Department of Homeland Security 

Operations of United States Immigration 

and Customs Enforcement’s Secure 

Communities 

OIG-12-64 April 2012 (Revised) 
 

 

 

 

 

 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

April 5, 2012 

Preface 

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. 

This report addresses the operations of the United States Immigration and Customs 

Enforcement’s Secure Communities. 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 

express our appreciation to all of those who contributed to the preparation of this report. 

Anne L. Richards 

Assistant Inspector General for Audits 
Executive Summary.............................................................................................................1
 

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

Results of Audit ..................................................................................................................5
 

Criminal Alien Identification.........................................................................................5
 

Enforcement Actions .....................................................................................................8
 

Secure Communities Incarceration Costs ....................................................................10
 

Actions Taken by ICE..................................................................................................11
 

Recommendations..............................................................................................................11
 

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

Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................13
 

Appendix B: Management Comments to the Draft Report .......................................14
 

Appendix C: ICE Enforcement and Removal Programs...........................................18
 

Appendix D: Jurisdictions Where ICE Activated Secure Communities ...................19
 

Appendix E: Major Contributors to this Report........................................................20
 

Appendix F: Report Distribution ..............................................................................21
 

Abbreviations 

ACRIMe Alien Criminal Response Information Management System
 

DHS Department of Homeland Security
 

FBI Federal Bureau of Investigation
 

FY fiscal year
 

IAFIS Integrated Automated Fingerprint Identification System
 

ICE United States Immigration and Customs Enforcement
 

IDENT Automated Biometric Identification System
 

LESC Law Enforcement Support Center
 

OIG Office of Inspector General
 

Table of Contents/Abbreviations 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Department of Homeland Security’s (DHS) United States 

Immigration and Customs Enforcement (ICE) is responsible for 

identifying, detaining, and removing deportable aliens from the 

United States. In 2008, it implemented Secure Communities to 

enhance its ability to identify criminal aliens nationwide. The key 

component of Secure Communities is automated information 

sharing between the Department of Homeland Security and the 

Federal Bureau of Investigation. Since 2008, ICE has spent about 

$750 million on Secure Communities and identified more than 

692,000 criminal aliens. In response to a request from 

Representative Zoe Lofgren, the Office of Inspector General 

initiated two reviews of Secure Communities. We performed this 

audit to determine if Secure Communities was effective in 

identifying criminal aliens and if Immigration and Customs 

Enforcement appropriately prioritized cases for removal action. 

Secure Communities was effective in identifying criminal aliens, 

and in most cases, ICE officers took enforcement actions according 

to agency enforcement policy. Under Secure Communities, the 

agency expanded its ability to identify criminal aliens in areas not 

covered by its other programs. In addition, it was able to identify 

criminal aliens earlier in the justice process, some of whom it 

would not have identified under other programs. Secure 

Communities was implemented at little or no additional cost to 

local law enforcement jurisdictions. Although ICE was able to 

identify and detain criminal aliens, field offices duplicated the 

research associated with their detention, and officers did not 

always sufficiently document their enforcement actions. To 

improve the transparency and thoroughness of its processes under 

Secure Communities, the agency needs to eliminate the duplication 

of research and ensure that officers fully document their actions. 

We made two recommendations to improve the agency’s overall 

management of Secure Communities. ICE concurred with the two 

recommendations and is taking action to implement them. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 1 
 

 

Background 

ICE is responsible for identifying, detaining, and removing 

deportable aliens from the United States. In addition to Secure 

Communities, ICE has three programs to identify and apprehend 

criminal aliens: the Criminal Alien Program, 287(g) Program, and 

the National Fugitive Operations Program. Appendix C contains 

descriptions of these programs. 

Funding for the identification and removal of criminal aliens has 

increased significantly, from $23.5 million in fiscal year (FY) 2004 

to about $690 million in FY 2011. ICE has spent about $3.3 billion 

on these efforts since FY 2004. Figure 1 shows the annual funding 

increases for criminal alien identification and removal. 

Figure 1. Funding for Criminal Alien Identification and 

Removal, FYs 2004 Through 2011 

$0 

$100 

$200 

$300 

$400 

$500 

$600 

$700 

$800 

Millions 

2004 2005 2006 2007 2008 2009 2010 2011 

Source: ICE. 

