STUDENT AND 

EXCHANGE VISITOR 

PROGRAM

DHS Needs to Assess 

Risks and Strengthen 

Oversight Functions 

Report to Congressional Requesters

June 2012

GAO-12-572

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-572, a report to 

congressional requesters 

June 2012 

STUDENT AND EXCHANGE VISITOR PROGRAM

DHS Needs to Assess Risks and Strengthen

Oversight Functions

Why GAO Did This Study

As of January 2012, more than 

850,000 active foreign students were in 

the United States enrolled at over 

10,000 U.S. schools. ICE, within DHS, 

is responsible for managing SEVP and

certifying schools to accept foreign 

students. GAO was asked to review 

ICE’s fraud prevention and detection 

procedures for SEVP. This report 

examines the extent to which ICE has 

(1) identified and assessed risks in 

SEVP and (2) developed and 

implemented policies and procedures 

to prevent and detect fraud during the 

initial school certification process and 

once schools begin accepting foreign 

students. GAO analyzed documents, 

such as ICE’s SEVP procedures, and 

tested recordkeeping controls by 

selecting a random sample of 50 

SEVP-certified schools and reviewing

case files. GAO interviewed officials 

from SEVP, CTCEU, and 8 of 26 ICE 

field offices, selected based on a mix 

of factors, including school fraud 

investigations and referrals from 

CTCEU. While the results of the case 

file reviews and interviews cannot be 

generalized, they provided insights 

about SEVP. 

What GAO Recommends

GAO recommends that ICE, among 

other things, identify and assess 

program risks; consistently implement 

procedures for ensuring schools’ 

eligibility; address missing school case 

files; and establish target time frames 

for notifying flight schools that lack 

required FAA certification that they 

must re-obtain FAA certification. DHS 

concurred with the recommendations. 

What GAO Found

U.S. Immigration and Customs Enforcement (ICE) has not developed a process 

to identify and analyze program risks since assuming responsibility for the 

Student and Exchange Visitor Program (SEVP) in 2003, in accordance with 

internal controls standards and risk management guidance. Within ICE, officials 

from SEVP and the Counterterrorism and Criminal Exploitation Unit (CTCEU), 

which tracks, coordinates, and oversees school fraud investigations, have 

expressed concerns about the fraud risks posed by schools that do not comply 

with requirements. Investigators said that identifying and assessing risk factors, 

such as the type of school, are critical to addressing potential vulnerabilities

posed across the more than 10,000 SEVP-certified schools. However, SEVP

does not have processes to (1) evaluate prior and suspected cases of school 

noncompliance and fraud and (2) obtain and assess information from CTCEU 

and ICE field offices on school investigations and outreach events. For example, 

ICE reported that it has withdrawn at least 88 schools since 2003 for noncompliance; however, ICE has not evaluated schools’ withdrawals to determine 

potential trends from their noncompliant actions because case information is not 

well-organized, according to SEVP officials. Without a process to analyze risks, it 

will be difficult for ICE to provide reasonable assurance that it is addressing highrisk vulnerabilities and minimizing noncompliance. 

ICE has not consistently implemented existing controls, in accordance with 

internal control standards and fraud prevention practices, to verify schools’ 

legitimacy and eligibility during initial SEVP certification and once schools begin 

accepting foreign students. Specifically, ICE officials do not consistently verify 

certain evidence initially submitted by schools in lieu of accreditation. In addition, 

ICE does not maintain records to document SEVP-certified schools’ ongoing 

compliance. GAO found that 30 of a randomly-selected sample of 48 SEVPcertified school case files lacked at least one piece of required evidence, such as 

proof of school officials’ citizenship or permanent residency. ICE was unable to 

produce 2 of the 50 case files. ICE officials noted that some files were missing 

because they were lost or destroyed when the Department of Homeland Security

(DHS) took over the program from the former Immigration and Naturalization 

Service; moreover, ICE officials cannot quantify how many files are missing. 

Without verification of evidence and complete case files, ICE cannot provide

reasonable assurance that schools were initially and continue to be eligible for 

certification. Further, ICE policies require that SEVP-certified flight schools 

offering flight training have specific Federal Aviation Administration (FAA) 

certifications; however, GAO found that approximately 167 of 434 (or 38 percent) 

SEVP-certified flight schools do not have the required certifications as of 

December 2011. The Border Security Act required recertification for all SEVPcertified schools by May 2004 and every 2 years thereafter to monitor schools’

continued program eligibility. SEVP officials stated that they rely on recertification 

to verify schools’ eligibility; however, SEVP began the first recertification cycle in 

May 2010 and, as of March 2012, has recertified 1,870 (or 19 percent) of certified 

schools. Implementing procedures to monitor state licensing and accreditation 

status for all types of schools and addressing flight schools that lack required 

FAA certification could better position ICE to reduce the risk of fraud and 

noncompliance. 

