ICE Does Not Fully Use 

Contracting Tools to Hold 

Detention Facility 

Contractors Accountable 

for Failing to Meet 

Performance Standards 

January 29, 2019 

OIG-19-18 
 

 

 

DHS OIG HIGHLIGHTS

 ICE Does Not Fully Use Contracting Tools to Hold Detention

Facility Contractors Accountable for Failing to Meet

Performance Standards 

January 29, 2019 

Why We 

Did This 

Inspection

U.S. Immigration and 

Customs Enforcement 

(ICE) contracts with 106 

detention facilities to 

detain removable aliens. 

In this review we sought 

to determine whether ICE 

contracting tools hold 

immigration detention 

facilities to applicable 

detention standards, and 

whether ICE imposes 

consequences when 

contracted immigration 

detention facilities do not 

maintain standards. 

What We 

Recommend 

We made five 

recommendations to 

improve contract oversight 

and compliance of ICE 

detention facility 

contractors. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

Although ICE employs a multilayered system to manage and 

oversee detention contracts, ICE does not adequately hold 

detention facility contractors accountable for not meeting 

performance standards. ICE fails to consistently include its quality 

assurance surveillance plan (QASP) in facility contracts. The QASP 

provides tools for ensuring facilities meet performance standards. 

Only 28 out of 106 contracts we reviewed contained the QASP. 

Because the QASP contains the only documented instructions for 

preparing a Contract Discrepancy Report and recommending 

financial penalties, there is confusion about whether ICE can 

issue Contract Discrepancy Reports and impose financial 

consequences absent a QASP. Between October 1, 2015, and June 

30, 2018, ICE imposed financial penalties on only two occasions, 

despite documenting thousands of instances of the facilities’ 

failures to comply with detention standards. 

Instead of holding facilities accountable through financial 

penalties, ICE issued waivers to facilities with deficient conditions, 

seeking to exempt them from complying with certain standards. 

However, ICE has no formal policies and procedures to govern the 

waiver process, has allowed officials without clear authority to 

grant waivers, and does not ensure key stakeholders have access 

to approved waivers. Further, the organizational placement and 

overextension of contracting officer’s representatives impede 

monitoring of facility contracts. Finally, ICE does not adequately 

share information about ICE detention contracts with key officials.

ICE Response 

ICE officials concurred with all five recommendations and 

proposed steps to update processes and guidance regarding 

contracting tools used to hold detention facility contractors 

accountable for failing to meet performance standards. 

www.oig.dhs.gov OIG-19-18 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

-DQXDU\

MEMORANDUM FOR: Ronald D. Vitiello 

Deputy Director and Senior Official Performing the 

Duties of Director 

U.S. Immigration and Customs Enforcement 

FROM: John V. Kelly 

Senior Official Performing the Duties of the 

Inspector General 

SUBJECT:	 ICE Does Not Fully Use Contracting Tools to Hold 

Detention Facility Contractors Accountable for Failing to 

Meet Performance Standards 

Attached for your information is our final report, ICE Does Not Fully Use 

Contracting Tools to Hold Detention Facility Contractors Accountable for Failing to
 

Meet Performance Standards. We incorporated the formal comments from the 

ICE Office of the Chief Financial Officer in the final report. 

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 Jennifer Costello, 

Deputy Inspector General, or Tatyana Martell, Chief Inspector, 

at (202) 981-6000. 

Attachment 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

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

Results of Inspection ...................................................................................... 7 

ICE Does Not Consistently Use Contract-Based Quality Assurance Tools 

and Impose Consequences for Contract Noncompliance ......................... 7 

ICE’s Waiver Process May Allow Contract Facilities to Circumvent 

Detention Standards and May Inhibit Proper Contract Oversight ........... 9 

Organizational Placement and Overextension of CORs Impede Monitoring 

of Detention Facilities .......................................................................... 12 

Lack of Direct Access to Important Contract Files Hinders CORs’ and 

DSMs’ Ability to Monitor Detention Contracts ...................................... 14 

Conclusion ................................................................................................... 15 

Recommendations ......................................................................................... 15 

Appendixes 

Appendix A: Objective, Scope, and Methodology .................................. 21 

Appendix B: Management Comments to the Draft Report ..................... 22 

Appendix C: Facility Listing and Quality Assurance Surveillance Plan 

Status......................... ....................................................................... 27 

Appendix D: Office of Inspections and Evaluations Major 

Contributors to This Report ................................................................. 31 

Appendix E: Report Distribution .......................................................... 32 

Abbreviations 

ADP average daily population 

CDF contract detention facility 

CFR Code of Federal Regulations 

COR contracting officer’s representative 

DIGSA dedicated inter-governmental service agreement 

DSM Detention Service Manager 

ERO Enforcement and Removal Operations 

FAR Federal Acquisition Regulation 

ICE U.S. Immigration and Customs Enforcement 

IGA inter-governmental agreement 

www.oig.dhs.gov OIG-19-18 


 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

IGSA inter-governmental service agreement 

NDS National Detention Standards 

ODO Office of Detention Oversight 

OIG Office of Inspector General 

PBNDS Performance-Based National Detention Standards 

QASP quality assurance surveillance plan 

www.oig.dhs.gov 2 OIG-19-18 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Background 

U.S. Immigration and Customs Enforcement’s (ICE) Office of Enforcement and 

Removal Operations (ERO) confines detainees in civil custody for the 

administrative purpose of holding, processing, and preparing them for removal 

from the United States. While ICE owns five detention facilities, it has executed 

contracts, inter-governmental service agreements (IGSA), or inter-governmental 

agreements (IGA) with another 206 facilities for the purpose of housing ICE 

detainees.1 Table 1 lists the types and numbers of facilities ICE uses to hold 

detainees as well as the average daily population (ADP) at the end of fiscal year 

2017. 

Table 1: Types of Facilities ICE Uses for Detention 

Facility Type Description Number 

of 

Facilities 

FY 17 End 

ADP 

Service Processing 

Center 

Facilities owned by ICE and 

generally operated by contract 

detention staff 

5 3,263 

Contract Detention 

Facility (CDF) 

Facilities owned and operated 

by private companies and 

contracted directly by ICE 

8 6,818 

Intergovernmental 

Service Agreement 

(IGSA) 

Facilities, such as local and county 

jails, housing ICE detainees (as well 

as other inmates) under an IGSA 

with ICE 

87 8,778 

Dedicated Intergovernmental 

Service Agreement 

(DIGSA) 

Facilities dedicated to housing 

only ICE detainees under an IGSA 

with ICE 

11 9,820 

U.S. Marshals 

Service Intergovernmental

Agreement (IGA) 

Facilities contracted by U.S. 