Federal Information Sharing 

The key component of Secure Communities is automated 

information sharing between the DHS’ Automated Biometric 

Identification System (IDENT)1 and the Federal Bureau of 

Investigation’s (FBI) Integrated Automated Fingerprint 

Identification System (IAFIS). IDENT collects fingerprints and 

other information for its mission-related functions, such as national 

security, law enforcement, immigration, and intelligence. IAFIS is 

1 IDENT is the primary DHS-wide system to collect and process biometric and limited biographic 

information for DHS’s mission-related functions such as national security, law enforcement, immigration, 

and intelligence. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 2 
 

the largest fingerprint database in the world, housing more than 70 

million fingerprints and criminal histories. 

The integration of information in IDENT and IAFIS began as early 

as 1998. In 2001, Congress mandated integration of the systems 

through the USA PATRIOT Act of 2001 (Public Law 107-56), 

which required the creation of an electronic system to share law 

enforcement and intelligence information to confirm the identities 

of persons applying for United States visas. The integrated system 

would be easily accessible to all consular offices, federal 

inspection agents, and law enforcement officers responsible for 

investigating aliens. The Enhanced Border Security and Visa 

Entry Reform Act of 2002 (Public Law 107-173), which amended 

the USA PATRIOT Act of 2001, mandated that immigration 

authorities have immediate access to relevant information in 

federal law enforcement agencies’ databases to determine the 

admissibility or deportability of an alien. 

Secure Communities Identification Process 

In the Consolidated Appropriations Act, 2008 (Public Law 110­

161), Congress appropriated $200 million for ICE to “improve and 

modernize efforts to identify aliens convicted of a crime, sentenced 

to imprisonment, and who may be deportable, and remove them 

from the United States once they are judged deportable.” In April 

2008, as required by Congress, ICE submitted Secure Communities: 

A Comprehensive Plan to Identify and Remove Criminal Aliens. 

According to ICE’s most recent plan, from March 2010, the goals 

of Secure Communities are to— 

•	 Identify criminal aliens through modernized information 

sharing; 

•	 Prioritize enforcement actions to ensure apprehension and 

removal of dangerous criminal aliens; and 

•	 Transform criminal alien enforcement processes and 

systems. 

Since FY 2008, Congress has appropriated about $750 million to 

ICE to improve and modernize the process for identifying and 

removing criminal aliens. According to ICE, as of September 30, 

2011, it had spent most of the $750 million and identified more 

than 692,000 criminal aliens. Prior to the implementation of 

Secure Communities, law enforcement agencies sent fingerprints 

of arrested individuals to the FBI to determine whether the 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 3 
 

 

 

individuals had outstanding warrants or a criminal history. Under 

Secure Communities, IAFIS automatically shares these fingerprints 

with DHS to screen IDENT for removable aliens. If the 

fingerprints match a person with an immigration record, the 

information is automatically sent to ICE’s Law Enforcement 

Support Center (LESC).2 

LESC personnel research each match, confirm the individual’s 

identity, and make an initial determination on the individual’s 

criminal history and immigration status. The LESC’s initial check 

may indicate that the alien is removable because he or she entered 

the country illegally, overstayed a visa, or was previously deported. 

After the LESC makes its initial determination, it alerts the 

appropriate ICE field office or one of ICE’s Interoperability 

Resource Centers. 

Field office personnel duplicate research of the criminal history 

and immigration status and determine whether to detain and 

remove the individual. In making a determination, officers consider 

the entire criminal and immigration history. For example, an alien 

previously convicted of an aggravated felony is considered high 

priority for removal, even if his or her current arrest is for an 

otherwise minor offense. If necessary, officers request the 

arresting local jurisdiction to detain aliens for up to 48 hours 

(excluding holidays and weekends) to allow ICE to take custody. 

Individuals With Fingerprints in IDENT 

Individuals with fingerprints in IDENT include persons with an 

immigration history, such as aliens who have been removed but 

have reentered the country, immigration visa applicants, legal 

permanent residents, naturalized citizens, and some U.S. citizens. 

