect the benefits to increase as cross-training is 

completed and investigators more fully learn the expertise of the other 

former agency. 

Former INS investigators we spoke with also noted beneficial aspects of 

the merger. Many of the former INS investigators we spoke with in our site 

visits said they are now able to concentrate on investigative work rather 

than services and they have received a pay increase to bring them up to 

par with the former Customs investigators. In one location, former INS 

investigators said that prior to the merger, the District Director would task 

investigators to assist with naturalization exams or to fill guard duties at 

district offices or ports of entry. In another location, former INS 

investigators said they now have more employees to carry out missions. 

Although DHS has issued guidance via Email on how administrative 

support shared services would function, several CBP, CIS, and ICE field 

officials told us that they were confused about what constitutes shared 

services, the processes for receiving services from a shared service 

provider, and how many of the administrative staff in their offices would 

be transferred to other offices. One official in headquarters told us in July 

2004 that decisions about shared services were not completely resolved. 

Additionally, officials in all three agencies cited problems with 

administrative computer systems for travel, budget, and payroll—

administrative functions that are handled by the individual bureaus and 

are not a part of shared services. As a result of several problems and 

changes that have occurred, according to officials in CBP, CIS, and ICE, 

some field offices have assigned administrative duties to inspectors, 

adjudicators or senior adjudications managers, or investigative staff 

because the office needed additional administrative support. 

In an attempt to provide more efficient administrative mission support 

services, DHS is in the process of developing and implementing systems 

and processes called “shared services.” DHS initiated the shared services 

system in December 2003, making determinations about the realignment of 

approximately 6,100 administrative positions. In January 2004, the 

Undersecretaries for Management and Border and Transportation Security 

and the heads of CBP, CIS, and ICE signed an agreement finalizing the 

interbureau governance of shared services. In commenting on a draft of 

this report, DHS said that the Department encountered delays in the 

execution of service level agreement and resource allocation. 

Many Officials 

Expressed Difficulty 

Understanding 

Administrative 

Services 
Page 29 GAO-05-81 Homeland Security 

Consequently, the implementation phase did not begin until late in the 

spring/summer of 2004. According a to DHS official, shared services is 

intended to represent a new model for government on delivering and 

managing administrative services. 

DHS’s shared services system utilizes four different approaches in 

providing and receiving services for CBP, CIS, and ICE staff. The shared 

services system’s approaches are (1) each bureau provides its staff some 

of its own services itself, (2) one bureau provides a certain service to staff 

in all three bureaus, (3) one bureau provides a service to its own 

workforce and staff in one other agency while the third bureau provides 

that service for its own staff, and (4) each bureau provides selected 

services to its own workforce as well as to selected staff in other bureaus. 

For example, CBP is providing human resource management to its 

workforce, in addition to workforces in CIS and ICE~. ICE is providing 

training for supervisors in ICE, CIS, and CBP but handles equal 

employment opportunity issues for only its own workforce, and CIS. CBP, 

CIS, and ICE are each providing their own workforces with procurement, 

budget, labor and employment relations, and professional development 

training, among other services. According to DHS officials, the decisions 

about which bureau would provide a certain service were made on the 

basis of an assessment of such factors as each bureau’s adaptability to an 

increased workload, level of modernization, and historical expertise with 

each shared service. See figure 2 for a description of the services each 

bureau is to provide under shared services. 
Page 30 GAO-05-81 Homeland Security 

Figure 2: Division of CBP, CIS, and ICE Roles Under DHS’s Shared Services 

A DHS briefing document and communication strategy indicated that 

through such means as the bureau’s intranet, chain of command, 

memorandums, fact sheets, and video broadcasts, DHS would 

communicate the roles and responsibilities of CBP, CIS, and ICE for 

providing shared services. DHS provided us evidence that it has used some 

of these communication methods. However, a senior official at DHS told 

us in June 2004 (6 months after the initiation of shared services) that 

although a communication strategy was in place, communicating about 

shared services to the field is a work in progress. This official also said 

Despite Communication 

about Recently 

Implemented Shared 

Services System, Officials 

Say Confusion Persists 

CIS

 provides:

ICE

 provides:

CBP

 provides:

Source: GAO analysis of DHS data.

CIS or ICE provides all these services to the other

CIS or ICE provides only these services to CBP

CBP provides all these services to CIS and ICE

Each bureau is responsible for providing the services below to its own workforce

Procurement, Budget, Labor and 

Employee relations

Training: Academies, Instructional 

Systems, Professional Development

To CBP

To ICE To CIS

To CBP

To ICE

To CIS

- Immigration forms management 

 and distribution 

 -Records management

- Mail program management (CIS/ICE)

- Firearms – armories

- Training – 

 supervisory leadership training

- Finance (CIS/ICE)

- EEO (CIS/ICE)

- HQ mail (CIS/ICE) 

