Report to Congressional Requesters

United States Government Accountability Office

GAO 

January 2009 IMMIGRATION 

ENFORCEMENT 

Better Controls 

Needed over Program 

Authorizing State and 

Local Enforcement of 

Federal Immigration 

Laws 

GAO-09-109 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2009

IMMIGRATION ENFORCEMENT 

Better Controls Needed over Program Authorizing

State and Local Enforcement of Federal Immigration 

Highlights of GAO-09-109, a report to Laws congressional requesters 

Section 287(g) of the Immigration

and Nationality Act, as amended, 

authorizes the federal government

to enter into agreements with state 

and local law enforcement agencies

to train officers to assist in 

identifying those individuals who

are in the country illegally. U.S. 

Immigration and Customs

Enforcement (ICE) is responsible 

for supervising state and local 

officers under this program. GAO

was asked to review this program.

This report reviews (1) the extent 

to which ICE has designed controls 

to govern 287(g) program 

implementation; and (2) how 

program resources are being used 

and the activities, benefits, and

concerns reported by participating

agencies. GAO reviewed

memorandums of agreement 

(MOA) between ICE and the 29

program participants as of

September 1, 2007. GAO compared

controls ICE designed to govern 

the 287(g) program with criteria in

GAO’s Standards for Internal 

Control in the Federal 

Government. GAO interviewed 

officials from both ICE and 

participating agencies on program

implementation, resources, and 

results.

What GAO Recommends

Among other things, GAO 

recommends that the Assistant 

Secretary for ICE document the

program objective, document and

communicate supervisory 

activities, and specify data each

agency is to collect and report. 

DHS and ICE agreed with our 

recommendations. 

ICE has designed some management controls to govern 287(g) program 

implementation, such as MOAs and background checks of state and local 

officers, but the program lacks other controls, which makes it difficult for ICE 

to ensure that the program is operating as intended. First, the program lacks 

documented program objectives to help ensure that participants work toward 

a consistent purpose. ICE officials stated that the objective of the program is 

to address serious crime, such as narcotics smuggling committed by 

removable aliens; however, ICE has not documented this objective in program 

materials. As a result, of 29 program participants reviewed by GAO, 4 used 

287(g) authority to process individuals for minor crimes, such as speeding,

contrary to the objective of the program. Second, ICE has not described the 

nature and extent of its supervision over participating agencies’ 

implementation of the program, which has led to wide variation in the 

perception of the nature and extent of supervisory responsibility among ICE 

field officials and officials from the participating agencies. ICE is statutorily 

required to supervise agencies participating in the 287(g) program, and 

internal control standards require an agency’s organizational structure to 

clearly define key areas of authority and responsibility. Defining the nature 

and extent of the agency’s supervision over this large and growing program 

would strengthen ICE’s assurance that management’s directives are being

carried out. Finally, while ICE states in its MOAs that participating agencies

are responsible for tracking and reporting data to ICE, in 20 of 29 MOAs GAO

reviewed, ICE did not define what data should be tracked or how it should be 

collected and reported. Communicating to participating agencies what data is

to be collected and how it should be gathered and reported would help ensure 

that ICE management has the information needed to determine whether the 

program is achieving its objective. 

ICE and program participants use resources for personnel, training, and 

equipment, and participants report activities, benefits, and concerns regarding 

the program. In fiscal years 2006–2008, ICE received about $60 million to 

train, supervise, and equip program participants. As of October 2008, ICE

reported enrolling 67 agencies and training 951 state and local law 

enforcement officers. According to data provided by ICE for 25 of the 29 

program participants reviewed by GAO, during fiscal year 2008, about 43,000 

aliens had been arrested pursuant to the program, and of those, ICE detained 

about 34,000. About 41 percent of those detained were placed in removal 

proceedings, and an additional 44 percent agreed to be voluntarily removed. 

The remaining 15 percent of those detained by ICE were given a humanitarian

release, sent to federal or state prison, or released due to the minor nature of 

their crime and federal detention space limitations. Program participants 

report a reduction in crime, the removal of repeat offenders, and other public 

safety benefits. However, over half of the 29 agencies GAO contacted 

reported concerns from community members that use of program authority 

would lead to racial profiling and intimidation by law enforcement officials. 

To view the full product, including the scope 

and methodology, click on GAO-09-109. 

For more information, contact Richard M. 

Stana at (202) 512-8777 or stanar@gao.gov. 
Contents 

Letter 1

Results in Brief 4

Background 7

ICE Lacks Key Internal Controls for the Implementation of the 

287(g) Program 10 

Program Resources Are Used for Training, Supervision, and 

Equipment; Benefits and Concerns Are Reported by ICE and 

Participating Agencies 20 

Conclusions 23

Recommendations for Executive Action 24 

Agency Comments 24 

Appendix I Statutory Provision Governing the 287(g) Program 27 

Appendix II Structured Interview Questions for All 29 Participants 

of the 287(g) Program 29 

Appendix III Objectives, Scope, and Methodology 33 

 

Appendix IV Copy of ICE Pamphlet on ACCESS Programs 38 

Appendix V Comments from the Department of Homeland Security 40 

Appendix VI GAO Contact and Staff Acknowledgments 44 

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Page i GAO-09-109 Management Controls for 287(g) Program 
United States Government Accountability Office

Washington, DC 20548 

 

January 30, 2009 

Congressional Requesters

Recent reports indicate that the total population of unauthorized aliens 

residing in the United States is about 12 million.1

 Some of these aliens have 

committed one or more crimes, although the exact number of aliens who 

have committed crimes is unknown. As of June 30, 2007—the most recent 

data available—about 31,000 of the approximately 199,000 convicted 

felons in federal prisons, about 56,000 of the approximately 1,400,000 

convicted felons in state prisons, and about 39,000 of the approximately 

504,000 inmates held in local jails, were aliens.2

 Removing those aliens 

who have committed serious crimes is of particular concern for the safety

of our nation’s communities. The Department of Homeland Security’s 

(DHS) U.S. Immigration and Customs Enforcement (ICE) is responsible 

for the enforcement of immigration laws within the interior of the United

States, including the identification, apprehension, detention, and removal

of removable aliens who committed crimes. ICE does not have the agents 

or the detention space that would be required to address all criminal 

activities. According to DHS, criminal activity is most effectively combated 

through a multiagency/multiauthority approach that utilizes federal, state, 

and local resources, skills, and expertise. State and local law enforcement 

officers play a critical role in protecting our homeland because, during the 

course of daily duties, they may encounter foreign-national criminals and 

immigration violators who pose a threat to national security or public 

safety. 

On September 30, 1996, the Illegal Immigration Reform and Immigrant 

Responsibility Act was enacted and added section 287(g) to the 

Immigration and Nationality Act (INA).3

 This section authorizes the federal

government to enter into agreements with state and local law enforcement 

agencies; to train selected state and local officers to perform certain 

functions of an immigration officer, including searching selected federal 

 1

Under section 101(a)(3) of the Immigration and Nationality Act, 8 U.S.C. § 1101(a)(3), the 

term “alien” means any person not a citizen or national of the United States. It does not

include foreign nationals who have become naturalized U.S. citizens. 

2

U.S. Department of Justice, Office of Justice Programs, Bureau of Justice Statistics

Bulletin, June 2008. The data for local jails is based on 2,416 reporting jurisdictions. 

3

Pub. L. No. 104-208, div. C, §133, 110 Stat. 3009–546, 3009-563 to 64. 

Page 1 GAO-09-109 Management Controls for 287(g) Program
 

databases and conducting interviews to assist in the identification of those 

individuals in the country illegally; and to carry out these activities under 

the supervision of ICE officers.4

 ICE is responsible for managing the 

implementation of 287(g). The first such agreement under the statute was 

signed in 2002, and as of October 2008, participation in this program had 

increased to 67 state and local agencies. Most of these state and local law 

enforcement agencies joined the program after 2007. 

The enforcement of immigration law by state and local officials has raised 

concerns among some community and immigrants’ rights groups about the 

proper role of such law enforcement officials. Groups are also concerned

that such activities could lead to apprehension in immigrant communities 

and less inclination to report crimes out of fear that officers with 287(g) 

authority would inquire about crime victims’ immigration status. Groups 

said that these concerns may reduce the effectiveness of the program and 

other law enforcement initiatives, which they believe were intended to 

target serious criminal activity. 

Given the growing interest of individual state and local entities in 

participating in the 287(g) program, and congressional interest in assisting 

state and local communities in addressing border security and immigration 

enforcement issues, you requested that we review the 287(g) program. 

This report addresses (1) the extent to which ICE has designed controls to

govern 287(g) program implementation and (2) how program resources 

are being used and the activities, benefits, and concerns reported by 

participating agencies. 

To accomplish our objectives, we collected and analyzed information from 

ICE and participating law enforcement agencies on the priorities, 

objectives, and guidance for implementing the 287(g) program. To better 

understand the parameters of the 287(g) program as agreed to by both ICE 

and the participating agency, we reviewed program-related documents, 

including program case files, the 287(g) brochure, training materials, 

certain ICE position descriptions, and the memorandums of agreement 

(MOA) between ICE and the 29 law enforcement agencies participating in

the program as of September 1, 2007. We also examined the controls ICE 

designed to govern implementation of the 287(g) program by requesting 

information on ICE’s management policies and practices as they relate to

 4

The change to the Immigration and Nationality Act is codified in 8 U.S.C. §1357(g). The 

complete text of 8 U.S.C. § 1357(g) appears in appendix I.