IDENT includes two categories of U.S. citizens: 

•	 Citizens who have adopted a child from abroad (which 

involves U.S. Citizenship and Immigration Services), 

participated in a trusted traveler program, or may have been 

fingerprinted by immigration officials for smuggling aliens 

or drugs across U.S. borders; 

•	 Individuals who were not citizens at the time that their 

fingerprints were collected, but subsequently became 

2 The LESC operates 24 hours a day, 7 days a week, and provides identity information, immigration status, 

and assistance to law enforcement agencies for aliens suspected, arrested, or convicted of criminal activity. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 4 
 

citizens through naturalization, legal permanent residency, 

or immigration. 

Results of Audit 

Under Secure Communities, ICE effectively identified criminal aliens, and in 

most cases ICE officers took enforcement actions according to ICE’s enforcement 

policy. Further, Secure Communities expanded ICE’s ability to identify criminal 

aliens in areas not previously covered by its other programs. ICE was also able to 

identify criminal aliens, some of whom it might not have otherwise identified, 

earlier in the criminal justice process. Secure Communities was implemented at 

little or no additional cost to local law enforcement jurisdictions. However, 

because technology did not allow the LESC to share its research on criminal 

aliens, ICE officers duplicated the research necessary to detain criminal aliens. In 

addition, ICE officers did not always sufficiently document their actions related to 

individuals with identity matches. ICE needs to eliminate duplication of research 

and ensure that officers document their actions regarding individuals identified 

through Secure Communities to improve transparency and demonstrate that its 

officers are taking appropriate actions. 

Criminal Alien Identification 

Secure Communities enhanced ICE’s ability to identify aliens with 

criminal convictions by expanding to areas not previously covered by its 

enforcement programs. In addition, Secure Communities allowed ICE to 

identify aliens who it normally would not encounter in the criminal justice 

process. 

Expanded Identification Coverage 

Secure Communities enhanced ICE’s ability to enforce U.S. 

immigration laws by expanding its coverage to jurisdictions where 

it did not previously have a presence. In FY 2008, ICE estimated 

that 300,000 to 450,000 criminal aliens were incarcerated in 

federal and State prisons and local jails. ICE’s Criminal Alien 

Program focused on screening and identifying aliens in all federal 

and State prisons and in some local jails. Although ICE screened 

all federal and State prisons for criminal aliens, it reported being 

able to screen only 14% of local jails nationwide. According to 

ICE, as of December 28, 2011, it had implemented Secure 

Communities in 2,027 jurisdictions in 44 States, or 64% of the 

Nation’s 3,181 jurisdictions. ICE planned to expand Secure 

Communities coverage nationwide by 2013. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 5 
As Secure Communities expanded to more jurisdictions, ICE 

reported a corresponding increase in the number of fingerprint 

matches in IDENT. Between FYs 2009 and 2011, the number of 

matches more than tripled. Figures 2 and 3 show the relationship 

between the implementation of Secure Communities and IDENT 

matches. 

Figure 2. Activated Jurisdictions, FYs 2009 Through 2011 

1000 

800 

600 

400 

200 

0 88 

570 

937 

FY 2009 FY 2010 FY 2011 

Figure 3. IDENT Matches, FYs 2009 Through 2011 

95,664 

248,166 

348,958 

0 

50,000 

100,000 

150,000 

200,000 

250,000 

300,000 

350,000 

400,000 

FY 2009 FY 2010 FY 2011 

Source: ICE. 

Earlier Identification of Criminal Aliens 

The information sharing capability of Secure Communities also 

allowed ICE to identify removable aliens earlier in the criminal 

justice process. ICE was able to identify individuals when local 

jurisdictions first submitted the fingerprints rather than after 

incarceration. Earlier identification meant that ICE could remove 

aliens with prior convictions or immigration violations regardless 

of the current charges against them. 

Prior to Secure Communities, under the Criminal Alien Program 

and the 287(g) Program, ICE might not have been able to identify 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 6 
 

aliens with prior convictions or immigration violations if their 

most current charges were minor and no prison sentences were 

imposed. Under Secure Communities, local jurisdictions that 

arrest individuals for minor charges submit their fingerprints to the 

FBI, which then sends the fingerprints to DHS for screening in 

IDENT. When IDENT matches are found, ICE researches these 

individuals’ immigration and criminal histories and requests 

detention. For example: 

•	 A person fleeing from police officers after a traffic 

violation who had previously served a 2-year sentence for 

illegal reentry into the United States and had 11 criminal 

convictions, including drug trafficking and assault; 

•	 A person possessing illegal drugs who had prior 

convictions for aggravated felonies, including larceny and 

fraud; and 

•	 A person driving without a license who had prior 

convictions for assault and larceny and who had been 

previously removed from the United States. 