- Facilities construction

- Facilities management and acquisition

- Fleet management

- Printing and graphics

- Health and safety

- HRM services including personnel security

- Training - management

- Customs forms design, management, and distribution 
Page 31 GAO-05-81 Homeland Security 

that it is the responsibility of the bureaus both receiving and providing 

services to communicate information about shared services to the field 

offices and staff. DHS officials also stated that the responsibilities of CBP, 

CIS, and ICE under shared services are still under development. One 

official who was involved in the formation of shared services told us that 

DHS would like to change some administrative functions that the bureaus 

currently handle for themselves—for example, procurement—into shared 

services. Further, even though CBP was designated as the provider of 

personnel services to CIS, the extent of that service is still in negotiation.27

Field officials told us that numerous officials in CBP, CIS, and ICE were 

uncertain about what constitutes shared services, the process for receiving 

services from a shared service provider, and which administrative staff 

would be re-aligned from their positions in local offices to work for 

providers of shared services. In our telephone interviews with SACs and 

ASACs, 33 of 40 said that their offices were experiencing problems with 

shared services to a moderate or great extent.28 The 4 SACs and ASACs 

who said they were experiencing problems to little or no extent provided 

such reasons as not interacting with shared services providers or relying 

on the staff who assisted them prior to the initiation of shared services in 

December 2003.29

Our meetings with field officials in CBP, CIS, and ICE indicated that 

despite communication from DHS, field office officials varied in their 

understanding about what constitutes shared services. For example, one 

ASAC believed that shared services consisted of sharing resources, such 

as buildings and computer technology, rather than having one bureau 

provide a certain administrative service for the other two. Additionally, in 

April 2004, approximately 3 to 4 months after the initiation of shared 

services, four ICE officials and one CBP inspections official were not 

aware that this occurred. 

Officials in four of the six sites we visited were unsure about who 

specifically to call or the process they were to use in obtaining a shared 

 27CBP stated in September 2004 that the two bureaus finalized the agreement for shared 

services on July 2, 2004. 

28The 9 SACs and ASACs we visited face-to-face were not asked the same question. 

29Three SACs and ASACs said that they were experiencing problems with shared services 

to “some extent.” 
Page 32 GAO-05-81 Homeland Security 

service from CBP, CIS, or ICE.30 For example, after the person responsible 

for facilities was transferred to ICE, an official in a CIS district office did 

not know who to call for assistance with setting up vacant office space for 

CIS staff who were being moved to that location. This official ultimately 

learned that the process was not a shared service but was instead handled 

within CIS. A SAC official in another office we visited said he and 

administrative staff did not know how to obtain an authorization to repair 

a vehicle that had been damaged in an accident in October 2003. The 

officials initiated a purchase order request in November 2003 for services 

to repair the vehicle and submitted it to ICE. However, under the shared 

services system, CBP was designated responsibility for authorizing fleet 

repairs for CBP, CIS, and ICE. The SAC official said that he and 

administrative staff spent several months contacting multiple officials at 

CBP offices and ICE headquarters about approval for the repair and how 

to pay for it. In March 2004 the car was scheduled to be sold at an 

auction.31 In late June 2004, CBP issued an informal policy, by Email to the 

SAC office, for receiving approval for repairs and invited the SAC office to 

resubmit a request (as it had been previously denied) if it had not already 

sold the car. Before SAC officials were informed of this process, we were 

told that the office paid approximately $1,000 for storage of the vehicle 

and stopped saving the funds initially set aside for the repair. 

In five of the six sites we visited, officials expressed uncertainty and 

unmet expectations about which administrative staff in their offices would 

be reassigned to shared services positions and transferred to other 

programs or agencies. The decision about the reassignment of 

administrative staff for shared services was made at the headquarters level 

by a working group of CBP, CIS, and ICE officials and led by DHS. For 

example, in one SAC office that we visited, approximately 50 

administrative staff from former INS had been supporting CBP and CIS in 

addition to ICE, and all but 1 were moved because of the realignment of 

staff for shared services. Because the SAC had expected to retain 3 rather 

than 1 of the 50 administrative staff, he assigned administrative work to 

several investigators as a collateral duty. Administrative staff in one CBP 

office for field operations that we visited had received e-mail messages 

from CBP headquarters notifying them that, within a few days, they would 

be transferred to another program or bureau. We were told that some 

 30We visited two sites before the official initiation of shared services in December 2003. 

31The vehicle registered approximately 4,000 miles on the odometer at the time of the 

accident, and the repairs were valued at approximately $6,500. 
Page 33 GAO-05-81 Homeland Security 

reassignments came as a surprise and involved moving from one office 

building to another, but usually they were in the same general geographic 

location. 

ICE provided us with a written statement explaining that it, along with 

CBP and CIS, could not begin delivering administrative services to one 

another under shared services until “reimbursable agreements”—the 

arrangement of costs and funding for a particular administrative service—

were finalized. As such, this delayed notifications to administrative staff 

about reassignments and affected the agencies’ ability to provide 

information to the field. 

