U.S. Immigration and 

Customs Enforcement's 

Alternatives to Detention 

(Revised) 

February 4, 2015 

OIG-15-22 
HIGHLIGHTS

 U.S. Immigration and Customs Enforcement’s 

Alternatives To Detention 

February 4, 2015

Why We Did This

ICE’s Intensive 

Supervision Appearance 

Program offers 

alternatives to detention. 

We reviewed whether: 

(1) the rate at which 

individuals in the 

Intensive Supervision 

Appearance Program 

have absconded or 

committed criminal acts 

has been reduced since 

2009; (2) ICE can 

improve the effectiveness 

of its alternatives to 

detention program, either 

by revising or expanding 

its Intensive Supervision 

Appearance Program 

contract, or through 

other cost-effective 

means; and (3) ICE’s 

Risk Classification 

Assessment is effective. 

What We Recommend

We made five 

recommendations to 

improve ICE’s 

management of the 

Intensive Supervision 

Appearance Program and 

the Risk Classification 

Assessment. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found

According to U.S. Immigration and Customs Enforcement 

(ICE), the Intensive Supervision Appearance Program is 

effective because, using its performance metrics, few program 

participants abscond. However, ICE has changed how it uses 

the program and no longer supervises some participants 

throughout their immigration proceedings. As a result, ICE 

cannot definitively determine whether the Intensive 

Supervision Appearance Program has reduced the rate at 

which aliens, who were once in the program but who are no 

longer participating, have absconded or been arrested for 

criminal acts. ICE should adjust its performance metrics to 

reflect changes in its criteria for program participation. 

ICE instructed field offices to consider redetaining 

noncompliant Intensive Supervision Appearance Program 

participants, but most field offices do not have sufficient 

funding for detention bed space to accommodate all 

noncompliant participants. ICE could improve the 

effectiveness of the program by allocating some Intensive 

Supervision Appearance Program contract funds to redetain 

noncompliant participants. 

ICE developed a Risk Classification Assessment to assist its 

release and custody classification decisions. However, the 

tool is time consuming, resource intensive, and not effective 

in determining which aliens to release or under what 

conditions. 

Agency Response

ICE concurred with all five recommendations. 

www.dhs.oig.gov OIG-15-22 
0~1.~ FP~Rrye

Q~~z OFFICE OF INSPECTOR GENERAL

F~~~~~ ~`~ND Std Department of Homeland Security

Washington, DC 20528 / www.oig.dhs.gov

February 4, 2015

MEMORANDUM FOR: The Honorable Sarah R. Saldana

Director

U.S. Immigration and Customs Enforcement

FROM: John Roth ~~~~

Inspector General

SUBJECT: U. S. Immigration and Customs Enforcement's

Alternatives to Detention

Attached for your information is our revised final report, U.S. Immigration

and Customs Enforcement's Alternatives to Detention (OIG-15-22). We

incorporated the formal comments from the U.S. Immigration and

Customs Enforcement (ICE) in the final report.

The report contains five recommendations aimed at improving ICE's

management of its alien release decisions and terms of release. Your

office initially concurred with Recommendation 1, 2, 3, and 4, and did

not concur with Recommendation 5.

Based on information provided in your initial response, we clarified

Recommendation 5 and provided ICE with an opportunity to modify its

response. ICE modified its response and now concurs with the

Recommendation 5. We consider Recommendations 1, 2, 3, 4, and 5

resolved and open.

As prescribed by the Department of Homeland Security Directive 077-01,

Follow-Up and Resolutions for Office of Inspector General Report

Recommendations, within 90 days of the date of this memorandum,

please provide our office with a written response that includes your

(1) corrective action plan and (2) target completion date for each

recommendation. Also, please include responsible parties and any other

supporting documentation necessary to inform us about the current

status of the recommendation.

Consistent with our responsibility under the Inspector General Act, we

will provide copies of our report to appropriate congressional committees
 OFFICE OF INSPECTOR GENERAL

 Department of Homeland Security 

with oversight and appropriation responsibility over the Department of 

Homeland Security. We will post the report on our website. 

Please call me with any questions, or your staff may contact 

Anne Richards, Assistant Inspector General for Inspections, at 

(202) 254-4100. 

2
 
Errata page for OIG-15-22 

U.S. Immigration and Customs Enforcement’s 

Alternatives to Detention
 

Change made to Recommendation 5, page 13, (see below): 

We revised the recommendation for clarity: 

OIG Draft Language: 

Recommendation 5. We recommend that ICE Executive Associate Director for 

the Office of Enforcement and Removal Operations: Revise the Risk 

Classification Assessment special vulnerabilities module to ensure that ICE 

conducts medical evaluations in accordance with the ICE Performance Based 

National Detention Standard on medical care. 

OIG Final Report Language: 

Recommendation 5. We recommend that ICE Executive Associate Director for 

the Office of Enforcement and Removal Operations: Revise the Risk 

Classification Assessment special vulnerabilities module to ensure that when 

ICE conducts the Risk Classification Assessment at a detention facility, 

medical staff or trained ERO officers ask detainees relevant medical questions 

in a setting that provides privacy. 
 

