Department of Homeland Security 

Office of Inspector General 

Efforts to Detect and Deter Fraud 


Committed by Immigration Services 


Officers 


OIG-10-118 September 2010 
Office ofInspector General

U.S. Department of Homeland Security

Washington, DC 20528

SEP 1 5 2010

Homeland

Security

Preface

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

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment

to the Inspector General Act of1978. 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.

This report addresses the strengths and weaknesses of the effort to prevent fraudulent and

criminal activity by Immigration Services Officers at U.S. Citizenship and Immigration

Services. It is based on interviews with employees and officials of relevant agencies and

institutions, direct observations, and a review of applicable documents.

The recommendations herein have been developed to the best knowledge available to our

office, and have been discussed in draft with those responsible for implementation. We

trust this report will result in more effective, efficient, and economical operations. We

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Richard L. Skinner

Inspector General
Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 

Background..........................................................................................................................2 

Results of Review ................................................................................................................3 

OSI’s Progress on Employee Reporting Can Be Further Promoted..............................3 

Recommendation ...........................................................................................................5 

Management Comments and OIG Analysis ..................................................................6 

The Effectiveness of Wall Posters Can Be Increased....................................................6 

Recommendation ...........................................................................................................8 

Management Comments and OIG Analysis ..................................................................8 

Greater Interaction Is Needed Between OSI and Field Offices.....................................9 

Recommendation .........................................................................................................11 

Management Comments and OIG Analysis ................................................................11 

The Integrity Coordinating Committee Should Include Field Representatives...........11 

Recommendation .........................................................................................................12 

Management Comments and OIG Analysis ................................................................12 

Policy Focus on Employee Discipline Would Be Beneficial ......................................12 

Recommendation .........................................................................................................13 

Management Comments and OIG Analysis ................................................................13 

Training Should Present More Examples of Misconduct............................................14 

Recommendation .........................................................................................................15 

Management Comments and OIG Analysis ................................................................15 

Appendixes 

Appendix A: Purpose, Scope, and Methodology.......................................................16 

Appendix B: Management Comments to the Draft Report.......................................17 

Appendix C: Fifteen Examples of Misconduct That Must Be Reported...................20 

Appendix D: The Survey of Service Center ISOs.....................................................21 

Appendix E: Major Contributors to This Report ......................................................24 

Appendix F: Report Distribution ..............................................................................26 

Abbreviations 

DHS Department of Homeland Security 

FSM Field Security Manager 

ICC Integrity Coordinating Committee 

ISO Immigration Services Officer 

LSO Local Security Officer 

OIG Office of Inspector General 
 

OSI Office of Security and Integrity 

USCIS United States Citizenship and Immigration Services 

I 
OIG
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

United States Citizenship and Immigration Services processes 

immigration benefit applications and petitions. Immigration 

Services Officers, who process benefit requests, sometimes commit 

fraudulent activities, such as accepting bribes or other favors in 

exchange for immigration benefits. The Office of Security and 

Integrity, created in 2007, leads the effort to detect and deter 

employee misconduct. 

We evaluated current programs that detect and deter Immigration 

Services Officer malfeasance. Through numerous interviews with 

all levels of employees, and an online survey of 292 adjudicators 

selected at random, we gathered a wide variety of observations and 

suggestions regarding employee misconduct. As we examined the 

office’s current practices, we identified ways to enhance training and 

promote the Office of Security and Integrity mission. 

Although the current training program has emphasized employees’ 

ethical responsibilities, a renewed directive from the uppermost 

managers on the existing requirement to report possible misconduct 

would further strengthen the effort. Greater interaction between the 

Office of Security and Integrity and the offices that process benefit 

applications would provide new perspectives on preventing 

employee fraud. We are making six recommendations to improve 

the Office of Security and Integrity’s overall efforts to counter 

employee misconduct. 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Background 

United States Citizenship and Immigration Services (USCIS) 

processes applications for immigration and citizenship benefits. 

With a staff of 10,700 full-time employees and an annual budget of 

approximately $2.6 billion, USCIS processes six million 

applications for immigration benefits each year. This makes 

USCIS the largest immigration service in the world.1 Benefit 

applications are processed in four large service centers, at the 

National Benefits Center, at 26 district offices throughout the 

country, and at 46 field offices that are district subcomponents. 