Marshals Service that ICE also 

agrees to use as a contract rider 

100 6,756 

Total: 211 35,435 

Source: ICE data 

 1 Unless otherwise indicated, in this report we use the term “contract” in reference to the 

contract, IGSA, or IGA instrument used to establish a relationship between ICE and the 

detention facility and the term “contract facility” to describe any detention facility operated 

under a contract, IGSA, or IGA. 

www.oig.dhs.gov 3 OIG-19-18 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

For this review, we focused on the 106 CDF, IGSA, and DIGSA facilities2 for 

which ICE has primary contracting authority.3 In FY 2017, these 106 facilities 

held an average daily population of more than 25,000 detainees. Since the 

beginning of FY 2016, ICE has paid more than $3 billion to the contractors 

operating these 106 facilities. 

Key ICE Offices Involved in Contract Management and Facility Oversight 

ICE spreads duties for planning, awarding, and administering contracts for 

detention management and overseeing contract facilities between Management 

and Administration and ERO, resulting in a multilayered system. Figure 1 

provides the organizational structure for the key offices involved in managing 

contracts and overseeing contract facilities. 

Figure 1: Offices Responsible for Contract Management and Oversight 

ICE Deputy

Director 

ERO Executive 

Associate Director 

Custody

Management 

Detention 

Management 

Division 

Detention 

Standards 

Compliance Unit 

Detention Planning

and Acquisitions 

Detention 

Monitoring Unit 

Operations Support 

Fiscal Management 

Division 

Budget Execution 

Unit 

Contract 

Management Unit 

Field Operations 

Domestic 

Operations Division 

Domestic 

Operations East 

Domestic 

Operations West 

ICE Health Services 

Corps 

Management and 

Administration 

Executive Associate 

Director 

Acquisitions

Management 

Acquisition Service

Division 

Detention 

Compliance and

Removal 

Office of Chief 

Financial Officer 

Office of Budget

and Program

Performance 

Office of Financial 

Management 

Source: Office of Inspector General (OIG) analysis of ICE data 

 2 See Appendix C: Facility Listing and Quality Assurance Surveillance Plan Status for a listing 

of the 106 facilities reviewed.
 3 We did not review contracts from the 100 detention facilities for which the U.S. Marshals 

Service has primary contracting authority. ICE executed IGAs (contract riders) with the U.S. 

Marshals Service to house ICE detainees at these facilities.
 

www.oig.dhs.gov 4 OIG-19-18 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Within ERO, the Custody Management Division (Custody Management) 

manages ICE detention operations and oversees the administrative detainees 

held in detention facilities. Custody Management has a Detention Standards 

Compliance Unit, which monitors oversight inspections to evaluate compliance 

with ICE’s national detention standards. As part of ICE ERO’s development of a 

Detention Monitoring Program in 2010, Custody Management assigned 

Detention Service Managers (DSM) to cover 54 contract facilities to monitor 

compliance with detention standards. Custody Management also analyzes 

operational bed space needs and initiates requests for additional contract 

facilities to the Office of Acquisitions Management (Acquisitions Management), 

within Management and Administration. 

Acquisitions Management is responsible for preparing, executing, and 

maintaining the contracts for detention facilities and for processing any 

modifications to contracts. Acquisitions Management contracting officers have 

signature authority to execute and modify contracts for detention facilities. 

Contracting officers also appoint contracting officers’ representatives (COR) to 

oversee the day-to-day management of each contract facility, but retain 

ultimate authority for enforcing the terms of the contract. 

ICE has 26 principal COR positions physically located at the 24 ERO Field 

Offices to function as liaisons between field operations and contracting. CORs 

report to Field Office management and are responsible for ensuring the 

contractor complies with the terms of the contract. CORs generally conduct 

detention facility site visits and should have first-hand knowledge of detention 

facility operations in order to approve invoices for payment and to address 

instances of noncompliance, such as by pursuing contractual remedies. The 

Field Operations Division provides guidance to and coordination among the 24 

national ERO Field Offices. The Field Office Directors are chiefly responsible for 

the detention facilities in their assigned geographic area. 

Detention Contracts and Standards Compliance 

Each detention facility with an ICE contract must comply with one of three sets 

of national detention standards: National Detention Standards, 2008 

Performance-Based National Detention Standards (PBNDS), or 2011 PBNDS. 

These standards (1) describe a facility’s immigration detention responsibilities, 

(2) explain what detainee services a facility must provide, and (3) identify what 

a facility must do to ensure a safe and secure detention environment for staff 

and detainees. 

www.oig.dhs.gov 5 OIG-19-18 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

ICE monitors facility compliance with the applicable detention standards 

through triennial Office of Detention Oversight (ODO) inspections,4 annual 

contractor-led compliance inspections by Nakamoto Group, Inc., and the 

assignment of Custody Management DSMs to cover 54 contract facilities. 

Inspectors and DSMs report deficiencies to the facility, the ERO Field Office 

responsible for the facility, and ICE headquarters. To correct these deficiencies, 

ICE’s Detention Standards Compliance Unit, which works independent of the 

contract offices, prepares and sends uniform corrective action plans to the ERO 

Field Offices and works with them to ensure the deficiencies get resolved. As we 

previously reported, this process is not as effective as intended.5 

Another path for correcting deficiencies is through the contracts. Though not 

required, detention contracts may include a quality assurance surveillance 

plan (QASP). The QASP is a standard template that outlines detailed 

requirements for complying with applicable performance standards, including 

detention standards, and potential actions ICE can take when a contractor fails 

to meet those standards. When facilities are found to be noncompliant, CORs 

may submit a Contract Discrepancy Report (Discrepancy Report), which 

documents the performance issue. 

After CORs submit Discrepancy Reports, facilities are responsible for correcting 

deficiencies or at least preparing a corrective action plan by the identified due 

date. If the facility is not compliant, a Discrepancy Report may include a 

recommendation for financial penalties, such as a deduction in or withholding 

of ICE payment to the contractor.6 For example, the QASP states that a 

deduction may be appropriate when an egregious event or deficiency occurs, 

such as when a particular deficiency is noted multiple times without correction 

or when the contractor failed to resolve a deficiency about which it was 

properly and timely notified. A withholding may be appropriate while the 

contractor corrects a deficiency. The contracting officer must approve any 

withholdings or deductions. 

We initiated this review to determine whether ICE is effectively managing 

detention facility contracts for its 106 CDF, IGSA, and DIGSA facilities. This 

report addresses (1) ICE’s failure to use quality assurance tools and impose 

consequences for contract noncompliance; (2) the use of waivers, which may 

circumvent detention standards specified in contracts; (3) how the CORs’ 

organizational placement hinders their ability to monitor contracts; and 

 4 ODO conducts compliance inspections at detention facilities housing detainees for greater 

than 72 hours with an average daily population greater than 10. ODO is under ICE’s Office of 

Professional Responsibility. 

5 ICE’s Inspections and Monitoring of Detention Facilities Do Not Lead to Sustained Compliance or 

Systemic Improvements, OIG-18-67, June 2018 

6 Detention facilities cannot recoup a deduction, but can recoup a withholding when they 

correct a deficiency. 

www.oig.dhs.gov 6 OIG-19-18 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

(4) CORs’ and DSMs’ lack of direct access to important contract files. 