Results of Inspection..............................................................................2 

Background ...........................................................................................3 

Intensive Supervision Appearance Program Performance Metrics 

Need Revision ...............................................................................6 

Risk Classification Assessment is Ineffective to Determine Release 

Decisions....................................................................................11 

Appendixes 

Appendix A: Transmittal to Action Official ..................................16 

Appendix B: Scope and Methodology ..........................................18 

Appendix C: ICE Comments to the Draft Report ..........................19 

Appendix D: Risk Classification Assessment Checklist ................22 

Appendix E: ISAP II Termination Rates .......................................23 

Appendix F: Risk Classification Assessment Overrides ...............25 

Appendix G: Medical Screening and Special Vulnerabilities 

Checklists...............................................................26 

Appendix H: Major Contributors to This Report ..........................31 

Appendix I: Report Distribution .................................................32 

Abbreviations 

ATD Alternatives to Detention 

DHS Department of Homeland Security 

ENFORCE Enforcement Case Tracking System 

ERO Enforcement and Removal Operations 

FY fiscal year 

GPS Global Positioning System 

ICE U.S. Immigration and Customs Enforcement 

INA Immigration and Nationality Act 

ISAP Intensive Supervision Appearance Program 

OIG Office of Inspector General 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

RCA Risk Classification Assessment 

www.dhs.oig.gov 1 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Inspection 

The Immigration and Nationality Act, as amended, grants U.S. Immigration and 

Customs Enforcement (ICE) administrative authority to detain aliens during 

the process of removing them from the United States. ICE’s Intensive 

Supervision Appearance Program offers alternatives to detention. Under the 

program, ICE supervises aliens it has released from detention, and monitors 

them electronically. As a condition of release, ICE requires aliens to appear in 

immigration court for removal proceedings and comply with removal orders 

from the United States. 

We reviewed whether: (1) the rate at which individuals in the Intensive 

Supervision Appearance Program have absconded or committed criminal acts 

has been reduced since 2009; (2) ICE can improve the effectiveness of its 

alternatives to detention program, either by revising or expanding its Intensive 

Supervision Appearance Program contract, or through other cost-effective 

means; and (3) ICE’s Risk Classification Assessment is effective. 

According to ICE, the Intensive Supervision Appearance Program is effective 

because, using its performance metrics, few program participants abscond. 

However, ICE has changed how it uses the program and no longer supervises 

some participants throughout their immigration proceedings. As a result, ICE 

cannot definitively determine whether the Intensive Supervision Appearance 

Program has reduced the rate at which aliens, who were once in the program 

but who are no longer participating, have absconded or been arrested for 

criminal acts. ICE should adjust its performance metrics to reflect changes in 

its criteria for program participation. 

ICE instructed field offices to consider redetaining noncompliant Intensive 

Supervision Appearance Program participants, but most field offices do not 

have sufficient funding for detention bed space to accommodate all 

noncompliant participants. ICE could improve the effectiveness of the program 

by allocating some Intensive Supervision Appearance Program contract funds 

to redetain noncompliant participants. 

ICE developed a Risk Classification Assessment to assist its release and custody 

classification decisions. However, the tool is time consuming, resource intensive, 

and not effective in determining which aliens to release or under what conditions. 

We made five recommendations to improve ICE’s management of the Intensive 

Supervision Appearance Program and the Risk Classification Assessment. 

www.dhs.oig.gov 2 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

The Immigration and Nationality Act, as amended (INA), grants ICE 

administrative authority to detain aliens during the process of removing them 

from the United States. ICE’s Office of Enforcement and Removal Operations 

(ERO) manages and oversees Federal immigration detention. ERO detains 

aliens to ensure they appear in court for immigration hearings and comply with 

removal orders that immigration courts may issue. 

ERO tracks more than 1.8 million aliens in immigration removal proceedings, 

but ICE’s budget only funds 34,000 detention beds. Because ERO cannot 

detain all aliens who are waiting to appear in immigration courts or waiting for 

removal, it prioritizes detention bed space for: (1) aliens it is required to detain 

under the INA; (2) those who pose a risk to public safety if released; and (3) 

those at risk of absconding. However, ERO may not detain all aliens who fall in 

these three categories. For example, ERO cannot indefinitely detain most aliens 

who have a final removal order, but are not removable from the United States.1 

ERO may also not be able to detain all aliens who are at risk of absconding. 

In 2003, to provide additional options for supervised release, Congress 

appropriated funds to pilot a 5-year Intensive Supervision Appearance Program 

(ISAP). Called ISAP I, the program operated in ten cities; it ran from 2004 to 

2009. In June 2008, Congress appropriated approximately $62 million to fund 

the first year of a program called ISAP II, which was designed to expand the 

original program nationwide. For fiscal year (FY) 2014, Congress appropriated 

approximately $90 million for the program; ERO plans to renew the program 

contract for ISAP III in November 2014. Our report focuses on ISAP II. 

ERO uses ISAP II in conjunction with the less restrictive release conditions 

associated with payment of a bond, or having to report periodically to an ERO 

field office. Under ISAP II, ERO, through a contractor, provides a supervised 

alternative to detention using technology and case management. The intent of 

this supervised release is to increase compliance with release conditions, 

appearances in immigration court for removal hearings, and final removal 

orders that immigration courts may issue. 

 1 Certain countries refuse to issue travel documents to their nationals who are under final 

removal orders or countries delay the removal process. Since 2001, the U.S. Supreme Court 

has determined that ICE generally should not detain aliens with a final removal order for longer 

than 6 months if there is no significant likelihood of removal in the reasonably foreseeable 

future. Even if there is no significant likelihood of removal within the reasonably foreseeable 

future, however, DHS regulations permit the continued detention of certain classes of 

removable aliens on account of special circumstances, such as national security or public 

safety reasons. See 8 C.F.R. § 241.14(f). Decisions include Zadvydas v. Davis, 533 U.S. 678, 

701 (2001) and Clark v. Martinez, 543 U.S. 371, 386 (2005). 

www.dhs.oig.gov 3 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

ISAP II currently has two supervision options, Technology-Only and FullService. As of February 2014, there were 10,833 active Technology-Only 

program participants and 11,368 active Full-Service participants. ERO’s 

contractor provides electronic monitoring services for both programs, either 

through use of an ankle bracelet that enables Global Positioning System (GPS) 

monitoring or voice recognition software for telephonic reporting. Contractor 

charges for supervision vary by type of monitoring. The full cost of TechnologyOnly supervision is difficult to estimate because ERO does not track the cost of 

using its personnel to manage cases, but the contractor charges $0.17 a day 

per participant for telephonic monitoring and $4.41 for GPS monitoring. For 

Full-Service supervision, the contractor provides case management, as well as 

electronic monitoring, and charges an average of $8.37 a day per participant. 