Page 2 GAO-09-109 Management Controls for 287(g) Program
 

the 287(g) program and comparing these controls with criteria in GAO’s 

Standards for Internal Control in the Federal Government, the 

Government Performance and Results Act (GPRA) and the Project 

Management Institute’s Standard for Program Management.5

 We visited 

nine participating agencies to observe how they are implementing the 

program. We selected these agencies based on the type of enforcement 

authority granted by ICE and length of time they have participated in the 

program, among other characteristics. Although we are not able to 

generalize the information gathered from these visits to all other 

participating law enforcement agencies, the visits provided us with a 

variety of examples of how the program is being implemented. We also 

interviewed officials from both ICE and the participating law enforcement 

agencies to obtain their perspectives on the activities, benefits, and 

concerns generated from the 287(g) program as well as the resources used 

to implement the program, including equipment, training, and assignment 

of supervisory ICE staff.6

 In addition, we examined budget and 

appropriations documentation from the program’s inception to the fiscal 

year 2009 budget request for the 287(g) program and inquired about future

funding requirements for this program from agency officials. More detailed 

information on our scope and methodology appears in appendix III. 

We conducted this performance audit from September 2007 through 

January 2009 in accordance with generally accepted government auditing

 5

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). These standards, issued pursuant to the requirements

of the Federal Managers’ Financial Integrity Act of 1982 (FMFIA), provide the overall 

framework for establishing and maintaining internal control in the federal government.

Also pursuant to FMFIA, the Office of Management and Budget issued Circular A-123,

revised December 21, 2004, to provide the specific requirements for assessing the reporting 

on internal controls. Internal control standards and the definition of internal control in 

Circular A-123 are based on GAO’s Standards for Internal Control in the Federal 

Government. GPRA is the primary legislative framework through which agencies are 

required to set strategic goals, measure performance, and report on the degree to which 

goals were met. GAO, Executive Guide: Effectively Implementing the Government

Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). Additional 

program management standards we reviewed are reflected in the Project Management 

Institute’s The Standard for Program Management © (2006). 

6

We contacted 29 state and local law enforcement agencies with regard to their 

implementation of the 287(g) program between October 2007 and February 2008. However,

for purposes of reporting the results of our structured interviews, only 23 of the 29 initial 

participating law enforcement agencies we contacted had been in the program long enough 

to report on their implementation experiences. The structured interview tool used to

collect information from the law enforcement agencies we reviewed appears in appendix 

II. 

Page 3 GAO-09-109 Management Controls for 287(g) Program
 

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 on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

ICE has designed some management controls to govern 287(g) program 

implementation, such as Memorandums of Agreement with participating 

agencies and background checks of officers applying to participate in the

program, but the program lacks other controls. First, while ICE officials 

have stated that the main objective of the 287(g) program is to enhance the 

safety and security of communities by addressing serious criminal activity 

committed by removable aliens, they have not documented this objective

in program-related materials consistent with internal control standards. As 

a result, some participating agencies are using their 287(g) authority to 

process for removal aliens who have committed minor crimes, such as 

carrying an open container of alcohol. While participating agencies are not 

prohibited from seeking the assistance of ICE for aliens arrested for minor 

offenses, if all the participating agencies sought assistance to remove 

aliens for such minor offenses, ICE would not have detention space to 

detain all of the aliens referred to them. ICE’s Office of Detention and 

Removal strategic plan calls for using the limited detention bed space 

available for those aliens who pose the greatest threat to the public, until 

more alternative detention methods are available. Second, ICE has not 

consistently articulated in program-related documents how participating 

agencies are to use their 287(g) authority. For instance, although the 

processing of individuals for possible removal is to be conducted in 

connection with a conviction of a state or federal felony offense, this issue 

is not mentioned in 7 of the 29 MOAs we reviewed. Internal control 

standards state that government programs should ensure that significant 

events are authorized and executed only by persons acting within the 

scope of their authority. Defining and consistently communicating how 

this authority is to be used would help ICE ensure that immigration 

activities undertaken by participating agencies are in accordance with ICE 

policies and program objectives. Third, ICE has not described the nature 

and extent of the agency’s supervision over participating agencies’ 

implementation of the program. This has led to wide variation in the 

perception of the nature and extent of supervisory responsibility among 

ICE field officials and officials from 23 of the participating agencies that 

provided information on ICE supervision. Internal control standards 

require an agency’s organizational structure to define key areas of 

authority and responsibility. Given the rapid growth of the program, 

Results in Brief 

Page 4 GAO-09-109 Management Controls for 287(g) Program
 

defining the nature and extent of the agency’s supervision over this large 

and growing program would strengthen ICE’s assurance that 

management’s directives are being carried out. Finally, while the MOAs 

state that participating agencies are responsible for tracking and reporting 

data to ICE, in 20 of 29 MOAs we reviewed, ICE did not define what data 

should be tracked or how it should be collected and reported. Internal 

control standards call for pertinent information to be recorded and 

communicated to management in a form and within a time frame that 

enables them to carry out internal control and other responsibilities. 

Communicating to participating agencies what data is to be collected and

how it should be gathered and reported would help ensure that ICE 

management has the information needed to determine whether the 

program is achieving its objectives. 

ICE and participating agencies used program resources mainly for 

personnel, training, and equipment, and participating agencies reported 

activities, benefits, and concerns stemming from the program. For fiscal 

years 2006 through 2008, ICE received about $60 million to provide 

training, supervision, computers, and other equipment for participating 

agencies. State and local participants provided officers, office space, and 

other expenses not reimbursed by ICE, such as office supplies and 

vehicles. ICE and state and local participating agencies cite a range of 

benefits associated with the 287(g) partnership. For example, as of 

October 2008, ICE reported enrolling 67 agencies and training 951 state 

and local law enforcement officers. According to data provided by ICE for 

25 of the 29 program participants reviewed by GAO, during fiscal year 

2008, about 43,000 aliens had been arrested pursuant to the program.7

Based on the data provided, individual agency participant results ranged 

from about 13,000 arrests in one location, to no arrests in two locations. Of

those 43,000 aliens arrested pursuant to the 287(g) authority, ICE detained

about 34,000, placed about 14,000 (41 percent) in removal proceedings, 

and arranged for about 15,000 (44 percent) to be voluntarily removed.8

 The

remaining 5,000 (15 percent) arrested aliens detained by ICE were either 

given a humanitarian release, sent to a federal or state prison to serve a 

 7

ICE provided data for 25 of the 29 participating agencies we reviewed. ICE also provided

data for four other participating agencies, but we do not report them as they were not

within the scope of our review. 

8

A voluntary removal (called “voluntary departure”) occurs when an alien is allowed to 

depart the country at his or her own expense (escorted by ICE) in lieu of formal removal 

proceedings or prior to completion of such proceedings. 

Page 5 GAO-09-109 Management Controls for 287(g) Program
 

sentence for a felony offense, or not taken into ICE custody given the 

minor nature of the underlying offense and limited availability of the 

federal government’s detention space.9

 Participating agencies cited 

benefits of the program including a reduction in crime and the removal of

repeat offenders. However, more than half of the 29 state and local law 

enforcement agencies we reviewed reported concerns members of their 

communities expressed about the 287(g) program, including concerns that 

law enforcement officers in the 287(g) program would be deporting 

removable aliens pursuant to minor traffic violations (e.g., speeding) and 

concerns about racial profiling. 

To help ensure that ICE program managers for the 287(g) program achieve

the results intended by implementing this program, we are recommending 

that the Assistant Secretary for ICE (1) document the objective of the 

287(g) program for participants, (2) clarify when the 287(g) authority is 

authorized for use by state and local law enforcement officers, (3) 

document in MOAs the nature and extent of supervisory activities ICE 

officers are expected to carry out as part of their responsibilities in 

overseeing the implementation of the 287(g) program and communicate 

that information to both ICE officers and state and local participating 

agencies, (4) specify the program information or data that each agency is 

expected to collect regarding their implementation of the 287(g) program 

and how this information is to be reported, and (5) establish a plan,

including a time frame, for the development of performance measures for 

the 287(g) program. We provided a draft of this report to DHS for review 

and comment. DHS provided written comments on January 28, 2009, 

which are presented in appendix V. In commenting on the draft report, 

DHS stated that it agreed with our recommendations and identified actions

planned or underway to implement the recommendations. ICE also 

 9

Individuals arrested on administrative charges who may be sole caregivers or who have 

other humanitarian concerns, including those with serious medical conditions that require

special attention, pregnant women, nursing mothers, parents who are the sole caretakers of 

minor children or disabled or seriously ill relatives, and parents who are needed to support 

their spouses in caring for sick or special needs children or relatives, may be released by 

ICE. As appropriate, if ICE is provided with new information regarding a humanitarian 

condition after an arrestee has been processed and detained, ICE may consider the 

possibility of release on humanitarian grounds based on such information. In general, 

aliens given a humanitarian release or not taken into custody due to limited detention 

space receive a notice to appear in immigration court at a later date for removal 

proceedings. Removable aliens serving a sentence in federal and state prison are to be 

processed for removal at the end of their sentences.