Results of Inspection 

Although ICE employs a multilayered system to manage and oversee detention 

contracts, ICE does not adequately hold detention facility contractors 

accountable for not meeting performance standards. ICE fails to consistently 

use contract-based quality assurance tools, such as by omitting the QASP from 

facility contracts. In fact, only 28 out of 106 contracts we reviewed included the 

QASP. Because the QASP contains the only documented instructions for 

preparing a Discrepancy Report and recommending financial penalties, there is 

confusion about whether ICE can issue Discrepancy Reports and impose 

financial consequences absent a QASP. Between October 1, 2015, and June 30, 

2018, ICE imposed financial penalties on only two occasions, despite 

documenting thousands of instances of the facilities’ failures to comply with 

detention standards. Instead of holding facilities accountable through financial 

penalties, ICE issued waivers to facilities with deficient conditions, seeking to 

exempt them from having to comply with certain detention standards. However, 

ICE has no formal policies and procedures about the waiver process and has 

allowed officials without clear authority to grant waivers. ICE also does not 

ensure key stakeholders have access to approved waivers. Further, we 

determined that the organizational placement and overextension of CORs 

impede monitoring of facility contracts. Finally, ICE does not adequately share 

information about ICE detention contracts with key officials, such as CORs and 

DSMs, which limits their ability to access information necessary to perform 

core job functions.

ICE Does Not Consistently Use Contract-Based Quality 

Assurance Tools and Impose Consequences for Contract 

Noncompliance 

As noted, there are two paths for correcting deficiencies: the facilities 

inspection process and the quality assurance tools in the facilities contracts 

themselves. With respect to the inspection process, we previously reported that 

ICE does not adequately follow up on identified deficiencies or consistently hold 

facilities accountable for correcting them.7 During our current work, we found 

similar problems with ICE’s use of contract-based quality assurance tools. 

Specifically, ICE did not consistently include the QASP in the facility contracts 

we reviewed, which has led to confusion among CORs about how to issue 

Discrepancy Reports. These problems are compounded because ICE does not 

 7 ICE’s Inspections and Monitoring of Detention Facilities Do Not Lead to Sustained Compliance or 

Systemic Improvements, OIG-18-67, June 2018 

www.oig.dhs.gov 7 OIG-19-18 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

track these reports and rarely imposes financial consequences, even when 

identified deficiencies present significant safety and health risks. 

Out of 106 contracts we reviewed, only 28 contained the QASP.8 The QASP is 

especially important because it contains the only documented instructions for 

preparing a Discrepancy Report and recommending financial penalties, when 

informal resolution is not practicable.9 Consequently, when contracts do not 

contain the QASP, CORs and contracting officers are left confused as to what 

actions they can take when deficiencies are identified. For example, of the 11 

CORs we interviewed, 5 told us they could issue a Discrepancy Report to a 

facility that did not have the QASP, while 2 said they could not. Two others 

said they could issue a Discrepancy Report without the QASP, but they could 

not seek financial penalties for noncompliance. The two remaining CORs told 

us they did not know whether they could issue a Discrepancy Report without a 

QASP. 

Even where ICE does issue Discrepancy Reports, ICE does not track their use 

or effectiveness. No office within ICE could provide any data on how many 

Discrepancy Reports are issued to facilities and for what reasons. An ICE 

official from Acquisitions Management explained that his office would have to 

review the individual contract files to see whether Discrepancy Reports were 

issued and why. The Discrepancy Reports we reviewed involved serious 

deficiencies such as significant understaffing, failure to provide sufficient 

mental health observation, and inadequate monitoring of detainees with 

serious criminal histories. However, we have no way of verifying whether any of 

these deficiencies have been corrected. 

Furthermore, ICE is not imposing financial penalties, even for serious 

deficiencies such as those we found in the Discrepancy Reports. In addition to 

the issues flagged by these Discrepancy Reports, from October 2015 to June 

2018 various inspections and DSMs found 14,003 deficiencies at the 106 

contract facilities we focused on for this review. These deficiencies include 

those that jeopardize the safety and rights of detainees, such as failing to notify 

ICE about sexual assaults and failing to forward allegations regarding 

misconduct of facility staff to ICE ERO. Despite these identified deficiencies, 

ICE only imposed financial penalties twice. ICE deducted funds from one 

facility as a result of a pattern of repeat deficiencies over a 3-year period, 

primarily related to health care and mental health standards. The other 

deduction was made due to a U.S. Department of Labor order against the 

 8 Specifically, all 8 CDF and 10 of the 11 DIGSA facilities had a QASP in place, but only 10 of 

87 non-dedicated IGSA facilities had a QASP. 

9 The QASP directs the COR to send a Discrepancy Report documenting the deficiencies to the 

facility. The facility is required to respond to the Discrepancy Report by a specified date, 

indicating that either the deficiencies have been corrected or a corrective action plan is in 

place. 

www.oig.dhs.gov 8 OIG-19-18 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

contractor for underpayment of wages and was not related to any identified 

deficiency. Our review of the corresponding payment data identified about $3.9 

million in deductions, representing only 0.13 percent of the more than $3 

billion in total payments to contractors during the same timeframe. ICE did not 

impose any withholdings during this timeframe. 

ICE’s Waiver Process May Allow Contract Facilities to 

Circumvent Detention Standards and May Inhibit Proper 

Contract Oversight 

Instead of holding facilities accountable through financial penalties, ICE 

frequently issued waivers to facilities with deficient conditions, seeking to 

exempt them from having to comply with certain detention standards.10 

However, we found that ICE has no formal policies and procedures to govern 

the waiver process and has allowed ERO officials without clear authority to 

grant waivers. We also determined that ICE does not ensure key stakeholders 

have access to approved waivers. In some cases, officials may violate Federal 

Acquisition Regulation requirements because they seek to effectuate 

unauthorized changes to contract terms. 

Lack of Guidance on the Waiver Process Potentially Exempts Contract Facilities 

from Complying with Certain Detention Standards Indefinitely 

Generally, waiver requests result from ICE’s inspections or DSMs’ monitoring. 

After completing an inspection, inspectors brief the facility on the deficiencies 

they find and issue inspection reports. The Detention Standards Compliance 

Unit then issues uniform corrective action plans to the ERO Field Offices and 

DSMs. The Field Offices forward the uniform corrective action plans to the 

facilities, work with the facilities to correct the identified deficiencies, and 

report those corrective actions to the Detention Standards Compliance Unit. 

DSMs monitor compliance on a daily basis and report deficiencies to the 

facilities, to local ICE Field Offices, and through weekly reports to Custody 

Management. 

As ICE ERO works with the contractor to resolve the deficiencies, a facility can 

assert that it could not remedy the deficiency because complying with the 

standard can create a hardship, because of a conflict with a state law or a local 

policy, a facility design limitation, or another reason. In these cases, the Field 

Office Director may submit a waiver request to Custody Management, which 

approves or denies the request. We analyzed the 68 waiver requests submitted 

 10 ICE’s Inspections and Monitoring of Detention Facilities Do Not Lead to Sustained Compliance 

or Systemic Improvements, OIG-18-67, June 2018 

www.oig.dhs.gov 9 OIG-19-18 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

between September 2016 and July 2018. Custody Management approved 96 

percent of these requests, including waivers of safety and security standards.11 

Despite this high approval rate, ICE could not provide us with any guidance on 

the waiver process. Key officials admitted there are no policies, procedures, 

guidance documents, or instructions to explain how to review waiver requests. 

