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October , 2017 

OIG-18-0
 

 

DHS OIG HIGHLIGHTS
 

DHS Needs a More Unified Approach to

Immigration Enforcement and Administration
 

October 30, 2017 

Why We Did 

This Audit 

Between fiscal years 2014 

and 2016, the Department 

of Homeland Security 

received $22.8 billion to 

enforce and administer 

immigration laws. We 

conducted this audit to 

determine whether DHS 

fosters collaboration and 

unity of effort departmentwide to enforce and 

administer immigration law 

and policy. 

What We 

Recommend 

DHS should establish a 

formal department-level 

group to facilitate longterm solutions for 

overarching component 

immigration enforcement 

and administration 

challenges, and improve 

efficiencies. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

U.S. Immigration and Customs Enforcement, U.S. 

Customs and Border Protection, and U.S. 

Citizenship and Immigration Services, continue to 

face challenges with emerging immigration 

enforcement and administration activities. 

Although DHS has established unity of effort 

initiatives to break silos and centralize decision 

making related to immigration, problems remain. 

We identified issues related to mission allocation 

and expenditure comparisons, the affirmative 

asylum application process, and the Department’s 

struggle to understand immigration outcomes and 

decisions. We also identified component 

coordination difficulties pertaining to the 

availability of bed space, language services, and 

processing aliens. These issues existed because 

DHS did not have a designated responsible official 

or department-level group that strategically 

addressed overarching issues to foster 

coordination and resolution. 

Without a more unified approach to immigration 

enforcement and administration that includes 

efficiency in management of resources, DHS will 

continue to allow vulnerabilities that may affect 

national security and public safety. 

DHS Response 

DHS concurred with our recommendation and 

has begun to develop corrective actions in 

response to our report. 

www.oig.dhs.gov OIG-18-07 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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


OCT 30 2017 


MEMORANDUM FOR: The Honorable Elaine C. Duke 

Acting Secretary 

FROM: John Roth h~\(o~ ..... 

Inspector General 

SUBJECT: DHS Needs a More Unified Approach to 

Immigration Enforcement and 

Administration 

Attached for your action is our final report, DHS Needs a More Unified Approach 

to Immigration Enforcement and Administration. We incorporated the formal 

comments from your office in the final report. 

The report contains one recommendation aimed at improving DHS' immigration 

enforcement and administration. DHS concurred with the recommendation. 

Based on information provided in your response to the draft report, we 

consider the recommendation resolved and open. Once your office has fully 

implemented the recommendation, please submit a formal closeout letter to us 

within 30 days so that we may close the recommendation. The memorandum 

should be accompanied by evidence of completion of agreed-upon corrective 

actions and of the disposition of any monetary amounts. Please send your 

closure request to OIGAuditsFollowup@oig.dhs.gov. 

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

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Don Bumgardner, 

Deputy Assistant Inspector General for Audits, at (202) 254-4100 or Patrick 

O'Malley, Audit Director at (856) 229-5105. 

Attachment 
 

 

 

 

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Table of Contents 

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

Results of Audit .............................................................................................. 2 

DHS Needs to Enhance Its Unified Approach with Immigration 

Enforcement and Administration to Combat Cross-component 

Challenges ............................................................................................. 3 

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

Recommendation .......................................................................................... 10 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 12 

Appendix B: DHS’ Comments to the Draft Report ................................ 14 

Appendix C:Office of Audits Major Contributors to This Report ........... 16 

Appendix D: Report Distribution .......................................................... 17 