Page 6 GAO-09-109 Management Controls for 287(g) Program
 

provided us with technical comments, which we considered and 

incorporated in the report where appropriate. 

Section 287(g) of the INA, as amended, authorizes ICE to enter into 

written agreements under which state or local law enforcement agencies

may perform, at their own expense and under the supervision of ICE 

officers, certain functions of an immigration officer in relation to the 

investigation, apprehension, or detention of aliens in the United States. 

The statute also provides that such an agreement is not required for state 

and local officers to communicate with ICE regarding the immigration 

status of an individual or otherwise to cooperate with ICE in the 

identification and removal of aliens not lawfully present in the United 

States. Thus, 287(g) agreements go beyond state and local officers’ 

existing ability to obtain immigration status information from ICE and to 

alert ICE to any removable aliens they identify. Under these agreements, 

state and local officers are to have direct access to ICE databases and act

in the stead of ICE agents by processing aliens for removal. They are 

authorized to initiate removal proceedings by preparing a notice to appear 

in immigration court and transporting aliens to ICE-approved detention 

facilities for further proceedings. 

Background 

Section 287(g) and its legislative history do not detail the exact 

responsibilities to be carried out, the circumstances under which officers 

are to exercise 287(g) authority, or which removable aliens should be 

prioritized for removal, thus giving ICE the discretion to establish 

enforcement priorities for the program. The statute does, however, contain 

a number of detailed requirements or controls for the program.10 It requires 

that 

• a written agreement be developed to govern the delegation of 

immigration enforcement functions (e.g., MOA), 

• ICE determine that any officer performing such a function is qualified

to do so (e.g., background security check), 

• the officer have knowledge of, and adhere to, federal law relating to 

immigration (e.g., training), 

• officers performing immigration functions have received adequate 

training regarding enforcement of federal immigration laws (e.g., 

written certification of training provided upon passing examinations), 

 108 U.S.C. § 1357(g); see appendix I. 

Page 7 GAO-09-109 Management Controls for 287(g) Program
 

• any officer performing such a function be subject to the direction and 

supervision of ICE, with the supervising office to be specified in the 

written agreement, and 

• specific powers and duties to be exercised or performed by state or 

local officers be set forth in the written agreement. 

Currently, the 287(g) program is the responsibility of ICE’s Office of State 

and Local Coordination (OSLC). The OSLC is responsible for providing 

information about ICE programs, initiatives, and authorities available to 

state and local law enforcement agencies. In August 2007, OSLC organized 

its various programs to partner with state and local law enforcement 

agencies as Agreements of Cooperation in Communities to Enhance Safety

and Security (ACCESS). ACCESS offers state and local law enforcement 

agencies the opportunity to participate in 1 or more of 13 programs, 

including the Border Enforcement Security Task Forces, the Criminal 

Alien Program, and the 287(g) program. More detailed descriptions of the 

ACCESS programs appear in appendix IV. Under ACCESS, OSLC officials 

are to work with state and local applicants to help determine which 

assistance program would best meet their needs. For example, before 

approving an applicant for 287(g) program participation, OSLC officials 

are to assess first whether ICE has the resources to support the applicant,

such as available detention space and transportation assets based on what

historical patterns indicate will be the approximate number of removable 

aliens apprehended per year by the applying law enforcement agency. 

Based on an overall assessment of these and other factors, such as the 

type of agreement requested, availability of training, congressional 

interest, and proximity to other 287(g) programs, ICE may suggest that 

one or more of the other assistance programs under ACCESS would be 

more appropriate. 

Within the 287(g) program, ICE has developed three models for state and 

local law enforcement participation. One model, referred to as the “jail 

model,” allows for correctional officers working in state prisons or local 

jails to screen those arrested or convicted of crimes by accessing federal

databases to ascertain a person’s immigration status. Another option, 

referred to as the “task force model,” allows law enforcement officers 

participating in criminal task forces such as drug or gang task forces to 

screen arrested individuals using federal databases to assess their 

immigration status. ICE has approved some local law enforcement 

agencies to concurrently implement both models, an arrangement referred 

to as the “joint model.” 

Page 8 GAO-09-109 Management Controls for 287(g) Program
 

The 287(g) program has grown rapidly in recent years as more state and

local communities seek to address criminal activity by those in the country 

illegally with specialized training and tools provided by ICE. From its 

initiation 287(g) authority was viewed by members of Congress as an 

opportunity to provide ICE with more resources—in the form of state and 

local law enforcement officers—to assist ICE in the enforcement of 

immigration laws. In 2005, the conference committee report for DHS’s 

appropriation encouraged ICE to be more proactive in encouraging state 

and local governments to participate in the program.11 Beginning in fiscal 

year 2006, DHS appropriations acts expressly provided funds for the 

287(g) program, and accompanying committee reports provided guidance

on program implementation. In fiscal year 2006, the DHS Appropriations 

Act provided $5.0 million to facilitate 287(g) agreements, and the 

accompanying conference report noted full support for the program, 

describing it as a powerful force multiplier to better enforce immigration 

laws and, consequently, to better secure the homeland.12 In fiscal year 

2007, ICE received $5.4 million for the 287(g) program in its regular 

appropriation and allocated $10.1 million in supplemental funding towards 

the program.13 In fiscal year 2008, ICE received $39.7 million for the 

program, and has received $54.1 million for fiscal year 2009 to support the 

program. Accompanying committee reports have emphasized that ICE 

should perform close monitoring of compliance with 287(g) agreements, 

extensive training prior to delegation of limited immigration enforcement 

functions, direct supervision of delegated officers by ICE, and enrollment 

of correctional facilities in the program to identify more removable aliens. 

Participating state and local law enforcement agencies in the 287(g) 

program may apply for financial assistance to cover some costs associated 

with the program either directly from ICE or through grants provided by 

the Department of Justice (DOJ). For example, for agencies with 

contractual reimbursement agreements, ICE can reimburse law 

enforcement agencies for (1) detention of incarcerated aliens in local 

 11H.R. Conf. Rep. No. 109-241, at 48 (2005). 

12Department of Homeland Security Appropriations Act, 2006, Pub. L. No. 109-90, 119 Stat. 

2064, 2068 (2005); H.R. Conf. Rep. No. 109-241, at 48 (2005). 

13Department of Homeland Security Appropriations Act, 2007, Pub. L. No. 109-295, 120 Stat. 

1355, 1361 (2006). In fiscal year 2006, a supplemental appropriation provided $50.0 million 

in 2-year funding for immigration enforcement training, information technologies, and 

additional detention beds. The 287(g) program was allotted $10.1 million from this 

supplemental funding. 

Page 9 GAO-09-109 Management Controls for 287(g) Program
 

facilities who are awaiting processing by ICE upon completion of their 

sentences and (2) transportation of incarcerated aliens, upon completion 

of their sentences, from a jurisdiction’s facilities to a facility or location 

designated by ICE. In addition, state and local law enforcement agencies

may apply for grants from the DOJ’s State Criminal Alien Assistance 

Program (SCAAP) for a portion of the costs of incarcerating certain 

removable aliens convicted of a felony or two or more misdemeanors.14 

The 287(g) program lacks several management controls that limit ICE’s 

ability to effectively manage the program. First, ICE has not documented

the program’s objectives in program-related materials. Second, programrelated documents, including the MOA, lack specificity as to how and 

under what circumstances participating agencies are to use 287(g) 

authority, or how ICE will supervise the activities of participating 

agencies. Third, ICE has not defined what program information should be 

tracked or ensured that program information is being consistently 

collected and communicated, which would help ensure that management 

directives are followed. And finally, ICE has not developed performance 

measures to assess the effectiveness of the 287(g) program and whether it 

is achieving its intended results. 

According to ICE senior program officials, the main objective of the 287(g) 

program is to enhance the safety and security of communities by 

addressing serious criminal activity such as violent crimes, human 

smuggling, gang/organized crime activity, sexual-related offenses, 

narcotics smuggling and money laundering committed by removable 

aliens. However, program-related documents, including the MOAs and 

program case files for the initial 29 participating agencies, the 287(g) 

brochure, training materials provided to state and local officers, and a 

“frequently asked questions” document do not identify this as the objective

ICE Lacks Key 

Internal Controls for 

the Implementation of 

the 287(g) Program 

ICE Has Not Documented 

the 287(g) Program 

Objective in ProgramRelated Documents

 14Authorized in 1994 by the Violent Crime Control and Law Enforcement Act of 1994, Pub.

L. No. 103-322, § 20301, 108 Stat. 1796, 1823-24, and administered by the Bureau of Justice 

Assistance, the SCAAP grant program reimburses states and localities that incur 

correctional officer salary costs for incarcerating undocumented criminals (as defined by 

statute) who: (1) have at least one felony or two misdemeanor convictions for violations of 

state or local law, and (2) are incarcerated for at least 4 consecutive days. 