Many officials we contacted in CBP, CIS, and ICE said that problems with 

travel and budget, and computer systems have at times adversely affected 

office operations. For example, because of problems with travel computer 

systems, many officials in ICE’s SAC offices said that staff are not 

receiving reimbursements. Thirty-two of 49 SACs and ASACs responding 

to our question about shared services cited Travel Manager—ICE’s off-theshelf computer system for processing travel requests and vouchers—

and/or the Federal Financial Management System (FFMS)—the computer 

system ICE SAC offices use to track their budgets—as significant 

administrative problems. Additionally, CBP officials identified such 

problems as cumbersome procedures for accessing data systems and the 

lack of computer program updates to reflect changes on time and 

attendance cards. In August 2004, headquarters officials told us they were 

making efforts to resolve the problems by providing training, reducing 

funding strings for Travel Manager, and reprogramming FFMS. 

Twenty-six of 49 SACs and ASACs responding to our question about 

shared services also discussed the problems they were having with Travel 

Manager. ICE headquarters officials told us that Travel Manager is a new 

system to the former Customs field staff in ICE’s investigations program. It 

was used in the former INS’s headquarters and in some field offices prior 

to the transfer. ICE headquarters officials told us that Travel Manager was 

chosen because it could interface with ICE’s accounting system and 

automate the process for managing travel documents. ICE investigations 

officials in the field and headquarters told us that with Travel Manager, the 

funding strings (codes that tell the system what account to charge and to 

what program to attribute travel) have caused problems for staff in the 

field and headquarters. ICE headquarters investigations officials estimated 

that there are approximately 80,000 separate funding strings, each 

approximately 48 characters long, from which field staff have to choose in 

Travel, Budget, and Other 

Computer System 

Problems Seen as 

Significant 
Page 34 GAO-05-81 Homeland Security 

carrying out a transaction such as completing a travel voucher. They 

explained that because the system is new to many staff and the funding 

strings are not labeled so that the user can select words rather than a 

string of numerical characters, some ICE staff may choose incorrect 

funding strings, causing their vouchers to “disappear” in the system or be 

routed to the wrong approving official. When this occurs, ICE 

headquarters officials for investigations told us, neither the traveler nor 

the approving official receives a notice that the voucher has failed to be 

processed. Additionally, because ICE’s Travel Manager interfaces with its 

Federal Financial Management System, if staff choose the wrong funding 

string, the voucher may be routed to an account that does not have the 

funds. If this happens, ICE officials said the system would reject the 

voucher. As a result, they said that some ICE investigators and managers 

have not received timely or accurate reimbursements for their travel. 

According to some ICE field officials we contacted, when staff 

inadvertently select the wrong funding string, it takes from several weeks 

to months to process the voucher. A few officials said that when staff do 

not receive timely reimbursements, they sometimes use their personal 

funds to pay their government credit card bills. For example, one SAC said 

that an agent in his office used personal funds to pay $15,000 for bills 

incurred from business travel. Another SAC official said that not all 

investigators are able to use their personal funds to pay for their business 

travel expenses. One SAC said that he was waiting to be reimbursed for 

$11,000 in travel bills that he had accrued on his government credit card. 

Because he had not been reimbursed, he felt he was in danger of having 

his government credit card revoked. These examples are to illustrate the 

types of concerns reported to us. We did not verify the facts reported to us 

or the circumstances surrounding these specific examples, e.g., whether 

the problems were caused by the travel system, the individual, or both. 

ICE headquarters investigations officials responsible for Travel Manager 

said that they have made some changes to Travel Manager to aid ICE staff. 

For example, they reduced the number of funding strings from the initial 

800,000 to about 80,000, and added alphabetical codes to help facilitate the 

use of the software. They also said they have suggested to an ICE group 

working on finance issues that either the system or a staff member should 

send notification to the approving official and traveler when vouchers 
Page 35 GAO-05-81 Homeland Security 

cannot be successfully processed.32 Officials responsible for all of ICE’s 

financial management told us that the office responsible for mission 

support for all of ICE had provided over 200 contacts in the field to assist 

with Travel Manager, held a training conference, and provided training 

opportunities in the field and in headquarters for staff regarding Travel 

Manager. However, they recognized that 48-character numerical funding 

strings are difficult to use. They also discussed additional reasons why 

staff in the field were having problems with Travel Manager. First, because 

ICE did not have a full accounting of its staff, 33 Travel Manager did not 

recognize all of the staff and was unable to route all of the vouchers. 

Second, many staff were unfamiliar with Travel Manager, so they did not 

know how to determine whether their vouchers have been approved or 

rejected. Third, in situations where staff did not travel for their home 

program office, e.g., if an investigator was traveling on behalf of the 

Federal Air Marshals, the travel documents could not be managed through 

Travel Manager. 

Twenty-two of 49 SACs and ASACs also discussed problems with FFMS, 

but the problems were not as numerous as those with Travel Manager. 