Duplicative Research 

ICE officers performed duplicative research before taking 

enforcement action because the LESC did not have the technical 

capability to share details of its initial research with ICE field 

offices. Once fingerprints matched an immigration record, LESC 

personnel reviewed as many as 16 databases to determine the 

criminal history and immigration status of the matched individual. 

After the LESC notified a field office or Interoperability Resource 

Center, ICE personnel researched matches again because the 

LESC’s notices did not contain details of its research, such as past 

convictions or a comprehensive immigration history. ICE officers 

conducted their own research of matches because of the LESC’s 

technical limitations, and because officers wanted to ensure that 

they took appropriate enforcement actions. 

ICE attempted to eliminate duplication in the research process by 

modernizing the LESC’s Alien Criminal Response Information 

Management System (ACRIMe).3 Since FY 2008, ICE has spent 

about $12 million for a contractor to develop ACRIMe into a 

system that would allow ICE’s field personnel to review the 

3 The LESC’s ACRIMe supports ICE’s responses to immigration status inquiries on individuals arrested or 

encountered by local law enforcement agencies. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

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LESC’s research or to perform their own research. However, after 

the initial attempt to modernize ACRIMe, the system did not 

function as intended. In October 2011, ICE obtained a new 

contractor to continue to develop ACRIMe, but it does not have a 

new timeline for ACRIMe deployment. 

Enforcement Actions 

Officers generally took enforcement actions consistent with ICE’s 

enforcement policy. However, officers did not always sufficiently 

document these actions. 

ICE’s Enforcement Priorities 

In March 2011, ICE reissued its policy outlining enforcement 

priorities for all ICE programs. According to the enforcement 

policy, ICE officers may still pursue the removal of all aliens 

unlawfully in the United States, but should commit resources 

primarily to the following: 

•	 Priority 1: Aliens who pose a danger to national security 

or a risk to public safety. ICE defined three levels of 

Priority 1 crimes: 

 Crime Level 1: Aliens convicted of aggravated 

felonies,4 or two or more crimes each punishable by 

more than 1 year (commonly referred to as 

“felonies”).

 Crime Level 2: Aliens convicted of any felony, or 

three or more crimes punishable by less than 1 year 

(commonly referred to as “misdemeanors”).

 Crime Level 3: Aliens convicted of crimes 

punishable by less than 1 year. 

•	 Priority 2: Aliens who violate immigration controls at the 

border and at ports of entry or have abused visa programs. 

4 The Immigration and Nationality Act of 1952, as amended, defines “aggravated felonies” for purposes of 

the act to include such crimes as murder; rape; illicit trafficking of firearms and controlled substances; 

violent crimes for which the term of imprisonment is at least 1 year; fraud offenses over $10,000; certain 

offenses related to alien smuggling; and theft or burglary for which the term of imprisonment is at least 1 

year. See 8 U.S.C. 1101(a)(43). 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 8 
•	 Priority 3: Aliens who are fugitives5 or have otherwise 

obstructed immigration controls. This priority includes 

aliens who reenter the country illegally after removal or 

enter fraudulently. 

Adjustment to Crime Levels 

Between FY 2008 and FY 2010, Secure Communities used a 

standard list of crimes to prioritize enforcement actions. As part of 

its new enforcement policy, ICE modified the crime levels under 

its top priority (Priority 1) as follows: 

•	 Level 1: Moved 17 crimes, which had been at Level 2 or 

3, up to this level, including 11 crimes with sentences of 

more than 1 year such as drug trafficking, alien smuggling, 

and arson. The remaining 6 of 17 included crimes such as 

terrorism and human slavery and trafficking. The 

Immigration and Nationality Act of 1952, as amended, 

defines all 17 of these crimes as aggravated felonies. 