Each day, these offices issue approximately 7,300 lawful 

permanent resident benefits and naturalize 3,400 new citizens.2 

Benefit applications are also processed abroad. However, we did 

not review foreign offices, as this was outside the scope of our 

assessment. 

Immigration Services Officers (ISOs), also known as adjudicators, 

process benefit requests. Some adjudicators have committed 

fraudulent activities, such as accepting bribes or other favors in 

exchange for favorable case determinations. Since 2007, 10 

USCIS employees or contractors have been convicted of criminal 

acts. We did not receive timely information regarding the number 

of instances of alleged employee misconduct in the first quarter of 

2010. 

The most notable occurrence of ISO fraud was the Robert 

Schofield case. Schofield was a supervisory adjudicator who, over 

an 8-year period, falsified documents and received more than 

$600,000 in bribes. Upon his conviction in April 2007, he was 

sentenced to 15 years in prison for bribery and falsifying 

naturalization certificates. Other adjudicators have been sentenced 

for sexual assault, inappropriately accessing official information, 

and other offenses. 

The Office of Security and Integrity (OSI), created in 2007, leads 

the USCIS effort to deter and detect employee misconduct. OSI’s 

mandate includes other duties, such as administering the USCIS 

personnel, physical, and administrative security programs. The 

Field Operations and Service Center Operations Directorates, 

which oversee the offices and centers that process benefits, are 

outside of OSI’s chain of command, as illustrated in Figure 1. 

1 http://www.uscis.gov/files/nativedocuments/operations_data.pdf 2 http://www.uscis.gov/files/nativedocuments/dayinthelife.pdf 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Figure 1. Abbreviated USCIS Organization Chart 

Adjudicator misconduct can affect national security. For example, 

as many as 700 persons were inappropriately given immigration 

benefits as a result of Schofield’s illicit schemes. Relatives of an 

individual who receive benefits through USCIS employee fraud 

may subsequently appear to be eligible for their own immigration 

benefits. This can create a cascading effect of fraud. OSI has 

worked with the USCIS Office of Transformation to improve 

information systems and identify those parts of the immigration 

process that adjudicators could exploit with the intent to use their 

position inappropriately. 

Results of Review 

OSI’s Progress on Employee Reporting Can Be Further Promoted 

The USCIS Director Should Reiterate OSI Reporting Policy 

OSI is logically positioned within USCIS as part of the 

Management Directorate. It has an enterprise-wide perspective 

and provides recommendations for improving all USCIS 

operations, not just those of the Field and Service Center 

Directorates. 

For an employee wishing to report a colleague’s suspicious 

behavior, OSI serves as an entity outside the employee’s chain of 

command, to which the employee can anonymously report 

suspicious activities. OSI has established a reporting system that 

allows for an OSI or Office of Inspector General (OIG) 

investigation of misconduct allegations submitted by employees. 

Giving employees an opportunity to notify OSI of a colleague’s 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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suspicious behavior is central to program integrity. Many of our 

interviewees said that the Schofield case became so serious 

because individuals who knew of his questionable actions did not 

wish to confront him because he had supervisory authority. 

OSI’s reporting policy is clear. In an August 2009 memo to all 

USCIS employees, the Chief of OSI informed employees of their 

duty to report suspicious behavior or possible illicit activities. The 

memo provides 15 examples of misconduct “that must be reported 

immediately” to OSI or through the Department of Homeland 

Security (DHS) OIG Hotline. These improper behaviors include 

bribery, theft, and a range of actions that constitute a misuse of 

official position. Appendix C lists the 15 behaviors. OSI policy 

does not limit required reporting to these 15 examples. 

However, OSI’s position outside of the chain of command of 

adjudicators can inhibit some reporting. As part of our fieldwork, 

we conducted an online survey of 292 service center adjudicators. 

The survey results provide perspective on the implementation of 

OSI’s reporting policy. Although 77% of survey respondents said 

that they would report suspicious activity, we found a range of 

opinions about where and how to report suspicious activity. Many 

employees do not understand that the policy specifically requires 

reporting outside of their management. Various interviewees and 

survey respondents said that USCIS has a rigid culture that stresses 

the local chain of command. Therefore, adjudicators have a 

natural tendency to report alleged misconduct to their own 

supervisors, rather than to OSI. Some survey respondents 

expressed confusion about where allegations of misconduct should 

be directed: 

“Additional guidance needs to be made if the person in question is a 

supervisor. Should the person go directly to [OSI or the] OIG or 

should they go to the next person up the chain of command to discuss 

this issue?” 