FFMS is a financial accounting system that allows the tracking of budget 

expenditures and balances. It was previously used by INS and ICE chose 

to adopt it, although DHS plans to transition to a new departmentwide 

financial system. The problems with FFMS are new to former Customs 

managers and administrative staff, but not necessarily new to former INS 

staff who began using the software shortly before the transition. The SACs 

and ASACs who stated that they had problems with FFMS said that it 

mostly affected their ability to manage the office budgets. In response to 

this problem, five SACs we contacted told us that they are tracking their 

budgets manually, with some using Excel spreadsheets so they can know 

how much they are spending from each budget area. One SAC said he is 

using over 20 Excel spreadsheets to track the office budget, and another 

 32In August 2004, ICE provided a statement that indicated that if staff chose an incorrect 

accounting string, the system would indicate an error before routing the document to the 

approving official. 

33According to ICE officials responsible for finance, when the Office of Management and 

Budget allocated staffing and funding to the Border and Transportation Security 

Directorate and CIS, the funding for several programs such as general counsel and 

information technology went to CBP and CIS but the staff went to ICE. These ICE officials 

told us that because ICE was funding additional support staff, the agency did not have an 

accurate account of staff funded by ICE and staff in ICE whose funding was with CBP and 

CIS. 
Page 36 GAO-05-81 Homeland Security 

bought an off-the-shelf budget software system to supplement FFMS. The 

officials in ICE headquarters responsible for finance told us that the 

limitations of FFMS were known, but FFMS was chosen after three studies 

were conducted by independent consultants approving its use by ICE and 

it was certified to meet auditing standards. Additionally, ICE officials in 

headquarters responsible for finance said in June 2004 that they have 

attempted to address field concerns by reprogramming FFMS to allow 

SAC offices to track their budgets in the manner they were used to doing 

in Customs and by providing weekly training to program officers in 

headquarters. 

CBP officials in inspections and Border Patrol in four of the six sites we 

visited also told us they were having problems with administrative 

computer systems and applications, mostly in the area of time and 

attendance. Inspections officials cited problems with CBP’s computerized 

time and attendance system, Customs Overtime Scheduling System 

(COSS), and in some cases, inspections officials said they were not 

accurately paid overtime. Officials we spoke with in CBP’s Border Patrol 

also cited problems with COSS and overtime payments and added that in 

some cases, staff were maintaining a manual record of actual time and 

attendance but inputting into COSS only the 40 hours per week recognized 

by COSS. CBP officials in Border Patrol headquarters acknowledged the 

problems with COSS when we talked with them in June 2004. However, in 

August 2004, CBP headquarters officials responsible for program 

management of COSS told us that there were initial problems with 

overtime payments for former INS staff that were attributed to errors in 

the calculation of pay after transmission from COSS to the Department of 

Agriculture for processing and the method the Border Patrol had used to 

schedule hours worked, while under former INS.34 They said that all 

problems with COSS had been resolved by January 1, 2004. We did not 

verify whether or when specific problems were addressed or the actual 

causes of the problems reported to us by Border Patrol and inspections 

officials but did note a difference in the causes field officials mentioned 

and the reasons provided by CBP headquarters officials. 

 34The National Finance Center, an office within the Department of Agriculture, handles 

payroll and other administrative services for some government agencies. 
Page 37 GAO-05-81 Homeland Security 

One criticism we had of the former INS was that because of staffing 

shortages, mission staff often had to assume administrative or other 

functions as a collateral duty. One effect of assigning mission staff to 

administrative work is that they are not spending all of their time on duties 

needed to accomplish the program’s mission and thus are not reaching the 

full potential of the program position. In our site visits, we found that this 

continues to be a problem in some offices. Some officials we contacted in 

CBP, CIS, and ICE said they had to use mission staff in this way because 

they did not have enough administrative support to compensate for the 

realignment of administrative staff to shared services, the addition of 

mission personnel that have come as a result of mergers of some programs 

in the transition, and hiring freezes. As a result, inspectors, adjudicators, 

and investigators in some field offices were taking on administrative work 

full-time or as a collateral duty: 

• In three of the six sites we visited, we found examples where CBP 

inspectors were assigned to handle various administrative functions as a 

collateral duty. For example, an inspector in one city was detailed to 

resolving problems related to time and attendance and payroll for former 

INS inspectors. In another city, supervisory inspectors were detailed to 

perform scheduling duties normally performed by administrative staff. 

• In three of the six CIS district offices we visited, we found examples of 

adjudicators or senior managers taking on administrative functions in 

addition to their work as a collateral duty. In two district offices, 

adjudicators were taking on such functions as managing office space and 

monitoring the budget. In another city, the third highest manager in a 

district office was assigned to handle personnel, procurement, and 

vacancies rather than duties related specifically to managing the 

adjudication of applications. Because these mission staff were spending 

time on administrative functions, they were spending less time addressing 

program missions such as reducing the backlog of applications. 