The only pertinent documents that ICE provided were examples of memoranda 

that Field Office Directors could use to request waivers of the detention 

standards’ provisions on strip searches. However, the memoranda did not 

acknowledge the important constitutional and policy interests implicated by a 

facility’s use of strip searches. ICE officials did not explain how Custody 

Management should handle such waiver requests when a contrary contractual 

provision requires compliance with a strip search standard. 

Further, contract facilities may be exempt from compliance with otherwise 

applicable detention standards indefinitely, as waivers generally do not have an 

end date and Custody Management does not reassess or review waivers after it 

approves them. In our sample of 65 approved waiver requests, only three had 

identified expiration dates; the 62 others had no end date. 

The Chief of the Detention Standards Compliance Unit within ICE ERO 

Custody Management has drafted written guidance on the waiver submission 

and approval process, but has not finalized that document. Without formal 

waiver guidance and review processes, ICE may be indefinitely allowing 

contract facilities to circumvent detention standards intended to assure the 

safety, security, and rights of detainees. A facility’s indefinite exemption from 

certain detention standards raises risks to detainee health and safety that ICE 

could reduce by enforcing compliance with those standards. For example, 

Custody Management granted a waiver authorizing a facility (a CDF) to use 2-

chlorobenzalmalononitrile (CS gas) instead of the OC (pepper) spray authorized 

by the detention standard. According to information contained in the waiver 

request, CS gas is 10 times more toxic than OC spray.12 Another waiver allows 

a facility (a DIGSA) to commingle high-custody detainees, who have histories of 

serious criminal offenses, with low-custody detainees, who have minor, nonviolent criminal histories or only immigration violations, which is a practice the 

standards prohibit in order to protect detainees who may be at risk of 

victimization or assault.13 

 11 PBNDS 2008 and PBNDS 2011 organize standards by seven topics: safety, security, order, 

care, activities, justice, and administration and management. NDS 2000 organizes standards 

by three topics: detainee services, health services, and safety and control. 

12 ICE PBNDS 2011, Part 2 – Security, 2.15 Use of Force and Restraints Section (V)(G)(4) states, 

“The following devices are not authorized [...] mace, CN, tear gas, or other chemical agents, 

except OC spray.” 

13 ICE PBNDS 2011, Part 2 – Security, 2.2 Custody Classification System requires facilities to
 

avoid commingling low-custody detainees, who have minor, non-violent criminal histories or 

www.oig.dhs.gov 10 OIG-19-18
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

ERO Officials without Clear Authority Are Granting Waivers That May 

Undermine Contract Terms 

ICE’s practice for issuing waivers could violate the Federal Acquisition 

Regulation (FAR), which establishes policies and procedures that executive 

agencies, including DHS, must use for acquisitions, unless other legal 

authority removes an acquisition from the FAR’s coverage. Under the FAR, 

“only contracting officers acting within the scope of their authority are 

empowered to execute contract modifications.”14 To prevent others from 

exercising authority expressly reserved for contracting officers, the FAR 

explains that other Federal personnel shall not “[a]ct in such a manner as to 

cause the contractor to believe that they have authority to bind the 

Government.”15 ICE asserts that only its CDFs, not its DIGSAs or IGSAs, are 

acquisitions governed by the FAR. However, Acquisitions Management 

procurement guidance stipulates that, in handling DIGSA and IGSA issues, 

contracting officers “should utilize applicable FAR principles and clauses that 

are in the Government’s best interest to the maximum extent possible.”16 

Despite these FAR provisions and this guidance, a senior official told us that 

the Assistant Director for Custody Management has the authority to act on 

waiver requests. The Assistant Director has, in turn, orally delegated authority 

to decide waiver requests to the Deputy Assistant Director for Custody 

Management. However, Custody Management did not provide any 

documentation of this authority, delegated or otherwise, to grant waivers. 

According to the same official, the detention standards are ICE policies and the 

current waiver approval process is sufficient. This position does not 

acknowledge that ICE contractually requires facilities to comply with detention 

standards, and that only the contracting officer — not the Assistant Director or 

the Deputy Assistant Director — can modify those contract terms. 

Through their approval of waivers, ERO officials without the authority to 

modify contracts have sought to remove certain detention standards from 

oversight, even though those standards are part of the contract for the 

detention facility. In reviewing waivers approved for CDFs, we found that ICE 

issued two waivers between October 2016 and July 2018 for aspects of ICE’s 

2011 PBNDS that are part of ICE’s contracts for these facilities. Through these 

waivers, ICE allowed facilities to deviate from PBNDS 2011 requirements. 



only immigration violations, with high-custody detainees, who have histories of serious 

criminal offenses. 

14 48 Code of Federal Regulations (CFR) § 43.102(a) 

15 Id. § 43.102(a)(2)
 16 ICE Acquisitions Management, Procurement Guide 18-02, Inter-governmental Service 

Agreements (IGSA) (Apr. 20, 2018)
 

www.oig.dhs.gov 11 OIG-19-18
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

ICE Staff Responsible for Management and Oversight of Facility Contracts Do 

Not Receive Information on Approved Waivers 

Custody Management does not share information on approved waivers with 

Acquisitions Management, which is responsible for administering detention 

contracts. Acquisitions Management contracting officers told us that most of 

them did not know that Custody Management had issued waivers after a 

facility entered into a detention contract with ICE. The Detention Standards 

Compliance Unit’s draft guidance for the waiver process does not require 

Custody Management to share waiver requests or approvals with Acquisitions 

Management. Because Acquisitions Management does not receive information 

on approved waivers, it cannot determine whether the waiver contradicts 

contract terms or violates the FAR or other procurement requirements. 

Further, Acquisitions Management cannot ensure that contracting officers and 

CORs know about Custody Management’s waiver decision, which undermines 

their ability to monitor their assigned contracts. 

Organizational Placement and Overextension of CORs Impede 

Monitoring of Detention Facilities 

COR placement under the Field Office raises concerns about the CORs’ ability 

to perform their primary functions of monitoring detention facilities and 

enforcing contract terms. They may not be able to fulfill these functions 

because the Field Office pressures them to do things outside of protocol and 

assigns them additional duties. In some cases, CORs have unachievable 

workloads that inhibit their ability to provide consistent and appropriate 

oversight. Overall, these issues may allow facility violations of contract terms 

and noncompliance with performance standards to go unaddressed and may 

lead to dangerous detention conditions. 