“I am not readily aware of the reporting protocol . . . I do not know 

who internally one would report concerns to, other than through my 

supervisor. I do feel confident that if faced with such a situation, I 

could find out who to contact through local management.” 

Some Field Security Managers (FSMs), OSI employees who work 

at benefit processing offices, said that local management may 

prefer that allegations be reported through supervisory channels. 

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These FSMs said that they would hesitate to clarify the reporting 

policy if local management did not stress the reporting scheme 

required in the August 2009 memo. Other FSMs said that field 

offices give employees an option to report to local management, or 

that the OSI reporting system was secondary if a district preferred 

that allegations go through an adjudicator’s field managers. Our 

survey confirmed that many employees are more comfortable 

reporting to their own supervisor. Even though most adjudicators 

understood the allegation reporting policy, 22% of respondents 

answered that they would be very uncomfortable reporting 

allegations without first contacting a supervisor. Such a 

perspective is contrary to the immediate reporting duty established 

in USCIS policy. 

An issue that relates to the reporting policy arose in many of our 

interviews and survey results: the protection of employees who 

report suspected misconduct from hostility and retribution. As 

with the reporting issue, we identified a range of opinion on what 

retribution or hostility an employee might suffer after reporting a 

colleague’s suspicious behavior. Many adjudicators stated that 

they would hesitate to report misconduct because of the negativity 

surrounding whistleblowers. Based on our survey results, 33% of 

the responses indicated a fear that USCIS culture, which is focused 

on processing applications and adhering to the chain of command, 

would not support an informant. Various staff expressed concern 

about reporting misconduct, even though OSI’s reporting process 

can be anonymous. 

It is likely that the employees who expressed hesitancy and feared 

retribution were imagining themselves reporting one colleague to 

another, rather than making an anonymous report to OSI. 

Nevertheless, the range of opinion was too wide to ensure that 

employees feel empowered to report their suspicions. 

The Director of USCIS should reiterate the reporting policy that 

OSI articulated in the August 2009 memo. This would help 

employees understand that reporting allegations to OSI or the OIG 

is the officially sanctioned process instead of reporting to a 

colleague or a superior. 

Recommendation 

We recommend that the Director, U.S. Citizenship and Immigration 

Services: 

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Recommendation #1: Issue guidance to all field offices that reiterates 

USCIS employee reporting responsibilities as discussed in the August 

2009 Office of Security and Integrity memorandum. 

Management Comments and OIG Analysis 

USCIS concurred with all of our 6 recommendations. We evaluated 

written comments we received from OSI and made changes where 

appropriate. A summary of the USCIS response to our recommendations 

and our analysis is included below. A copy of the entire USCIS response 

is included as Appendix B. 

Additional information that discusses actions taken on the 

recommendations should be included in the USCIS corrective action plan 

due within 90 days of the issuance of this report. 

Management Comments to Recommendation #1 

USCIS concurred with this recommendation. In the fourth quarter of Fiscal 

Year 2010, the USCIS Director will send quarterly messages to employees 

about the importance of and procedures for reporting possible misconduct. 

OIG Analysis 

Messages from the Director of USCIS will be an important means to 

informing employees about the need to report misconduct. This 

recommendation is resolved and open pending receipt of the first quarterly 

message on the reporting of alleged misconduct. 

The Effectiveness of Wall Posters Can Be Increased 

OSI has created a range of posters to remind employees of the 

importance of ethical conduct and the need to inform OSI about 

allegations of employee misbehavior. The posters create and maintain 

employee awareness about their responsibilities and the important role 

of each employee in protecting the integrity of USCIS programs. 

Posters usually include information on how to report employee 

misconduct or security violations to OSI. OSI makes available on its 

intranet site guidance to staff about displaying posters. Next to two 

misconduct-reporting posters on OSI’s website, a message notes: 

“Prominently display this poster in all USCIS spaces not open or visible 

to the public.” 