Abbreviations 

CBP U.S. Customs and Border Protection 

EAD Employment Authorization Document 

FYHSP Future Years Homeland Security Program 

ICE U.S. Immigration and Customs Enforcement 

ICE ERO ICE Enforcement and Removal Operations 

ICE HSI ICE Homeland Security Investigations 

JRC Joint Requirements Council 

JTF Joint Task Forces 

NDAA National Defense Authorization Act 

OIG Office of Inspector General 

PPBE Planning, Programming, Budgeting, and Execution 

QHSR Quadrennial Homeland Security Review 

USCIS U.S. Citizenship and Immigration Services 

www.oig.dhs.gov OIG-18-07 
OFFICE OF INSPECTOR GENERAL 

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Background 

The Homeland Security Act of 2002 (the Act) abolished the Immigration and 

Naturalization Service, separated its benefit and enforcement functions, and 

transferred those functions to distinct components within the Department of 

Homeland Security. Specifically — 

x the Act gave the U.S. Citizenship and Immigration Services (USCIS) 

authority to adjudicate immigration benefits; 

x the Act gave the U.S. Immigration and Customs Enforcement (ICE) and 

U.S. Customs and Border Protection (CBP) authority for immigration 

enforcement functions; and 

x	 Congress transferred immigration policy making and implementation to 

each component for its area of responsibility. 

Between fiscal years 2014 and 2016, DHS allocated $22.8 billion to accomplish 

the enforcement and administration of immigration laws — one of its strategic 

missions. ICE, CBP, and USCIS account for $21.7 billion (or 95 percent) of all 

resources allocated to this mission. Table 1 provides FYs 2014–16 allocations 

by component for enforcing and administering immigration laws. 

Table 1: DHS Mission 3: Enforcing and Administering Our Immigration 

Laws ($ in Thousands) 

Department Components FY 14 FY 15 FY16 Total 

U.S. Immigration and Customs

Enforcement $3,441,531 $3,148,657 $3,942,579 $10,532,767 

U.S. Citizenship and Immigration 

Services $3,219,466 $2,892,117 $3,259,881 $9,371,464 

U.S. Customs and Border Protection $1,002,538 $416,491 $373,694 $1,792,723 

United States Coast Guard $0 $441,001 $248,956 $689,957 

National Protection and Programs 

Directorate $0 $142,035 $161,896 $303,931 

Federal Law Enforcement Training 

Center $36,912 $35,172 $32,303 $104,387 

Office of Health Affairs $0 $12,212 $0 $12,212 

Departmental Management and 

Operations $5,428 $832 $1,515 $7,775 

Science and Technology $0 $0 $500 $500 

DHS TOTALS $7,705,875 $7,088,517 $8,021,324 $22,815,716 

Source: DHS FY 2014–16 Future Year Homeland Security Program Allocations. 

Strong unity of effort allows for effective decision making, identification of 

priorities, and successful execution of the homeland security mission. In 2014, 

former DHS Secretary Jeh Johnson wrote a memorandum on “unity of effort” to 

www.oig.dhs.gov	 OIG-18-07 

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encourage greater coordination among DHS components.1 In the same year, 

the Unity of Effort Initiative created the Joint Task Forces (JTF) by region and 

function to coordinate the Department’s resources and missions along the 

Southern Border. The purpose of the JTFs is to enhance DHS’ unity of effort in 

securing the Southern Border and maritime approaches. These task forces are 

relatively small operations within DHS that focus primarily on combating 

transnational criminal organizations as opposed to daily operations, like 

processing, transporting, and housing aliens. We recently provided a review2 on 

the operational status of DHS’ JTFs and plan to audit their progress in the 

near future. 

DHS allocated millions of dollars to its immigration efforts while generally 

committing to a more unified approach. The Department also continues to 

emphasize improving major stakeholder relationships. Increasing crosscomponent coordination and information sharing is critical to the Department’s 

overall success in addressing ongoing and emerging immigration challenges. 

Results of Audit 

ICE, CBP, and USCIS continue to experience challenges with emerging 

immigration enforcement and administration activities. Although DHS has 

established unity of effort initiatives to break silos and centralize decision 

making related to immigration, problems remain. 

We identified challenges related to mission allocation and expenditure 

comparisons, the affirmative asylum application process, and the Department’s 

struggle to understand immigration outcomes and decisions. We also identified 

component coordination difficulties pertaining to the availability of bed space, 

language services, and processing aliens. These problems existed because DHS 

did not have a designated responsible official or department-level group that 

strategically addressed overarching issues to foster coordination and 

resolution. 

Without a more unified approach to immigration that includes efficiency in 

management of resources, DHS will continue to allow vulnerabilities that may 

affect national security and public safety to persist. 