Contractor-provided case management includes: 

x encouraging participants to comply with immigration proceedings, 

obtain travel documents, and plan for return to their country of origin; 

x providing information on transportation, medical care, religious services, 

legal resources, and other community resources; 

x scheduling unannounced visits to the participant’s work and/or living 

address; 

x scheduling participant visits to the contractor’s office; and 

x reporting any instances of program noncompliance to ERO, such as 

tampering with or removing a GPS ankle bracelet or missing a visit. 

When ISAP II expanded to a nationwide program in 2009, ERO identified three 

high priority categories of aliens to enroll: 

(1) aliens with final removal orders who are not removable from the United 

States and cannot be legally held in custody more than 6 months, but 

who are a danger to the community; 

(2) aliens in removal proceedings, not issued final removal orders, who are 

at high risk of absconding; and 

(3) aliens with final removal orders, previously released under supervision, 

who violate the terms of supervision by committing crimes or otherwise 

fail to comply with release conditions. 

Risk Classification Assessment 

ICE implemented the Risk Classification Assessment (RCA) in January 2013, in 

response to a 2009 immigration detention review.2 The RCA is a module in 

ICE’s Enforcement Case Tracking System (ENFORCE), which ERO uses to 

 2 Dr. Dora Schriro, Immigration Detention Overview and Recommendations, ICE, 

October 6, 2009. 

www.dhs.oig.gov 4 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

track detention, removal, and release operations. When ERO first detains an 

alien, ERO uses the RCA to generate standardized recommendations for: 

(1) detention or release; 

(2) custody classification level for detained aliens; 

(3) immigration bond amount, if applicable; and 

(4) community supervision level (including ISAP II) for released aliens. 

ICE expects ERO officers to complete the RCA at intake or within 5 days of 

detention, unless detention is mandatory. Appendix D shows the RCA 

information ERO collects for each alien. 

www.dhs.oig.gov 5 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Intensive Supervision Appearance Program 

Performance Metrics Need Revision 

According to ERO, ISAP II is effective because, using its performance metrics, 

few program participants abscond. However, ERO has not adjusted its 

performance metrics to account for changes in the criteria for ISAP II 

participation. In 2011, ERO began removing some participants from the 

program and reducing GPS monitoring for others when their immigration 

proceedings were delayed. As a result, ERO cannot definitively determine 

whether ISAP II has reduced the rate at which aliens, who were once in the 

program but who are no longer participating, have absconded or been arrested 

for criminal acts. In addition, some program participants willfully violate the 

terms of ISAP II supervision, but ERO currently does not have sufficient 

resources to redetain these aliens. 

Intensive Supervision Appearance Program 

When ERO expanded ISAP II nationwide in 2009, it developed performance 

metrics to verify the effectiveness of the program. At that time, ERO was 

enrolling aliens in the program who were at high risk of committing criminal 

acts, absconding, or violating the terms of their release, such as reporting 

requirements. ERO intended for these aliens to continue participating in ISAP 

II and remain under supervision until their immigration cases were completed, 

either because they were removed from the United States or granted an 

immigration benefit, such as asylum. Thus, to determine whether ISAP II would 

reduce the rate of those who absconded or were arrested for criminal acts, ERO 

only measured the rate for those participating in the program. 

For contract years 2010 through 2012, ERO reported that the rates at which 

ISAP II participants absconded and were arrested for criminal acts declined 

each year. Figure 1 and appendix E show these numbers as percentages of the 

total number of aliens whose ISAP II participation ended during the contract 

year. 

Figure 1: Number of ISAP II Participants Who Absconded or Were Arrested 

Contract Year 

[November to November] 2010 2011 2012 

Total number of participants whose participation in 

ISAP II ended during the contract year 8,591 12,268 17,524 

Number of participants who absconded 

927 

(10.79%) 

982 

(8.00%) 

851 

(4.86%) 

Number of participants arrested by other law 

enforcement agency 

576 

(6.70%) 

729 

(5.94%) 

705 

(4.02%) 

Source: ISAP II annual reports from contract years 2010 through 2012. 

www.dhs.oig.gov 6 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In 2011, ERO changed the criteria for participation in ISAP II for aliens whose 

immigration proceedings were delayed, when ERO had no control over the 

delays. Specifically, ERO changed participation criteria for: 

x	 Non-removable aliens: ERO headquarters instructed field offices to 

terminate ISAP II participation for aliens in the program who could not be 

removed from the United States and not enroll additional nonremovable 

aliens in the program. For example, ERO terminated the participation of 

Cuban criminals who could not be repatriated because Cuba would not 

accept them. According to ERO, it could release most of these aliens from 

detention using an immigration bond or another monitoring method, such 

as having them report to an ERO field office. 

x	 Aliens at risk of absconding: ERO headquarters instructed field offices to 

limit GPS monitoring for aliens who did not yet have a removal order, but 

were waiting to appear in immigration court, and were generally compliant 

with the terms of ISAP II supervision. According to ERO, because some 

immigration cases can take years to complete, it was not always feasible to 

continue GPS monitoring for aliens waiting to appear in immigration court. 

ERO also reasoned that those who had been complying with program terms 

and had a set court date would be less likely to abscond months before the 

court date. ERO headquarters recommended using another monitoring 

method during this period, such as having participants report 

telephonically. 

As a result of these changes in criteria, as shown in figure 2, and in more detail 

in appendix E, ERO terminated the participation of more than half of its 

compliant ISAP II participants before their immigration cases were completed 

through removal from the United States or granting of an immigration benefit. 