View GAO-12-572. For more information, 

contact Rebecca Gambler at (202) 512-6912 

or gamblerr@gao.gov. 
Page i GAO-12-572 Student and Exchange Visitor Program

Letter 1 

Background 5

Identifying and Assessing Risks to SEVP Could Strengthen ICE’s 

Management of the Program 10

Weaknesses in ICE’s Monitoring and Oversight of SEVP-Certified 

Schools Contribute to Security and Fraud Vulnerabilities 21

Conclusions 37

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 38

Appendix I Scope and Methodology 41

Appendix II Comments from the Department of Homeland Security 46

Appendix III GAO Contact and Staff Acknowledgments 49

Table

Table 1: ICE’s Budget Authority, Obligations, and Fee Collections 

for SEVP, Fiscal Years 2006 through 2012 19

Figures

Figure 1: Total Academic (F) and Vocational (M) Visas Issued by 

the Department of State, Fiscal Years 2005 through 2011 6

Figure 2: Key Steps in SEVP’s Initial and Recertification Processes 9

Figure 3: ICE’s Recertification Milestones 26

Contents
Page ii GAO-12-572 Student and Exchange Visitor Program

Abbreviations 

CTCEU Counterterrorism and Criminal Exploitation Unit 

DHS Department of Homeland Security 

FAA Federal Aviation Administration

ICE U.S. Immigration and Customs Enforcement 

INS Immigration and Naturalization Service

SEVIS Student and Exchange Visitor Information System

SEVP Student and Exchange Visitor Program

TECS Treasury Enforcement Communication System

USCIS U.S. Citizenship and Immigration Services

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-572 Student and Exchange Visitor Program

United States Government Accountability Office

Washington, DC 20548

June 18, 2012

Congressional Requesters

As of January 2012, more than 850,000 active foreign students in the 

United States were enrolled at over 10,000 schools.1 We have previously 

reported that terrorist attacks in the United States have pointed to the 

need for close monitoring and oversight of foreign students.2 For 

example, one of the September 11, 2001, terrorists entered the country 

on a student visa, and subsequently attended flight schools. Two of the 

September 11, 2001, terrorists received visas for temporary visits to the 

United States for business or pleasure, and, after entering the country, 

illegally attended flight schools.3 In addition, as we reported in April 2011, 

schools have sometimes attempted to exploit the immigration system by 

knowingly reporting that foreign students were fulfilling their visa 

requirements, such as maintaining a full course load, when they were not 

attending school or attending intermittently.4

U.S. Immigration and Customs Enforcement (ICE), within the Department 

of Homeland Security (DHS), is responsible for managing the Student 

and Exchange Visitor Program (SEVP), which was created in conjunction 

with DHS’s formation on March 1, 2003.5

 

1

The Department of Homeland Security reports that the five countries with the highest 

number of active foreign students are China, South Korea, India, Saudi Arabia, and 

Canada. These countries account for more than 50 percent of the total number of active 

foreign students in the country. Of active foreign students, 70 percent are enrolled in 

bachelor’s, master’s, or doctoral post-secondary programs.

Under this program, ICE is 

responsible for ensuring that foreign students studying in the United 

2

GAO, Overstay Enforcement: Additional Mechanisms for Collecting, Assessing, and 

Sharing Data Could Strengthen DHS’s Efforts but Would Have Costs, GAO-11-411 

(Washington, D.C.: Apr. 15, 2011).

3

Temporary visitors to the United States generally are referred to as “nonimmigrants.” The 

United States also issues visas to people who intend to immigrate to the United States. In 

this report, we use the term “visa” to refer to nonimmigrant visas only. For a listing and 

descriptions of nonimmigrant categories, see 8 U.S.C. § 1101(a)(15); see also 8 C.F.R. § 

214.1(a)(1)-(2). 

4

GAO-11-411. 

5

The former Immigration and Naturalization Service was previously responsible for 

monitoring foreign students in the United States and the schools that accept them.

 
 

Page 2 GAO-12-572 Student and Exchange Visitor Program

States comply with the terms of their admission into the country. 

Specifically, ICE certifies schools as authorized to accept foreign students 

in academic and vocational programs. In addition, ICE manages the 

Student and Exchange Visitor Information System (SEVIS), which assists 

the agency in tracking and monitoring certified schools, as well as 

students—while they are approved to participate in U.S. educational 

institutions—and their dependents.6 Designated school officials are 

responsible for monitoring students and entering and maintaining 

students’ information in SEVIS, such as information on their courses of 

study.7

 SEVP-certified schools span all education levels from 

kindergarten to secondary education, as well as post-secondary 

academic, vocational, English language, and flight schools.8

You asked us to review ICE’s fraud prevention and detection procedures, 

including whether it uses risk factors to inform its efforts to monitor SEVPcertified schools. This report examines the extent to which ICE has (1) 

identified and assessed risks in SEVP, and (2) developed and 

implemented policies and procedures to prevent and detect fraud during 

the initial school certification process and once schools begin accepting 

foreign students.

 SEVP’s 

fiscal year 2012 enacted budget authority is $120 million, and, as of 

December 2011, the program includes authorized staff of 151 full-time 

government employees and approximately 600 full- and part-time 

contractors.

 

6

The Illegal Immigration Reform and Immigrant Responsibility Act of 1996, as amended, 

requires a program to collect information for tracking and monitoring foreign students from 

approved institutions of higher education, other approved educational institutions, and 

designated exchange visitor programs in the United States. See 8 U.S.C. § 1372. The 

statute, as amended by the Enhanced Border Security and Visa Entry Reform Act of 2002 

(Border Security Act), requires that an electronic means be established to monitor and 

verify the acceptance of foreign students by schools and that schools inform DHS of 

foreign students who fail to enroll within 30 days after the end of a school’s enrollment 

period. See Pub. L. No. 107-173, § 501(a)(1), 116 Stat. 543, 560-61 (codified at 8 U.S.C. 