In our survey, 64% of the respondents said that they do not notice 

posters during their daily activities at the four service centers. Only 3% 

reported that there are a number of highly visible posters in their work 

environment. We visited various district offices and noticed that OSI 

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posters are not always prominently displayed. In some offices, we saw 

only smaller versions of a reporting poster, the larger version of which 

we saw in the OSI Office of Investigations headquarters. While visiting 

one office, we did see the large version of the poster, but it was located 

outside of the FSM’s office in an infrequently used side hallway. The 

size and placement of OSI posters could be enhanced in most USCIS 

field offices to ensure that employees have reminders about their ethical 

and reporting responsibilities. 

Posters highlighting the cases of convicted USCIS employees could 

further develop ethics and reporting messages. Employees would 

become aware of the criminal conduct of their former colleagues and the 

punishment received. Posters that feature specific, convicted 

adjudicators could be more meaningful for some employees than general 

directives to report suspicious activities. 

Other federal agencies have used incidents of criminal employee 

conduct as a training tool. For example, the Office of the National 

Counterintelligence Executive, part of the Office of the Director of 

National Intelligence, has created such posters. Figure 2 is a poster that 

discusses Robert Hanssen, a Federal Bureau of Investigation employee 

who provided U.S. security information to the Soviet Union for 22 

years. Hanssen is now serving a life sentence for betraying his country. 

Figure 2. Robert Hanssen Conviction Poster 

Source: Office of the National Counterintelligence Executive 

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One survey respondent suggested that USCIS create such posters to 

inform employees about the cost of violating the public trust. The 

respondent suggested that OSI— 

“Make a poster showing actual Officers/Managers who have 

been caught and sent to prison. The poster would have them 

holding their prisoner number card, would briefly describe 

the offense committed, and the sentence given.” 

This type of poster would instill a powerful message. OSI should create 

such posters to augment ethics and reporting lessons. 

Recommendation 

We recommend that the Chief, Office of Security and Integrity, in 

consultation with the Associate Directors of the Field Operations and 

Service Center Operations Directorates: 

Recommendation #2: Create and display posters that describe the crimes 

and sentences of convicted USCIS employees as a means to facilitate 

ethics and promote misconduct reporting. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #2 

USCIS concurred with this recommendation. Based on the work of the 

Convictions Task Force, USCIS will create the posters envisioned in this 

recommendation. These posters will serve to reiterate employee reporting 

procedures. USCIS will work with counsel to ensure that the crimes are 

limited to those committed in the workplace, that USCIS does not violate 

privacy laws, and that publication of conviction details will not expose 

USCIS to liability. 

OIG Analysis 

We support USCIS’s continued efforts to learn from the expert analysis 

gained from task forces. The posters can be an important learning tool 

while protecting rights of convicted individuals. This recommendation is 

resolved and open. We anticipate closure after receiving examples of 

posters and related educational materials sent to USCIS field managers. 

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Greater Interaction Is Needed Between OSI and Field Offices 

Task Forces That Study Previous Convictions Add Value 

OSI uses task forces to examine previous cases of employee fraud 

and identify (1) how such conduct was possible and (2) corrective 

actions to lessen the chance of further malfeasance. Because of 

operational improvements that task forces identified, USCIS 

employees said it is less likely that adjudicators could hide illicit 

activities: There is much better control over an adjudicator’s work, 

including the tracking of building access, greater security over 

naturalization certificates, and random assignment of cases. 

USCIS employees we interviewed and surveyed said that the risk 

of adjudicator misconduct has dropped significantly over the past 

few years. 

During our fieldwork, a convictions task force held its first 

meeting to begin an examination of 10 cases where employee fraud 

led to criminal convictions. As with the task force that examined 

the Schofield case, OSI managers expect that the convictions task 

force will help to diminish the threat of employee fraud through 

process improvements. Another task force had previously 

examined how USCIS can better control adjudication stamps, 

which officially mark the status of particular benefit applications. 

Full control over access to facilities, naturalization certificates, and 

adjudication stamps can inhibit an adjudicator’s ability to grant 

benefits improperly. 

Field Security Managers Can Be More Thoroughly Supported 

OSI needs to work with leadership in service centers and district 

offices to deter employee fraud. A work environment that inhibits 

fraud is the most effective way to protect USCIS customers and 

impede an employee’s fraudulent schemes. 