Reporting to Field Offices May Compromise a COR’s Independent Oversight 

Efforts 

When the COR program was initially developed in 2009, CORs were located at 

Field Offices, but the COR Program Manager at headquarters served as their 

first-line supervisor. Field Office Directors provided input for CORs’ 

performance work plans and ratings, but did not directly supervise them. This 

supervisory chain allowed the COR to remain independent from the Field Office 

and detention facility operations. However, after a year under this supervisory 

structure, the COR supervisory chain was changed by making the assigned 

Field Office responsible for COR supervision. 

An email to Field Office Directors and Deputy Field Office Directors announcing 

the transition gave four reasons for the initial alignment of CORs reporting to 

www.oig.dhs.gov 12 OIG-19-18 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

headquarters.17 In contrast, the only justification ICE provided for the 

realignment was that the current organizational reporting relationship was 

“proving to be cumbersome and sub-optimal.” During interviews, ICE officials 

could not provide any additional explanation for why ICE moved supervision of 

CORs from headquarters to the Field Offices. Most CORs we interviewed who 

held those positions during the transition explained that this organizational 

realignment was detrimental to their duties and independence. For example, 

two CORs said they were hesitant to identify instances of noncompliance or 

issue Discrepancy Reports on contracts they oversee because they feared 

retaliation from Field Office management. 

The contracting officers we spoke with had similar concerns regarding the 

CORs’ ability to do their jobs independently. Some contracting officers noted 

that CORs might be reluctant to disagree with their Field Office supervisors, 

who complete their performance appraisals. For example, one contracting 

officer identified a time when, at the request of the Field Office supervisor, a 

COR was authorizing payment for transport of ICE detainees on a contract that 

did not allow transportation. However, this COR lacked the authority to 

approve such contract additions because only the contracting officer can 

modify contracts. 

The current COR position descriptions permit CORs to complete “other duties 

as assigned,” which allows Field Offices to task CORs with duties outside of 

contracting oversight and management. During interviews with 11 CORs we 

heard that Field Office managers have tasked CORs with collateral duties to 

the detriment of their primary function. These tasks included supervising 

mission support personnel; acting as the interim DSM; processing background 

investigations for all employees; and developing requirements for contracts on 

projects unrelated to detention, like retirement planning and finding office 

space for employees. 

Furthermore, inconsistent support from the Field Office can create an 

environment that impedes CORs’ oversight of detention contracts. According to 

the ERO Contracting Officer’s Representative Supplement, dated October 2015, 

the COR work plan template identifies site visits as a possible monitoring 

technique for contracts, but not all CORs are encouraged to conduct these 

visits. Three Field Offices restricted CORs from traveling to detention facilities, 

which impedes proper evaluation of facilities’ compliance with contract terms. 

 17 The May 26, 2010 email from ERO’s Assistant Directors for Field Operations and Mission 

Support announcing the transition of CORs (formerly COTRs) from headquarters to Field 

Offices stated, “While the COTR positions were established in the field, they reported directly to 

Headquarters (HQ) primarily to (1) provide the COTR with the ability and autonomy to ensure 

that contracts are properly established and administered; (2) ensure that the COTR’s primary 

duty is contract monitoring and administration; (3) establish and standardize best practices 

across the DRO enterprise; and (4) enhance dialogue with HQ regarding field office acquisition, 

contract administration, and facility project management issues.” 

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According to a senior official, ICE is working with the Office of Personnel 

Management to adjust the current COR position descriptions; expected 

changes include removing the “other duties as assigned” language and 

providing clearer guidance on COR responsibilities. 

Overextending CORs May Weaken Contract Oversight 

Although some CORs are assigned additional work, others are overtasked with 

detention contracts. CORs tasked with overseeing many facility contracts and 

invoices, as well as non-detention contracts supporting the functions of a Field 

Office, told us they were overextended. For example, of the 11 CORs we 

interviewed: 

• Four CORs oversee 10 or more facilities, with 2 overseeing 16 and 22 

contracts, respectively, across multiple states. 

• One COR has been assigned as the primary Project Manager for a new 

processing center that will be used by four Federal agencies, while also 

being a COR for three detention contracts. 

• Five CORs also oversee large transportation contracts, which require CORs 

to spend substantial time reviewing and approving invoices. 

In one Field Office covering multiple states, Field Office leadership allowed 

CORs to develop a network of assistants to aid oversight efforts. Other Field 

Offices use mission support personnel to support CORs with administrative 

tasks, such as reconciling invoices. 

Lack of Direct Access to Important Contract Files Hinders 

CORs’ and DSMs’ Ability to Monitor Detention Contracts 

CORs are integral to ICE’s efforts to monitor its detention contracts, a process 

in which DSMs are also heavily involved. However, CORs and DSMs lack 

consistent access to all pertinent contracts and modifications. Although DHS 

requires ICE to maintain an official file folder for each contract, which should 

contain the contract and all modifications to it, this system does little to ensure 

all key stakeholders have access to pertinent contract documents. 

Acquisitions Management places contracts and modifications in an electronic 

database called PRISM, to which several members of Contract Management 

have access but neither CORs nor DSMs have access. Acquisitions 

Management also places contract documents, including modifications, on the 

“Q Drive,” an electronic library that will eventually replace PRISM as the official 

repository for detention contracts. However, CORs and DSMs do not have 

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access to the Q Drive either. Acquisitions Management also has some historical 

paper-only files for active contracts initiated around 2005 or earlier, but does 

not give CORs automatic access to these documents. 

CORs must maintain their own file, which is part of the official contract file, 

and which should include a copy of the contracts and modifications that CORs 

oversee. One interviewee noted that CORs should receive contracts and 

modifications from contracting officers or contract specialists, but this practice 

is not consistent. Absent access to contracts and modifications through 

Acquisitions Management, CORs in the field must obtain these documents on 

their own, which can be time consuming and inefficient. When one COR began 

her position, she had to create her own electronic drive of documents, where 

she maintains copies of all contracts and modifications. 

Conclusion 

From October 2015 to June 2018, ICE paid contractors operating the 106 

detention facilities subject to this review more than $3 billion. Despite 

documentation of thousands of deficiencies and instances of serious harm to 

detainees that occurred at these detention facilities, ICE rarely imposed 

financial penalties. ICE should ensure that detention contracts include terms 

that permit ICE to hold contractors to performance standards and impose 

penalties when those standards are not maintained. ICE needs to finalize 

policies and procedures for the waiver process to ensure that officials do not 

circumvent contract terms. ICE also needs to develop or enhance policies and 

procedures to ensure that those responsible for contract oversight have access 

to information necessary to do their jobs and receive adequate guidance about 

the actions available to them when contract performance standards are not 

met. Further, ICE should ensure CORs in the field are unencumbered in their 

ability to manage and oversee detention contracts. Finally, ICE should 

strengthen the ability of CORs and DSMs to access documents related to 

pertinent detention contracts. 

Recommendations 

We recommend the Executive Associate Director for Management and 

Administration: 

Recommendation 1: Develop a process to decide when to seek to include a 

QASP in existing contracts and IGSAs that are not subject to a QASP and all 

future detention contracts and IGSAs. For each contract and IGSA that 

remains without a QASP, document the reason(s) why a QASP could not be 

included and summarize the actions available to contracting officers and CORs 

when contractors fail to meet applicable detention standards. 