§ 1372(a)(3)-(4)). 

7

A designated school official is a regularly-employed member of the school administration 

whose office is located at the school and whose compensation does not come from 

commissions for recruitment of foreign students. The designated school official is required 

to be familiar with the regulations governing nonimmigrant students and school 

certification (8 C.F.R. § 214.3(l)).

8

Vocational schools are community colleges, junior or 2-year institutions, high schools, 

and other types of schools that provide vocational or technical training, usually leading to 

a job rather than a bachelor’s degree.
 

Page 3 GAO-12-572 Student and Exchange Visitor Program

To evaluate the extent to which ICE has identified and assessed risks in 

SEVP, we analyzed documentation on ICE’s efforts to evaluate SEVP 

risk, including a current contract to develop a risk management approach. 

We also analyzed ICE news bulletins to help determine the magnitude of 

previous cases of fraud and evaluated information provided by the 

Counterterrorism and Criminal Exploitation Unit (CTCEU)—ICE’s 

investigative component responsible for investigating school fraud cases, 

among other things—on criminal investigations related to school 

certification fraud. We reviewed publicly available information on 12 cases 

of school fraud dating from 2006 to 2011, which allowed us to better 

understand SEVP program risks. Because we selected a 

nongeneralizable sample of 12 cases to review, the information obtained 

from them is not necessarily representative of all school fraud cases 

nationwide. We also compared ICE’s risk management practices for 

SEVP against Standards for Internal Control in the Federal Government9

and DHS’s Policy for Integrated Risk Management.

10

To address both objectives, we interviewed officials from each of SEVP’s 

seven branches

To determine the 

extent to which ICE has developed and implemented policies and 

procedures to prevent and detect school fraud, we reviewed standard 

operating procedures and tested internal controls designed to ensure 

school oversight. To test SEVP’s internal controls, we selected a 

nongeneralizable, stratified random sample of 50 SEVP-certified schools 

and reviewed their case files to verify that evidence required for 

certification existed, such as designated school officials’ proof of 

citizenship or lawful permanent residency. The results of our case file 

review provided us with insights into SEVP’s internal controls and case 

management practices. Further, we reviewed SEVP’s compliance case 

log, as of December 2011, which identifies specific SEVP-certified 

schools that are under additional review for suspected non-compliant 

activity, to identify common school attributes such as type of school.

11

 

9

GAO, Standards for Internal Control in the Federal Government, 

and criminal investigators from CTCEU, as well as 

GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999).

10Department of Homeland Security, DHS Policy for Integrated Risk Management

(Washington, D.C.: May 27, 2010).

11SEVP has seven branches: School Certification, Response, Policy, Analysis and 

Operations Center, Field Representative Program, Mission Support, and Information 

Technology. 
 

Page 4 GAO-12-572 Student and Exchange Visitor Program

eight ICE field offices, which allowed us to obtain their perspective on the 

magnitude and risks associated with school fraud.12 We selected these 

locations based on their experience in investigating previous and/or 

ongoing cases of school fraud. Although the results from these interviews 

cannot be generalized to officials at all 26 ICE field offices, they provided 

us with useful insights into lessons learned from fraud cases. Additionally, 

we compared ICE’s risk management and fraud prevention and detection 

practices to the Standards for Internal Control in the Federal 

Government13 and the United Kingdom National Audit Office’s Good 

Practice in Tackling External Fraud.

14 Our review encompassed ICE’s 

management of SEVP since 2003, when the agency assumed 

responsibility for managing the program. Our scope did not include the 

Exchange Visitor Program, a separate program administered by the 

Department of State.15

We conducted this performance audit from September 2011 through June

2012 in accordance with 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 on our audit objectives. We believe 

Appendix I presents more details about our 

objectives, scope, and methodology.

 

12We interviewed officials from ICE field offices in Atlanta, Ga; Dallas, Tex; Miami, Fla; 

New York, N.Y.; Washington, D.C.; and Los Angeles, San Diego, and San Francisco, 

Calif.

13GAO/AIMD-00-21.3.1. 

14U.K. National Audit Office, Good Practice in Tackling External Fraud (London, England: 

2008). This guidance on fraud control practices was prepared by the U.K.’s National Audit 

Office, which is among the internationally recognized, leading organizations in fraud 

control. This guidance includes a discussion of sound management practices for 

controlling fraud that complements the internal control standards. See GAO, Immigration 

Benefits: Additional Controls and a Sanctions Strategy Could Enhance DHS’s Ability to 

Control Benefit Fraud, GAO-06-259 (Washington, D.C.: Mar. 10, 2006). 