Figure 2: Reasons for ISAP II Participation Termination 

0%

10%

20%

30%

40%

50%

60%

70%

80%

Immigration Case

Completed

(Removed /

Granted Benefit)

Criminal Arrest Abscond ISAP Program

Violation

Other Reason

2010

2011

2012

Source: ISAP II annual reports from contract years 2010 through 2012. 

www.dhs.oig.gov 7 OIG-15-22 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Although ERO reasoned these changes in participation would increase ISAP II’s 

effectiveness, the office did not define effectiveness. Nor did ERO update its 

performance metrics to account for former ISAP II program participants who 

had absconded or were arrested for criminal acts after their participation 

ended. Although ERO ended participation in ISAP II for many aliens before 

their immigration cases were completed, the office continued to measure 

whether aliens absconded or were arrested for criminal acts only while actually 

participating in ISAP II. 

As a result, ERO cannot accurately determine whether transitory participation 

in ISAP II reduces the rate at which aliens, who were once in the program, later 

abscond or are arrested for criminal acts. To better evaluate the program’s 

effectiveness, ERO should develop and implement performance metrics to 

determine whether transitory participation in ISAP II contributes over time to 

reducing the rate at which aliens abscond or are arrested for criminal acts. 

Program Violators 

ERO does not have sufficient resources to redetain participants who willfully 

violate ISAP II’s terms of supervision, such as those who tamper with GPS 

monitors or miss appointments. Beginning in 2012, ERO instructed field offices 

to consider redetaining noncompliant participants, but most field offices do not 

have sufficient funding for the number of beds needed to accommodate 

program violators.3 ERO officers said that dedicating funding for approximately 

150 to 200 detention beds nationally, to redetain program violators as 

necessary, would discourage willful noncompliance. Currently, ERO uses most 

ISAP II contract funds for electronic monitoring and supervision. ERO could 

improve ISAP II’s effectiveness by allocating some ISAP II contract funds to 

redetaining noncompliant participants. 

Recommendation 1. We recommend that ICE Executive Associate Director for 

the Office of Enforcement and Removal Operations: Develop and implement 

performance metrics to evaluate Intensive Supervision Appearance Program 

effectiveness. 

Recommendation 2. We recommend that the Principal Deputy Assistant 

Secretary: Assess and report on the feasibility of using funds from the 

Alternatives to Detention (ATD) program to provide detention beds for 

noncompliant Intensive Supervision Appearance Program participants. 

 3 Alternatives to Detention (ATD) Program Guidance, Executive Associate Director for 

Enforcement and Removal Operations, August 10, 2012; De-escalation of Alternatives to
 

Detention Full Service Participants, Associate Director, Custody Management, 

January 31, 2013.
 

www.dhs.oig.gov 8 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis 

We evaluated ICE’s written response and have made changes to the report 

where we deemed appropriate. A summary of ICE’s written response to the 

report recommendations and our analysis of the response follows each 

recommendation. A copy of ICE’s response, in its entirety, is appendix C. ICE 

concurred with all report recommendations. We appreciate ICE’s comments 

and contributions. 

Management Response: ICE officials concurred with Recommendation 1. In 

its response ICE said the program has established metrics to evaluate 

effectiveness and programmatic success of the Alternatives to Detention 

program. However, ICE has found it difficult to develop a methodology that can 

measure appropriately the latent effects of Alternatives to Detention 

participation on aliens' future compliance with their reporting and court 

appearance requirements. ICE will continue to assess existing data and data 

collection methods with a view to identify more specifically the challenges that 

need resolution before such a methodology can be implemented. After the 

initial evaluation, ICE will work to develop one or more performance metrics to 

gauge such latent effects. ICE requests that this recommendation be 

considered resolved and open pending the results of this initial evaluation, 

which ICE estimates completing by July 1, 2015. 

OIG Analysis: We consider ICE’s proposed actions responsive to the intent of 

Recommendation 1, which is resolved and open. Rather than focusing solely on 

the latent effects of program participation, ICE officials may want to consider 

performance metrics that recognize milestones participants achieve while 

enrolled in the program. These milestones could include obtaining travel 

documents and planning for departure. This recommendation will remain open 

pending our receipt of ICE’s developed and implemented performance metrics 

to evauate ISAP effectiveness. 

Management Response: ICE officials concurred with Recommendation 2. ICE 

responded that it believes there is sufficient detention capacity to accommodate 

noncompliant ATD participants should the program’s increased monitoring 

and/or reporting requirements prove insufficient to correct noncompliant 

behavior. ICE will continue to exercise its prosecutorial discretion appropriately 

when deciding whom to detain, and align ATD resources appropriately with 

ICE’s enforcement priorities. Should future need for additional bed space funds 

arise, ICE will reprogram, as it has in the past, funds from other programs, 

including ATD. ICE requests that this recommendation be considered resolved 

and closed. 

OIG Analysis: We consider ICE’s actions partially responsive to the intent of 

Recommendation 2, which is resolved and open. ICE officials stated there is 

sufficient detention capacity to accommodate noncompliant ATD participants, 

www.dhs.oig.gov 9 OIG-15-22 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

but many field office directors said they need existing detention bed space for 

higher risk cases. ICE has the option of reprogramming funds, but this process 

is cumbersome. We will close this recommendation when ICE officials obtain a 

legal opinion on whether reserving a portion of existing ATD funding to redetain 

noncompliant participants is feasible. ICE may, as a matter of policy, continue 

to fund redetention of noncompliant participants through other means, or not 

fund redetention at all. 

www.dhs.oig.gov 10 OIG-15-22 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Risk Classification Assessment is Ineffective to 

Determine Release Decisions 

ICE developed the RCA to assist its release and custody classification decisions. 

However, the tool is time consuming, resource intensive, and not effective in 

determining which aliens to release or under what conditions. In addition, RCA 

questions on special vulnerabilities conflict with ICE’s Performance Based 

National Detention Standards. 