•	 Level 2: Moved eight crimes up to this level from Level 3, 

including illegal reentry, identity theft, extortion, and gang 

activity. 

•	 Level 3: Added 13 crimes to this level, including violating 

court orders, harboring fugitives, and disorderly conduct. 

Regardless of the crime level, ICE’s priority is to remove aliens 

with criminal convictions. However, ICE considers aliens with 

Level 1 convictions higher priority than those with Level 2 or 3 

convictions. 

Assessing Enforcement Decisions 

In most cases, ICE officers took enforcement action consistent 

with enforcement policy. We selected 766 Secure Communities 

cases from FY 2011 to assess the actions officers took in response 

to matches in IDENT. In 43 of the 766 cases, officers did not enter 

all pertinent information into the case management system. ICE’s 

records were not sufficient to determine whether officers took 

appropriate actions. In some of the 43 cases, officers did not enter 

any information into the system. 

5 Fugitive aliens are those who receive a final order of removal but have not surrendered to ICE or have not 

left the United States. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

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Of the 723 cases we could assess, officers took enforcement 

actions consistent with ICE’s policy in 698 (97%). Our review 

showed that officers— 

•	 Requested detention, removed, or determined that 

individuals could not be removed from the United States 

for 267 Priority 1 criminal cases and 48 Priority 2 or 3 

cases; 

•	 Requested detention of 11 legal permanent residents with 

removable convictions; 

•	 Did not request detention of 88 U.S. citizens, 218 aliens 

with legal status, and 21 aliens with no prior immigration 

or criminal records; and 

•	 Requested detention of 45 aliens with criminal charges. 

Although these cases did not fall under one of ICE’s three 

priorities, ICE determined that the individuals were in the 

country unlawfully and pursued removal. 

In the remaining 25 (3%) of 723 cases, officers’ enforcement 

actions did not appear to align with ICE’s enforcement policy. 

Although information in the case management system indicated 

that these cases fell under one of ICE’s priorities, there was no 

record of officers requesting detention in 16 Priority 1 cases or 8 

Priority 2 or 3 cases. In addition, officers requested detention of 

one legal permanent resident who did not have a removable 

conviction. According to ICE, this individual had a lengthy 

criminal record, but ICE could not provide information showing 

any removable conviction. 

Secure Communities Incarceration Costs 

Law enforcement agencies in jurisdictions activated under Secure 

Communities did not incur significant incarceration costs resulting from 

activation. We interviewed law enforcement officials at 37 activated local 

jurisdictions to determine whether Secure Communities resulted in 

increased incarceration costs. Of these 37 jurisdictions, 31 (84%) reported 

that they did not incur incarceration costs, and the remaining 6 (16%) 

incurred minimal costs. However, none of the jurisdictions that reported 

minimal costs could quantify them. 

We attempted to interview officials in Cook County, Illinois, after the 

county claimed that it incurred significant costs detaining criminal aliens 

identified through Secure Communities. Cook County claimed that it 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 10 
 

incurred about $43,000 per day, or $15 million per year, in incarceration 

costs, but at the time of our review ICE had not activated Secure 

Communities in Cook County. 

Actions Taken by ICE 

During the time of our review, ICE developed and implemented changes 

in its case management process. In July 2011, ICE issued a new policy 

instructing its officers to document alien encounters in the case 

management system. In addition, in November 2011, ICE reiterated to all 

field offices its case management requirement to document all Secure 

Communities matches, whether or not officers took enforcement actions. 

Recommendations 

We recommend that the Immigration and Customs Enforcement’s 

Enforcement and Removal Operations, Executive Associate 

Director: 

Recommendation #1: Develop procedures to eliminate 

duplication in the identification process. If necessary, develop 

short-term and long-term procedures. 

Recommendation #2: Develop procedures and system controls to 

ensure that officers complete all records for individuals identified 

through Secure Communities. 

Management Comments and OIG Analysis 

We obtained and reviewed written comments on the draft report 

from ICE’s Chief Financial Officer. Where appropriate, we made 

changes to the report. According to its response to the draft report, 

ICE concurred with both of the recommendations. We included a 

copy of the management comments in their entirety in appendix B. 

The following is an evaluation of ICE’s official response. 