Page 10 GAO-09-109 Management Controls for 287(g) Program
 

of the 287(g) program.15 Internal controls also call for agencies to establish 

clear, consistent objectives. In addition, GPRA requires agencies to consult 

with stakeholders to clarify their missions and reach agreement on their 

goals. Successful organizations we have studied in prior work involve 

stakeholders in program planning efforts, which can help create a basic 

understanding among the stakeholders of the competing demands that 

confront most agencies, the limited resources available to them, and how 

those demands and resources require careful and continuous balancing.16

The statute that established the 287(g) program and associated legislative 

history do not set enforcement priorities for the program, which leaves the 

responsibility to ICE. Therefore, ICE has the discretion to define the 

287(g) program objectives in any manner that is reasonable. Although ICE 

has prioritized its immigration enforcement efforts to focus on serious 

criminal activity because of limited personnel and detention space, ICE 

officials told us they did not document the stated 287(g) program 

objectives as such because a situation could arise where detention space

might be available to accommodate removable aliens arrested for minor 

offenses. We identified cases where participating agencies have used their 

287(g) authority to process for removal aliens arrested for minor offenses. 

For example, of the 29 participating agencies we reviewed, 4 agencies told

us they used 287(g) authorities to process for removal those aliens the 

officers stopped for minor violations such as speeding, carrying an open 

container of alcohol, and urinating in public. None of these crimes fall into 

the category of serious criminal activity that ICE officials described to us 

as the type of crime the 287(g) program is expected to pursue. Due to the 

rapid growth of the 287(g) program, an unmanageable number of aliens 

could be referred to ICE if all the participating agencies sought assistance 

to remove aliens for such minor offenses. Another potential consequence 

of not having documented program objectives is misuse of authority. The 

sheriff from a participating agency said that his understanding of the 

287(g) authority was that 287(g)-trained officers could go to people’s 

homes and question individuals regarding their immigration status even if

 15In some portions of the ICE Web site, there is discussion about the 287(g) program as a 

tool to pursue investigations related to aliens involved with violent crimes, human 

smuggling, gang/organized crime activity, sexual-related offenses, narcotics smuggling, and 

money laundering. 

16GAO/GGD-96-118.

Page 11 GAO-09-109 Management Controls for 287(g) Program
 

the individual is not suspected of criminal activity.17 Although it does not 

appear that any officers used the authority in this manner, it is illustrative 

of the lack of clarity regarding program objectives and the use of 287(g) 

authority by participating agencies. 

While agencies participating in the 287(g) program are not prohibited from

seeking the assistance of ICE for aliens arrested for minor offenses, 

detention space is routinely very limited and it is important for ICE to use 

these and other 287(g) resources in a manner that will most effectively 

achieve the objective of the program—to process for removal those aliens

who pose the greatest threat to public safety. According to ICE’s Office of 

Detention and Removal (DRO) strategic plan, until more alternative 

detention methods are available, it is important that their limited detention 

bed space is available for those aliens posing greater threats to the public. 

ICE’s former Assistant Secretary made this point in her congressional 

testimony in February 2008, stating that given the rapid growth of the 

program in the last 2 years, it is important to ensure that ICE’s bed space 

for the 287(g) program is used for the highest priority aliens.18 This may 

not be achieved if ICE does not document and communicate to 

participating agencies its program objective of focusing limited 

enforcement and detention resources on serious and/or violent offenders. 

Program-Related 

Documents Lack Detail 

Regarding Program 

Implementation and ICE 

Supervision Activities 

ICE has not consistently articulated in program-related documents, such 

as MOAs, brochures and training materials, how participating agencies are 

to use their 287(g) authority, nor has it described the nature and extent of 

ICE supervision over these agencies’ implementation of the program. 

Internal control standards state that government programs should 

establish control activities to help ensure management’s directives are 

carried out. According to ICE officials, they use various controls to govern 

the 287(g) program, including conducting background checks on officers 

working for state and local law enforcement agencies that apply to 

participate in the 287(g) program, facilitating a training program with 

mandatory examinations to prepare law enforcement officers to carry out 

 17However, this officer’s agency established its own criteria about whom to detain, limiting 

it to those who have committed a violent offense or crimes such as drug activity and 

driving-under-the-influence violations, to prevent serious overcrowding in their jail. 

18Julie Myers, Assistant Secretary, Immigration and Customs Enforcement, Department of 

Homeland Security in testimony to House Appropriations Subcommittee on Homeland 

Security, February 26, 2008. 

Page 12 GAO-09-109 Management Controls for 287(g) Program
 

287(g) program activities, and documenting agreements reached on 

program operations in the MOA. 

ICE has not consistently communicated, through its MOAs with 

participating agencies, how and under what circumstances 287(g) 

authority is to be used.19 Internal control standards state that government 

programs should establish control activities, including ensuring that 

significant events are authorized and executed only by persons acting 

within the scope of their authority.20 For the 287(g) program, ICE officials 

identified the MOA as a key control document signed by both ICE and 

participating agency officials. The MOA is designed to help ensure that 

management’s directives for the program are carried out by program 

participants. However, the MOAs we reviewed were not consistent with 

statements by ICE officials regarding the use of 287(g) authority. For 

example, according to ICE officials and other ICE documentation, 287(g)

authority is to be used in connection with an arrest for a state offense; 

however, the signed agreement that lays out the 287(g) authority for 

participating agencies does not address when the authority is to be used. 

While all 29 MOAs we reviewed contained language that authorizes a state 

or local officer to interrogate any person believed to be an alien as to his 

right to be or remain in the United States, none of them mentioned that an

arrest should precede use of 287(g) program authority.21 Furthermore, the 

processing of individuals for possible removal is to be in connection with a 

conviction of a state or federal felony offense. However, this circumstance 

is not mentioned in 7 of the 29 MOAs we reviewed, resulting in

implementation guidance that is not consistent across the initial 29 

participating agencies.22 Due to the rapid expansion of the 287(g) program 

Use of 287(g) Authority Is Not 

Consistently Communicated to 

Program Participants 

 19Section 287(g) and its legislative history do not specify the exact enforcement 

responsibilities authorized or the circumstances under which they are to be exercised, 

giving ICE the discretion to make reasonable determinations regarding these aspects of 

program implementation. 

20GAO/AIMD-00-21.3.1. 

21While law enforcement officers without 287(g) designation are not prohibited from 

contacting ICE to get information on the immigration status and identity of aliens 

suspected, arrested, or convicted of criminal activity, the statutory authority of an ICE

officer to interrogate individuals as to their immigration status is one of the federal 

immigration enforcement functions specifically delegated to state and local officers who 

are certified to perform this function under the 287(g) program. 

22The seven MOAs that did not specify that the 287(g) authorities be carried out to process 

individuals convicted of a felony offense were signed prior to 2007, and as of October 2008, 

they had not been amended to reflect the change found in the 2007 MOAs. 

Page 13 GAO-09-109 Management Controls for 287(g) Program
 

in the last 2 years, it is important that ICE consistently communicate to 

participating agencies how this authority is to be used to help ensure that 

state and local law enforcement agents are not using their 287(g) authority 

in a manner not intended by ICE. 

ICE has also not defined in its program-related documents the 

responsibilities required of ICE agents directing and supervising local

officers under the 287(g) program. Internal control standards state that a 

good internal control environment requires that an agency’s organizational 

structure define key areas of authority and responsibility. The statute that 

established the program specifically requires ICE to direct and supervise 

the activities of the state and local officers who participate in the 287(g) 

program. The statute and associated legislative history, however, do not 

define the terms of direction and supervision, which leaves the 

responsibility for defining them to ICE. Although ICE has the discretion to 

define these terms in any manner that it deems reasonable, it has not 

defined them in program documents. 

Program-Related Documents 

Do Not Define Nature and 

Extent of ICE Supervision 

In our analysis of the 29 MOAs, we found little detail regarding the nature 

and extent of supervisory activities to be performed by ICE working with 

state and local law enforcement officers. For example, the MOAs state that 

participating officers will be supervised and directed by ICE regarding 

their immigration enforcement functions. The MOAs also state that 

participating officers cannot perform any immigration officer functions 

except when being supervised by ICE, and that those actions will be 

reviewed by ICE supervisory officers on an ongoing basis to ensure 

compliance and to determine if additional training is needed. The MOAs 

further state that the participating state or local agency retains supervisory 

responsibilities over all other aspects of the officers’ employment. 

However, details regarding the nature and extent of supervision, such as 

whether supervision is to be provided remotely or directly, the frequency 

of interaction, and whether reviews are conducted as written assessments 

or through oral feedback, are not described in the MOAs or in any 

documentation provided to us by ICE. 

In response to our inquiry, ICE officials did not provide a clear definition 

of the nature and extent of ICE supervision to be provided to participating 

agencies. These officials also cited a shortage of supervisory resources. 

