ICE Deportation 

Operations 

April 13, 2017 

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DHS OIG HIGHLIGHTS
 

ICE Deportation Operations 

April 13, 2017 

Why We 

Did This 

Inspection 

This is the second 

inspection related to U.S. 

Immigration and Customs 

Enforcement’s (ICE) 

management of aliens 

released from detention and 

under ICE supervision. We 

sought to determine 

whether there are systemic 

factors hampering ICE’s 

ability to deport these 

aliens. 

What We 

Recommend 

We made five 

recommendations to 

improve ICE’s management 

of its deportation 

operations. 

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 

ICE does not effectively manage the deportation of 

aliens who are no longer detained, but are under 

its supervision. Effective management requires 

preparing and deploying the right number of 

employees to achieve program and policy 

objectives. In contrast, although many ICE 

Deportation Officers supervising aliens reported 

overwhelming caseloads and difficulty fulfilling 

their responsibilities, ICE does not collect and 

analyze data about employee workloads to allocate 

staff judiciously and determine achievable 

caseloads. Effective management also requires 

providing well-defined policies and procedures to 

employees. ICE has not clearly and widely 

communicated Department of Homeland Security 

deportation priorities to Deportation Officers; not 

issued up-to-date, comprehensive, and accessible 

procedures; and not provided sufficient training. 

ICE’s failure to effectively balance and adequately 

prepare its workforce also makes it harder to 

address other obstacles to deportation, which may 

require significant time and resources. These 

management deficiencies and unresolved obstacles 

make it difficult for ICE to deport aliens 

expeditiously. ICE is almost certainly not deporting 

all the aliens who could be deported and will likely 

not be able to keep up with growing numbers of 

deportable aliens. 

ICE Response 

ICE concurred with all five recommendations and 

has initiated corrective actions that should 

improve its management of deportation of aliens 

under its supervision. We consider all five 

recommendations resolved and open. 

www.oig.dhs.gov OIG-17-51 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

April 13, 2017 

MEMORANDUM FOR: 

FROM: 

The Honorable Thomas Homan 

Acting Director 

U.S. Immigration and Customs Enforcement 

John Roth ~~'\(.oh Inspector General 

SUBJECT: ICE Deportation Operations 

Attached for your information is our final report, ICE Deportation 

Operations. We have incorporated ICE's formal comments as appropriate in 

the final report. 

The report contains five recommendations to improve ICE's management of 

its deportation operations. Your office concurred with all five 

recommendations. Based on information provided in your response to the 

draft report, we consider all five recommendations resolved and open. Once 

your office has implemented the recommendations, please submit a formal 

closeout letter to us within 30 days so that we may close the 

recommendations. The memorandum should be accompanied by evidence of 

completion of agreed upon corrective actions. Please send your response or 

closure request to OIGinspectionsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We 

will post the report on our website for public dissemination. 

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

Rimon, Acting Assistant Inspector General for Inspections and Evaluations, 

at (202) 254-4100. 

Attachment 

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OFFICE OF INSPECTOR GENERAL 

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Table of Contents 

Background .................................................................................................... 1 

Results of Inspection ....................................................................................... 3 

ICE Does Not Ensure Deportation Officer Workloads Are Balanced and 

Achievable ............................................................................................. 3 

ICE Does Not Provide Clear Policies and Procedures 

Or Sufficient Training ............................................................................ 7 

ICE Does Not Effectively Prepare Its Workforce to Handle Complicated 

Deportations.......................................................................................... 8 

Conclusion ............................................................................................ 9 

Recommendations......................................................................................... 10 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 14 

Appendix B: ICE Comments to the Draft Report ................................... 15 

Appendix C: Office of Inspections Major Contributors to This Report.... 18 

Appendix D: Report Distribution .......................................................... 19 

Abbreviations 

BIETP Basic Immigration Enforcement Training Program 

CBP U.S. Customs and Border Protection 

CMT Case Management Training 

DO Deportation Officer 

ERO Enforcement and Removal Operations 

ICE U.S. Immigration and Customs Enforcement 

OIG Office of Inspector General 

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Background 

This is the second inspection related to U.S. Immigration and Customs 

Enforcement’s (ICE) management of aliens who have been released from 

detention. In our first inspection,1 undertaken in response to a congressional 

request, we reviewed the circumstances surrounding the case of an alien from 

Haiti, Jean Jacques, who committed murder after receiving final deportation 

orders.2 Our initial review revealed potentially broader issues affecting ICE’s 

efforts to deport aliens. We conducted this second inspection to determine 

whether there are systemic factors hindering ICE’s ability to deport aliens who 

are not in ICE detention, but are under its supervision. 