 1 Strengthening Departmental Unity of Effort Memorandum, April 22, 2014 

2 DHS’ Joint Task Forces (OIG-17-100, August 2017) 

www.oig.dhs.gov OIG-18-07 

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DHS Needs to Enhance Its Unified Approach with Immigration 

Enforcement and Administration to Combat Cross-component 

Challenges 

Although DHS has fostered unity of effort initiatives to break silos and 

centralize decision making, challenges still exist. For instance, Department and 

component offices are involved with immigration-related tasks; however, these 

groups do not always coordinate efforts to address strategic immigration 

activities. According to the 2010 Quadrennial Homeland Security Review 

(QHSR), successful immigration management requires a unified approach that 

employs shared policy and priorities, a common understanding and respect for 

stakeholder roles, as well as improved sharing of information and analysis. 

DHS does not have a department-level group that strategically addresses 

immigration challenges in order to foster better coordination and to resolve 

cross-cutting problems. 

Challenges related to the evaluation of immigration outcomes, the affirmative 

asylum application process, and cross-component coordination difficulties 

existed because no specific department-level group is responsible for 

addressing overarching component immigration challenges. In part, that is 

because the Homeland Security Act of 2002 (the “Act”) pushed the Department’s 

immigration enforcement and administration oversight authority into separate 

components within the Department, decentralizing immigration policy making 

and enforcement. Nothing in the Act would prohibit greater cross-component 

coordination and unity of effort with respect to immigration. We believe that 

would provide a stronger foundation to combat current, emerging, and future 

threats to the homeland with respect to risks related to immigration. 

The Department should provide reasonable assurance toward achieving its 

mission by ensuring discipline and structure for the organization, especially 

where immigration is concerned. The Department does not efficiently collect 

meaningful performance information to measure how well it is accomplishing 

its mission or where to make improvements. According to the Government 

Accountability Office’s Standards for Internal Control, the oversight body is 

responsible for overseeing the strategic direction of the entity and obligations 

related to the accountability of the entity. The Department should define the 

objectives in specific and measurable terms to enable management to identify, 

analyze, and respond to risks related to achieving those objectives. 

In the past, we identified the need for DHS to facilitate sharing and cooperative 

efforts among its components. In a 2007 report,3 we recommended that 

 3 DHS’ Progress In Addressing Coordination Challenges Between Customs and Border Protection 

and Immigration and Customs Enforcement (OIG-07-38, April 2007) 

www.oig.dhs.gov OIG-18-07 

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DHS create an Undersecretary for Policy that has authority over CBP and ICE 

with respect to policy and operational coordination. DHS had previously 

established the department-wide Office of Policy, Office of Operations 

Coordination, and the Office of Intelligence and Analysis, and charged the 

offices with using the tools of all components to address the Department’s 

homeland security mission. 

In the National Defense Authorization Act of 2017 (NDAA), Congress established 

an Office of Strategy, Policy, and Plans with an Under Secretary in order “to 

lead, conduct, and coordinate department-wide policy development”; develop 

“strategic plans”; and “promote quality and consistency” across components.4 

Although the NDAA was not an attempt to re-centralize immigration policy 

making and implementation in this new office, or to deprive the components of 

their spheres of responsibility under the Act, it is nevertheless evidence that 

Congress values greater unity of effort within the Department. 

Despite the previous Office of Inspector General (OIG) recommendations and 

efforts by the Department to promote a more coordinated approach for 

immigration, significant problems still remain. Ten years after our report, the 

Department’s Office of Immigration Policy still lacks the capability to provide 

immigration guidance to the Department because of limited support and 

authority. Additionally, the Homeland Security Act of 2002 decentralized 

immigration policy making and enforcement authority. Although the 

Department has made efforts to improve cohesiveness, we found areas of 

immigration policy and enforcement that could benefit from more strategic 

coordination. 