15The Exchange Visitor Program allows nonimmigrants to travel to the United States on a 

J visa to teach, study, conduct research, and receive on-the-job training. Such 

nonimmigrants are monitored by program sponsors, including employers, cultural 

exchange organizations, professional associations, and government agencies. We did not 

evaluate this program because it is a separate process administered by the Department of 

State, and our focus was on DHS’s oversight of schools that enroll foreign students. For 

more information on the Exchange Visitor Program, see GAO, State Department: Stronger 

Action Needed to Improve Oversight and Assess Risks of the Summer Work Travel and 

Trainee Categories of the Exchange Visitor Program, GAO-06-106 (Washington, D.C.: 

Oct.14, 2005). 
 

Page 5 GAO-12-572 Student and Exchange Visitor Program

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Foreign students interested in studying in the United States must first be 

admitted to a school or university before applying for a visa at a U.S. 

embassy or consulate overseas.16 The process for determining who will 

be issued or refused a visa, including F and M visas, contains several 

steps, including documentation reviews, in-person interviews, collection of 

applicants’ fingerprints, and cross-references against State’s name-check 

database.17 F visas are for academic study at 2- and 4-year colleges and 

universities and other academic institutions.18 M visas are for 

nonacademic study at institutions, such as vocational and technical 

schools.19

 

16According to the Department of State’s regulations, a student visa applicant must meet 

the following requirements to qualify: (1) acceptance at an approved school; (2) 

possession of sufficient funds; (3) sufficient knowledge of the English language to 

undertake the chosen course of study or training (unless coming to participate exclusively 

in an English language training program); and, (4) present intent to leave the United 

States at conclusion of studies. See 22. C.F.R. § 41.61(b)(1). According to the 

Department of State guidance for consular officers, if an applicant fails to meet one or 

more of the above criteria, he or she must be refused a visa under section 214(b) of the 

Immigration and Nationality Act (8 U.S.C. § 1184(b)). If consular officers have reason to 

believe that a visa applicant engaged in fraud or misrepresentation to garner acceptance 

into a school, then consular officers are instructed to consider this as an important factor 

in determining if the applicant has a bona fide intent to engage in study in the United 

States. If consular officers have reason to question the authenticity of a school, they are 

instructed to contact SEVP and the fraud prevention office in the Bureau of Consular 

Affairs. 

An increasing number of foreign students have applied for 

visas to attend school in the United States since fiscal year 2005. 

Specifically, the Department of State issued approximately 244,000 F and 

M visas in fiscal year 2005 and approximately 457,000 in fiscal year 2011 

(see figure 1).

17We have previously reported on visa process issues. For example, see GAO, Border 

Security: Strengthened Visa Process Would Benefit from Improvements in Staffing and 

Information Sharing, GAO-05-859 (Washington, D.C.: Sept. 13, 2005). 

188 U.S.C. § 1101(a)(15)(F); 8 C.F.R. § 214.2(f).

198 U.S.C. § 1101(a)(15)(M); 8 C.F.R. § 214.2(m).

Background
 

Page 6 GAO-12-572 Student and Exchange Visitor Program

Figure 1: Total Academic (F) and Vocational (M) Visas Issued by the Department of 

State, Fiscal Years 2005 through 2011

Note: Data include initial issuances and any renewals per fiscal year. 

A visa allows a foreign citizen to travel to a U.S. port of entry and request 

permission from an officer with DHS’s Customs and Border Protection to 

enter the United States; it does not guarantee entry into the country. 

Among other things, foreign students remain “in status” and therefore 

eligible to remain in the United States as students as long as they are 

enrolled in a school certified by SEVP. Individuals traveling on student 

visas generally are not issued a specific date until which they are 

authorized to remain in the United States, but instead are admitted for 

what is referred to as “duration of status.” This means that they may 

remain in the country as long as they maintain their student status (e.g., 
 

Page 7 GAO-12-572 Student and Exchange Visitor Program

by being enrolled in an academic or work-study program).20 Some 

nonimmigrants enter the country on a non-student visa and subsequently 

apply to U.S. Citizenship and Immigration Services for a change in status 

to a student visa. In general, if students fail to maintain their student 

status or to depart on time, they are considered out of status and begin to 

accrue unlawful presence either on the day after U.S. Citizenship and 

Immigration Services or an immigration judge determines that they are 

out of status or on the day after their authorized period of admission 

expires.21

Schools interested in accepting foreign students on F and M visas must 

petition for SEVP certification by submitting a Form I-17 to ICE and 

paying an application fee. Once certified, schools are able to accept 

foreign students by issuing Forms I-20 for students, which enable the 

students to apply for nonimmigrant student status. As of March 2012, 

students applying for F or M visas were required to pay a $140 fee to the 

Department of State for visa processing and a $200 fee to DHS for 

SEVIS, and schools applying for initial certification were required to pay 

DHS $1,700, as well as a $655 site visit fee per campus.22 The Border 

Security Act requires DHS to confirm, every 2 years, SEVP-certified 

schools’ continued eligibility and compliance with the program’s 

requirements.23

 

20Students traveling on M visas (students in vocational or other nonacademic institutions) 

generally are admitted for a fixed time period, although extensions are possible. See 8 

C.F.R. § 214.2(m)(5), (10).

During the initial petition and recertification processes, a 

school must provide ICE with evidence of its legitimacy and its eligibility. 

Such evidence includes the following:

21They are subject to 3- to10-year bars on their readmission to the country, respectively, if 

they accrue more than 180 days or 1 year of unlawful presence. See 8 U.S.C. § 

1182(a)(9)(B). 