ICE shares responsibility for enforcing the nation’s civil immigration laws with 

U.S. Customs and Border Protection (CBP) and U.S. Citizenship and 

Immigration Services. ICE's two primary missions are to (1) identify and 

apprehend criminal aliens and other deportable individuals in the United 

States and (2) detain and deport those individuals apprehended in the interior 

of the United States. ICE Enforcement and Removal Operations (ERO) is 

responsible for carrying out this two-fold mission. 

ICE detains aliens, both criminal and non-criminal, who are apprehended and 

determined to need custodial supervision. While in detention, ICE attempts to 

deport aliens with final deportation orders. ICE refers to aliens in its detention 

facilities as cases in a “detained docket.” 

A 2001 Supreme Court decision3 limits the length of time under the 

Immigration and Nationality Act [8 U.S.C. § 1231(a)(1)(A)] that ICE can detain 

aliens who are subject to a deportation order but cannot be deported in the 

near future.4 When aliens are released from detention because deportation is 

no longer reasonably foreseeable, ICE continues its efforts to deport those with 

final deportation orders. 

ICE also monitors aliens released from detention who are waiting for a hearing 

in immigration court. Some aliens released from detention do not have final 

1 Release of Jean Jacques from ICE Custody, June 16, 2016 

2 When an immigration judge orders an alien to be deported the judge issues an order of 

removal. In this report, we refer to orders of removal as deportation orders and to removal as 

deportation. 

3 Zadvydas v. Davis, 533 U.S. 678, 697 (2001) 4 There are several reasons why ICE may have difficulty deporting an alien with final 

deportation orders. For example, some countries refuse to repatriate their citizens and other 

countries restrict the number of aliens they will accept for repatriation. For more information 

on the Supreme Court decision and ICE’s policies and procedures in one release from 

detention, see Release of Jean Jacques from ICE Custody, June 16, 2016. 

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OFFICE OF INSPECTOR GENERAL 

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deportation orders, but instead are waiting to appear in immigration court for a 

ruling on their deportation. For example, aliens who claim they are fearful of 

returning to their home countries or who are seeking asylum in the United 

States must wait to appear in immigration court for a judge to render a 

decision. It may take months or years for an appearance before an immigration 

judge. 

Aliens released from detention with final deportation orders, as well aliens who 

have been released and are waiting for an immigration court hearing, compose 

ICE’s “non-detained docket.” 

Among other duties, ICE DOs may work on either a detained or a non-detained 

docket. We focused this review on DOs primarily responsible for the nondetained docket. In this report, we refer to an ICE DO’s responsibilities for nondetained aliens as “supervision.” Supervision of non-detained aliens with final 

deportation orders entails facilitating their deportation and repatriation by 

working with embassies and consulates to obtain travel identification 

documents, which officially permit ICE to deport aliens. Supervision of nondetained aliens awaiting final court decisions on their immigration status 

entails ensuring the aliens check in at regular intervals to report any changes 

in their status, such as a change of address or updates on their immigration 

court proceedings. These DOs also interview the aliens and run criminal 

background checks. 

In fiscal year 2014, the United States experienced a surge in illegal immigration 

along the southwest border. That year, the Border Patrol apprehended nearly 

500,000 individuals entering the United States illegally. This represented a 

nearly 16 percent increase from FY 2013 and about a 34 percent increase from 

FY 2012. An increase in Border Patrol apprehensions potentially translates to 

more aliens that ICE must detain, deport, and supervise. 