The FSM is the OSI official in each district office or service 

center. FSMs oversee security management practices in their 

entire district, including access control, protection of sensitive 

property, and threat management. Although FSMs cannot focus 

exclusively on employee misconduct, the relationship between 

FSMs and field office management is important to fostering a 

climate where adjudicators are comfortable talking to OSI. 

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FSMs offered a range of opinion on their ability to bring change to 

USCIS operations. Some FSMs view themselves as part of the 

district staff, and attend local management meetings. Other FSMs 

said that local managers view OSI’s presence as a burden. One 

even suggested that it is a “constant battle” to keep staff informed 

about security procedures because of an inability to gain office 

management’s respect for the FSM’s role. FSMs we met who felt 

less integrated into the management of their office suggested that 

OSI’s organizational position outside of the benefit processing 

chain of command leads district managers to believe that OSI does 

not contribute to the core function of the office: processing cases. 

Office managers believe that their production numbers are central 

to how headquarters views the office. 

FSMs expressed some frustration with the Local Security Officer 

(LSO) program. The LSO is a field office employee, usually a 

senior adjudicator or mission support specialist, with security as a 

collateral duty. LSOs are not OSI employees, but they have a 

range of duties related to security and must work with the FSM to 

facilitate OSI’s security management mission. District office 

FSMs oversee the work of, but do not supervise, the LSOs in the 

field offices. FSMs reported that it is difficult to have sufficient 

time with an LSO during visits to field offices, mainly because 

LSOs have other duties, such as processing benefit applications, 

which are a higher priority for district leadership. This makes a 

true partnership difficult and hinders the oversight of an office’s 

security procedures, including access and information control that 

can be important steps to detecting an adjudicator fraud scheme. 

Some FSMs in districts that cover larger geographic areas said that 

they are unable to monitor all field office locations effectively. 

The FSMs generally said that LSOs, as employees of the district 

office, will allow OSI security efforts to wane rather than fall 

behind on adjudications or other regular work. An LSO’s 

adjudication or office support functions can make it difficult for 

FSMs to spend enough time with the LSO to ensure that all 

security procedures are implemented. 

Some FSMs suggested that more LSOs should be focused 

exclusively on security and employee training functions. During 

the annual budget process, OSI has requested that field offices 

provide full-time LSOs, rather than individuals who have other 

duties. FSMs need reliable local partners to perform the tasks now 

assigned to LSOs. With a revitalized LSO program, the FSM 

could expand work in ethics, reporting, and compliance training. 

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This expansion would be a way for OSI to foster additional 

collaboration within the district and field offices. 

Recommendation 

We recommend that the Chief, Office of Security and Integrity, in 

consultation with the Associate Directors of the Field Operations and 

Service Center Operations Directorates: 

Recommendation #3: Redefine the Local Security Officer position to 

ensure that collateral security duties are completed in consultation with the 

Field Security Manager. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #3 

USCIS concurred with this recommendation. The Chief of OSI is reviewing 

a draft management directive that will improve the LSO program. 

Collaboration with Field Security Managers will be emphasized in this new 

policy, which will be the first official USCIS guidance on LSO duties. The 

policy is designed to serve as a reference for FSMs as they work with LSOs 

to improve security procedures. 

OIG Analysis 

This is a credible step that should improve the relationship between OSI 

and USCIS district and field offices. This will have positive effects on 

overall security, and should provide opportunities for FSMs to interact 

with field office staff. This recommendation is resolved and open pending 

finalization of the management directive. 

The Integrity Coordinating Committee Should Include Field 

Representatives 

OSI has established an Integrity Coordinating Committee (ICC) to create 

ethics training and review policy. The ICC, which meets several times a 

year, includes representatives from 10 headquarters offices, including OSI. 

The committee’s facilitator said that the ICC’s collaborative approach 

provides the views of operational components on various OSI programs. 

Their insight has improved training sessions and fostered better 

relationships. 

The committee does not have representation from regional or district 

managers, although field leadership is vital to the implementation of OSI’s 

mission. None of the field leaders we interviewed knew of the ICC’s 

existence. Creating seats on the ICC for local managers would integrate 

field staff in the creation and implementation of OSI policies. Because of 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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the local viewpoints that district managers could offer, seats on the ICC 

for service center and district office managers would encourage greater 

cooperation between USCIS field operations and OSI. Increasing the 

number of ICC members would not require a major expansion of seats on 

the committee. One new seat for each of USCIS’s four regions, for 

example, would allow local managers to advise the ICC on local 

perspectives. 