22SEVP and the program’s management of SEVIS are funded solely with the fees it 

collects from foreign students as well as schools applying for certification. When the Illegal 

Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) first required the 

establishment of SEVIS, it required that schools collect the SEVIS fee. See Pub. L. No. 

104-208, div. C, § 641(e), 110 Stat. 3009-546, 3009-706. The Visa Waiver Permanent 

Program Act amended IIRIRA to require that the government collect the fee. See Pub. L. 

No. 106-396, § 404(1), 114 Stat. 1637, 1649 (2000).

238 U.S.C. § 1762.
 

Page 8 GAO-12-572 Student and Exchange Visitor Program

• designated school officials’ attestation statements that both the school 

and officials intend to comply with program rules and regulations, 

such as ensuring that students attend classes, and that the school is 

eligible for certification. The attestations provide that willful 

misstatements constitute perjury;

• designated school officials’ proof of U.S. citizenship or lawful 

permanent residency; and

• proof of licensing by an appropriate state-level licensing or approving 

agency.

In addition, accredited schools must provide proof of certification by an 

accrediting agency recognized by the Department of Education.

24

• a school catalog or written statement including information on the 

school’s facilities and faculty;

Unaccredited schools must provide other evidence, including:

• for unaccredited schools seeking to enroll F visa students, “in lieu of” 

letters from three accredited institutions stating that graduates or 

credits of the petitioning school are unconditionally accepted at the 

accredited institution;

• for unaccredited schools seeking to enroll M visas students, “in lieu of” 

letters from three employers stating that graduates of the petitioning 

school are fully qualified in the field of training provided by the 

petitioning school; and

• for schools offering flight training, Federal Aviation Administration 

(FAA) certificates.

Following a school’s petition and receipt of supporting evidence, ICE uses 

contracted firms to conduct a site visit to the school, including each 

instructional site foreign students attend, to interview school officials and 

review the facilities. In particular, site inspectors review whether schools’ 

facilities are commensurate with the number of students and type of 

academic programs. After receiving all necessary evidence and a site 

visit report from the contracted firm, ICE staff in the SEVP School 

 

24The goal of accreditation is to ensure that education provided by institutions of higher 

education meets acceptable levels of quality. Accrediting agencies, which are private 

educational associations of regional or national scope, develop evaluation criteria and 

conduct peer evaluations to assess whether or not those criteria are met. Institutions 

and/or programs that request an agency’s evaluation and that meet an agency’s criteria 

are then “accredited” by that agency. There are more than 70 accrediting bodies 

recognized by the Department of Education, including the Accrediting Council for 

Continuing Education and Training, and the Accrediting Commission of Career Schools 

and Colleges.
 

Page 9 GAO-12-572 Student and Exchange Visitor Program

Certification Branch analyze the documentation, determine the school’s 

eligibility, and certify those schools that they determine meet all of the 

program’s requirements. According to the School Certification Branch 

Chief, the initial certification process takes at least 4 months. During the 

recertification process, the School Certification Branch requires schools to 

resubmit evidence for certification and evaluates schools’ compliance with 

recordkeeping and reporting on its enrolled foreign students. Figure 2 

illustrates the initial certification and recertification processes that are 

described in SEVP’s regulations, policy, and guidance.

Figure 2: Key Steps in SEVP’s Initial and Recertification Processes

ICE’s SEVP Analysis and Operations Center (compliance unit) may 

conduct out-of-cycle, compliance reviews of certified schools at its 
 

Page 10 GAO-12-572 Student and Exchange Visitor Program

discretion. The compliance unit may decide to conduct a compliance 

review if it has evidence that indicates a school may no longer be 

legitimate or eligible. As part of these reviews, SEVP staff may conduct 

unannounced site visits to schools. Based on the results of compliance 

reviews, some schools may be withdrawn from the program or referred to 

CTCEU for possible criminal investigation.25

CTCEU tracks, coordinates, and oversees criminal investigations related 

to potential cases of student and school certification fraud. In that role, 

CTCEU identifies both foreign students who fail to enroll in or maintain 

status at their schools and SEVP-certified schools that do not remain in 

compliance with program requirements. For example, CTCEU takes the 

lead in pursuing criminal investigations against school officials that may 

have exploited the system by operating “sham” institutions, which are 

operating solely to admit foreign nationals into the country without 

participation in educational programs. CTCEU refers leads to ICE field 

offices for further review and investigation, and these offices also open 

their own investigations based on local leads. CTCEU also conducts 

outreach to schools through its Campus Sentinel program which aims to 

foster relationships between ICE law enforcement officials and schools 

through on-site visits and information sessions at national and regional 

conferences.

ICE does not have a process to identify and analyze risks across schools 

applying for certification, as well as across the more than 10,000 schools 

that are SEVP-certified. Specifically, SEVP faces two key challenges in 

(1) evaluating information on prior and suspected cases of school

noncompliance and fraud, and (2) obtaining and assessing information 

from CTCEU and ICE field offices’ investigations and school outreach 

events to identify possible trends and lessons learned. In addition, ICE 

has not conducted an analysis to assess how to allocate resources based 

on risk to help ensure that SEVP resources are targeted to the highestrisk program activities. ICE has taken initial actions to study the potential 

 

25Withdrawing a school’s certification is the final action in the compliance process. SEVP 

notifies schools of withdrawal decisions through a letter and schools have an opportunity 

to appeal these decisions. If SEVP denies the appeal, the program disseminates an 

official notification of certification withdrawal to the school. SEVP requires students who 

are enrolled at a school that is withdrawn from the program to transfer to another SEVPcertified school to maintain their student visa status. 