Management Response on Recommendation #1 

ICE concurred with the recommendation and stated that it 

continues to modernize ACRIMe to provide an interface that will 

make data available to specialists. The enhancements will provide 

searching capabilities to field offices and will provide field agents 

with access to the information that an LESC specialist used in their 

query response. This will provide a more efficient process for both 

the LESC and field offices to determine and report an individual’s 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 11 
 

status and will eliminate the duplication that currently occurs when 

a field agent validates the LESC research and status determination. 

ICE estimated that it will provide all field offices nationwide with 

the enhancements in FY 2013. In addition, ICE stated that shortterm solutions would add inefficiencies to the identification 

process, increase processing times for status determinations, and 

lengthen time for incoming queries from law enforcement 

agencies. 

OIG Analysis: We consider ICE’s actions responsive and 

consider the recommendation resolved, but it will remain open 

until ICE completes deployment of the modernized ACRIMe 

system. 

Management Response on Recommendation #2 

ICE concurred with the recommendation and stated that it is 

developing a monthly report that will identify compliance rates in 

line with the requirement to document encounters and dispositions 

on all IDENT matches, even for cases where ICE did not take 

enforcement action. The report will document the compliance rate 

for each ICE field office and provide details for the IDENT 

matches that did not have a corresponding encounter and 

processing disposition entered into ICE’s enforcement systems. 

OIG Analysis: We consider ICE’s actions responsive and 

consider the recommendation resolved, but it will remain open 

until ICE provides an example of its recurring report. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 12 
Appendix A 

Purpose, Scope, and Methodology 

In response to a request from Representative Zoe Lofgren, the 

Office of Inspector General initiated two reviews of Secure 

Communities. This report provides the results of our work to 

determine whether ICE’s Secure Communities was effective in 

identifying criminal aliens and prioritizing cases for removal 

actions. To achieve our objectives, we— 

•	 Interviewed ICE officials in Washington, DC; LESC 

officials in Burlington, Vermont; and ICE officers in 

Boston, Massachusetts; Denver, Colorado; Miami, Florida; 

Houston, Texas; Phoenix, Arizona; Los Angeles, San 

Diego, and San Francisco, California; and Chicago, Illinois; 

•	 Interviewed law enforcement agencies in 37 local 

jurisdictions to determine whether they incurred 

incarceration costs attributable to activation of Secure 

Communities; 

•	 Reviewed a random sample of 766 cases to determine 

whether ICE officers’ enforcement actions were consistent 

with ICE’s priorities; 

•	 Reviewed policies and procedures related to identification 

of criminal aliens, prioritization of enforcement actions, 

and officer use of prosecutorial discretion; 

•	 Reviewed contract documentation for ICE’s ACRIMe 

modernization effort; 

•	 Assessed the reliability and validity of ICE’s data; and 

•	 Reviewed prior audit reports regarding enforcement action 

decisions and identification and removal of criminal aliens. 

We conducted this performance audit between July and November 

2011 under the authority of the Inspector General Act of 1978, as 

amended, and according to generally accepted government 

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

upon our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities
 

Page 13
 
Appendix B 

Management Comments to the Draft Report 

Offin' 0/1111' Chilf F;lI(lIIcioJ Ofjii;('r 

U.S. 1>cpa rllllcnl of Homela nd 

Seruritv 

500 12'" Street. SW 

W~slrnslon. DC 20536 

u.s. Immigration 

and Customs 

Enforcement 

February 23, 2012 

MEMORANDUM FOR: Anne L. Richards 

Assistant Inspector General ror Audits 

Office of 11~~",­

FROM: abaC. ,~ 

SUBJECT: Errectiveness or United States Immigration and Customs 

Enrorcement 's Secure Communities -- OIG Project No. 11 -

138-AUD-ICE 

U.S. Immigration and Customs Enrorcement (ICE) is pleased to provide a response to the 

draft report ror this subject <Iudit. ICE concurs with the two recommendations and our 

comments are attached. 

IrYOll have any questions, please contact Michael Moy, D IG portrolio Manager, at 202-

732-6263, or via email at Michael.Moy@dllS.goV. 

Attachments 

- I -

Operations of United States Immigration and Customs Enforcement’s Secure Communities
 

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Appendix B 

Management Comments to the Draft Report 

Recommelldatiolf 1: Develop procedures to eliminate duplication ill the identification 

process. If necessary, develop short~term and long~term procedures. 