On November 20, 2014, the then Secretary of Homeland Security issued a 

memorandum, Policies for the Apprehension, Detention and Removal of 

Undocumented Immigrants, with revised department-wide immigration 

enforcement priorities to “inform enforcement and removal activity, detention 

decisions, budget requests and execution, and strategic planning.” The 

memorandum directed the Department, including ICE, to focus resources and 

deportation efforts on, among others, criminals convicted of felonies, multiple 

misdemeanors, and “significant” misdemeanors (e.g., domestic violence and 

sexual abuse and exploitation), as well as aliens who unlawfully enter or rewww.oig.dhs.gov 2 OIG-17-51 
 

 

 

OFFICE OF INSPECTOR GENERAL 

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enter the United States and “cannot establish ... that they have been physically 

present ... continuously since January 1, 2014.”5 

According to ICE, as directed by the Secretary, in FY 2015 it focused its 

resources on apprehending, arresting, and deporting the most serious threats 

to national security, border security, and public safety. ICE also reported that 

its deportation statistics for the last three quarters of FY 2015 aligned with the 

Secretary’s revised immigration enforcement priorities. As of August 2016, ICE 

was supervising about 2.2 million aliens (on the non-detained docket); of these, 

about 368,574 are convicted criminals. In FY 2015, ICE removed or returned 

235,413 individuals of which 139,368 were convicted criminals. 

Results of Inspection 

ICE does not effectively manage the supervision and deportation of nondetained aliens. Effective management requires preparing and deploying the 

right number of employees to achieve program and policy objectives. In 

contrast, although many ICE DOs supervising aliens reported overwhelming 

caseloads and difficulty fulfilling their responsibilities, ICE does not collect and 

analyze data about employee workloads to allocate staff judiciously and 

determine achievable caseloads. Effective management also requires providing 

well-defined policies and procedures to employees. ICE has not clearly and 

widely communicated Department priorities for deportation to DOs; not issued 

up-to-date, comprehensive, and accessible procedures for supervising aliens; 

and not provided sufficient training. ICE’s failure to effectively balance and 

adequately prepare its workforce also makes it harder to address obstacles to 

deportation, which may require significant time and resources. These 

management deficiencies and unresolved obstacles make it difficult for ICE to 

deport aliens expeditiously. ICE is almost certainly not deporting all the aliens 

who could be deported and will likely not be able to keep up with growing 

numbers of deportable aliens. 

ICE Does Not Ensure Deportation Officer Workloads Are 

Balanced and Achievable 

DO workloads appear to be uneven — DOs working on non-detained dockets 

have many more aliens they must supervise than DOs working with detained 

aliens. While the tasks associated with overseeing detained and non-detained 

5 On February 20, 2017, the Secretary of Homeland Security issued a memo, Enforcement of 

the Immigration Laws to Serve the National Interest, which rescinded “all existing conflicting 

directives, memoranda, or field guidance regarding the enforcement of our immigration laws 

and priorities for removal,” including the November 20, 2014 memo. 

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10,156 

10,000 

Non-detained Caseload 

8,000 Detained Caseload 

6,000 5,337

4,000 

1,720 1,872

2,000 

104 100 84 65 

0 

Seattle, WA Washington, DC St. Paul, MN Atlanta, GA 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

aliens differ, ICE could not adequately explain the reasons for the workload 

differences at the locations we visited. Many of those working with nondetained aliens reported they had difficulty fulfilling all their responsibilities, 

such as working with embassies and consulates to obtain travel documents 

necessary for deportation, interviewing aliens under their supervision, and 

running criminal checks on aliens in their docket. Yet, ICE has not collected or 

analyzed workload data to determine the time and effort DOs need to 

adequately supervise and facilitate the deportation of non-detained aliens. 

Without workload data, ICE cannot ensure its caseload distribution is balanced 

and that non-detained workloads are achievable. ICE also cannot measure 

performance and apply lessons learned to ensure effective and efficient 

supervision and deportation of aliens. 

Caseload Distribution Is Uneven 

At all four ICE field offices we visited, the caseloads of DOs supervising nondetained aliens were much larger than those of DOs working with detained 

aliens. As shown in Figure 1, on average, DOs working on non-detained 

dockets were responsible for about 1,700 to about 10,000 non-detained aliens, 

compared to averages ranging from 65 to 110 for DOs working on detained 

dockets. 

Figure 1: Average Number of Cases per Deportation Officer For Nondetained and Detained Aliens in Four ICE Field Offices, 2016 

Source: ICE-reported data from July through October 2016 

Deportation Officers Report Overwhelming Workloads 

ICE personnel at all four field offices agreed that the workloads of DOs 

supervising non-detained aliens are unmanageable, yet ICE has not tried to 

determine what is achievable and what would alleviate the burden. 