The Assistant Director for the Office of State and Local Coordination that 

manages the 287(g) program said the ICE officer who supervises the 

activities of a participating agency’s officers is responsible for conducting 

general tasks, such as reviewing and providing oversight over the 

information added to immigration files; however, he also said the ICE 

Page 14 GAO-09-109 Management Controls for 287(g) Program
 

official responsible for supervising the activities of a participating agency’s 

officers may not have a supervisory designation within ICE. He added that

documentation of an ICE 287(g) supervisor’s responsibilities may be 

included in the position description of a Supervisory Detention and 

Deportation Officer. We examined seven position descriptions provided by

ICE, including this position. Some of the activities described in this 

position description address such issues as level of supervision or 

direction and expectations setting for subordinates. For example, the 

position description for a Supervisory Detention and Deportation Officer 

establishes guidelines and performance expectations that are clearly 

communicated, observes workers’ performance and conducts work 

performance critiques, provides informal feedback, assigns work based on 

priorities or the capabilities of the employee, prepares schedules for 

completion of work, gives advice and instruction to employees, and 

identifies developmental and training needs, in addition to other duties. 

However, because supervision activities specific to the 287(g) program (or 

more generally, state and local law enforcement officers carrying out 

immigration enforcement activities) were not contained in the description, 

it is unclear the extent to which the supervisory activities enumerated in 

those position descriptions would apply to the supervision of state and 

local officers in the 287(g) program.23

Further, ICE officials in headquarters noted that the level of ICE 

supervision provided to participating agencies has varied due to a shortage

of supervisory resources. The officials said it has been necessary in many 

instances for ICE to shift local resources or to utilize new supervisory 

officers to provide the required oversight and to manage the additional 

workload that has resulted from the 287(g) program. For example, agents

from ICE’s Office of Investigations (OI) and DRO have been detailed to the 

287(g) program to fulfill the requirement within section 287(g) of the INA, 

which mandates that ICE supervise officers performing functions under 

each 287(g) agreement. Officials explained that these detailees have been

taken away from their permanent positions, which affects ICE’s ability to 

address other criminal activity. ICE officials noted that the small number 

of detailed agents does not have a significant impact on ICE’s overall 

ability to supervise the 287(g) program in the field. 

 23Additionally, a senior ICE officer commented that, unlike position descriptions, an

employee’s work performance plan contains the specific duties of an ICE officer and 

describes the supervisory activities; however, such a work performance plan for a 287(g)

supervisory officer was not provided by ICE.

Page 15 GAO-09-109 Management Controls for 287(g) Program
 

In addition to the views by ICE officers in headquarters, we asked ICE 

field officials about 287(g) supervision. There was wide variation in the 

perceptions of what supervisory activities are to be performed. For 

example, one ICE official said ICE provides no direct supervision over the 

local law enforcement officers in the 287(g) program in their area of 

responsibility. Conversely, another ICE official characterized ICE 

supervisors as providing frontline support for the 287(g) program. ICE 

officials at two additional offices described their supervisory activities as 

overseeing training and ensuring the computer systems are working 

properly. Officials at another field office described their supervisory 

activities as reviewing files for completeness and accuracy. 

We also asked state and local officers about ICE supervision related to this 

program. Officials from 14 of the 23 agencies that had implemented the 

program gave positive responses when asked to evaluate ICE’s supervision 

of their 287(g)-trained officers. Another four law enforcement agencies 

characterized ICE’s supervision as fair, adequate, or provided on an asneeded basis. Three agencies said they did not receive direct ICE 

supervision or that supervision was not provided daily, which one agency 

felt was necessary to assist with the constant changes in requirements for 

processing of paperwork. Officials from two law enforcement agencies 

said ICE supervisors were either unresponsive or not available. One of 

these officials noted that it was difficult to establish a relationship with the 

relevant managers at the local ICE office because there was constant 

turnover in the ICE agents responsible for overseeing the 287(g) program. 

Given the rapid growth of the program and ICE’s limited supervisory 

resources, defining supervision activities would improve ICE’s ability to 

ensure management directives are carried out appropriately. 

ICE Has Not Ensured 

Information Regarding the 

287(g) Program Is 

Obtained and 

Communicated 

While ICE states in its MOAs that participating agencies are responsible 

for tracking and reporting data, the MOA did not provide details as to what 

data needs to be collected or in what manner data should be collected and

reported. For example, in 20 of the 29 MOAs we reviewed, ICE generally

required participating agencies to track data, but the MOA did not define 

Collection and Reporting 

Requirements Are Not Defined 

Page 16 GAO-09-109 Management Controls for 287(g) Program
 

what data should be tracked, or how data should be collected and 

reported to ICE. 

Specifically, the reporting requirements section in 20 of the MOAs states: 

The LEA [law enforcement agency] will be responsible for tracking 

and maintaining accurate data and statistical information for their 

287(g) program, including any specific tracking data requested by 

ICE. Upon ICE’s request, such data and information shall be 

provided to ICE for comparison and verification with ICE’s own 

data and statistical information, as well as for ICE’s statistical 

reporting requirements and to help ICE assess the progress and 

success of the LEA’s 287(g) program. 

Furthermore, results of our structured interview with 29 program 

participants indicated confusion regarding reporting requirements. For 

example, of the 20 law enforcement agencies we reviewed whose MOA 

contained a reporting requirement: 

• 7 agencies told us they had a reporting requirement and reported data 

to ICE; 

• 3 agencies told us they had a requirement, but were not sure what 

specific data was to be reported; 

• 3 agencies told us they were not required to report any data;

• 2 agencies told us that while ICE did not require them to report data, 

they submitted data to ICE on their activities anyway; and 

• 5 agencies did not respond directly regarding a reporting requirement. 

Of the nine program participants we interviewed without a reporting 

requirement in the MOA: 

• 5 agencies told us they reported data to ICE; 

• 2 agencies told us they were not required to report data to ICE, but did 

so anyway; 

• 1 agency told us they do not report data to ICE; and 

• 1 agency did not know if they were required to report data to ICE. 

According to internal control standards, pertinent information should be 

recorded and communicated to management and others within the entity

that need it in a form and within a time frame that enables them to carry 

out internal control and other responsibilities. Consistent with these 

standards, agencies are to ensure that information relative to factors vital 

to a program meeting its goals is identified and regularly reported to 

management. For example, collecting information such as the type of 

Page 17 GAO-09-109 Management Controls for 287(g) Program
 

crime for which an alien is detained could help ICE determine whether 

participating agencies are processing for removal those aliens who have 

committed serious crimes, as its objective states. Without clearly 

communicating to participating agencies guidance on what data is to be 

collected and how it should be gathered and reported, ICE management 

may not have the information it needs to ensure the program is achieving

its objective.

Performance Measures to 

Fully Evaluate the 287(g) 

Program Are Lacking 

While ICE has defined the objective of the 287(g) program—to enhance 

the safety and security of communities by addressing serious criminal 

activity by removable aliens— the agency has not developed performance 

measures for the 287(g) program to track the progress toward attaining

that objective.24 GPRA requires that agencies clearly define their missions, 

measure their performance against the goals they have set, and report on 

how well they are doing in attaining those goals.25 Measuring performance 

allows organizations to track the progress they are making toward their 

goals and gives managers critical information on which to base decisions 

for improving their programs. Our previous work has shown that agencies

successful in evaluating performance had measures that demonstrated 

results, covered multiple priorities, provided useful information for 

decision making, and successfully addressed important and varied aspects 

of program performance.26 Internal controls also call for agencies to 

establish performance measures and indicators. ICE officials stated that 

they are in the process of developing performance measures, but have not

provided any documentation or a time frame for when they expect to 

complete the development of these measures. In accordance with standard 

practices for program and project management, specific desired outcomes 

or results should be conceptualized and defined in the planning process as 

part of a road map, along with the appropriate projects needed to achieve 

those results, and milestones.27

 24In general, performance measures are indicators, statistics, or metrics used to gauge 

program performance. 

25GAO/GGD-96-118. 

26GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: November 22, 2002). 

27The Project Management Institute, The Standard for Program Management © (2006). 

Page 18 GAO-09-109 Management Controls for 287(g) Program
 

ICE officials told us that, although they have not yet developed 

performance measures, in an effort to monitor how the program is being 

implemented, they are beginning to conduct compliance inspections based 

on information provided in the MOA in locations where the 287(g) 

program has been implemented. ICE’s Office of Professional 

Responsibility (OPR) was recently directed to conduct field inspections of 

all participating 287(g) program agencies. OPR officials state that the 

inspections are based on a checklist drawn from participating agencies’ 

MOAs as well as interviews with state and local law enforcement agencies 

and ICE officials who are responsible for overseeing these agencies. OPR’s 

checklists include items such as the review of the arrest and prosecution 

history of undocumented criminals, relevant immigration files, and ICE’s 

Enforcement Case Tracking System (ENFORCE) entries, as well as review

of any complaints by those detained pursuant to the 287(g) program 

directed towards ICE, state and local law enforcement officers. OPR 

officials use this checklist to confirm whether the items agreed to in the 

MOA have been carried out. As discussed earlier in this report, the 29 

MOAs we reviewed did not contain certain internal controls to govern 

program implementation consistent with federal internal control 

standards. According to OPR officials, they have completed six 

compliance inspections, and have a seventh inspection underway. In 

addition, OPR officials told us that they are planning to complete 

compliance inspections for the rest of the initial 29 program participants 

within the next 2 years. Although ICE has initiated compliance inspections 

for the 287(g) program, ICE officials stated that the compliance 

inspections do not include performance assessments of the program. 