Processing Time and Resources 

As shown in appendix D, ERO field officers ask each alien as many as 178 RCA 

questions during intake processing. This requirement adds 15 to 30 minutes to 

each alien interview. The RCA also requires at least two ERO levels of review. As a 

result, completing the RCA can add several hours to alien intake processing. To 

avoid holding aliens overnight at intake processing, ICE headquarters authorizes 

its field offices with high intake volume the option of postponing the RCA for up to 

5 days.4 However, postponing the RCA requires field officers to conduct two risk 

assessments, (1) an informal assessment at intake and (2) the formal RCA later. 

The RCA adds unnecessary processing time because it does not allow ERO 

officers the ability to triage an alien’s intake; officers must ask each alien every 

RCA question.5 For example, officers must ask aliens who are: 

x a risk to public safety all questions related to terms of release; 

x too ill to detain all questions related to terms of custody; and 

x redetained because ERO has scheduled their removal all questions related 

to terms of custody and terms of release. 

Alien Release Decisions 

The RCA does not enhance the quality of ERO field office release decisions. For 

example, the system is not capable of making recommendations on complex 

cases and refers such cases to an ERO supervisor.6 As shown in appendix F, of 

the 228,095 RCA decisions made between July 30, 2012, and 

December 31, 2013, the RCA made no recommendation for 41,971, or 18.4 

percent of cases. When the system does make a recommendation, ERO officers 

routinely override the recommendation. Of the 228,095 RCA recommendations 

 4 RCA guidance states that all aliens must have an RCA completed as early in the process as 

possible, unless they are subject to mandatory detention and will be removed within 5 days, in 

which case the RCA is not necessary. 

5 ERO officers do not ask male aliens whether they are pregnant or nursing. 

6 The system refers high risk aliens with serious medical issues to ERO supervisors. RCA also 

refers aliens with both minor criminal convictions and weak community ties to ERO 

supervisors. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

between July 30, 2012, and December 31, 2013, ERO officers overrode 49,861, 

or 21.9 percent of the RCA recommendations. 

RCA recommendations are of limited value to ERO officers in determining 

which aliens to place on ISAP II. For example, the system generally 

recommends bond for higher risk releases and supervision without a bond for 

lower risk releases. In practice, ERO field offices are encouraged to ensure 

compliance among higher risk releases with a combination of a bond and 

ISAP II GPS monitoring. RCA recommendations also do not take into account 

ISAP II’s available funding for new participants or the program’s Full-Service 

and Technology-Only geographic locations. 

RCA Predictive Capabilities 

ICE did not design the RCA to improve its predictive capabilities over time. For 

example, ICE headquarters does not evaluate the rate at which: 

x aliens kept in detention were later granted relief; 

x aliens determined not to be vulnerable were later determined to require 

specialized care; 

x ICE lowered bond amounts for aliens unable to pay bond; 

x immigration judges offered bonds to aliens ICE had determined not to 

release; or 

x aliens recommended for release who abscond. 

RCA Special Vulnerabilities Assessment 

RCA questions on special vulnerabilities conflict with ICE’s Performance Based 

National Detention Standards medical screening guidance.7 According to the 

Standards, all detainees must undergo an intake medical screening within 12 

hours of entry into a detention facility.8 Appendix G shows the Standards 

medical screening questionnaire and the RCA special vulnerability questions. 

The Standards require that a medical professional or trained detention officer 

conduct the screening and provide privacy to the detainee. In contrast, an ERO 

officer may not have the necessary medical training and cannot offer privacy 

when asking the RCA special vulnerabilities questions. 

 7 ICE, Performance Based National Detention Standards 2011, as modified by February 2013 

errata, 4.3 Medical Care, page 288. http://www.ice.gov/doclib/detentionstandards/2011/medical_care.pdf. 8 Performance Based National Detention Standards 2011, pages 288ï289.
 

http://www.ice.gov/doclib/detention-standards/2011/medical_care.pdf. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

As shown in appendix G, most of the 31 RCA special vulnerabilities questions 

have a medical component.9 ICE can protect vulnerable populations better by 

ensuring medical staff or ERO officers trained in the Standards conduct the 

detainee intake medical screenings. 

Recommendation 3. We recommend that ICE Executive Associate Director for 

the Office of Enforcement and Removal Operations: Revise the Risk 

Classification Assessment tool to eliminate nonmaterial questions when 

statutory requirements, humanitarian considerations, or bed space limitations 

determine custody and release decisions. 

Recommendation 4. We recommend that ICE Executive Associate Director for 

the Office of Enforcement and Removal Operations: Establish and implement 

performance measures to evaluate and improve the accuracy, efficiency, and 

effectiveness of the Risk Classification Assessment. 

Recommendation 5. We recommend that ICE Executive Associate Director for 

the Office of Enforcement and Removal Operations: Revise the Risk 

Classification Assessment special vulnerabilities module to ensure that when 

ICE conducts the Risk Classification Assessment at a detention facility, 

medical staff or trained ERO officers ask detainees relevant medical questions 

in a setting that provides privacy. 

Management Response: ICE officials concurred with Recommendation 3. ICE 

responded it reviews RCA deployment success on an ongoing basis and has 

already made changes to the RCA to allow for more efficient processing. ICE 

continues to pursue enhancements and efficiencies. For example, in August 

2013, ICE streamlined the RCA by generating an automatic detain decision in 

expedited removal cases, allowing field offices to skip the submission/approval 

steps otherwise required. ICE said it initiated a formal process to review 

whether greater efficiencies could be achieved by eliminating nonmaterial 

questions, without lessening the RCA's usefulness. The process will require 

input from ERO field offices and relevant ICE headquarters programs, analysis 

of performance measures and other data, and an assessment of the costs and 

benefits of any possible changes. However, ICE officials disagree with the 

examples of nonmaterial questions cited in the our report, and cannot commit 

to making specific changes before ICE completes its assessment. ICE requests 

that this recommendation be considered resolved and open pending completion 

of its review of the RCA, which ICE estimates completing by July 31, 2015. 