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OFFICE OF INSPECTOR GENERAL 

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In general, DOs working on non-detained dockets are supposed to obtain travel 

documents for aliens with final deportation orders as well as supervise aliens 

awaiting final decisions on their immigration status. To deport aliens, ICE DOs 

must work with embassies and consulates to obtain travel identification 

documents, such as birth certificates and passports, which officially permit ICE 

to deport the aliens. Each country that accepts its citizens has its own rules 

and proof of citizenship requirements that must be satisfied before it will issue 

travel documents and accept its citizens. All these tasks can be time 

consuming. 

Supervision of non-detained aliens entails ensuring they check in at regular 

intervals to report any changes in their status, such as a change of address or 

updates on their immigration court proceedings. During and prior to an alien’s 

check-in appointment, DOs respond to aliens’ attorneys’ inquiries and 

requests, interview non-detained aliens, run criminal background checks, and 

are supposed to record any changes in status in the ICE electronic case 

management system. The system is also used to alert DOs about upcoming 

scheduled check-ins. The large backlog of aliens awaiting final decisions on 

their immigration status drives increasing workloads for DOs supervising nondetained aliens. 

Among the field offices we visited, however, DO responsibilities vary widely and 

shift, sometimes unexpectedly. For example, DOs working on the non-detained 

docket are sometimes asked to help with aliens in detention. DOs are also 

taken from assignments supervising non-detained aliens to work in specialized 

units that target criminals and fugitive aliens. Further, to assist with the 

increase in aliens crossing the southwest border, ICE has required some field 

offices to temporarily assign staff to the border field offices for 45-day rotations. 

One field office reported regular staffing shortages in supervising aliens 

because of these assignments. Also, other DOs must pick up the workload of 

those temporarily working elsewhere. 

In addition, DOs may be asked to help with other “collateral” duties including: 

x transporting and escorting departing aliens on commercial and chartered 

flights, which can take several days; 

x rotating on “window duty” to check in aliens arriving for interviews; and 

x transporting aliens to and from detention centers for immigration court 

proceedings. 

At the four offices we visited, DOs supervising non-detained aliens reported 

they do not have enough time to obtain necessary travel documents to deport 

aliens. According to the DOs, their collateral duties leave them time only to 

deal with daily scheduled check-in appointments and unscheduled visits by 

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aliens, answer phone calls from aliens, and input new cases into the electronic 

system. One DO also reported that because of competing work responsibilities 

criminal background checks are not conducted every time a non-detained alien 

checks in with the field office. 

In a particularly troubling example of overworked staff, a DO at one field office 

we visited reported that a heavy workload limited oversight of non-detained 

aliens in that geographic area that ICE had flagged as risks to national 

security. In addition to oversight of these aliens, the DO supervised about 

6,000 juvenile aliens, 150 of whom were detained; the DO said managing the 

detained juveniles took up most of the workday, including many hours of 

overtime. Without adequate oversight, this ICE DO may be unaware of missed 

check-in appointments and missed court dates and may have inaccurate 

information on the whereabouts of the non-detained aliens deemed to be a risk. 

In addition to reported staffing shortages because of temporary DO 

assignments to the southwest border, ICE’s non-detained unit also has unfilled 

vacancies for positions that are relatively hard to fill. According to ICE officials 

at one field office we visited, 6 of 19 DO positions assigned to the non-detained 

case management unit were vacant, and the number of personnel who provide 

administrative and clerical support has also dwindled, so DOs have had to take 

on administrative duties. 

Because of the overwhelming workload, DOs at these four offices reported they 

need to work overtime to try to keep up with their caseloads. Nevertheless, as 

one DO said, “you might work 18 hours a day, but you still won’t get caught 

up.” 

ICE Does Not Distribute Caseloads Systematically 

Although the non-detained and detained caseloads appear unequal and DOs 

working on the non-detained docket seem overwhelmed, ICE could not provide 

any data on how it determines the staff needed to handle non-detained 

dockets. 

In February 2009, ICE developed a draft staffing model to reorganize DO 

assignments to manage field offices. The model included suggested DO staffing 

levels for the detained and non-detained dockets, as well as mission support. 

However, ICE has not used the 2009 staffing model to allocate human 

resources at field offices. 