ICE concurs with this r.commendation. As th. report has indicated, ICE continues its 

development of the modernized Alien Criminal Response Information Management 

System (ACRIMe). which will automate key components of the status determination 

process, decrease the number of systems the Law Enforcement Support Cent.r (LESC) 

law enforcement specialist must manually search, and provide specialists an interface to 

make data available to ENFORCE. Thesc enhanccments will provide searching capability 

to field offices, as well as provide field agents access to the information an LESC 

specialist used in their query response. This functionality will provide a more efficient 

process for both the LESC and field offices to determine and report an individual's status 

and will eliminate the duplication that currently occurs when a field agent validates the 

LESC research and status determination. 

The implementation milestones for ACRlMe include: 

• Develop a web-based interface for searching of National Crime Information Center 

(NCIC) and National Law Enforcement Telecommunications System (NLETS): 

Completed during quarter one fiscal year 2012. 

• Deploy the web-based interface for searching NCIC and NLETS: Completed during 

quarter two of fiscal year 2012. 

• Begin development of Immigration Alien Query (IAQ) processing to replace the 

legacy ACRlMe IAQ processing component: Estimated during quarter two of fiscal 

year 2012. 

• Begin development ofField Access Release to allow field office staff to review the 

LESC's research or to perform their own research. Estimated during quarter three of 

fiscal year 2012. 

• Begin training the LESC on the improVed IAQ Processing: Estimated during quarter 

four of fiscal year 2012. 

• Deploy limited field access functionality at selected field offices in a phased roll out: 

Estimated during quarter one of fiscal year 2013. 

ICE completed a lessons learned exercise on the initial modernized ACRIMe effort and 

identified two primary challenges: complex business requirements had not been fully 

understood by the development tearn. and the development tearn had adhered to poor 

coding practices. ICE developed mitigation strategies to address these challenges, and 

has implemented an agile systems development methodology. This new development 

methodology requires direct and constanl (daily) inleraclion between developers and end 

users, helping to ensure productive understanding and communication relaled 10 

requirements. Additionally, the agile methodology is based on a test-driven developmenl 

approach Ihal encourages direcl inleraclion between ICE's lechnical archilecture staffand 

the development tearn to ensure that the developmenttearn is coding to a clear standard 

and is following acceptable coding practices. ICE understands Ihe risks involved with 

employing a new systems development methodology and will rely heavily on Ihe Office 

oflhe Chieflnforrnation Officer to inlegrate the work of several small business vendors 

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Operations of United States Immigration and Customs Enforcement’s Secure Communities
 

Page 15
 
Appendix B 

Management Comments to the Draft Report 

and assisl in implemenling !he agile approach 10 Ihe ACRlMe development effort. ICE 

understands that failure to transition to these new strategies and methods are a risk to 

schedule, budget, and perfonnance. 

ICE assessed alternative short·term solutions and has determined that such activity would 

only add additional inefficiencies to the identification process. For example, providing 

ICE field personnel with "screen shots" from systems used by LESe technicians or 

faxing the results of database searches would increase the processing times for status 

detenninations and lengthen queue times for incoming queries from law enforcement 

agencies. 

ICE requests that this recommendation be considered Resolved and Open pending 

complele deploymenl and conlinued operalion oflhe modernized ACRIMc syslem. ICE 

eslimales !hallhe modernized syslem will be in use nalionwide by all ICE field offices in 

fiscal year 2013. 

Recommendation 2: Develop procedures alld system controls to ellsure ofllcers 

complete til/ records for individuals Identified through Secure Communides 

ICE concurs with this recommendation. There is often a Jag between the time that a 

criminal conviction is rendered and the time that these convictions are recorded in law 

enforcement systems (e.g .• the Federal Bureau ofInvestigation's National Crime 

Information Center). While ICE agents and officers' conduct prioritized enforcement 

operations with the knowledge of such criminal convictions, the agency cannot label the 

case as a "criminal alien" removal until the appropriate judgment and disposition record 

is loealed and recorded. To mitigate Ihe impact to ICE's reponing, !he field is provided 

access to a list of public websites and sources that contain criminal history infonnation 

from various states and localities. These criminal history sources provide the field with 

more timely access to conviction documentation, thereby improving its reponing. 