ICE officials stated that developing performance measures for the 

program will be difficult because each state and local partnership 

agreement is unique, making it challenging to develop measures that 

would be applicable for all participating agencies. Nonetheless, these 

measures are important to provide ICE with a basis for determining 

whether the program is achieving its intended results. Without a plan for 

the development of performance measures, including milestones for their 

completion, ICE lacks a roadmap for how this project will be achieved. 

Page 19 GAO-09-109 Management Controls for 287(g) Program
 

ICE and participating agencies used program resources mainly for 

personnel, training, and equipment. From fiscal years 2006 through 2008, 

ICE received approximately $60 million to provide 287(g) resources for 67 

participating agencies nationwide as follows: 

Program Resources 

Are Used for Training, 

Supervision, and 

Equipment; Benefits 

and Concerns Are 

Reported by ICE and 

Participating Agencies 

Program Resources Are 

Used for Training, 

Supervision, and 

Equipment 

• Training. Once officers working for state and local law enforcement 

participating agencies pass a background investigation performed by 

ICE, they are also required to attend a 4-week course and pass

mandatory examinations to be certified. Training is focused on

immigration and nationality law, and includes modules on identifying 

fraudulent documents, understanding removal charges, cross-cultural 

communications, and alien processing (e.g., accessing federal

databases). Of the 27 participating agencies that had received training 

at the time of our interviews 20 said the training prepared them to 

perform their 287(g) activities; four of these agencies also reported 

that their participation in the program was delayed due to problems 

with scheduling training. ICE provided information reflecting an 

average training cost per student of $2,622 using the on-site training 

facility—the Federal Law Enforcement Training Center—and $4,840 

using off-site facilities. These average costs include travel, lodging, 

books, meals, and miscellaneous expenses. As of October 2008, ICE 

had trained and certified 951 state or local officers in the 287(g) 

program.28

 28According to ICE officials, a total of 994 state and local officers started 287(g) training: 13

failed the mandatory examinations, 30 officers removed themselves from the training, and 

951 were certified for the 287(g) program.

Page 20 GAO-09-109 Management Controls for 287(g) Program
 

• Equipment. ICE is to provide the equipment necessary to link 

participating state and local law enforcement agencies with ICE to 

assist these agencies in performing their immigration enforcement 

activities. ICE estimates that, on average, for each participating agency

it spends $37,000 for equipment set-up and installation, and about 

$43,000 for equipment hardware. These costs include installation of a 

secure transmission line, which connects the participating agency to 

ICE databases, one or more workstations, one or more machines that 

capture and transmit fingerprints electronically, and personnel labor 

and support costs. In addition, it spends on average about $107,000 

annually for recurring equipment operations and maintenance costs 

for each participating agency. 

• Supervision. ICE is to provide supervision to state and local law 

enforcement agencies participating in the 287(g) program. However, as 

mentioned earlier in this report, ICE has not identified what 

responsibilities are required of ICE agents directing and supervising 

local officers under the 287(g) program, and comments about program 

supervision from ICE officers at headquarters and in field offices, as 

well as officers from participating agencies, differ widely. Therefore, 

we are unable to provide more detail as to this 287(g) resource 

provided by ICE. 

In addition to the resources provided by ICE, state and local law 

enforcement agencies also provide resources to implement the 287(g) 

program. For example, state and local law enforcement agencies provide 

officers, space for equipment, and funding for any other expenses not 

specifically covered by ICE, such as office supplies and vehicles. Of the 29 

state and local participating agencies we interviewed, 11 were able to

provide estimates for some of their costs associated with participating in

the 287(g) program; however, the data they provided was not consistent. 

Therefore, it was not feasible to total these costs. Those law enforcement 

agencies able to identify costs may be able to recover some of these 

expenses through an intergovernmental service agreement, or through 

DOJ’s SCAAP grant process. When we asked state and local law 

enforcement participating agencies whether they received federal 

reimbursement from any source for costs associated with the 287(g) 

program (e.g., detention or transportation), 18 of the 29 reported that they 

Page 21 GAO-09-109 Management Controls for 287(g) Program
 

did not.29 Six participating state and local agencies said they received 

SCAAP funding for some of these costs, and another five said they 

received federal reimbursements for some costs related to detention, 

transportation, and hospitalization.

The rapid growth of the 287(g) program has presented resource challenges

that ICE has begun to address. For example, 11 of the 29 participating 

agencies we contacted told us of equipment-related problems. Specifically, 

two of these agencies did not have equipment to carry out the 287(g) 

program for several months after their staff had received training on how 

to use it, and they had concerns that refresher training would be needed,

while another agency received more equipment than it needed. ICE has 

worked with participating agencies to address the problems with program 

equipment distribution. ICE headquarters and field staff also told us that 

their resources to supervise activities of program participants are being 

stretched to their maximum capacities to manage the increased growth of 

the program. To address these issues, ICE has detailed agents from OI and 

DRO to meet supervisory and other program requirements. ICE is also 

considering other ways to address the challenges presented by program 

growth. As discussed earlier in this report, the 287(g) program is 1 of 13 

ICE programs to partner with state and local law enforcement agencies

under ACCESS. ICE officials are working with state and local participants

and applicants to help determine whether a different ACCESS program 

would better meet their needs, and as a result, ICE has reduced the 

backlog of applications to the 287(g) program from approximately 80 

applications to 29 as of October 2008. 

Program Activities Are 

Reported by ICE and 

Participating Agencies 

Reported Benefits and 

Concerns

Both ICE and state and local law enforcement agencies participating in the 

287(g) program have reported activities, benefits, and concerns associated 

with the program. As of October 2008, ICE reported that 67 state and local 

law enforcement agencies had enrolled in the 287(g) program, and that 

about 25 state and local jurisdiction program applications were pending. In 

addition, ICE reported that 951 state and local officers received training in

immigration law and enforcement functions and were certified to use 

287(g) authority. ICE’s data show that for 25 of the 29 participating 

agencies we reviewed in fiscal year 2008 that about 43,000 aliens had been

 29The question was not limited to possible reimbursements from DHS/ICE. GAO also did 

not independently verify whether these law enforcement agencies met criteria for federal

reimbursement agreements. 

Page 22 GAO-09-109 Management Controls for 287(g) Program
 

arrested under the 287(g) program authority, with individual agency 

participant arrests ranging from about 13,000 in one location to no arrests 

in two locations. Of those 43,000 aliens arrested by program participants 

pursuant to the 287(g) authority, ICE detained about 34,000 and placed 

about 14,000 (41 percent) of those detained in removal proceedings, and 

arranged for about 15,000 (44 percent) to be voluntarily removed. The 

remaining 5,000 (15 percent) arrested aliens detained by ICE were either 

given a humanitarian release, sent to a federal or state prison to serve a 

sentence for a felony offense, or not taken into ICE custody given the 

minor nature of the underlying offense and limited availability of detention 

space. 

State and local law enforcement agencies we interviewed have reported 

specific benefits of the 287(g) program, including the reduction of 

crime/making the community safer, identifying/removing repeat offenders,

improving the quality of life for the community, and giving law 

enforcement officers a sense of accomplishment related to immigration 

enforcement. On the other hand, more than half of the 29 state and local 

law enforcement agencies we interviewed reported concerns that some 

members of their communities expressed about the 287(g) program, 

including concerns that law enforcement officers in the 287(g) program 

would be deporting removable aliens because of minor traffic violations 

(e.g., speeding); fear and apprehension in the Hispanic community about 

possible deportation; and concerns that officers would be performing 

increased enforcement of immigration laws at worksites and would 

engage in racial profiling. To help mitigate these fears and concerns, 27 of 

the 29 law enforcement agencies we reviewed reported that they had

conducted outreach in their communities regarding the program (e.g., 

newspaper articles, press releases, TV and radio spots, speaking 

engagements, and public meetings). 

Removing aliens who have committed violent crimes is of great 

importance to the safety of the community at large. Through the 287(g) 

program and its partnerships with state and local agencies, ICE has an 

opportunity to identify and train additional law enforcement resources 

that could help it meet this challenge. However, the lack of internal 

controls governing the program limits ICE’s ability to take full advantage 

of this additional resource. For example, without documenting that the 

objective of the program is to remove aliens who have committed serious 

crimes or pose a threat to public safety, participating agencies may further 

burden limited detention resources by continuing to seek ICE assistance 

for aliens detained for minor crimes. According to ICE, it is important to 

Conclusions 

Page 23 GAO-09-109 Management Controls for 287(g) Program
 

ensure that their limited detention bed space is available for those aliens 

posing the greatest threat to the public. Moreover, without consistently 

communicating to participating agencies how and under what 

circumstances 287(g) authority is to be used, participating agencies may 

use this authority in a manner that is not intended by ICE. Additionally, 

given the rapid growth of the program, the lack of defined supervision 

activities could hamper ICE’s ability to ensure management directives are 

being carried out appropriately. Furthermore, without guidance for what

data participating agencies are to collect and how this information is to be 

gathered and reported, ICE may not have the information it needs to help

ensure participating agencies are adhering to program objectives. Finally, 

performance measures are important to provide ICE with a basis for 

determining whether the program is achieving its intended results. While it

is encouraging that ICE is working to develop these measures, without 

establishing a plan, including a time frame for development, ICE lacks a 

roadmap for how it will achieve this goal. 