Rather than determine how to distribute staff based on caseload requirements, 

supervisory personnel reported they arbitrarily assign the aliens in their 

geographic area of responsibility to staff working on the detained and nondetained dockets. This means cases are distributed without regard to the work 

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they entail or whether DOs will be able to handle the number of cases they are 

assigned. An ICE official said that field office case management is complicated 

and both detained and non-detained caseloads vary based on enforcement 

priorities and other factors. These complications likely mean the two dockets 

will never be equal, but gathering and analyzing workload data could help ICE 

ensure a more balanced workload distribution. 

ICE Does Not Provide Clear Policies and Procedures or 

Sufficient Training 

ICE does not adequately communicate overall policies or give overstretched 

DOs comprehensive, up-to-date, and accessible procedures to guide them in 

supervising and deporting aliens. In addition, ICE has not routinely reviewed, 

updated, and organized its procedures to give DOs access to up-to-date 

manuals. Guidance is often communicated to field office personnel orally or by 

email, rather than through formal, documented policies and procedures. These 

deficiencies hinder proper supervision of non-detained aliens, including those 

who may be fugitives or who commit crimes. Field office staff confirmed that 

ICE’s available policies and procedures did not help them properly manage 

their non-detained cases. 

ICE often communicates changes in enforcement priorities for deportation 

through memoranda, directives, and broadcast messages to field offices. 

Because they are not reviewed by the ICE Enforcement Removal Operations 

Policy Office these communications are not official policies. According to ICE 

staff we interviewed, the official policy review and issuance process can be 

lengthy, so ICE opts to issue more immediate guidance through unofficial 

chains, but does not formalize these policies after the fact. Further, the 

communications are usually posted on websites where they are poorly 

organized and difficult for field office staff to find. Many of the documents on 

these websites had not undergone a periodic review every 4 years as required 

by ICE’s Policy Development Handbook. 

ICE has not issued comprehensive procedures for monitoring aliens 

throughout immigration court proceedings and taking aliens into ICE custody 

if deportation orders are issued. ICE also does not have an official policy 

requiring DOs to periodically review aliens’ case files to verify and record 

contact information, the status of immigration proceedings, and criminal 

history. As a result, according to staff we interviewed, ICE’s records on the 

number and status of aliens are likely inaccurate, which can cause 

repercussions. For example, the cases of aliens who have relocated may not be 

referred to the appropriate field office for supervision. Unless they verify the 

status of immigration proceedings, ICE DOs may not know about aliens who 

fail to report for court appearances and, thus, whose names should be 

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forwarded to the fugitive operations unit. Without checking on criminal history, 

DOs may be unaware of aliens who have committed crimes and should be 

detained. 

Deportation policies and procedures are outdated and unclear. Officials we 

interviewed said ICE considers the 2003 Detention and Removal Operations 

Policy and Procedure Manual (manual) “the official guide” to operations, but ICE 

has not periodically reviewed the manual or revised it since 2008. For a time, 

ICE would affix a memo to the front of the appropriate chapter to indicate 

changes, rather than incorporate changes and issue a revised manual. 

Eventually, many chapters were individually archived or left pending with 

unfinished revisions. To date the manual has not been extensively revised. 

Staff in the field offices confirmed the neglected state of ICE’s guidance. 

Probably as a result of ICE’s failure to issue clear guidance, procedures at the 

ICE field offices we visited vary widely. Some field offices have created their own 

policies and procedures. Also, DOs are often allowed to act autonomously in 

determining alien reporting intervals, documenting alien check-ins, and even 

deciding which aliens to recommend for scheduled deportation charters. 

According to ICE staff, DOs do not get enough training to help them supervise 

and deport non-detained aliens. Staff at all four field offices said that training 

was primarily on-the-job and informal. To compound this issue, since 

September 2015, ICE has transitioned about 2,900 Immigration Enforcement 

Agents to DO positions without, in our opinion, adequately training the fresh 

DOs on their new responsibilities. 

From July to September 2016, ICE headquarters scheduled non-detained 

training for all 24 field offices, but did not plan for recurring training nor 

document training attendance to ensure all required staff attended. In our 

opinion, the training did not fully cover all necessary information. The training 

slides we reviewed did not sufficiently cover managing cases electronically, for 

example, by updating and sorting cases of deceased and self-deported aliens, 

which would help reduce the number of aliens in the non-detained docket. 

Overall, this combination of training did not give field office staff enough 

information to carry out their non-detained responsibilities. ICE headquarters 

personnel acknowledged they could improve training and communication with 

field offices. 