Identifying and 

Assessing Risks to 

SEVP Could 

Strengthen ICE’s 

Management of the 

Program 
 

Page 11 GAO-12-572 Student and Exchange Visitor Program

risks posed by schools that are not in compliance with requirements, but it 

is too early to evaluate the results of these actions.

ICE has not developed and implemented a process to identify and 

analyze program risks since assuming responsibility for SEVP in 2003, 

making it difficult for ICE to determine the potential security and fraud 

risks across the more than 10,000 SEVP-certified schools and to identify 

actions that could help mitigate these risks and reduce schools’ 

noncompliance. SEVP and CTCEU officials expressed concerns about 

the security and fraud risks posed by schools that do not comply with 

program requirements. For example, investigators at CTCEU and each of 

the eight ICE field offices we interviewed told us that they are concerned 

about the cases of school certification fraud they have seen. They stated 

that identifying and assessing risk factors, such as the type of school 

(accredited or unaccredited), is critical to addressing security 

vulnerabilities and removing opportunities for criminal exploitation within 

SEVP. In 2011, CTCEU began tracking data on school fraud using 

increased resources funded with SEVP’s fee collections. For example, 

CTCEU focused more attention on fraud detection through its SEVIS 

Exploitation Unit, established in September 2011, which analyzes SEVIS 

data to identify potentially fraudulent activity among schools and allows 

CTCEU to generate additional leads on school fraud or noncompliance. In 

its Fiscal Year 2013 Congressional Budget Justification, DHS reported 

that during fiscal year 2011, CTCEU analyzed 48 percent more leads on 

potential school and student visa fraud than in fiscal year 2010. In 

addition, various cases of school fraud have demonstrated vulnerabilities 

in the management and oversight of SEVP-certified schools. For 

example:

• In the case of California Union University, foreign students stated they 

paid the school owner fees ranging from $600 to more than $10,000 

for documentation enabling the students to fraudulently obtain visas 

and, in some cases, bogus degrees, despite the fact that they never 

attended class. In the case affidavit, one student who purportedly 

received his bachelor’s degree in education from California Union 

University recounted how the school owner staged a graduation 

ceremony at the campus where students received their phony 

diplomas.

• In the case of Florida Language Institute, foreign nationals who had 

been issued Forms I-20—a key document required in obtaining a 

student visa—were not required to attend classes. When ICE officials 

conducted a site visit at the Institute while the school was supposed to 

ICE Does Not Have a 

Process to Identify and 

Assess Risks Posed by 

Schools in SEVP
 

Page 12 GAO-12-572 Student and Exchange Visitor Program

be conducting classes, no students were present. The school had 

reported to ICE that 150 students attended class daily.

• In other instances, school officials have run criminal enterprises that 

are tied to illegitimate schools. For example, in the Tri-Valley 

University case in California, the owner was indicted for issuing 

fraudulent Forms I-20, which falsely certified that its students were 

required to attend a full course of study. Investigators believe school 

officials were intentionally maintaining false information in SEVIS in an 

effort to acquire and maintain immigration status for students that 

were actually ineligible for that status.

ICE could benefit from a process that identifies and analyzes risks 

because previous investigations of school fraud indicate that there are 

vulnerabilities within the program. Moreover, given that there are more 

than 10,000 SEVP-certified schools, identifying and assessing 

programwide risks could help ICE target its operations to those program 

areas that are of highest risk. Standards for Internal Control in the Federal 

Government provides guidance on the importance of identifying and 

analyzing risks, and using that information to make decisions.26

SEVP faces two primary challenges to identifying and assessing risks 

posed by schools: (1) it does not evaluate program data on prior and 

suspected instances of school fraud and noncompliance and (2) it does 

not obtain and assess information from CTCEU and ICE field office 

school investigations and outreach events. Information from these 

These

standards address various aspects of internal control that should be 

continuous, built-in components of organizational operations. One internal 

control standard, risk assessment, calls for identifying and analyzing risks 

that agencies face from internal and external sources and deciding what 

actions should be taken to manage these risks. The standards indicate 

that conditions governing risk continually change and periodic updates 

are required to ensure that risk information, such as vulnerabilities in the 

program, remains current and relevant. Information collected through 

periodic reviews, as well as daily operations, can inform the analysis and 

assessment of risk. Furthermore, DHS’s Policy for Integrated Risk 

Management states that DHS and its component agencies should use a 

risk-based approach when managing programs that includes, among 

other things, identifying potential risks; assessing and analyzing identified 

risks; and using risk information and analysis to inform decision making.

 

26GAO/AIMD-00-21.3.1. 
 

Page 13 GAO-12-572 Student and Exchange Visitor Program

sources could help ICE identify trends and lessons learned from prior and 

ongoing cases and outreach events, providing it with factors it could 

consider in identifying and assessing SEVP programwide risks.