Additionally, ICE headquarters continues its data quality initiatives to maintain a 

"feedback loop" to field offices regarding the completeness and accuracy of data entered 

into ICE systems. For example, ICE headquarters provides the field, on a bi-monlhly 

basis. with the results ofa report that examines non-criminal alien removals and identifies 

specific cases where criminal history information shows evidence of a conviction. 

Through !his report, ICE headquarters !hen provides each unique case 10 !he appropriale 

ICE field office with instructions to examine the case and provide the requisite criminal 

history information. This data quality initiative ensures that aliens with criminal 

convictions who are removed by ICE are accurately recorded in ICE systems as criminal 

alien removals. 

As !he draft repon stated, ICE did not hislorically record much data regarding case 

referrals Ihrough the use of IDENT/IAFIS inleroperability that did not result in an ICE 

enforcement action. ICE is developing a recurring report that will identify compliance 

rates in line with the requirement to document encounters and processing dispositions on 

all alien IDENT matches, even those for which no ICE enforcement action has been 

- 3-

Operations of United States Immigration and Customs Enforcement’s Secure Communities
 

Page 16
 
Appendix B 

Management Comments to the Draft Report 

taken. This monthly report will document the compliance rate for each ICE field office's 

area of responsibility and provide detai ls for the IDENT matches that did not have a 

corresponding encounter and processing disposition entered into ICE's enfot'cemen\ 

systems. The report findings will be aggregated by individual alien identification number 

and assessed to detenlline if the applicable case details require additional review and 

updates. For those cases that have not been appropriately documented, ICE field offices 

will be provided guidance and required to enter or update the appropriate inronnatioll. 

ICE requests that this recommendation be considered Resolved and Open pending the 

development and issuance of the aforementioned report. The estimated completion dale 

of the report development is March 31, 2012. 

- 4 -

Prior to Secure Communities, ICE had three programs focused on identifying and 

removing criminal aliens: 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 17 
 

Appendix C 

ICE Identification and Removal Programs 

•	 Criminal Alien Program: Identifies, processes, and 

removes criminal aliens incarcerated in federal, State, and 

local prisons and jails throughout the United States, 

preventing their release into the general public by securing 

a final order of removal prior to the termination of their 

sentences. 

•	 National Fugitive Operations Program: Identifies, 

locates, and arrests fugitive aliens; aliens who have been 

previously removed from the United States; removable 

aliens who have been convicted of crimes; and aliens who 

enter the United States illegally or otherwise defy the 

integrity of U.S. immigration laws and border control 

efforts. 

•	 Delegation of Immigration Authority Section 287(g) 

Immigration and Nationality Act (the 287(g) Program): 

The 287(g) Program allows States and local law 

enforcement agencies to enter into partnerships with ICE 

through bilateral memorandums of agreement under which 

they are delegated authority for immigration enforcement 

in their jurisdictions. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 18 
Appendix D 

Jurisdictions Where ICE Activated Secure Communities 

In October 2008, ICE began activation of Secure Communities in 

Harris County, Texas. As of December 28, 2011, ICE reported 

that it had activated Secure Communities in 2,027 jurisdictions in 

44 States. 

Source: ICE. 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 19 
Appendix E 

Major Contributors to this Report 

Linda Howard, Director 

Sean Pettersen, Audit Manager 

Holly Snow, Auditor-In-Charge 

Patricia Benson, Auditor-In-Charge 

Andrew Herman, Auditor 

Emily Pedersen, Program Analyst 

G. Scott Crissey, Program Analyst 

Gary Crownover, Program Analyst 

Ignacio Yanes, Program Analyst 

Pamela Weatherly, Auditor 

Ruth Arevalo, Program Analyst 

Steve Doran, Auditor 

Mark S. Phillips, Independent Referencer 

Kelly Herberger, Communication Analyst 

Operations of United States Immigration and Customs Enforcement’s Secure Communities 

Page 20 
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 

Director, U.S. Immigration and Customs Enforcement 

ICE Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Operations of United States Immigration and Customs Enforcement’s Secure Communities
 

Page 21
 
 

 

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