Recommendation 

We recommend that the Chief, Office of Security and Integrity: 

Recommendation #4: Include Regional Office representatives on the 

Integrity Coordinating Committee. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #4 

USCIS concurred with this recommendation. In May 2010, USCIS field 

management was invited to join the ICC, which led to regional office 

representation in ongoing Committee activities. 

OIG Analysis 

This is another positive step that should improve OSI’s relationships with 

USCIS field offices. The USCIS Intranet has not been updated to reflect 

the expanded membership on the ICC. This recommendation is resolved 

and open, with closure expected after we have been provided a revised 

ICC membership list. 

Policy Focus on Employee Discipline Would Be Beneficial 

Proper discipline for employees and contractors who engage in 

misconduct is an important part of an effective integrity program. Some 

of the staff we interviewed believed that many employee misconduct cases 

did not result in penalties severe enough to instill respect for the USCIS 

ethics and integrity message. The Schofield task force suggested that 

mandatory removal or reassignment be instituted for some offenses, but 

this policy was not adopted. 

In employee misconduct cases resulting in administrative punishments, 

local managers and USCIS human resources personnel, rather than OSI, 

determine employee punishment. In the OSI investigative case files we 

reviewed, field leaders received reports from OSI investigations and were 

asked to take whatever disciplinary action they deemed necessary. 

Because they select and enforce the discipline imposed on noncriminal 

misconduct, district directors and other managers in field offices are 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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essential to making ethics and integrity an enduring part of the USCIS 

culture. 

A process is under way to update a table of penalties that can guide 

managers in making disciplinary decisions. OSI expects that this new 

information will provide for more consistent and supportable discipline 

decisions. Field managers need such guidance to ensure more reasonable 

and consistent disciplinary decisions. Employees and contractors prone to 

misconduct must be seen as threats to USCIS program integrity. Although 

OSI is involved in credible work to shift the existing paradigm, the 

Director of USCIS must reiterate this message. The Director of USCIS is 

best positioned to inform operational offices of agency expectations. As 

the new table of penalties is created, USCIS must also provide regular 

information to all managers about the types of misconduct that led to 

disciplinary action, in addition to the expected discipline for particular 

offenses. By sharing more information about discipline cases and 

ensuring that actions are taken that might deter future misconduct, USCIS 

will create a climate of respect for its employee integrity initiatives. 

Recommendation 

We recommend that the Director, U.S. Citizenship and Immigration 

Services: 

Recommendation #5: Create guidance reports for field managers related 

to the disposition of employee misconduct cases and the expected 

penalties for various types of misconduct. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #5 

USCIS concurred with this recommendation. A new management directive, 

which included a revised table of penalties, was released in June 2010. This 

new policy includes an expanded section related to OSI’s focus on ethics and 

integrity. Efforts are also being made to reconfigure a database to improve 

information sharing related to employee discipline. These changes will allow 

managers to consult reports related to disciplinary actions taken against 

employees. 

OIG Analysis 

Consistent and credible employee discipline is an important step toward 

deterring employee misconduct. This recommendation is closed. No 

further reporting is necessary. 

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Training Should Present More Examples of Misconduct 

OSI’s current training program was designed to deter workplace 

misconduct. Various tools inform employees of ethical expectations, 

including videos of Robert Schofield discussing his crimes and the 

consequences. OSI uses this video of Schofield in jail to stress that there 

is no place for criminal activities at USCIS. Other training materials 

include the August 2009 OSI Memo on Reporting Allegations of 

Misconduct or Other Inappropriate Behavior, and the “Integrity Begins 

with You” booklet. Also, small laminated cards (in Figure 3), designed to 

be carried by employees, include important ethical guidelines. 

Figure 3. Laminated Pocket Card

 Front view Rear view 

Source: OSI website 

Most USCIS staff we interviewed believe that the current training program 

is good, and that OSI’s general message is reaching its target audience. 

One supervisor said that her subordinates tend to explain their actions to 

avoid the appearance of impropriety. USCIS employees also suggested 

ways to improve training frequency, content, and use of visual learning 

tools. Most USCIS staff we interviewed had seen the Schofield video. 