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ICE Does Not Effectively Prepare Its Workforce to Handle 

Complicated Deportations 

According to ICE officials, deporting aliens to some countries is nearly 

impossible, but in other instances, if ICE managed its operations better and 

provided DOs with clear guidance and sufficient training, there would be a 

greater chance of overcoming obstacles to deportation. Some countries refuse 

to repatriate any of their citizens, and ICE generally cannot deport aliens to 

these countries without intervention by the Department of State. Other 

countries restrict the number of individuals they will repatriate, and some 

accept their citizens, but ICE has difficulty obtaining the travel documents 

needed for deportation. ICE officials explained they would likely be more 

successful in deporting aliens to these countries if they could better coordinate 

with the Department of State and work more effectively with embassies and 

consulates representing these countries. 

For ICE to deport an alien to his or her home country, the country must agree 

to repatriation. As of August 2016, ICE had identified 23 “uncooperative” 

countries to which it generally cannot deport aliens. To help deport aliens to 

these countries ICE may request diplomatic intervention by the Department of 

State, which determines whether and what action to take against the country. 

ICE officials also said that some countries, such as China, Bangladesh, and 

India, restrict the number of aliens for whom they will issue travel documents 

and accept for repatriation. Finally, ICE has identified 62 countries that are 

cooperative, but with which it has experienced delays in obtaining required 

travel documents. Deporting aliens to these 62 countries also requires more 

time and effort working with embassies and consulates to obtain travel 

documents and approval for alien repatriation. 

ICE management at the field offices we visited noted that staff need to “stay on 

top” of the embassies and consulates because ICE has more success deporting 

aliens when DOs can be persistent in obtaining travel documents. DOs cited 

the large number of cases they are assigned and their collateral duties as 

hindrances to pursuing complicated deportations. If workloads were more 

reasonable and ICE provided better guidance and training, DOs would likely 

have more success with these deportations. 

Conclusion 

Our inspection and site visits of four ICE field offices revealed weaknesses in 

ICE’s management of its deportation operations. These weaknesses are 

hampering ICE’s ability to adequately supervise aliens awaiting immigration 

hearings, as well as efforts to deport those who should be deported, including 

some convicted criminals. Factors beyond ICE’s control may virtually prohibit 

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deportation to some countries. In general, however, a more organized, diligent, 

and complete approach to management would help ICE deport aliens 

expeditiously and keep up with growing numbers of aliens who should be 

deported. 

Recommendations 

We recommend that the Director of ICE or a designee: 

Recommendation 1: Comprehensively review, revise, update, and maintain 

ICE Enforcement and Removal Operations policies, procedures, and guidance 

to address gaps and outdated information. 

Recommendation 2: Comprehensively review Deportation Officer functions at 

field offices to determine staffing allocations for non-detained units and identify 

appropriately sized caseloads for Deportation Officers working with nondetained aliens. 

Recommendation 3: Based on a completed comprehensive review, develop a 

plan to identify and implement appropriate staffing of Deportation Officers. 

Recommendation 4: Develop a standardized training curriculum for all 

current and future Deportation Officers, including recurrent refresher training 

courses for docket review and detained and non-detained case management. 

Recommendation 5: Collaborate with the Department of State to identify 

potential mechanisms to address issues that hinder deportation efforts. 

Management Comments and OIG Analysis 

In its response to our draft report, ICE concurred with all five 

recommendations and has initiated corrective actions that should improve the 

effectiveness of managing the deportation of aliens under its supervision. We 

consider all five recommendations resolved and open. 

Recommendation 1: We recommend that the Director of ICE or a designee 

comprehensively review, revise, update, and maintain ICE Enforcement and 

Removal Operations policies, procedures, and guidance to address gaps and 

outdated information. 

ICE Response: ICE concurred with the recommendation. ICE agrees that ERO 

policies, procedures, and guidance should be reviewed, revised, updated, and 

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maintained to address gaps and outdated information. ICE is currently working 

with the Department's Office of Policy and others to examine current ICE 

policies and guidance to ensure that they align with the President’s recent 

Executive Orders and the Secretary of Homeland Security's vision and plans for 

implementing those orders. This will be an iterative process that will also 

address gaps in current policies, procedures, and guidance. The estimated 

completion date is January 31, 2018. 