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Recommendation 2: Develop protocols to guide CORs and contracting officers 

in issuing Discrepancy Reports and imposing appropriate financial penalties 

against detention facility contractors in response to contract noncompliance. 

The protocols should include: 

1. clear guidance for determining when to issue a Discrepancy Report; 

2. instructions for issuing and approving a Discrepancy Report; 

3. clear guidance for determining when to impose a financial penalty and 

what type of financial penalty to impose; 

4. instructions for imposing a financial penalty; and 

5. a process to track all Discrepancy Reports issued and financial penalties 

imposed by ICE, to include data regarding the final resolution of the 

issue that led to the Discrepancy Report or financial penalty. 

We recommend the Executive Associate Director for Enforcement and Removal 

Operations: 

Recommendation 3: Develop protocols to ensure that all existing and future 

waivers are: 

1. approved by ICE officials with appropriate authority; 

2. distributed to key stakeholders, such as contracting officers, CORs, and 

DSMs, who need the waivers to perform core job functions; 

3. consistent with contract terms; and 

4. compliant with FAR requirements, as applicable. 

Recommendation 4: Develop a staffing plan for detention CORs, to permit 

adequate contract oversight and ensure an achievable workload. Evaluate the 

organizational placement of CORs. If CORs remain under Field Office 

supervision, develop safeguards to prevent Field Office supervisors from 

interfering with CORs’ ability to fulfill their contract oversight duties. 

We recommend the Executive Associate Director for Management and 

Administration: 

Recommendation 5: Develop protocols to ensure that CORs and DSMs have 

full and expedient access to the contract documentation they need to perform 

core job functions. 

Management Comments and OIG Analysis 

We have included a copy of ICE’s Management Response in its entirety in 

appendix B. We also received technical comments from ICE and incorporated 

them in the report where appropriate. We consider all recommendations to be 

resolved and open. A summary of ICE’s responses and our analysis follows. 

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ICE concurred with all five recommendations but disagreed with some of the 

report’s conclusions. As a result, we will be closely monitoring all actions ICE 

takes in reponse to the reccomendatiosn to ensure compliance. Specifically, 

ICE purports that it “already has practices in place to maintain and distribute 

waivers to appropriate stakeholders” (emphasis added). However, ICE did not 

provide DHS OIG with documentation supporting its claim that it has practices 

in place to distribute waivers to appropriate stakeholders; rather, the evidence 

indicates only that ICE makes approved waivers accessible to stakeholders 

upon request. Providing access to waivers upon request is not the same as 

distributing approved waivers to appropriate stakeholders. Compounding the 

issue, we determined that ICE did not provide notification of approved waivers 

effectively. For instance, we determined that CORs and a DSM were not notified 

of approved waivers, and contracting officers confirmed that most of them did 

not know that Custody Management had issued waivers. 

ICE also stated that the report does not discuss actions it took to resolve “noncompliance issues” at facilities, including removing detainees from a facility, 

scaling back its usage of a facility, and terminating agreements. However, ICE 

failed to provide specific examples of corrective action at particular facilities, 

thereby limiting DHS OIG’s ability to evaluate whether the actions were 

effective means by which to hold contractors accountable. Moreover, the 

objectives of this review focused on whether ICE uses contracting tools to 

ensure facilities meet applicable detention standards. ICE’s purported removal 

of detainees from a facility, or diminished use of a facility, are not relevant to 

review of its use of contracting tools to drive contractor accountability. ICE’s 

assertion that it terminated facility agreements for unspecified “noncompliance issues” at other, unnamed facilities is also irrelevant to our review. 

Our review focused on ICE’s efforts to use contracting tools to ensure 

compliance with applicable detention standards at 106 CDF, IGSA, and DIGSA 

facilities (see appendix C). Based on the information provided by ICE during the 

review, ICE’s facility contracts for these facilities were not terminated because 

of a failure to meet applicable detention standards. 

ICE also stated it uses a “layered approach to monitor detention conditions at 

facilities, with processes in place to implement corrective actions in instances 

where non-compliance with ICE detention standards is found.” We determined 

that the processes in place do not ensure consistent compliance with detention 

standards. Not only does ICE not fully use contracting tools to hold detention 

facility contractors accountable for failing to meet performance standards, our 

previous work has determined that ICE’s inspections and onsite monitoring do 

not ensure consistent compliance with detention standards or promote 

comprehensive deficiency corrections.18 We identified serious incidents of 

 ϭΘ ICE’s Inspections and Monitoring of Detention Facilities Do Not Lead to Sustained Compliance 

or Systemic Improvements, OIG-18-67, June 2018

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noncompliance during our own unannounced inspections of ICE detention 

facilities19 and the more than 14,000 deficiencies identified by various 

inspections and DSMs from October 2015 to June 2018 suggest room for 

improvement in the current processes for addressing noncompliance with ICE 

detention standards. 

ICE Response to Recommendation 1: ICE concurred with the 

recommendation. ICE will ensure that all CDF, service processing centers, and 

DIGSA facilities will have a QASP. ICE will develop a process to evaluate 

whether to include a QASP in the remaining contracts or IGSAs. For each 

contract and IGSA that remains without a QASP, ICE will document the reason 

why a QASP was not included. ICE will provide training and issue procurement 

guidance to summarize the actions available to contracting officers and CORs 

when contractors fail to meet applicable detention standards. ICE anticipates 

completing these actions by March 31, 2019. 

OIG Analysis: We consider these actions responsive to the recommendation, 

which is resolved and open. We will close this recommendation when we 

receive documentation showing that ICE has: (1) included a QASP for all CDFs, 

service processing centers, and DIGSA facilities; (2) implemented a process to 

evaluate whether to include a QASP in all remaining and future detention 

contracts or IGSAs; (3) documented the reason why a QASP was not included 

for each contract or IGSA that remains without a QASP; and (4) completed 

training and issued procurement guidance summarizing the actions available 

to contracting officers and CORs when contractors fail to meet applicable 

detention standards. 

ICE Response to Recommendation 2: ICE concurred with the 

recommendation. ICE has already begun providing additional training to all 

ERO CORs responsible for detention contracts, consisting of six training 

sessions that cover various aspects of COR duties. The training includes 

sessions that cover various methods to ensure contract compliance, monitoring 

and inspections, and dealing with unsatisfactory contractor performance. ICE 

will also provide more specific training on monitoring and inspections and 

dealing with unsatisfactory performance to Acquisitions Management 

contracting officers responsible for detention contracts. 