 9 The RCA special vulnerabilities questions include serious physical illness, serious mental 

illness, disability, age, pregnancy, and risk based on sexual orientation or gender identity, all of 

which the Standards’ medical screening covers. The RCA special vulnerabilities questions also 

include whether an alien is a victim of persecution or torture, sexual abuse or violent crime, or 

human trafficking. While these cases may require medical attention, the RCA does not instruct 

ERO officers to refer the case to medical staff. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Analysis: We consider ICE’s proposed actions responsive to the intent of 

Recommendation 3, which is resolved and open. 

Management Response: ICE officials concurred with Recommendation 4. ICE 

responded that it will continue to use performance measures to improve RCA 

accuracy, efficiency, and effectiveness. Since initial deployment, ICE has 

measured RCA accuracy, efficiency, and effectiveness by using a variety of 

performance measures. These include field office completion rates, 

recommendation rates by type, decision rates by type, and system override 

rates. 

ICE also conducted rigorous analyses of RCA recommendations and field office 

decisions, cross referencing every crime category and flight risk factor. ICE 

used this data to assess the likely impact of a large number of possible 

changes. Based on this ongoing analysis, as well as input from field offices, ICE 

said it made significant RCA process changes in August 2013 and January 

2014, such as for scoring and decision logic. These changes have reduced 

override rates from 21.9 percent to 7.6 percent for all decisions from January 

to August 2014, and have resulted in RCA recommendations that are more 

closely aligned with ICE’s enforcement priorities. ICE notes the importance that 

some overrides are not only expected, but even desirable. Supervisors must 

maintain the ability to exercise discretion and the RCA requires written 

justifications in cases where recommendations are overridden. 

Further, the principal goals of the RCA are to promote consistency and 

transparency in detention-related decision making and to better align field 

office decisions with ICE policies and priorities. ICE said it disagrees with the 

hypothetical performance measures listed in our report, as the RCA was not 

intended to predict factors such as the likely future rulings of immigration 

judges or a detainee’s ability to pay bond. ICE deployed the most recent set of 

scoring changes in January 2014. Further review of performance measures and 

consideration of additional changes are ongoing. ICE requests that this 

recommendation be considered resolved and closed. 

OIG Analysis: We consider ICE’s proposed actions partially responsive to the 

intent of Recommendation 4, which is resolved and open. ICE should provide 

us documentation on the program analysis it described. Based on ICE’s 

description, the metrics developed focus on whether field officers are 

completing the RCA and whether the RCA’s recommendations match the 

decisions officers would already make. The RCA offers ICE an opportunity to 

use its limited resources more effectively. ICE officials may want to consider 

performance metrics to evaluate how the RCA can provide field officers better 

information or allow officers to work more efficiently. 

Management Response: ICE did not concur with Recommendation 5 in its 

original response. ICE officials responded that in some circumstances, ICE 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

asks the RCA Special Vulnerability questions in field office facilities. ICE said 

that field office facilities are not governed by ICE detention standards. Based on 

ICE’s original response, we clarified Recommendation 5 to apply only when ICE 

conducts the Risk Classification Assessment at a detention facility. We 

provided ICE with an opportunity to modify its original response. ICE modified 

its response and now concurs with Recommendation 5. ICE will ensure that 

controls are in place to ensure that RCA Special Vulnerability assessments 

performed at detention facilities are conducted in a setting that provides 

privacy to the alien being assessed, and in accordance with applicable 

detention standards. ICE said modifications to the RCA would not be necessary 

to implement this recommendation. 

OIG Analysis: We consider ICE’s proposed actions responsive to the intent of 

Recommendation 5, which is resolved and open. ICE should provide us 

documentation on the controls it implements to ensure that RCA Special 

Vulnerability assessments performed at detention facilities are conducted in 

accordance with applicable detention standards. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Transmittal to Action Official 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Scope and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) 

was established by the Homeland Security Act of 2002 (Public Law 107-296) by 

amendment to the Inspector General Act of 1978. This is one of a series of 

audit, inspection, and special reports prepared as part of our oversight 

responsibilities to promote economy, efficiency, and effectiveness within the 

Department. 

We reviewed ICE’s alternatives to detention. Our objectives were to determine 

whether: 

(1) the rate at which individuals in the ISAP II program have committed 

criminal acts or absconded has been reduced since 2009; 

(2) ICE can improve the effectiveness of its alternatives to detention 

program, either by revising or expanding its ISAP II contract, or through 

other cost-effective means; and 

(3) ICE’s release risk assessment tool is effective. 

We conducted field work for this report from April 2013 to April 2014. We 

conducted more than 100 interviews with ICE officials, ICE contractors, 

nongovernmental organizations, and officials from the Department of Justice 

Executive Office for Immigration Review, and the Probation and Pretrial Service 

Office, Administrative Office of the United States Courts. These included inperson and telephone interviews with ERO field office directors, deputies, and 

assistants from 18 of the 24 ERO field offices. We interviewed ERO 

headquarters staff, including detailed field officials to headquarters. We also 

interviewed ICE officials from the Law Enforcement and Statistical Analysis 

Unit. We conducted eight field site visits to interview ERO supervisory and 

nonsupervisory officers. We obtained direct access to the ENFORCE database 

and conducted an independent review of alien records in the ISAP II program, 

and aliens for whom ERO had conducted risk classification assessments. 