To help ensure that the ICE 287(g) program achieves the results intended, 

we are recommending that the Assistant Secretary for ICE take the 

following five actions: 

• Document the objective of the 287(g) program for participants, 

• Clarify how and under what circumstances 287(g) authority is to be 

used by state and local law enforcement officers in participating 

agencies, 

• Document in MOAs the nature and extent of supervisory activities ICE 

officers are expected to carry out as part of their responsibilities in 

overseeing the implementation of the 287(g) program and 

communicate that information to both ICE officers and state and local

participating agencies, 

• Specify the program information or data that each agency is expected 

to collect regarding their implementation of the 287(g) program and 

how this information is to be reported, and 

• Establish a plan, including a time frame, for the development of 

performance measures for the 287(g) program. 

We provided a draft of this report to DHS for review and comment. DHS 

provided written comments on January 28, 2009, which are presented in 

appendix V. In commenting on the draft report, DHS stated that it agreed 

Recommendations for 

Executive Action 

Agency Comments 

Page 24 GAO-09-109 Management Controls for 287(g) Program
 

with our recommendations and identified actions planned or underway to 

implement the recommendations. 

ICE also provided us with technical comments, which we considered and 

incorporated in the report where appropriate. 

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of Homeland 

Security, the Secretary of State, the Attorney General, and other interested

parties. In addition, the report will be available at no charge on the GAO 

Web site at http://www.gao.gov. 

If you or your staff has any questions about this report, please contact me 

at (202) 512-8777 or at stanar@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are acknowledged in 

appendix VI.

Richard M. Stana, Director 

Homeland Security and Justice Issues 

Page 25 GAO-09-109 Management Controls for 287(g) Program
 

List of Congressional Requesters 

The Honorable Joseph I. Lieberman 

Chairman 

The Honorable Susan M. Collins 

Ranking Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Bennie G. Thompson

Chairman 

Committee on Homeland Security 

House of Representatives 

The Honorable Christopher P. Carney 

The Honorable Mike Rogers 

The Honorable Mark E. Souder 

House of Representatives 

Page 26 GAO-09-109 Management Controls for 287(g) Program
Appendix I: Statutory Provision Governing 

the 287(g) Program 

Page 27 GAO-09-109 Management Controls for 287(g) Program

Appendix I: Statutory Provision Governing 

the 287(g) Program 

 8 U.S.C. § 1357(g) 

(g) Performance of immigration officer functions by State officers and 

employees 

(1) Notwithstanding section 1342 of title 31, the Attorney General1

 may 

enter into a written agreement with a State, or any political subdivision of

a State, pursuant to which an officer or employee of the State or 

subdivision, who is determined by the Attorney General to be qualified to

perform a function of an immigration officer in relation to the 

investigation, apprehension, or detention of aliens in the United States 

(including the transportation of such aliens across State lines to detention 

centers), may carry out such function at the expense of the State or 

political subdivision and to the extent consistent with State and local law. 

(2) An agreement under this subsection shall require that an officer or 

employee of a State or political subdivision of a State performing a 

function under the agreement shall have knowledge of, and adhere to, 

Federal law relating to the function, and shall contain a written 

certification that the officers or employees performing the function under 

the agreement have received adequate training regarding the enforcement 

of relevant Federal immigration laws. 

(3) In performing a function under this subsection, an officer or employee 

of a State or political subdivision of a State shall be subject to the 

direction and supervision of the Attorney General. 

(4) In performing a function under this subsection, an officer or employee 

of a State or political subdivision of a State may use Federal property or 

facilities, as provided in a written agreement between the Attorney 

General and the State or subdivision. 

(5) With respect to each officer or employee of a State or political 

subdivision who is authorized to perform a function under this subsection, 

the specific powers and duties that may be, or are required to be, 

 1

Under the Homeland Security Act of 2002, this and other immigration enforcement 

functions of the Attorney General were transferred to the Department of Homeland 

Security upon its creation in March 2003 and were delegated to ICE pursuant to the

Department of Homeland Security Reorganization Plan of November 25, 2002, as modified. 

See 6 U.S.C. § 251; Reorganization Plan Modification for the Department of Homeland

Security, H. Doc. 108-32, at 3 (Feb. 4, 2003). 
Appendix I: Statutory Provision Governing 

the 287(g) Program 

exercised or performed by the individual, the duration of the authority of 

the individual, and the position of the agency of the Attorney General who 

is required to supervise and direct the individual, shall be set forth in a 

written agreement between the Attorney General and the State or political

subdivision. 

(6) The Attorney General may not accept a service under this subsection if 

the service will be used to displace any Federal employee. 

(7) Except as provided in paragraph (8), an officer or employee of a State

or political subdivision of a State performing functions under this 

subsection shall not be treated as a Federal employee for any purpose 

other than for purposes of chapter 81 of title 5 (relating to compensation 

for injury) and sections 2671 through 2680 of title 28 (relating to tort 

claims). 

(8) An officer or employee of a State or political subdivision of a State 

acting under color of authority under this subsection, or any agreement 

entered into under this subsection, shall be considered to be acting under 

color of Federal authority for purposes of determining the liability, and 

immunity from suit, of the officer or employee in a civil action brought 

under Federal or State law. 

(9) Nothing in this subsection shall be construed to require any State or 

political subdivision of a State to enter into an agreement with the 

Attorney General under this subsection. 

(10) Nothing in this subsection shall be construed to require an agreement 

under this subsection in order for any officer or employee of a State or 

political subdivision of a State — 

(A) to communicate with the Attorney General regarding the immigration 

status of any individual, including reporting knowledge that a particular 

alien is not lawfully present in the United States; or 

(B) otherwise to cooperate with the Attorney General in the identification,

apprehension, detention, or removal of aliens not lawfully present in the 

United States. 

Page 28 GAO-09-109 Management Controls for 287(g) Program
Appendix II: Structured Interview Questions 

for All 29 Participants of the 287(g) Program 

Page 29 GAO-09-109 Management Controls for 287(g) Program

Appendix II: Structured Interview Questions 

for All 29 Participants of the 287(g) Program 
Appendix II: Structured Interview Questions 

for All 29 Participants of the 287(g) Program 

Page 30 GAO-09-109 Management Controls for 287(g) Program
Appendix II: Structured Interview Questions 

for All 29 Participants of the 287(g) Program 

Page 31 GAO-09-109 Management Controls for 287(g) Program
Appendix II: Structured Interview Questions 

for All 29 Participants of the 287(g) Program 

Page 32 GAO-09-109 Management Controls for 287(g) Program
Appendix III: Objec

Methodology 

tives, Scope, and

Page 33 GAO-09-109 Management Controls for 287(g) Program

Appendix III: Objectives, Scope, and 

Methodology 

This report addresses (1) the extent to which ICE has designed controls to

govern 287(g) program implementation and (2) how program resources 

are being used and the program activities, benefits, and concerns reported 

by participating agencies. 

To address our objectives, we contacted and obtained information from 

key people and organizations associated with the arrest, detention, and 

removal of aliens, and U.S. Immigration and Customs Enforcement’s (ICE) 

287(g) program, including the following: 

Objectives 

Scope and 

Methodology 

• ICE headquarters officials from the following offices: Office of

Investigations, Office of the Principal Legal Advisor, Office of 

Detention and Removal, Office of the Chief Financial Officer/Budget 

Office, Office of State and Local Coordination, and Office of 

Professional Responsibility. 

• ICE officials from ICE Field Offices in Phoenix, Arizona, and in the 

California offices of Los Angeles, Santa Ana, Riverside, and San 

Bernardino in conjunction with our site visits to state and local law 

enforcement agencies in these areas.

• Officials from all 29 state and local law enforcement agencies that had 

entered into agreements with ICE as of September 1, 2007, listed 

below. Six of these agencies reported that they had not yet begun 

implementing the program. Our analysis includes information from 

these six agencies as appropriate.1

 We conducted structured interviews 

with officials from these organizations from October 2007 through 

February 2008. By interviewing officials from all participating 

agencies, we were able to obtain information and perspectives from 

participating agencies that had been involved in the program for the 

longest period of time as well as from those agencies that had just 

started participating to learn how law enforcement agencies get their 

program implemented. 