Evaluating SEVP information on prior and suspected cases of 

school noncompliance and fraud. SEVP does not have a process to 

evaluate prior and suspected cases of school fraud and noncompliance to 

identify lessons learned from such cases, which could help it better 

identify and assess program risks. SEVP has maintained a compliance 

case log since 2005—a list of approximately 172 schools as of December 

2011—that officials have determined to be potentially noncompliant with 

program requirements. The compliance case log represents those 

schools that SEVP, based on tips and leads and out-of-cycle reviews, is 

monitoring for potential noncompliance. SEVP uses this log for monitoring 

potentially noncompliant schools, but, according to SEVP officials, it has 

not looked across schools on this list to identify and evaluate possible 

trends in schools’ noncompliance, which could provide useful insights to 

SEVP to assess programwide risks. Further, according to SEVP officials, 

SEVP has not looked across previous cases of school fraud and school 

withdrawals to identify lessons learned on program vulnerabilities and 

opportunities to strengthen internal controls. They stated that developing 

a comprehensive list of prior cases for school fraud would require 

significant time and effort because information on school fraud and 

noncompliance is maintained in multiple databases and files are not 

linked electronically and do not share information, including SEVIS, the 

Student and Exchange Visitor Program Automated Management 

System,27

As of March 2012, ICE reported that it had withdrawn 860 SEVP-certified 

schools from the program since 2003 for various reasons including 

compliance issues, voluntary withdrawals, and school closures. ICE 

reported that it has withdrawn at least 88 of these schools since 2003 for 

noncompliance issues, such as failure to report a change in ownership. 

and paper-based case files. However, SEVP could use the 

existing compliance case log as a starting point to identify any trends or 

factors in schools’ noncompliance. Further, SEVP could select a sample 

of prior school fraud cases to analyze for possible trends and lessons 

learned, and leverage this analysis to help identify programwide risks.

 

27The Student and Exchange Visitor Program Automated Management System is a 

document management system that contains case file information on schools, such as site 

visit reports and evidence provided to support the I-17petition.
 

Page 14 GAO-12-572 Student and Exchange Visitor Program

However, a senior official told us that SEVP has not conducted a lessons 

learned evaluation of school withdrawals to determine potential trends in 

their noncompliant actions, and use that information to focus compliance 

activities. Our analysis indicates that there are patterns in the 

noncompliant schools, such as the type of school. For example, of the 

172 post-secondary institutions on SEVP’s December 2011 compliance 

case log, about 83 percent (or 142) offer language, religious, or flight 

studies, with language schools representing the highest proportion. 

CTECU identified, and shared with SEVP officials other potential 

indicators of higher-risk schools based on prior school fraud cases, 

including school location/type of campus; the ratio of foreign students to 

overall students; the ratio of enrolled students to reported average annual 

number of students; the concentration of online courses; and the average 

length of time that students, particularly foreign language students, have 

been in the United States.

SEVP’s Policy Branch Chief told us that while the program has not 

conducted a comprehensive analysis of previous fraud cases, the Policy 

Branch developed a lessons learned analysis in response to the 2011 TriValley University case in California and submitted this analysis to SEVP 

senior management. In the Tri-Valley University case, the school’s owner 

was indicted for issuing fraudulent documentation without regard for 

students’ academic qualifications or intent to pursue a course of study 

required to maintain lawful immigration status. In February 2012, SEVP’s 

Director stated that he did not recall this analysis and thus had not made 

any policy or operational changes recommended in the analysis. He 

noted, however, that his office had made a number of changes as a direct 

result of the Tri-Valley University case, including establishing a separate 

compliance unit in August 2011 and instituting a process to identify 

schools that have more enrolled students than their stated capacity, 

which is an indicator of risk.28

 

28As part of initial certification, schools are required to report to SEVP their average 

annual number of students. In the case of Tri-Valley University, the school reported the 

average annual number of students as less than 100. However, at the time that ICE began 

investigating the school, the population of students was close to 1,000. Based on the TriValley University case, SEVP officials stated that they began evaluating discrepancies 

between schools’ average annual number of students and the number of Forms I-20 

issued. 

The SEVP Director further stated that 

although the program has not systematically evaluated previous fraud 

cases, it has devoted increased attention to fraud prevention and 

detection since the Tri-Valley University case, such as through funding 
 

Page 15 GAO-12-572 Student and Exchange Visitor Program

additional investigative resources in CTCEU. Officials at both SEVP and 

CTCEU stated that evaluating prior school fraud cases could help in 

assessing program risks, but the agency has not completed an analysis 

on data from school case files. According to DHS’s Policy for Integrated 

Risk Management, risk information and analysis can help provide 

defensible decisions, made with the best available tools and information, 

for the best achievable outcomes. In addition, the U.K. National Audit 

Office’s Good Practice in Tackling External Fraud advises that in the 

fraud context, a risk-based approach involves such things as assessing 

areas most vulnerable to fraud and the characteristics of those who 

commit fraud. SEVP officials told us that case information is not 

organized well, and that they generally operate on a reactive basis after 

evidence indicates that a fraud has been perpetrated and do not have 

sufficient quantitative data to help detect the fraud before it occurs. 