Employees agreed that, while the video provided a shocking look at how a 

supervisor committed fraud and the consequences, it may lose some of its 

effectiveness over time. Some staff expressed an interest in viewing 

videos featuring more recent convictions, or cases with local connections. 

It was suggested that when employees view misconduct cases involving 

employees most like themselves, the educational benefit is greater. 

OSI is updating the training program in cooperation with USCIS’ ethics 

office. Training podcasts are being created and made available on the OSI 

website. Some of the podcast topics, such as the appropriate employee 

response if offered a bribe, are directly relevant to the adjudications 

process. Our fieldwork suggested, however, that additional work is 

needed to focus on a variety of adjudication scenarios when the correct 

ethical choice is less clear. 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Several interviewees suggested that additional guidance is needed in areas 

where fraud concerns are not obvious. Adjudicators expressed an interest 

in receiving additional information on handling gray-area situations. An 

example of such a case appears below. 

An adjudicator is attending a family reunion. A relative 

approaches to say that his girlfriend is trying to become a U.S. 

citizen and the application is pending. She has not heard anything 

from USCIS. The relative wants to know if the adjudicator can 

check on the status of the application. 

Although adjudicators have access to secure files and databases, they are 

prohibited from checking on the status of an application not related to their 

official duties. As OSI is developing more scenario-based training, it is 

important to ensure that new information is directly relevant to choices 

that adjudicators may face when the correct solution may not be obvious. 

Recommendation 

We recommend that the Chief, Office of Security and Integrity: 

Recommendation #6: Update the current training program to include 

recent examples of employee misconduct and scenarios to address less 

obvious forms of misconduct. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #6 

USCIS concurred with this recommendation. Rollout of the revised training 

program is slated for September 2010. USCIS will be including scenarios 

designed to provide real-life examples for Immigration Services Officers. 

The training can be modified to ensure employees receive further instruction 

on misconduct issues as a way to expand OSI’s educational efforts. 

OIG Analysis 

OSI’s work to create a dynamic and relevant training program is a very 

important step to fostering a culture of ethical conduct. USCIS employees 

provided a variety of suggestions on ways to make the training program 

more interesting and informative. This recommendation is resolved and 

open, with closure expected after receipt of updated training materials. 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix A 

Purpose, Scope, and Methodology 

We initiated this review to determine USCIS’ efforts to prevent 

adjudicator misconduct. We reviewed USCIS polices, data, and 

investigation reports. Our fieldwork did not include a review of 

how the OSI Office of Investigations tracks employee misconduct 

cases after allegations are reported. 

We conducted 82 interviews, including Immigration Service 

Officers, district and field office personnel, and OSI managers. 

We visited seven district offices, one service center, and one 

regional office. We interviewed Field Security Managers in all 

four USCIS regions. 

Our analysis included results from an online survey that was sent 

to 25% of Immigration Service Officers at the four USCIS service 

centers. We received 292 responses, a 67% response rate. A 

majority of the respondents had been adjudicating cases for more 

than 5 years. Survey questions dealt with ethics training, the 

visibility of ethics posters, whistleblowers, and USCIS 

vulnerability to employee misconduct. The results of the survey 

are discussed throughout the report; the survey appears in 

Appendix D. 

We conducted our review between January and April 2010 under 

the authority of the Inspector General Act of 1978, as amended, 

and according to the Quality Standards for Inspections issued by 

the President’s Council on Integrity and Efficiency. 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix B 

Management Comments to the Draft Report 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix B 

Management Comments to the Draft Report 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix B 

Management Comments to the Draft Report 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix C 

Fifteen Examples of Misconduct That Must Be Reported 

•	 Fraud, corruption, bribery, and embezzlement; 

•	 Theft or misuse of funds and theft of government property 

•	 Perjury 

•	 Physical assault 

•	 Unauthorized release of classified information 

•	 Drug use/possession 

•	 Unauthorized use/misuse of sensitive official government databases 

•	 Misuse of official position for private gain 

•	 Misuse of a government vehicle or property 

•	 Failure to properly account for government funds 

•	 Unauthorized use/misuse of a government purchase or travel card 

•	 Falsification of travel documents 

•	 Falsification of employment application documents 

•	 Misconduct by an employee at the GS-15 level or higher 

•	 Arrest of an employee or contractor by law enforcement personnel, including your 

own arrest 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix D 

The Survey of Service Center ISOs 

1.	 How long have you been an ISO/adjudicator for USCIS/INS? 

Number Percent 

Less than 1 year 5 1.7% 

More than 1 but less than 3 years 111 38.4% 

More than 3 but less than 5 years 18 6.2% 

More than 5 but less than 10 years 97 33.6% 

More than 10 years 58 20.1% 

2. At which Service Center do you currently work? 

Number Percent 

California 74 25.7% 

Nebraska 84 29.2% 

Texas 55 19.1% 

Vermont 75 26.0% 

3.	 How well-trained do you feel about the ethical and legal expectations that have 

been placed on you? 