Evaluation of Mission Allocations 

DHS may not be able to determine whether its investment decisions provided 

the intended outcomes and mission success. The Department has not aligned 

its mission allocations to its actual expenses in order to improve immigration 

decision making and provide better outcomes. The Department began a 

planning, programming, budgeting, and execution (PPBE) cycle as a method to 

allocate resources among its components and programs. The PPBE is a 

framework for resource allocation decision making and for articulating program 

priorities. 

To test the PPBE, we attempted to test the Department’s Future Years 

Homeland Security Plan (FYHSP) allocation data to its expenses or obligations. 

This would allow us to evaluate the immigration enforcement and 

4 National Defense Authorization Act of 2017, § 1902, Public Law 114-328, 130 Stat. 2000, 

amending Homeland Security Act of 2002, by adding “Sec. 709. Office of Strategy, Policy, and 

Plans.”
 

www.oig.dhs.gov OIG-18-07
 

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administration mission allocations with expenditures to identify duplicative 

DHS projects, programs, and activities. We were unable to do this comparison 

because FYHSP Office of Policy allocates and plans by mission, but the budget 

office tracks resources by program project activity. The Office of Policy and the 

Office of Budget do not track the two data groups similarly. 

The Department’s budget office does not have the capability to track 

expenditures by mission. According to the DHS Office of Budget, once the 

common appropriation structure and new PPBE information technology 

solutions are in place,5 DHS will be in a better position to make these 

assessments. For now, DHS is limited to planning and programming by 

mission, with component-tracked execution. Without an evaluation between 

allocations and expenditures, DHS cannot identify budget disparities and 

inconsistencies between its components, appropriations, and programs to 

ensure taxpayer funds effectively accomplish the immigration enforcement and 

administration mission. 

DHS also needs improvement in evaluating immigration enforcement and 

administration outcomes. The Department has aligned its mission and goals 

with both the 2010 and 2014 QHSRs. Within the QHSR, the Department has 

developed a number of performance goals and objectives to ensure achievement 

of its immigration mission. The DHS Annual Performance Report identifies 

performance measures aligned with the QHSR’s goals and objectives. To assess 

the performance measures, DHS relies on components to complete annual selfassessments that review the progress of their own strategic goals. Strategic 

review teams involving component personnel completed these self-assessments, 

but the Department did not conduct independent reviews or provide feedback. 

Without the Department comprehensively evaluating its immigration mission, 

DHS has no assurance it is achieving its intended outcomes in the most 

efficient and effective manner, and may be duplicating efforts. 

Affirmative Asylum Backlog 

The Department identified asylum as a vulnerability, and in 2016, DHS 

implemented an asylum surge issue team that developed recommendations for 

addressing the causes of the growth in affirmative asylum claims from an interagency perspective. Affirmative Asylum refers to an alien physically in the 

United States who files an application for asylum within 1 year of the date of 

last arrival and not in removal proceedings. The issue team is an example of a 

unity of effort initiative as it involved collaboration from multiple components, 

including USCIS, ICE, and CBP. The issue team was to analytically understand 

the asylum seeker, identify resource implications, and improve the efficiency of 

 5 The common appropriation structure is a simplified, uniform structure across components 

that allows decision makers to compare like missions and activities over time. 

www.oig.dhs.gov OIG-18-07 

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OFFICE OF INSPECTOR GENERAL 

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asylum processing. Because of its efforts, the issue team arrived at a number of 

recommendations, including: 

x establishing an immigration coordination council by the end of 2016; 

x continuing analysis of asylum surge team policy options; 

x identifying and vetting ongoing and emerging challenges to immigration; 

and 

x standing up teams to explore, develop, and pilot policy and operational 

proposals. 

However, according to a DHS official, due to changes in administration, 

leadership did not review the results of this effort and failed to address the 

previously listed recommendations. 

Despite DHS reviewing the affirmative asylum surge and associated problems, 

the backlog has dramatically increased in size with no meaningful changes 

implemented. For example, we identified that the national backlog has more 

than quadrupled from 56,898 in 2014 to 254,128 in March of 2017. According 

to a USCIS official, it would take more than 5 years if 100 percent of his local 

staff were to address the backlog of 40,000 cases in his area of responsibility. 