• In two of our six site visits and in telephone interviews, we learned that 

ICE investigators are also taking on administrative functions as a collateral 

duty. In one SAC office we visited, the SAC assigned 10 special 

investigators, including 1 associate special agent in charge, 1 assistant 

special agent in charge, 2 group supervisors, and 6 junior investigators, to 

administrative duties. In our telephone interviews, we found examples 

consistent with our site visits. For example, we were told that special 

investigators in a subordinate office of one SAC office were assigned all of 

the clerical work in addition to their normal duties when the office lost its 

administrative support staff. Rather than assign administrative duties to 

investigators, other SAC offices said they are converting unfilled agent 

Mission Staff Sometimes 

Assigned Administrative 

Work Full-Time or as 

Collateral Duty 
Page 38 GAO-05-81 Homeland Security 

positions to administrative positions. For example, an official in one office 

said he would have to convert unfilled agent positions to administrative 

positions, and an official in another office gained an administrative staff 

member from CBP by transferring (through a personnel action) one of its 

staff vacancies to CBP. 

The challenges we identify in this report highlight the importance of using 

the transition of immigration functions into DHS as an opportunity for 

further addressing long-standing and new challenges through positive 

transformation. We realize that carrying out this transformation will be no 

easy or quickly realized task. In this regard, we and others have studied 

the experiences of other public and private organizations that have 

undergone successful mergers and transformations. In a July 2003 report, 

we identified nine key practices that have consistently been found at the 

center of successful mergers and transformations, as shown in figure 3.35

This report was done to help federal agencies implement successful 

transformations of their cultures, as well as help the new DHS merge its 

various originating components into a unified department. Collectively, in 

our view, these key practices and related implementation steps discussed 

in our July 2003 report can help transform the sometimes diverse cultures 

of DHS legacy agencies into a cohesive unit that fulfills its new mission, 

meets current and emerging needs, maximizes performance, and ensures 

accountability. 

 35GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

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

Key Practices for 

Successful Mergers 

and Transformations 
Page 39 GAO-05-81 Homeland Security 

Figure 3: Key Practices for Successful Mergers and Organizational Transformations 

We did not perform an in-depth analysis comparing these key practices 

with the transfer of immigration functions into DHS. Nonetheless, we 

believe that all nine are important for DHS in its transformation of 

immigration programs and noted two key practices that we think would be 

particularly helpful as it addresses the challenges we identified in this 

report. We realize that DHS has started using many of these nine practices 

and, while we did not assess how well each of the practices has been 

followed, we did identify certain parts of the two practices that we believe 

would further assist DHS in its transformation efforts. 

Creating an effective, ongoing communication strategy is essential to 

implementing a merger or transformation. Communication is most 

effective when done early, clearly, and often, and is downward, upward, 

and lateral. Organizations must develop a comprehensive communication 

strategy that reaches out to employees, customers, and stakeholders and 

seeks to genuinely engage them in the merger and transformation process. 

Implementation steps that accompany this key practice include 

communicating early and often to build trust and understanding, ensuring 

consistency of message, encouraging two-way communication, and 

providing information to meet specific needs of employees. 

Establish a 

Communication Strategy 

to Create Shared 

Expectations and Report 

Related Progress 

Ensure top 

leadership 

drives the 

transformation

Establish a 

coherent 

mission and 

integrated 

strategic goals 

to guide the 

transformation

Focus on a key 

set of principles 

and priorities at 

the outset of 

the 

transformation

Set 

implementation 

goals and a 

timeline to build 

momentum and 

show progress 

from day one

Dedicate an 

implementation 

team to 

manage the 

transformation 

process

Use the 

performance 

management 

system to 

define 

responsibility 

and ensure 

accountability 

for change

Establish a 

communication 

strategy to 

create shared 

expectations 

and report 

related progress

Build a worldclass 

organization

Involve 

employees to 

obtain their 

ideas and gain 

their ownership 

for the 

transformation

Sources: GAO (presentation); Photos: Photo Disc, Dynamic Graphics, EyeWire, and Ingram Publishing.

SUCCESSFUL TRANSFORMATION
Page 40 GAO-05-81 Homeland Security 

DHS’s office responsible for shared services provided us with a 

communication strategy dated May 2004 and a briefing, dated February 

2004, outlining communication strategies, both with the objectives of 

raising awareness and promoting understanding of shared services within 

and outside of DHS. CBP told us that the agency has developed and 

implemented a communications strategy and provided us with examples 

of communications activities. Additionally, 22 of the 36 SACs and ASACs 

responding to our question by telephone told us that concerning 

communication, they received information from headquarters regarding 

transition goals and milestones.36 In addition, a few of the SACs and ASACs 

who responded that they had received transition information said that the 

information was received through such means as e-mail, broadcast 

messages, ICE’s intranet, and SAC conferences. These efforts, however, do 

not appear to have been completely effective since, as previously 

discussed, about a quarter of the officials we contacted in CBP, CIS, and 

ICE wanted a clearer understanding of their roles and responsibilities with 

other immigration programs. 

A successful merger and transformation must involve employees and their 

representatives from the beginning to gain their ownership of the changes 

that are occurring in the organization. Employee involvement strengthens 

the transformation process by including frontline perspectives and 

experiences. Further, employee involvement helps to create the 

opportunity to establish new networks and break down existing 

organizational silos, increase employees’ understanding and acceptance of 

organizational goals and objectives, and gain ownership of new policies 

and procedures. Implementation steps that accompany this key practice 

include using employee teams, involving employees in planning and 

sharing performance information, incorporating employee feedback into 

new policies and procedures, and delegating authority to appropriate 

organizational levels. 