 19 Management Alert – Issues Requiring Action at the Adelanto ICE Processing Center in 

Adelanto, California, OIG-18-86, September 2018; Concerns About ICE Detainee Treatment and 

Care at Detention Facilities, OIG-18-32, December 2017; and Management Alert on Issues 

Requiring Immediate Action at the Theo Lacy Facility in Orange, California, OIG-17-43-MA, 

March 2017 

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ICE will also develop and issue procurement guidance that will provide 

protocols for Discrepancy Reports, which will address when to issue a 

Discrepancy Report, instructions for issuing and approving a report, when to 

impose a financial penalty, what type of financial penalty to impose, and 

instructions for imposing a financial penalty. The procurement guidance will 

also include a process to track all Discrepancy Reports issued and financial 

penalties imposed. ICE anticipates completing all actions responsive to this 

recommendation by March 31, 2019. 

OIG Analysis: We consider these actions responsive to the recommendation, 

which is resolved and open. We will close this recommendation when we 

receive documentation showing that: (1) all ERO CORs have completed the 

specified training covering methods to ensure contract compliance, monitoring 

and inspections, and dealing with unsatisfactory contractor performance; (2) all 

Acquisitions Management contracting officers have completed the specified 

training covering monitoring and inspections and dealing with unsatisfactory 

performance; and (3) ICE has developed and issued procurement guidance 

providing protocols for Discrepancy Reports, which addresses when to issue a 

Discrepancy Report, instructions for issuing and approving a report, when to 

impose a financial penalty, what type of financial penalty to impose, 

instructions for imposing a financial penalty, and a process to track all 

Discrepancy Reports issued and financial penalties imposed. 

ICE Response to Recommendation 3: ICE concurred with the 

recommendation. ICE will document the waiver process in a policy or standard 

operating procedure (SOP) that is accessible to stakeholders, such as 

contracting officers, CORs, and on-site DSMs. The policy or SOP will clearly 

address when waivers need to be incorporated via contract modification. ICE 

will also review all current waivers to determine continuing applicability and, if 

appropriate, cancel any waivers that are no longer needed. ICE will also ensure 

that the annual or more frequent review of approved waivers by appropriate 

personnel is included in its documented waiver process. Finally, ICE will 

ensure stakeholders have access to approved waivers and expand waiver 

distribution to DSMs, contracting officers, CORs, and other staff who monitor 

detention conditions or contract performance, in addition to the ERO Field 

Office personnel and facility management staff who already receive the waivers. 

ICE anticipates completing these actions by April 30, 2019. 

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OIG Analysis: We consider these actions responsive to the recommendation, 

which is resolved and open. We will close this recommendation when we 

receive the waiver policies or SOP addressing when waivers need to be 

incorporated via contract modification, requiring annual or more frequent 

review of approved waivers by appropriate personnel, and ensuring access to 

and distribution of waivers to stakeholders, along with documentation showing 

that current waivers were reviewed to evaluate whether they were approved by 

ICE officials with the authority to do so, are consistent with contract terms, 

comply with FAR requirements, and continue to be applicable. 

ICE Response to Recommendation 4: ICE concurred with the 

recommendation. ICE will review the workload of its detention facility CORs, 

and determine an ideal staffing level to oversee its existing contracts. ICE will 

consider the operational placement of CORs under Field Office supervisors. If 

CORs remain under Field Office supervision, ERO leadership will ensure Field 

Office managers are fully aware of the importance of the CORs’ responsibilities 

and allowing them sufficient time and resources to complete their contract 

oversight duties. ICE anticipates completing these actions by September 30, 

2019. 

OIG Analysis: We consider these actions responsive to the recommendation, 

which is resolved and open. We will close this recommendation when we 

receive documentation showing ICE completed a review of the workload of 

detention facility CORs and determined an ideal staffing level to oversee its 

existing contracts, evaluated the operational placement of CORs, and, if CORs 

remain under Field Office supervision, ensured Field Office managers are made 

fully aware of the importance of the CORs’ responsibilities and allowing them 

sufficient time and resources to complete their contract oversight duties. 

ICE Response to Recommendation 5: ICE concurred with the 

recommendation. ICE now requires that every contract document be available 

electronically on a shared drive. ICE will give CORs and DSMs read-only access 

to this system to allow them efficient access to contract documentation. ICE 

anticipates completing this action by June 30, 2019. 

OIG Analysis: We consider these actions responsive to the recommendation, 

which is resolved and open. We will close this recommendation when we 

receive adequate supporting documentation that CORs and DSMs have full and 

expedient access to the contract documentation they need to perform core job 

functions. 

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Appendix A 

Objective, Scope, and Methodology 

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

107ï296) by amendment to the Inspector General Act of 1978. In this review, 

we sought to determine whether ICE contracting tools hold immigration 

detention facilities to applicable detention standards; and whether ICE imposes 

consequences when contracted immigration detention facilities do not maintain 

standards. 

To answer the objective, we evaluated the policies and procedures governing 

ICE detention contract execution, amendment, and oversight and conducted a 

walkthrough of contract files with ICE Acquisitions Management to obtain an 

understanding of the detention contracting process. We reviewed a judgmental 

sample of current contracts, which included CDF, IGSA, and DIGSA facilities, 

and obtained and reviewed payment and penalty data for the 106 facilities 

within the scope of this review. We collected and analyzed data regarding 

detention facility inspections and calculated the number of deficiencies 

identified by ICE. We reviewed all of the proposed waivers submitted for 

detention facilities subject to this review and evaluated the waiver process and 

ICE’s authority to issue waivers. We interviewed contracting officers, CORs, 

and DSMs, along with ICE representatives from several components, including 

Acquisitions Management, Office of Contract Management, ERO’s Budget 

Office, Office of the Chief Financial Officer, Detention Management Division, 

Burlington Finance Center, and Office of Detention Policy and Planning. We 

also interviewed Field Office leadership from ICE’s Baltimore Field Office. 

We conducted this review between January and October 2018 pursuant to the 

Inspector General Act of 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 evidence obtained provides a 

reasonable basis for our findings and conclusions based upon our objectives. 

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Appendix B 

Management Comments to the Draft Report 

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Appendix C

Facility Listing and Quality Assurance Surveillance Plan Status 

Detention Facility Facility 

Type 

QASP Included in 

Contract 

BROWARD TRANSITIONAL CENTER CDF YES 

DENVER CONTRACT DETENTION 

FACILITY 

CDF YES 

ELIZABETH CONTRACT DETENTION 

FACILITY 

CDF YES 

HOUSTON CONTRACT DETENTION 

FACILITY 

CDF YES 

NORTHEAST OHIO CORRECTIONAL 

CENTER (YOUNGSTOWN CDF) 

CDF YES 

NORTHWEST DETENTION CENTER CDF YES 

OTAY MESA DETENTION CENTER (SAN 

DIEGO CDF) 

CDF YES 

SOUTH TEXAS DETENTION COMPLEX CDF YES 

ADELANTO ICE PROCESSING CENTER DIGSA YES 

ELOY FEDERAL CONTRACT FACILITY DIGSA YES 

FOLKSTON ICE PROCESSING CENTER (D. 