Figure 1 illustrates the affirmative asylum backlog of cases at one location. 

Although USCIS has made a proposal for a vetting center in Atlanta that would 

offer some relief, these issues need a more unified and cross-component 

approach to reduce the risks. Moreover, these cases present a significant risk 

to national security and public safety when not vetting the applicants’ 

backgrounds. 

Figure 1: Affirmative Asylum Backlog in Anaheim, CA 

Source: USCIS 

www.oig.dhs.gov OIG-18-07 

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USCIS officials have identified fraud trends with the affirmative asylum 

backlog. Individuals may file for affirmative asylum, anticipating a prolonged 

waiting period, as a means of exploiting the application process to obtain an 

Employment Authorization Document (EAD) while cases are pending. There 

may be additional vulnerabilities exploited by procurement of an EAD, for 

example facilitating travel or applying for other subsidiary benefits (figure 2 

displays an EAD card.) 

Figure 2: Sample EAD card 

Source: USCIS

Cross-component Issues 

During our field visits, we identified examples of multiple component 

challenges that occur in the performance of the immigration enforcement and 

administration mission. Decisions made by one component negatively affected 

other components, which the Department could avoid with better coordination 

and a more unified approach. We identified issues related to bed space 

availability, custodial and transfer responsibility, language services, and the 

processing of aliens. Although components were able to overcome their 

situations, these issues highlight the need for better strategic guidance and 

oversight from the Department. 

Bed Space Availability 

Communicating bed space availability varied by location, which makes it 

difficult to manage apprehensions. CBP’s apprehensions require bed space at 

ICE’s Enforcement and Removal Operations (ERO) facilities. At one location, 

ICE ERO provided e-mail updates to CBP’s Border Patrol on the availability of 

bed space at its family residential facilities. Border Patrol officials at this 

location explained this practice was beneficial for minimizing the time subjects 

were in custody. At other locations we visited, updates were not readily 

available or provided, thereby making planning efforts more difficult. If bed 

space information were more readily available and transparent, CBP could 

www.oig.dhs.gov OIG-18-07 

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more efficiently manage the detention of apprehended aliens by minimizing the 

time detained in CBP’s custody. 

At locations we visited, the difference in hours worked contributed to issues 

with bed space availability. CBP is a 24-hour, 7-day-a-week operation, but ICE 

ERO normally does not work night or weekend shifts for processing aliens. As 

such, ICE ERO may not have staff available to process the aliens during certain 

times. At one location, during a period of increased CBP apprehension activity 

on a Friday, CBP attempted to contact ICE ERO for bed space. Because ICE 

ERO did not work weekend hours, there was no one available to transfer 

custody. As a result, CBP struggled to locate bed space options. 

Custodial and Transfer Responsibility 

CBP only holds individuals temporarily and relies on ICE to make a decision on 

whether to detain, release, or remove a person. At one location we visited, ICE 

ERO no longer accepted aliens with certain medical issues or unaccompanied 

children. In cases like these, CBP may incur costs for temporarily housing, 

transporting, and caring for aliens. In addition, medical practitioners must 

clear aliens medically before transferring custody. 

Language Services 

Decisions made by one component regarding language services could negatively 

affect other components. For example, USCIS contractors provided language 

interpretation and translation services to CBP and ICE during alien interviews. 

During FY 2016, USCIS informed ICE ERO that USCIS would curtail these 

services. At the locations visited, CBP and ICE were able to implement 

mitigating strategies, such as using internal staff. Nevertheless, USCIS’s 

decision to curtail this important service did not take into account the impact 

on its immigration partners. Although CBP and ICE implemented workarounds 

at the locations visited, the lack of interpretation and translation services may 

still negatively affect operations at other locations. 

Processing Aliens 

Lack of coordination in processing aliens creates potential vulnerabilities to 

national security and public safety, and leads to component inefficiencies. In 

June 2016, USCIS officials at one location informed ICE ERO they would no 

longer interview their non-detained population of pending credible fear and 

reasonable fear cases until further notice.6 As a result, ICE ERO converted 

 6 USCIS conducts credible and reasonable fear interviews on DHS-detained individuals to 

determine whether there is a possibility they would be subject to persecution or torture upon 

returning to their home country.