In conducting our field work and in meetings with headquarters officials, 

we did not identify any indication that the bureaus responsible for 

immigration programs had formal mechanisms for obtaining periodic 

feedback from field staff (other than the top manager in the office) about 

how well the transition was occurring or their concerns or ideas for 

improvement. In addition, several headquarters officials seemed 

 36Four of the 40 we contacted did not respond to our question. 

Involve Employees to 

Obtain Their Ideas and 

Gain Their Ownership for 

the Transformation 
Page 41 GAO-05-81 Homeland Security 

somewhat surprised by the concerns reported to us by field officials when 

we discussed them in August 2004. On the other hand, while we did not 

conduct an exhaustive search of employee involvement by all field staff, 

our work did identify examples of such involvement. For example, we 

found two instances where field officials had participated in working 

groups held at headquarters regarding issues related to roles and 

responsibilities. That is, the working group to outline roles and 

responsibilities between the Border Patrol and ICE investigations involved 

field managers, two of whom we interviewed. Additionally, we were told 

that a meeting held in July 2004 involved CIS and ICE headquarters 

managers, field staff, investigators, and adjudicators in discussions about 

benefit fraud. Without a formal mechanism for obtaining employee 

feedback, however, the bureaus run the risk of missing opportunities for 

improvement and of allowing field-related problems to arise and continue 

without adequate responses. 

With its critical roles in helping protect national security and enforcing 

immigration laws, it is very important that INS’s integration into DHS and 

its related transformation successfully address longstanding and new 

management challenges. To accomplish this, DHS’s three immigration 

bureaus are tasked with establishing clear communication and 

coordination among one another and with the efficient and effective 

integration of the roles and responsibilities of the former immigration and 

customs investigative workforces, all while implementing a new system 

for providing administrative services. In managing this transformation, 

DHS is faced with not only the previous management challenges that beset 

INS for years, but with new challenges that come with creating a new 

department and managing diverse agencies. Notwithstanding this daunting 

endeavor, the transformation provides DHS with a unique opportunity to 

successfully address these inherited and new challenges and thus better 

accomplish its important mission. 

While DHS has started addressing many of the challenges and has 

experienced some successes in its communication and coordination and 

other efforts, the challenges and uncertainties reported by field officials 

and discussed in this report show that these efforts have not been 

sufficient to fully realize the potential benefits of this transformation. The 

sentiment among the field officials within CBP, CIS, and ICE we contacted 

demonstrates the importance of them having additional explanation and 

guidance from DHS and the headquarters management of each of the 

respective bureaus that delineates the (1) specific roles and 

responsibilities for conducting uniform immigration program operations, 

Conclusions 
Page 42 GAO-05-81 Homeland Security 

such as benefit fraud investigations, parole decisions, and controlled 

deliveries and (2) processes and procedures for making the shared 

services system work more efficiently. Without clear guidance, conflicts 

that the programs have had prior to and after the transition will likely 

persist and staff in the field will lack a complete road map for addressing 

cross-cutting issues that may arise in the future, as well as the necessary 

information to efficiently utilize the administrative services they need to 

accomplish their mission. 

Collectively, the nine key practices and related implementation steps that 

we identified in our 2003 report can help DHS transform the diverse 

cultures of former agencies into a cohesive unit that fulfills its new 

mission, meets current and emerging needs, maximizes performance, and 

ensures accountability. Specifically, while DHS efforts to incorporate the 

key practices and implementation steps we discuss in this report into its 

transformation plans should help address the challenges, in our view, a 

communication strategy that obtains and considers employee feedback to 

create shared expectations and gains their ownership in changes would 

improve the likelihood of success in addressing the integration challenges. 

We realize that carrying out a successful transformation is no easy or 

quickly realized task and believe that this makes having a strategy that 

fully incorporates these key practices all the more important. 

To assist DHS in successfully transforming its immigration related 

programs and address the challenges discussed in this report, we 

recommend that the Secretary of Homeland Security direct the heads of 

CBP, CIS, and ICE, as appropriate, in consultation with the 

Undersecretary for Border and Transportation Security, to take the 

following three actions. 

• First, the bureaus should create a mechanism for periodically obtaining 

employee feedback on their ideas and concerns and consider this 

feedback in its future transformation and communications strategies, 

including assessing the challenges reported to us. 

• Second, the bureaus should provide additional specific guidance to field 

managers and staff that establishes uniform policies and procedures on all 

cross-cutting integration issues that affect operational effectiveness, 

including specific descriptions of the roles and responsibilities of each 

bureau and its staff in investigative techniques such as benefit fraud 

investigations, parole decisions, and controlled deliveries. 

Recommendations 
Page 43 GAO-05-81 Homeland Security 

• Finally, the bureaus should provide additional detailed written guidance to 

field managers and staff on the processes and procedures to follow for the 

provision of shared administrative services. 