We conducted this review under the authority of the Inspector General Act of 

1978, as amended, and according to the Quality Standards for Inspections and 

Evaluation issued by the Council of the Inspectors General on Integrity and 

Efficiency. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

ICE Comments to the Draft Report 

www.dhs.oig.gov 19 OIG-15-22 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Risk Classification Assessment Checklist 

ENFORCE Database 

Tab 

Examples of Data Recorded Data 

Fields 

Person Details x Biographical Information 

x Tracking Information (photos, 

fingerprints, alien number, and 

social security number) 

26 

Encounter Details x Apprehension Information 

x Physical Description 

45 

Supporting Information x Relatives 

x Attorney/Representative 

13 

Summary x Supervisory Approval 11 

Special Vulnerabilities10 x Physical and Mental Illness 

x Victim of Persecution/Abuse 

31 

Mandatory Detention x Subject to Mandatory Detention 

in INA 

x Final Removal Order 

5 

Risk to Public Safety x Most Severe Conviction 

x Disciplinary Infractions 

20 

Risk of Flight x Immigration Violation History 

x Community Ties 

27 

Total Data Fields 178 

Source: ENFORCE. 

 10 A complete list of Special Vulnerabilities questions is included in appendix G. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

ISAP II Termination Rates 

(Full-Service/Technology-Only) 

Contract Year

[November to

November]

2010 2011 2012

FullͲService (FS)

TechnologyͲOnly (TO)

FS TO Total FS TO Total FS TO Total

Total Served 19,996 5,782 25,778 24,047 11,333 35,380 24,359 16,093 40,452

Active in Program (at end of

contract year) 13,429 3,758 17,187 13,862 9,250 23,112 12,611 10,317 22,928

Terminated from Program

(at end of contract year) 6,567 2,024 8,591 10,185 2,083 12,268 11,748 5,776 17,524

Reasons for Termination

Departure Verified (Final

Order of Removal) 999 122 1,121 1,126 203 1,329 923 220 1,143

Relief/Benefit Granted 601 100 701 603 168 771 401 433 834

Departure Verified

(Voluntary Departure) 526 22 548 963 61 1,024 1,087 133 1,220

Departed the United States

while in proceedings 142 1 143 121 5 126 95 9 104

Total Favorable

Outcomes 2,268 245 2,513 2,813 437 3,250 2,506 795 3,301

No Longer Required to

Participate (As determined

by ERO) 2,534 1,110 3,644 5,429 1,033 6,462 7,488 3,904 11,392

Arrested by ICE for Removal 83 65 148 99 63 162 97 95 192

Pending Departure

Verification 183 31 214 147 31 178 160 92 252

Arrested by Other Law

Enforcement Agency 515 61 576 640 89 729 546 159 705

Other (No longer required

to report: medical or

deceased) 120 84 204 133 27 160 161 39 200

Total Neutral

Outcomes 3,435 1,351 4,786 6,448 1,243 7,691 8,452 4,289 12,741

PreͲRemoval Order Program

Absconder 432 59 491 395 40 435 271 59 330

PostͲRemoval Order

Program Absconder 325 111 436 405 142 547 348 173 521

PreͲRemoval Order Program

Violator 61 45 106 107 56 163 156 205 361

PostͲRemoval Order

Program Violator 46 213 259 17 165 182 15 255 270

Total Unfavorable

Outcomes 864 428 1,292 924 403 1,327 790 692 1,482

Source: ISAP II annual reports for contract years 2010 through 2012. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

ISAP II Termination Rates – Percentages 

Contract Year

[November to

November]

2010 2011 2012

FullͲService (FS)

TechnologyͲOnly (TO)

Total Total Total

Total Served 25,778 35,380 40,452

Active in Program (at

end of contract year) 17,187 23,112 22,928

Terminated from

Program (at end of

contract year) 8,591 12,268 17,524

Reasons for Termination

FullͲService (FS)

TechnologyͲOnly (TO) Total Percent Total Percent Total Percent

Departure Verified (Final

Order of Removal) 1,121 13.05% 1,329 10.83% 1,143 6.52%

Relief/Benefit Granted 701 8.16% 771 6.28% 834 4.76%

Departure Verified

(Voluntary Departure) 548 6.38% 1,024 8.35% 1,220 6.96%

Departed the United

States while in

proceedings 143 1.66% 126 1.03% 104 0.59%

Total Favorable

Outcomes 2,513 29.25% 3,250 26.49% 3,301 18.83%

No Longer Required to

Participate (As

determined by ERO) 3,644 42.42% 6,462 52.67% 11,392 65.01%

Arrested by ICE for

Removal 148 1.72% 162 1.32% 192 1.10%

Pending Departure

Verification 214 2.49% 178 1.45% 252 1.44%

Arrested by Other Law

Enforcement Agency 576 6.70% 729 5.94% 705 4.02%

Other (No longer

required to report:

medical or deceased) 204 2.37% 160 1.30% 200 1.14%

Total Neutral

Outcomes 4,786 55.70% 7,691 62.68% 12,741 72.71%

PreͲRemoval Order

Program Absconder 491 5.72% 435 3.55% 330 1.88%

PostͲRemoval Order

Program Absconder 436 5.08% 547 4.46% 521 2.97%

PreͲRemoval Order

Program Violator 106 1.23% 163 1.33% 361 2.06%

PostͲRemoval Order

Program Violator 259 3.01% 182 1.48% 270 1.54%

Total Unfavorable

Outcomes 1,292 15.04% 1,327 10.82% 1,482 8.45%

Source: ISAP II annual reports for contract year 2010 through 2012. 

www.dhs.oig.gov 24 OIG-15-22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Risk Classification Assessment Overrides 

RCA No Recommendation 

Final Decisions 

Detain in 

the 

Custody of 

this 

Service 

Detain, 

Eligible for 

Bond 

Release on 

Community 

Supervision 

Total 

Detain in the Custody of this 

Service 117,291 226 2,157 119,674 

Detain, Eligible for Bond 42,957 17,933 4,002 64,892 

Release on Community Supervision 252 267 1,039 1,558 

Officer to Determine - Detain or 

Release on Community Supervision 17,573 12,010 12,388 41,971 

Totals 178,073 30,436 19,586 228,095 

228,095 Total Decisions and 41,971 with No Recommendation = 18.4 % with No RCA Recommendation11 

RCA Overrides 

Final Decisions 

Detain in 

the 

Custody of 

this 

Service 

Detain, 

Eligible for 

Bond 

Release on 

Community 

Supervision 

Total 

Detain in the Custody of this 

Service 117,291 226 2,157 119,674 

Detain, Eligible for Bond 42,957 17,933 4,002 64,892 

Release on Community Supervision 252 267 1,039 1,558 

Officer to Determine - Detain or 

Release on Community Supervision 17,573 12,010 12,388 41,971 

Totals 178,073 30,436 19,586 228,095 

228,095 Total Decisions and 49,861 with ERO Overrides = 21.9 % with ERO Overrides12 

Source: ICE RCA Cumulative Report, December 2013. 