Number Percent 

I feel very confident that I have 

received sufficient training regarding
 

the expectations placed on me 151 52.2% 

I have received sufficient information 

and guidance 107 37.0% 

I would like to receive additional 

information and guidance 28 9.7% 

I am not trained at all on the expectations 

placed on me 3 1.0% 

4.	 How much additional support is needed from USCIS and OSI for the Service to 

better detect possible criminal activity and fraud committed by ISOs? 

Number Percent 

A tremendous amount 11 3.8% 

Some, but good progress is being made 76 26.4% 

I’m fully confident that USCIS and OSI are 

taking appropriate steps 132 45.8% 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix D 

The Survey of Service Center ISOs 

I’m not sure 69 24.0% 

5.	 Have you ever been placed in an ethically compromised position related to your 

official duties (e.g., a neighbor asking you for a favor or another individual 

pressuring you to approve a petition?) 

Number Percent 

Yes 38 13.2% 

No 250 86.8% 

6.	 The Office of Security and Integrity has provided posters for USCIS offices for 

purposes of ensuring that OSI reporting information is visible to employees. 

What is your assessment of the number and visibility of posters at your Center 

in work areas, break rooms, and other common areas? 

Number Percent 

There are a number of highly visible 

posters around the Center 9 3.2% 

There are enough visible posters to make 

OSI reporting information visible on a 

regular basis to employees 66 22.8% 

Posters are displayed in certain areas, 

but they are relatively small and not easy 

to read 28 9.7% 

I do not notice posters much during the 

course of my daily activities 186 64.4% 

7.	 Have you experienced difficulty with OSI when reporting possible improper 

activities or criminal activity committed by ISOs? 

Number Percent 

Yes 2 0.7% 

No 19 6.6% 

I have not reported any 267 92.7% 

8.	 Have you observed suspicious or unusual behavior from a supervisor or 

colleague that you believed could indicate unethical or illegal activity? 

Number Percent 

Yes 25 8.7% 

No 234 81.0% 

I have not observed such behavior 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix D 

The Survey of Service Center ISOs 

personally but other ISOs have told me
 

that they have observed such behavior 30 10.4% 

9.	 Do you believe that the USCIS culture supports “whistleblowers,” those 

individuals who report possible malfeasance, fraud, or unusual/unexpected 

actions committed by supervisors or ISOs? 

Number Percent 

Yes 191 66.8% 

No 95 33.2% 

10. If you suspected that a colleague was accepting a bribe or engaged in other 

illegal conduct, how comfortable would you be reporting your suspicions to OSI 

or the Office of Inspector General? 

Number Percent 

I would be fully comfortable 104 36.0% 

It would make me somewhat uncomfortable, 

but I would report the information directly to 

OSI or the OIG without any problem 120 41.5% 

I would feel very uncomfortable reporting 

information without first contacting 

my supervisor 65 22.5% 

11. Even with the efforts of OSI and the focus on ethical conduct at USCIS, how 

vulnerable do USCIS and its customers remain to fraudulent activity committed 

by the Service’s ISOs? 

Number Percent 

Highly vulnerable 19 6.6% 

Somewhat vulnerable 121 42.0% 

Generally not vulnerable 129 44.8% 

Not vulnerable at all 19 6.6% 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix E 

Major Contributors to This Report 

Douglas Ellice, Chief Inspector, Office of Inspections 

Darin Wipperman, Senior Inspector, Office of Inspections 

LaDana Crowell, Inspector, Office of Inspections 

Ericka Kristine Odiña, Inspector, Office of Inspections 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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Appendix F 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

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 

USCIS Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Efforts to Detect and Deter Fraud Committed by Immigration Services Officers 

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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.