DHS provided written comments on a draft of this report, and these 

comments are reprinted in appendix II. DHS said that, while there are 

instances where contextual clarification is needed, it generally agreed with 

our overall findings and recommendations and that our analysis would be 

beneficial to the department. 

DHS agreed with our recommendation that the bureaus–CBP, CIS, and 

ICE–should create a mechanism for periodically obtaining employee 

feedback. DHS commented that there have been accomplishments in this 

area and provided examples for each of the three bureaus. The examples 

include both existing and new efforts started since our field work, 

including a contract by CBP in September 2004 for a professional services 

firm to take periodic surveys of randomly sampled employees to measure 

the effectiveness of communications. If effectively implemented, the new 

efforts should provide the bureaus with additional employee ideas and 

concerns to consider in its transformation and communication efforts. 

Concerning our recommendation that the bureaus provide additional 

specific guidance to the field on cross-cutting issues, DHS said that it has 

provided clear and thorough guidance and uniform policies and 

procedures in critical cross-cutting integration issues. It also said that the 

transition challenges it faced were compounded because the overarching 

priority was to accomplish all of the department’s missions. DHS said 

there has been progress related to the consistency and delivery of 

guidance on cross-cutting issues that should be acknowledged in the final 

report. While we have not assessed the results of some of these examples 

of progress, we considered them and added them to the report where 

needed to add context. Further, we note that many of the examples DHS 

provided of its progress were ongoing during our fieldwork and staff still 

raised the concerns we report and said that more guidance on crosscutting immigration issues is needed. Although these recent efforts, if 

properly implemented could address some of the deficiencies we 

identified, we believe that this feedback from field officials shows that 

more attention is needed in this area to address uncertainties and 

confusion about cross-cutting issues. 

DHS agreed with our recommendation that the bureaus provide additional 

guidance on the processes and procedures in providing shared services 

Agency Comments 
Page 44 GAO-05-81 Homeland Security 

but noted its concern about our discussion of communication problems 

during the transition to shared services. DHS said that it used best 

practices to develop a communication strategy and plan to realign various 

administrative or support services into a shared services environment. It 

said that it experienced delays in rolling out the shared services initiative, 

so it is understandable that field managers lacked familiarity with certain 

issues at the time of our interviews. However, DHS did not believe the 

field managers views expressed in this report accurately portray the 

initiative or the level of comprehension of the initiative. We commend 

DHS for developing a communication strategy and plan for this initiative 

but believe that the views expressed in this report do portray the level of 

comprehension of the initiative by those officials at the time of our 

interviews. The concerns they raised, along with additional feedback DHS 

obtains in future employee surveys, should assist DHS in accomplishing 

the goals of this initiative. 

DHS also offered technical comments, which we considered and 

incorporated where appropriate. 

We plan to provide copies of this report to other appropriate committees, 

the Secretary of DHS, and other interested parties. We will also make 

copies available to others upon request. In addition, this report will be 

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

or your staff have any questions, please call me at (202) 512-8777. Key 

contributors to this report are listed in appendix II. 

Richard M. Stana 

Director, Homeland Security and Justice 
Page 45 GAO-05-81 Homeland Security 

List of Congressional Committees 

The Honorable Orrin G. Hatch 

Chairman 

The Honorable Patrick J. Leahy 

Ranking Minority Member 

Committee on the Judiciary 

United States Senate 

The Honorable Thad Cochran 

Chairman 

The Honorable Robert C. Byrd 

Ranking Minority Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

United States Senate 

The Honorable James Sensenbrenner, Jr. 

Chairman 

The Honorable John Conyers, Jr. 

Ranking Minority Member 

Committee on the Judiciary 

House of Representatives 

The Honorable Harold Rodgers 

Chairman 

The Honorable Martin Olav Sabo 

Ranking Minority Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

House of Representatives 
Appendix I: Objectives, Scope, and 

Methodology 

Page 46 GAO-05-81 Homeland Security 

The Homeland Security Act —(P.L. 107-296, Sec. 477(d)(1)—mandated us 

to review the transfer of functions from the Immigration and 

Naturalization Service (INS) to the Department of Homeland Security 

(DHS) and identify issues associated with the transition. Our overall 

objectives were to assess the status of (1) communication and 

coordination among immigration programs in DHS field offices, 

(2) integration of immigration and customs investigators in U.S. 

Immigration and Customs Enforcement (ICE) field offices, and 

(3) administrative services and systems used by DHS’s immigration 

agencies’ field offices. We did not assess program performance or DHS’s 

overall response to long-standing problems in this review. Additionally, 

our analysis was based on a snapshot in time, primarily during fiscal year 

2004, and it is possible our results would have been different if our 

interviews had been conducted today. 

To obtain information on our objectives, we reviewed laws; U.S. 