OIG Analysis: ICE’s response addresses the intent of the recommendation. 

This recommendation is resolved and will remain open until ICE provides 

evidence that ERO policies, procedures, and guidance have been reviewed, 

revised, updated, and maintained to address gaps and outdated information 

and that such policies, procedures, and guidance align with the Executive 

Orders and the Secretary’s plans to implement them. 

Recommendation 2: We recommend that the Director of ICE or a designee 

comprehensively review Deportation Officer functions at field offices to 

determine staffing allocations for non-detained units and identify appropriately 

sized caseloads for Deportation Officers working with non-detained aliens. 

ICE Response: ICE concurred with the recommendation. ICE ERO is currently 

examining staffing structures throughout the organization to inform future 

hiring that will implement the President's Executive Order 13768, Enhancing 

Public Safety in the Interior of the United States. This effort, along with ERO's 

evolving enforcement posture, will determine the future operational footprint 

for ERO's 24 field offices. This initiative is also aligned with ICE's project to 

complete a workforce staffing model that uses subject matter expertise and 

operational data to determine appropriate workforce staffing in positions and 

geographical areas. Such analyses will include a review of DO functions, 

including management of the non-detained docket and an appropriate case-toofficer ratio. The estimated completion date is January 31, 2018. 

OIG Analysis: ICE’s response provides an initial corrective action plan that 

addresses the intent of the recommendation. This recommendation is resolved, 

but will remain open until ICE provides specific information about its planned 

staffing structure initiative, especially as it affects DO staffing, as well as 

evidence of the completed workforce staffing model, including a comprehensive 

review of DO functions, all of which will help determine appropriate staffing 

allocations for non-detained units and caseload sizes for DOs assigned to nondetained dockets. 

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Recommendation 3: We recommend that the Director of ICE or a designee, 

based on a completed comprehensive review, develop a plan to identify and 

implement appropriate staffing of Deportation Officers. 

ICE Response: ICE concurred with the recommendation. As stated above, ICE 

ERO is currently examining staffing structure determine the future operational 

footprint for ERO's 24 field offices and a multi-year hiring plan. The estimated 

completion date is January 31, 2018. 

OIG Analysis: ICE’s response addresses the intent of the recommendation. 

This recommendation is resolved and will remain open until ICE provides 

evidence of the completed examination of its staffing structure to determine the 

future operational footprint for ERO's 24 field offices and a multi-year hiring 

plan, in conjunction with recent hiring surges proposed by the new 

Administration and DHS leadership. 

Recommendation 4: We recommend that the Director of ICE or a designee 

develop a standardized training curriculum for all current and future 

Deportation Officers, including recurrent refresher training courses for docket 

review and detained and non-detained case management. 

ICE Response: ICE concurred with the recommendation. Standardized training 

curriculum for future DOs is operated through ICE’s basic program, the Basic 

Immigration Enforcement Training Program (BIETP), instructed by the ICE 

Office of Training and Tactical Programs. Immigration Enforcement Agents, 

who have been recently upgraded to the DO position, and new DOs who have 

attended a substantially equivalent course of instruction to the BIETP, must 

complete ICE ERO Case Management Training (CMT), which provides 

instruction that includes docket-related duties (docket review and detained and 

non-detained case management). CMT classes began in the latter part of 2016. 

ERO intends to have 70 percent of the upgraded Immigration Enforcement 

Agents complete the program by December 2017 and 100 percent by March 

2018. ICE ERO is also currently working with the ICE Office of Principal Legal 

Advisor to begin the process of negotiating an ICE ERO on-the-job training 

program with the national union, which will also be used as a recurrent 

refresher for several ERO specific skill sets, including those related to docket 

review, detained casework, and non-detained casework. The estimated 

completion date is March 30, 2018. 

OIG Analysis: ICE’s response addresses the intent of the recommendation. 

This recommendation is resolved and will remain open until ICE provides 

evidence that 100 percent of Immigration Enforcement Agents converted to 

DOs have completed CMT, and that it has fully implemented an ICE ERO onwww.oig.dhs.gov 12 OIG-17-51 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the-job (or similar) recurrent refresher training program for docket review and 

detained and non-detained case management. 

Recommendation 5: We recommend that the Director of ICE or a designee 

collaborate with the Department of State to identify potential mechanisms to 

address issues that hinder deportation efforts. 