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1,983 cases pending an asylum hearing to Notices to Appear. According to an 

ICE ERO official, these individuals would have likely been removed and not 

released into communities had the asylum claims been adjudicated upon entry. 

Processing an alien also requires USCIS to schedule timely credible and 

reasonable fear interviews. USCIS conducts these interviews to establish the 

legitimacy of an individual’s claim of persecution or torture if returned to his or 

her home country. For detained aliens, ICE officials made detention decisions 

on facility relocation or release without informing USCIS. According to USCIS 

officials, this affected their ability to make timely case decisions. USCIS officials 

spent time and resources setting up interviews at facilities only to find out that 

ICE relocated the subjects without notice, rendering subjects unavailable for 

the scheduled interview. As a result, USCIS officials had to identify the new 

detention locations and reschedule interviews. 

Need for Overarching Oversight 

Issues related to the evaluation of immigration outcomes, the affirmative 

asylum application process, and cross-component coordination difficulties 

existed because no specific department-level group is responsible for 

addressing overarching component immigration challenges. 

Recent Efforts and Best Practices for More Unified Operations 

The Department’s Joint Requirements Council (JRC) efforts could serve as a 

template for addressing cross-component immigration enforcement and 

administration challenges. Former Secretary Johnson established the JRC to 

make informed investment recommendations that support a more operationally 

effective, unified, and efficient department. The JRC comprises senior level 

officials from the Department’s seven operational components and key 

headquarters organizations. The JRC develops recommendations for the 

Deputy’s Management Action Group, which is the Department’s basic decisionmaking body. The group addresses investment areas such as systems 

modernization and asset acquisitions. 

Conclusion 

After years of handling immigration and Department initiatives, components 

continue to operate independently to accomplish their respective immigration 

missions. Between FYs 2014 and 2016, DHS allocated $22.8 billion to 

accomplish the enforcement and administration of immigration laws — one of 

its strategic missions. ICE, CBP, and USCIS account for $21.7 billion (or 95 

percent) of all DHS resources allocated to immigration enforcement. Without a 

more unified approach to immigration, DHS will continue to face cross-cutting 

www.oig.dhs.gov OIG-18-07 

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component vulnerabilities and risks that may affect national security and 

public safety. If the Department identifies greater efficiencies in managing its 

immigration enforcement and administration resources, it could better address 

these deficiencies. 

Recommendation 

We recommend that the Secretary, Department of Homeland Security, 

establish and oversee a formal department-level group comprising senior level 

officials from the Department’s operational components and key headquarters 

organizations responsible for enforcement and administration of immigration 

laws. The responsible officials will facilitate long-term solutions to overarching 

and cross-cutting component immigration enforcement and administration 

challenges. The Department should research and follow similar successful 

structures from other Federal agencies to guide this endeavor. At a minimum, 

the designated responsible officials will — 

a.	 foster better awareness of roles and responsibilities; 

b. facilitate better coordination and communication among the involved 

components and guide current cross-component immigration initiatives; 

c.	 ensure components collect and report data for immigration activity and 

analyze the information to make decisions and reduce inefficiencies; and 

d. serve as mediators for conflicts regarding mission accomplishment and 

overarching legal, policy, and other issues. 

www.oig.dhs.gov	 OIG-18-07 

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DHS Comments and OIG Analysis 

The Department concurred with our recommendation and provided comments 

to the draft report. A summary of DHS’ management comments and our 

analysis follows. We have included a copy of these comments in their entirety 

in appendix B. DHS also provided technical comments, which we incorporated 

as appropriate. 

DHS: DHS concurred. According to the Department, the DHS Office of Strategy, 

Policy, and Plans will seek to charter a senior level cross-component 

Immigration Policy Council. This Council will provide an institutionalized 

structure for department-wide strategic planning related to immigration policy 

and operations. At a minimum, the Council will comprise representatives from 

the Office of Strategy, Policy, and Plans; USCIS; ICE; CBP; the Office of Civil 

Rights and Civil Liberties; and the Office of General Council; with ad hoc 

representation from other components, as needed. It will also provide a forum 

to address and clarify immigration policies, strategies, and processes. 