Citizenship and Immigration Services (CIS) and ICE transition documents; 

DHS, CIS, U.S. Customs and Border Protection (CBP), and ICE memos on 

communicating and coordinating; DHS shared services implementation 

plans; our past reports; and other relevant documents. We also spoke with 

immigration experts in the public and private sectors, and with 

representatives of pro- and anti-immigration advocacy groups in the 

Washington, D.C., area. These included the American Immigration 

Lawyers’ Association, the Arab-American Antidiscrimination Committee, 

the Center for Immigration Studies, Electronic Data Systems Corporation 

Inc., the Institute for the Study of International Migration, the Migration 

Policy Institute, the National Immigration Forum, and the National Council 

of La Raza. 

We interviewed officials at DHS headquarters who were responsible for 

managing ICE’s detention and removal, intelligence, and investigations 

programs; CIS’s adjudications program; and CBP’s inspections and the 

Border Patrol. We also interviewed ICE, CIS, and CBP officials responsible 

for developing plans for the transition and officials in the former INS 

Office of Statistics and Office for Policy and Planning. 

We conducted structured interviews with officials in ICE’s special agent in 

charge (SAC) offices, CIS’s district offices, and CBP’s offices for field 

operations in 6 of the 27 cities that have SAC offices and with U.S. Border 

Patrol sector headquarter offices in 3 of those 6 cities. The 6 cities we 

visited were Arlington, Virginia; Baltimore, Maryland; New York, New 

York; Miami, Florida; Detroit, Michigan; and San Diego, California. Our 

visits to Arlington and Baltimore were used as preliminary site visits to 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 47 GAO-05-81 Homeland Security 

design our interview questions. We selected these locations because of 

their geographic dispersion; their proximity to ports of entry; and the 

relative proximity of ICE, CBP, and CIS offices to one another. 

• In site visits to CBP’s Offices for field operations, we met with directors 

for field operations, assistant directors for field operations, and, in some 

cases, inspectors. In these interviews, we collected information and 

documentation on (1) communication and coordination with ICE 

investigations and other DHS components, (2) the role of ICE investigators 

at the ports of entry, and (3) administrative services. 

• In site visits to CBP Border Patrol offices, we met with Border Patrol 

sector chiefs, directors for administration, and administrative officers. In 

these interviews, we collected information and documentation on 

(1) communication and coordination with ICE investigations and other 

immigration components, (2) the Border Patrol’s work on antismuggling, 

and (3) administrative services. 

• In site visits to CIS offices, we met with district directors, assistant district 

directors, as well as section chiefs. In these interviews, we collected 

information and documentation on (1) communication and coordination 

with ICE investigations and other immigration components, (2) benefit 

fraud, and (3) administrative services. 

• In site visits to four ICE field offices, we used a structured interview 

instrument to obtain information from the SAC and associate special 

agents in charge (ASAC). In one location, we spoke with the two ASACs. 

In all four visits, we also met with assistant special agents in charge and 

administrative staff. In some locations, SACs and ASACs were in interim 

positions until ICE made permanent appointments. In New York, Miami, 

Detroit, and San Diego, we also conducted individual and group interviews 

with investigators and supervising investigators from the former INS. In 

these interviews, we collected information and documentation on 

(1) ICE’s investigative mission and performance measures for the 

program, (2), communication and coordination with other immigration 

components in DHS, (3) communication and coordination with other 

federal agencies, (4) integrating immigration and customs investigators, 

and (5) administrative services. 

We used our structured interview instrument to obtain information from 

ICE’s SAC offices with telephone interviews with the two most senior 

managers in the 21 ICE field offices we did not visit—20 SACs and 20 

ASACs. We conducted these interviews between March and April of 2004 

and made some follow-up calls in June 2004. In our telephone interviews 
Appendix I: Objectives, Scope, and 

Methodology 

Page 48 GAO-05-81 Homeland Security 

we asked about (1) ICE’s mission and performance measures; 

(2) communication and coordination with CBP, CIS, and other ICE 

programs; (3) communication and coordination with other federal 

agencies; (4) integrating immigration and customs investigators; and 

(5) administrative services. We did not speak with one SAC because he 

was new to the position and did not believe he could provide us with 

useful information. We had previously interviewed him as the ASAC in 

another city. We did not speak with one ASAC because he, too, was new to 

the position. In total, we spoke with 49 SACs and ASACs in person and by 

telephone. 
Appendix II: Comments from the Department 

of Homeland Security 

Page 49 GAO-05-81 Homeland Security 

Appendix II: Comments from the Department 

of Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 50 GAO-05-81 Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 51 GAO-05-81 Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 52 GAO-05-81 Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 53 GAO-05-81 Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 54 GAO-05-81 Homeland Security 
Appendix II: Comments from the Department 

of Homeland Security 

Page 55 GAO-05-81 Homeland Security 
Appendix III: GAO Contacts and Staff 

Acknowledgments 

Page 56 GAO-05-81 Homeland Security 

Evi Rezmovic (202) 512-2580 or rezmovice@gao.gov 

David Alexander, Gabrielle Anderson, Leo Barbour, Carole Cimitile, 

Randall Cole, Patricia Dalton, Katherine Davis, Nancy Finley, Larry 

Harrell, Tahra Nichols, Rachel Seid, and Sarah Veale made key 

contributions to this report. 

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(440233) 
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