 1

Law enforcement agencies that could not provide complete information during our 

structured interviews because they had not implemented or had little experience with the 

287(g) program included: Georgia Department of Public Safety, Massachusetts Department

of Corrections, El Paso County Sheriff’s Office (Colorado), Cabarrus County Sheriff’s 

Office (North Carolina), Barnstable County Sheriff’s Office (Massachusetts), and the New

Mexico Department of Corrections. 
Appendix III: Objectives, Scope, and

Methodology 

State and local law enforcement agencies that had entered into

agreements with ICE as of September 1, 2007: 

Alabama Department of Public Safety; 

Arizona Department of Corrections; 

Arizona Department of Public Safety;

Maricopa County Sheriff’s Office (Arizona); 

Los Angeles County Sheriff’s Office (California) 

Orange County Sheriff’s Office (California); 

Riverside County Sheriff’s Office (California); 

San Bernardino County Sheriff’s Office (California); 

Colorado Department of Public Safety/State Patrol; 

El Paso County Sheriff’s Office (Colorado); 

Collier County Sheriff’s Office (Florida); 

Florida Department of Law Enforcement; 

Cobb County Sheriff’s Office (Georgia); 

Georgia Department of Public Safety;

Barnstable County Sheriff’s Office (Massachusetts); 

Framingham Police Department (Massachusetts); 

Massachusetts Department of Corrections; 

Alamance County Sheriff’s Office (North Carolina); 

Cabarrus County Sheriff’s Office (North Carolina); 

Gaston County Sheriff’s Office (North Carolina); 

Page 34 GAO-09-109 Management Controls for 287(g) Program
Appendix III: Objectives, Scope, and

Methodology 

Mecklenburg County Sheriff’s Office (North Carolina); 

Hudson Police Department (New Hampshire) 

New Mexico Department of Corrections; 

Tulsa County Sheriff’s Office (Oklahoma); 

Davidson County Sheriff’s Office (Tennessee); 

Herndon Police Department (Virginia); 

Prince William-Manassas Adult Detention Center (Virginia); 

Rockingham County Sheriff’s Office (Virginia); and 

Shenandoah County Sheriff’s Office (Virginia). 

We also conducted site visits with nine state and local law enforcement 

agencies that entered into an agreement with ICE as of September 1, 2007,

and had begun implementing the program. These sites were selected to 

represent variation in length of partnership with ICE, type of model (e.g., 

jail, task force, or joint), geographic location, size of jurisdiction, and 

proximity to ICE Special-Agent-in-Charge or regional office. The offices 

from which we interviewed officials about their participation in the 287(g) 

program, include Rockingham County Sheriff’s Office, Shenandoah County 

Sheriff’s Office, Los Angeles County Sheriff’s Office, Orange County 

Sheriff’s Office, San Bernardino County Sheriff’s Office, Riverside County 

Sheriff’s Office, Arizona Department of Corrections, Maricopa County 

Sheriff’s Office (including the Enforcement Support, Human Smuggling 

Unit), and Arizona Department of Public Safety (including the Gang 

Enforcement Bureau and the Criminal Investigations Division). Although 

we are not able to generalize the information gathered from these visits to 

all other participating law enforcement agencies, they provided us with a 

variety of examples related to program implementation. 

To determine what the 287(g) program’s objectives are and to what extent 

ICE has designed controls to govern implementation, we collected and

analyzed information regarding the program’s objective and obtained 

information from both ICE and the participating law enforcement agencies 

we interviewed and visited to determine if ICE objectives for the program 

were clearly articulated to law enforcement agencies. We reviewed 

available program-related documents, including program case files for the 

Page 35 GAO-09-109 Management Controls for 287(g) Program
Appendix III: Objectives, Scope, and

Methodology 

initial 29 participating agencies, the 287(g) brochure, training materials 

provided to state and local officers to become certified in the program, 

and a “frequently asked questions” document on the program. In addition,

we analyzed the MOAs of each state and local agency participating in the

287(g) program as of September 1, 2007. Specifically, we examined 

sections of the MOAs related to program authority, designation of 

enforcement functions, and ICE supervision responsibilities, among other 

areas of these written agreements. We completed a content analysis of 

responses to structured interviews that were conducted with key officials 

from each of the participating law enforcement agencies in this review and 

from information gathered from site visits. Our content analysis consisted 

of reviewing the responses to the structured interview questions and 

identifying and grouping responses by theme or characterization. These 

themes were then coded and tallied. For some questions, participating 

agencies gave multiple responses or characterizations, therefore responses 

are not always mutually exclusive. Selection of themes and coding of 

responses were conducted separately by two analysts; any discrepancies 

were resolved. We also compared controls ICE told us they designed to 

govern implementation of the 287(g) program, including conducting 

background checks, providing formal training with qualifying exams for 

the applicants’ officers, and agreeing with state and local agencies to 

MOAs, with criteria in GAO’s Standards for Internal Control in the Federal 

Government, the Government Performance and Results Act (GPRA) and 

standard practices for program management.2

 To corroborate the 

information we received from the law enforcement agencies through both 

the structured interviews and site visits, we interviewed officials from ICE 

both at headquarters and in the field, and examined documentation on 

guidance given to both ICE and state and local participants about the 

implementation of the program, as well as reviewed all 29 case files 

 2

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). These standards, issued pursuant to the requirements

of the Federal Managers’ Financial Integrity Act of 1982 (FMFIA), provide the overall 

framework for establishing and maintaining internal control in the federal government.

Also pursuant to FMFIA, the Office of Management and Budget issued Circular A-123,

revised December 21, 2004, to provide the specific requirements for assessing the reporting 

on internal controls. Internal control standards and the definition of internal control in 

Circular A-123 are based on GAO’s Standards for Internal Control in the Federal 

Government. GPRA is the primary legislative framework through which agencies will be 

required to set strategic goals, measure performance, and report on the degree to which 

goals were met. GAO, Executive Guide: Effectively Implementing the Government

Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). Additional 

program management standards we reviewed are reflected in the Project Management 

Institute’s The Standard for Program Management © (2006). 

Page 36 GAO-09-109 Management Controls for 287(g) Program
Appendix III: Objectives, Scope, and

Methodology 

created and maintained by ICE on program participants. We identified for 

what purposes ICE relies on data collected from law enforcement 

agencies, and how data reliability checks are performed for data collection 

associated with the 287(g) program. We interviewed ICE officials and 

participating law enforcement agencies to determine what guidance ICE 

has provided to law enforcement agencies on how data are collected,

stored, and reported to ICE. We interviewed officials and examined 

documentation from ICE to determine the measures established to 

monitor performance and improvements made to the program. We 

reviewed reports that use data from ICE’s Enforcement Case Tracking 

System or the ENFORCE database, which automates the processes 

associated with the identification, apprehension, and deportation of 

removable aliens. During our review, we learned that some data regarding

the 287(g) program may not have been included in ENFORCE, and 

therefore, we are unsure of the completeness of the information relevant

to this program in this database. We used this data to a limited extent in 

our Objective II discussion related to activities, benefits, and concerns of 

the 287(g) program. The data used was for illustrative purposes only and 

not used to draw conclusions about the program. 

To determine what resources ICE and participating law enforcement 

agencies provide to the program including the equipment and training for 

program participants, and the assignment of ICE supervisory staff for this 

program, we examined ICE’s budget for the 287(g) program, including 

how ICE calculates the funding requirements for each additional 

agreement. We also interviewed officials from the participating law 

enforcement agencies, analyzed information collected from these agencies 

to determine what resources they reported using to implement the 

program and the activities, benefits, and concerns they reported 

associated with the program. In addition, we examined budget and 

appropriations documentation from the program’s inception to the fiscal 

year 2009 budget request for the 287(g) program. We collected and 

analyzed information on the activities reported by ICE stemming from the 

program. Through our structured interviews, we gathered and analyzed

the participating state and local agencies views on the activities, benefits, 

and concerns related to the program. We did not conduct a fiscal 

examination of the cost of detention facilities, nor review the budgetary 

effect on law enforcement agencies implementing the 287(g) program. 

Page 37 GAO-09-109 Management Controls for 287(g) Program
Appendix IV: Copy of ICE Pamphlet on 

ACCESS Programs

Page 38 GAO-09-109 Management Controls for 287(g) Program

Appendix IV: Copy of ICE Pamphlet on 

ACCESS Programs 
Appendix IV: Copy of ICE Pamphlet on 

ACCESS Programs

Page 39 GAO-09-109 Management Controls for 287(g) Program
Appendix V: Comments from the Department 

of Homeland Security

Page 40 GAO-09-109 Management Controls for 287(g) Program

Appendix V: Comments from the Department 

of Homeland Security 
Appendix V: Comments from the Department 

of Homeland Security

Page 41 GAO-09-109 Management Controls for 287(g) Program
Appendix V: Comments from the Department 

of Homeland Security

Page 42 GAO-09-109 Management Controls for 287(g) Program
Appendix V: Comments from the Department 

of Homeland Security

Page 43 GAO-09-109 Management Controls for 287(g) Program
Appendix VI: 

A

GAO Contact and Staff 

cknowledgments 

Page 44 GAO-09-109 Management Controls for 287(g) Program

Appendix VI: GAO Contact and Staff 

Acknowledgments 

Richard M. Stana, (202) 512-8777 or stanar@gao.gov

In addition to the contact named above, Bill Crocker, Assistant Director, 

and Lori Kmetz, Analyst-in-Charge, managed this assignment. Susanna 

Kuebler, Carolyn Garvey, and Orlando Copeland made significant 

contributions to the work. Michele Fejfar assisted with design, 

methodology, and data analysis. Katherine Davis, Linda Miller, Adam Vogt 

and Peter Anderson provided assistance in report preparation, and 

Frances Cook provided legal support.

GAO Contact 

Staff 

Acknowledgments 

(440641) 
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