The Council will serve as a mechanism for developing creative solutions to fully 

integrate immigration policy into department-wide planning. Most importantly, 

it will establish a forum to communicate, collaborate, and implement 

Secretarial policy priorities while incorporating component feedback, policy 

priorities, and needs. Fundamentally, the Council will allow component and 

headquarters representatives to continually engage at both the leadership and 

staff levels to ensure successful implementation of the Secretary's priorities. 

This will help the representatives share best practices and analyze crosscomponent immigration policy, strategy, procedure, and operations. 

The Council will identify common interests and needs of the components 

engaged in fulfilling DHS's mission to enforce and administer our immigration 

laws. Further, the Council will promote consistent use of immigration 

terminology and standard data collection and tracking across the Department. 

The estimated completion date is March 31, 2018. 

OIG Analysis: The actions DHS proposed should meet the intent of the 

recommendation, which is considered resolved and open until we have 

reviewed documentation confirming that the Council is fully operational and a 

plan has been developed and implemented to ensure department-wide strategic 

planning related to immigration policy and operations. Actions should also 

focus on addressing duplicative efforts through the coordination efforts. 

www.oig.dhs.gov OIG-18-07 

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Appendix A 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Public Law 107−296) by 

amendment to the Inspector General Act of 1978. 

Our audit objective was to determine whether DHS fosters collaboration and 

unity of effort department-wide to enforce and administer immigration policy. 

The scope of our audit focused on fiscal years 2014–16. 

To answer our objective, we interviewed headquarters officials from the 

Department to gain a better understanding on how immigration enforcement 

and administration efforts are coordinated. At DHS Headquarters, we met with 

officials from the Joint Task Force — Investigations; Office of Chief Financial 

Officer; Office of Policy; Joint Requirements Council; Office of Intelligence and 

Analysis; and the Office of Operations Coordination. 

We reviewed DHS available policies, organizational charts, strategic plans, 

Department studies, quadrennial homeland security reviews, fiscal year 

homeland security program allocations, budget justification reviews, and 

annual performance reports. We attempted to conduct a comparative analysis 

of agency allocations and expenditures by mission, but this information was 

not available at the time of our audit. 

We met with officials from U.S. Customs and Border Protection (CBP), U.S. 

Immigration and Customs Enforcement (ICE), and U.S. Citizenship and 

Immigration Services (USCIS), at both Headquarters and in the field. 

Specifically, in the field, we interviewed officials from the following groups: 

 CBP Office of Border Patrol, 

 CBP Office of Field Operations, 

 USCIS Refugee Asylum and International Operations, 

 USCIS Office of Policy, 

 ICE Enforcement and Removal Operations, and 

 ICE Homeland Security Investigations. 

We conducted site visits to the following CBP, ICE, and USCIS locations: 

McAllen, Houston, El Paso, TX; and Los Angeles and San Diego, CA. We chose 

these locations because of the high volume of immigration activity, and they 

were centrally located for the multiple DHS components involved with 

immigration enforcement and administration. 

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In gathering information from the respective field offices, we attempted to 

quantify the extent of the crosscutting issues identified in the report. However, 

data was not always available or tracked by the components. 

We conducted this performance audit between October 2016 and May 2017 

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

generally accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based upon our 

audit objectives. We believe that the evidence obtained provides a reasonable 

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

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Appendix B 

DHS’ Comments to the Draft Report 

. 

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Appendix C 

Office of Audits Major Contributors to This Report 

Patrick O’Malley, Director 

Brad Mosher, Audit Manager 

Ignacio Yanes, Audit Manager 

Denis Foley, Program Analyst 

Andrew Herman, Auditor 

Jon King, Auditor 

Michael Levy, Auditor 

Kevin Dolloson, Communications Analyst 

Jennifer Eads, Independent Referencer

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Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov OIG-18-07 

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Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

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

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

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

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305