RAY JAMES) 

DIGSA YES 

IMMIGRATION CENTERS OF AMERICA 

FARMVILLE 

DIGSA YES 

IMPERIAL REGIONAL DETENTION 

FACILITY 

DIGSA YES 

JENA/LASALLE DETENTION FACILITY DIGSA YES 

MESA VERDE DETENTION FACILITY DIGSA YES 

OTERO COUNTY PROCESSING CENTER DIGSA YES 

PINE PRAIRIE CORRECTIONAL CENTER DIGSA NO 

PRAIRIELAND DETENTION FACILITY DIGSA YES 

STEWART DETENTION CENTER DIGSA YES 

ALLEGANY COUNTY JAIL IGSA NO 

ALLEN PARISH PUBLIC SAFETY 

COMPLEX 

IGSA NO 

BAKER COUNTY SHERIFF'S OFFICE IGSA NO 

BALDWIN COUNTY CORRECTIONAL 

CENTER 

IGSA NO 

BEDFORD MUNICIPAL DETENTION 

CENTER 

IGSA NO 

BRISTOL COUNTY DETENTION CENTER IGSA NO 

BURNET COUNTY JAIL IGSA NO 

BUTLER COUNTY JAIL IGSA NO 

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CABARRUS COUNTY JAIL IGSA NO 

CALDWELL COUNTY DETENTION 

CENTER 

IGSA NO 

CALHOUN COUNTY CORRECTIONAL 

CENTER 

IGSA NO 

CARVER COUNTY JAIL IGSA NO 

CHASE COUNTY DETENTION FACILITY IGSA NO 

CHAUTAUQUA COUNTY JAIL IGSA NO 

CHIPPEWA COUNTY SSM IGSA NO 

CHRISTIAN COUNTY JAIL IGSA NO 

CIBOLA COUNTY CORRECTIONAL 

CENTER 

IGSA YES 

COBB COUNTY JAIL IGSA NO 

COLLIER COUNTY NAPLES JAIL CENTER IGSA NO 

DALE G. HAILE DETENTION CENTER IGSA NO 

DAVIDSON COUNTY SHERIFF IGSA NO 

DEARBORN POLICE DEPARTMENT IGSA NO 

DOUGLAS COUNTY DEPARTMENT OF 

CORRECTIONS 

IGSA NO 

EL PASO COUNTY CRIMINAL JUSTICE 

CENTER 

IGSA NO 

ELGIN POLICE DEPARTMENT IGSA NO 

ESSEX COUNTY CORRECTIONAL 

FACILITY 

IGSA YES 

EULESS CITY JAIL IGSA NO 

FAIRFAX COUNTY ADULT DETENTION 

CENTER 

IGSA NO 

FREDERICK COUNTY DETENTION 

CENTER 

IGSA NO 

FREEBORN COUNTY ADULT DETENTION 

CENTER 

IGSA NO 

GARVIN COUNTY DETENTION CENTER IGSA NO 

GASTON COUNTY JAIL IGSA NO 

GLADES COUNTY DETENTION CENTER IGSA NO 

GLENDALE POLICE DEPARTMENT IGSA NO 

GRAND FORKS COUNTY CORRECTIONAL 

FACILITY 

IGSA NO 

HALL COUNTY DEPARTMENT OF 

CORRECTIONS 

IGSA NO 

HARDIN COUNTY JAIL IGSA NO 

HOWARD COUNTY DETENTION CENTER IGSA NO 

HUDSON COUNTY CORRECTIONAL 

CENTER 

IGSA NO 

JAMES A. MUSICK FACILITY IGSA YES 

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JEFFERSON COUNTY JAIL IGSA NO 

JOE CORLEY DETENTION FACILITY IGSA YES 

JOHNSON COUNTY CORRECTIONS 

CENTER 

IGSA YES 

KENT COUNTY JAIL IGSA YES 

LINCOLN COUNTY DETENTION CENTER IGSA NO 

LONOKE POLICE DEPARTMENT IGSA NO 

MINICASSIA DETENTION CENTER IGSA NO 

MOFFAT COUNTY JAIL IGSA NO 

MONROE COUNTY DETENTION CENTER IGSA NO 

MONROE COUNTY DETENTION-DORM IGSA NO 

MONTGOMERY CITY JAIL IGSA NO 

MONTGOMERY COUNTY JAIL IGSA NO 

MORGAN COUNTY ADULT DETENTION 

CENTER 

IGSA NO 

MORROW COUNTY CORRECTIONAL 

FACILITY 

IGSA NO 

NAVAJO COUNTY SHERIFF IGSA NO 

NEW HANOVER COUNTY JAIL IGSA NO 

NOBLES COUNTY JAIL IGSA NO 

NORTHERN OREGON CORRECTIONAL 

FACILITY 

IGSA NO 

OLDHAM COUNTY JAIL IGSA NO 

ORANGE COUNTY INTAKE RELEASE 

FACILITY 

IGSA YES 

ORANGE COUNTY JAIL IGSA NO 

PIKE COUNTY CORRECTIONAL FACILITY IGSA NO 

PLATTE COUNTY DETENTION CENTER IGSA NO 

PLYMOUTH COUNTY CORRECTIONAL 

FACILITY 

IGSA NO 

POLK COUNTY ADULT DETENTION 

FACILITY 

IGSA NO 

PULASKI COUNTY JAIL IGSA NO 

RIO COSUMNES CORRECTIONAL 

CENTER 

IGSA NO 

RIO GRANDE COUNTY JAIL IGSA YES 

ROANOKE CITY JAIL IGSA NO 

ROLLING PLAINS DETENTION CENTER IGSA NO 

SAINT CLAIR COUNTY JAIL IGSA YES 

SAINT TAMMANY PARISH JAIL IGSA NO 

SENECA COUNTY JAIL IGSA NO 

SHAWNEE COUNTY DEPARTMENT OF 

CORRECTIONS 

IGSA NO 

STRAFFORD COUNTY CORRECTIONS IGSA NO 

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SUFFOLK COUNTY HOUSE OF 

CORRECTIONS 

IGSA NO 

TAYLOR COUNTY ADULT DETENTION 

FACILITY 

IGSA NO 

TELLER COUNTY JAIL IGSA NO 

THEO LACY FACILITY IGSA YES 

TULSA COUNTY JAIL (DAVID L. MOSS 

JUSTICE CENTER) 

IGSA NO 

WAKE COUNTY SHERIFF DEPARTMENT IGSA NO 

WAKULLA COUNTY JAIL IGSA NO 

WHITFIELD COUNTY JAIL IGSA NO 

WORCESTER COUNTY JAIL IGSA NO 

YAVAPAI COUNTY DETENTION CENTER IGSA NO 

YORK COUNTY PRISON IGSA NO 

YUBA COUNTY JAIL IGSA NO 

Source: ICE Data (as of June 7, 2018) 

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Appendix D 

Office of Inspections and Evaluations Major Contributors to 

This Report 

Tatyana Martell, Chief Inspector 

Inez Jordan, Lead Inspector 

Christopher Zubowicz, Assistant Counsel 

Jason Wahl, Senior Inspector 

Erika Algeo, Inspector 

James Johnson, Inspector 

Ryan Nelson, Independent Referencer 

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Appendix E 

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 

ICE Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committee 

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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