 11 Between January 2014 and August 2014, the no recommendation rate was 15.7 percent. 

12 Between January 2014 and August 2014, the override rate was 7.6 percent. ICE officials said 

they reduced the override rate by adjusting the RCA’s scoring and decision logic.

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G 

Medical Screening and Special Vulnerabilities 

Checklists 

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Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

RCA: Special Vulnerabilities 

ENFORCE TABS 

Data Fields 

Does a Special Vulnerability exist? Inquire, observe, and review all documentation. If based on your 

assessment, the vulnerability exists, select the appropriate boxes below. 

Serious Physical Illness (Yes/No) 

Assess whether the individual has been diagnosed or claims to have a serious physical illness such as: 

diabetes, seizures, HIV AIDS, heart problems, cancer, epilepsy, or other serious illness. 

Ask: x Has the individual been hospitalized in the past six months? 

x Is the individual taking prescription medication? 

x Does the individual require daily medical care? 

x Is the individual terminally ill? 

Review sources of information including: medical records or prescription medications, information on I-794 

or I-795 or other medical intake screening documents. 

Serious Mental Illness (Yes/No) 

Assess through questioning, observation and documentation whether the individual has or claims to have a 

serious mental illness. 

Ask: x Has the individual been hospitalized or treated for mental illness? 

x Is the individual taking medication for mental illness? 

Observe: x Did the individual appear to be disoriented? 

x Does the individual appear to be aware of his/her surroundings? 

x Is the individual unable to focus on instructions? 

x Is the individual hearing voices? 

x Is the individual expressing irrational or violent thoughts towards themselves or 

others? 

Disabled (Yes/No) 

Assess whether the individual has a serious physical or mental disability. 

Ask: x Does the individual require assistance with the activities of daily living, such as 

bathing, eating, toileting, and dressing? 

Observe: x Does the individual use a wheelchair, cane, crutches, walker or have a prosthesis? 

x Is the individual blind, deaf, mute, an amputee, or have other disabilities? 

Elderly (Yes/No) 

Assess whether the individual has physical indicators of infirmity or fragility caused by old age. Although 

elderly status is often defined as being 65 years or older, the key issue is whether the individual is infirm 

due to old age (some under 65 may meet that definition and some 65 or older may not). 

Pregnant (Yes/No) 

Ask female individuals if they are currently pregnant or have reason to believe they are pregnant. 

Nursing (Yes/No) 

Ask female individuals if they are currently nursing an infant/toddler. 

Source: ENFORCE. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

RCA: Special Vulnerabilities 

ENFORCE TABS 

Data Fields 

Does a Special Vulnerability exist? Inquire, observe, and review all documentation. If based on your 

assessment, the vulnerability exists, select the appropriate boxes below. 

Primary Caretaking Responsibility (Yes/No) 

Ask the individual if he/she is the primary person responsible for the care of a child, elderly person or an 

individual who otherwise is unable to care for him or herself. If the response is positive, inquire about the 

circumstances regarding that dependent, such as: relationship, age, nature of infirmity, and who is currently 

caring for that dependent. 

Risk Based on Sexual Orientation/Gender Identity (Yes/No) 

Ask the individual if he/she fears any harm in detention based on his/her sexual orientation or gender 

identity. 

Victim of Persecution/Torture (Yes/No) 

In making your assessment, consider country of origin, documentation of claim, and evidence of trauma. 

Note: If the individual answers positively, provide the detainee with the number for UNHCR: 1-888-272-

1913. 

Ask: x Were you persecuted in your home country, or have you been tortured? 

Note: x If the individual answers positively, provide the detainee with the number for 

UNHCR: 1-888-272-1913. 

Victim of Sexual Abuse or Violent Crime (Yes/No) 

Review any evidence substantiating the claim. Note: If the individual answers positively, provide the detainee 

with number for the federally funded National Domestic Violence Hotline: 1-800-799-7233 which can also 

assess eligibility for U visas. 

Ask: x Have you been the victim of sexual abuse or violent crime? 

Note: x If the individual answers positively, provide the detainee with number for the 

federally funded National Domestic Violence Hotline: 1-800-799-7233 which 

can also assess eligibility for U visas 

Victim of Human Trafficking (Yes/No) 

Verbatim what is in the Ask: and Note: fields 

Ask: x Since entering the United States, has someone intimidated, deceived, obligated 

or forced you into prostitution or labor against your will? 

Note: x If the individual answers positively, contact the local ICE HSI duty agent and 

provide biographic and location details to the ICE HSI duty officer for further 

investigation. 

Other (Yes/No) 

If you believe individual would be vulnerable in detention for a reason not listed here, check this box and 

provide further details below. 

Source: ENFORCE. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix H 

Major Contributors to This Report 

Marcia Moxey Hodges, Chief Inspector 

Lorraine Eide, Lead Inspector 

Jennifer Kim, Inspector 

Morgan Ferguson, Inspector 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix I 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Director, U.S. Immigration and Customs Enforcement 

Chief Privacy Officer 

ICE Audit Liaison 

U.S. Department of Justice 

GAO/OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.dhs.oig.gov 32 OIG-15-22 
 

 

 


 

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Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on 

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on the red "Hotline" tab. If you cannot access our website, call our hotline at 

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