ICE Response: ICE concurred with this recommendation. Since 2011, there 

has been a standing Memorandum of Understanding between the Department 

of State and ICE ERO that specifically identifies and uses available 

mechanisms to address issues that hinder removal efforts. Additionally, ICE 

ERO currently uses a Removal Cooperation Initiative tool to better assess a 

country's level of cooperation with the removal process and is thereby able to 

develop a plan of action to specifically address the issue(s) at hand, with the 

assistance of the Department of State. ICE ERO and the Department of State 

will continue to work together to ensure that countries accept the return of 

their nationals who have been ordered removed from the United States, in 

accordance with international law. ICE requested that DHS OIG consider this 

recommendation resolved and closed. 

OIG Analysis: In its response, ICE identified the Memorandum of 

Understanding with the Department of State, current mechanisms, and the 

Removal Cooperation Initiative tool as addressing the intent of the 

recommendation. We acknowledge these ongoing efforts, but ICE continues to 

have problems ensuring deportation of aliens to uncooperative countries and 

countries with which it has problems obtaining travel documents. Therefore, 

this recommendation is resolved, but will remain open until ICE provides 

evidence of enhancements to current mechanisms and improvements to 

cooperation with the Department of State to remove hindrances to deportation. 

In particular, ICE needs to provide details on how it uses assessments from the 

Removal Cooperation Initiative tool to address issues and work with the 

Department of State to deport aliens to these countries. ICE also needs to 

provide any new plans and strategies it is developing with the Department of 

State to improve cooperation with these countries. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

DHS OIG was established by the Homeland Security Act of 2002 (Public 

Law 107–269) by amendment to the Inspector General Act of 1978. 

We conducted this inspection from June 2016 to October 2016 under the 

authority of the Inspector General Act 1978, as amended, and according to the 

Quality Standards for Inspection and Evaluation issued by the Council of the 

Inspectors General on Integrity and Efficiency. The objective of our review was to 

determine whether ICE has systemic factors that may hamper deportations of 

aliens not in detention facilities. 

We analyzed ICE’s available supervision and deportation metrics as well 

as its field office case workload data, organizational charts, and staffing 

models. We also examined ICE’s supervision and deportation priorities, 

policies, procedures, and information on uncooperative countries; 

agreements with the Department of State; and email communication 

and training provided to ICE field offices. Further, we reviewed 

congressional hearings and testimony, as well as media articles 

relevant to the objective of this review, which focused on the failure to 

deport criminal aliens who allegedly endangered the public. During this 

review, we also met with congressional staff to understand concerns 

related to their requests for inspection. 

We interviewed ICE headquarters staff and traveled to ICE field offices 

in Atlanta, GA; Washington, DC; St. Paul, MN; and Seattle, WA to 

discuss the above subject areas, local policies and procedures, and 

issues beyond ICE’s control. During these site visits, we interviewed 

Field Office Directors and their senior staff as well as DOs working on 

non-detained dockets and supervisors. We also observed DOs 

interviewing and gathering information from non-detained aliens and 

accessing the electronic case management system, ENFORCE Alien 

Removal Module. As needed, we followed up with ICE headquarters and 

field office personnel by phone and email. We interviewed ICE 

headquarters and field office staff members during site visits. 

After October 2016, we contacted subject matter experts in ICE to clarify 

issues in our report and to confirm that the conditions we identified had 

not changed. In December 2016, we briefed these subject matter experts 

on our report’s findings and conclusions. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

ICE Comments to the Draft Report 

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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 C 

Office of Inspections Major Contributors to This Report 

John Shiffer, Chief Inspector 

Wayne Ekblad, Lead Inspector 

Stephanie Christian, Lead Inspector 

Marybeth Dellibovi, Senior Inspector 

Ryan Nelson, Senior Inspector 

Jason Wahl, Senior Inspector 

Anna Leslie, Senior Inspector 

Kimberley Crabbe, Inspector 

Kelly Herberger, Communications Analyst 

Tatyana Martell, Independent Referencer 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

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 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

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ADDITIONAL INFORMATION AND COPIES 

To view this and any of our other reports, please visit our website at: www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General Public Affairs 

at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on Twitter at: @dhsoig. 

OIG HOTLINE 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click on the red 

"Hotline" tab. If you cannot access our website, call our hotline at (800) 323-8603, fax our 

hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305