However, ICE could use its existing compliance case log and a sample of 

prior cases of school fraud, which contain qualitative information, as a 

starting point to help identify and assess factors that could pose security 

and fraud risks to the program. Without an evaluation of prior and 

suspected cases of school fraud and noncompliance, ICE is not wellpositioned to identify and apply lessons learned from prior school fraud 

cases, which could help it take action to identify and mitigate program 

risks going forward.

Obtaining information from CTCEU and ICE field offices’ 

investigations and outreach efforts. SEVP’s Director and other senior 

officials stated that SEVP has not established a process to obtain 

information from CTCEU’s criminal investigators. Investigators may have 

valuable knowledge in working cases of school fraud for identifying and 

assessing program risks, including information such as the characteristics 

of schools that commit fraud, how school officials exploited weaknesses 

in the school certification process, and what actions ICE could take to 

strengthen internal controls. For example, according to investigators in 

one ICE field office, CTCEU was hampered in pursuing a criminal 

investigation because SEVP officials did not obtain a signed attestation 

statement within the I-17 application from a school official stating that the 

official agreed to comply with rules and regulations. Another risk area is 

designated school officials’ access to SEVIS. In 2011, CTCEU provided 

SEVP officials with a position paper expressing concerns that designated 

school officials, who are not required to undergo security background 

checks, are responsible for maintaining updated information of foreign 

students in SEVIS. Further, according to investigators at three of the eight

field offices we interviewed, SEVP allowed designated school officials to 

maintain SEVIS access and the ability to modify records in the system 
 

Page 16 GAO-12-572 Student and Exchange Visitor Program

while being the subject of an ongoing criminal investigation, despite 

requests from CTCEU to terminate SEVIS access for these officials. The 

SEVP office has the authority to immediately terminate SEVIS access

upon request from CTCEU in cases where criminal wrongdoing is 

suspected, and SEVP officials stated that they have taken action in the 

past to terminate SEVIS access due to noncompliance. SEVP’s Director 

stated that his office has, on occasion, requested more information or 

evidence from CTCEU to substantiate a request to terminate SEVIS 

access for a designated school official. In addition, he stated that, in some 

instances, his office may be hesitant to terminate access because doing 

so might alert the school to an open investigation and thus compromise 

CTCEU’s efforts.

In addition to information from CTCEU’s criminal investigations, CTCEU 

collects data on its outreach efforts with schools through its Campus 

Sentinel program; however, the SEVP Director stated that his office has 

not obtained and analyzed reports on the results of these visits. CTCEU 

initiated Campus Sentinel in 2011, which ICE operates across all of its 

field offices nationwide. Funded with SEVP fee collections and facilitated 

based on SEVP’s outreach and liaison efforts with schools, the program 

aims to foster relationships between ICE law enforcement officials and 

schools through on-site visits and information sessions at national and 

regional conferences and to make school officials more aware of recent 

investigations of school fraud. CTCEU officials stated that the goal of 

Campus Sentinel is to enable CTCEU officials and schools to better 

identify and report criminal behavior within the population of certified 

schools.

From October 1, 2011 through March 6, 2012, CTCEU conducted 314 

outreach visits to schools. According to CTCEU investigators that we 

interviewed, these visits provide an opportunity to identify potential risks, 

including whether schools have the physical capacity and necessary 

resources to support programs for foreign students. As of March 2012, 

CTCEU initiated two criminal investigations based on information 

obtained as part of Campus Sentinel outreach. ICE field offices document 

the results of each site visit, as well as information on school 

investigations, in the Treasury Enforcement Communication System 

(TECS), which is accessible to SEVP officials in the compliance unit, 
 

Page 17 GAO-12-572 Student and Exchange Visitor Program

including an SEVP compliance liaison in CTCEU.29

In addition, ICE has taken some initial actions to study the potential risks 

posed by schools that are not in compliance with SEVP requirements, but 

it is too early to evaluate the results of these actions. Specifically, in 

September 2011, ICE hired a contractor to develop a risk-based 

approach to overseeing schools applying for certification as well as those 

already certified schools under the program. The objective of this contract 

is to define and document programmatic risks and incorporate such 

information into a risk-based approach to school oversight. As of March 

2012, the contractor had reviewed ICE’s SEVP standard operating 

procedures and interviewed agency officials responsible for school 

Standards for Internal 

Control in the Federal Government states that management needs to 

comprehensively identify risks and ensure there are adequate means of 

obtaining information from external stakeholders that may have a 

significant impact on the agency achieving its goals. SEVP officials, 

including the Director, stated that the program conducts ongoing outreach 

with schools through annual conferences and efforts related to the 

Campus Sentinel program, among other things. The Director indicated 

that SEVP officials helped launch and fund it through SEVP fee 

collections, but were not aware of the site visit reports and thus have not 

taken steps to obtain information on them. A senior SEVP official stated 

that the program lacks processes to obtain information from CTCEU due 

to a strained relationship between the organizations. CTCEU officials 

disagreed that the relationship is strained and stated that there are 

processes in place to share information, such as through regular, 

bimonthly meetings between CTCEU and SEVP officials that began in 

late 2011; however, they stated that SEVP has not adequately 

emphasized enforcement in its mission. In February 2012, SEVP’s 

Director stated that data on the results of Campus Sentinel would be 

valuable and planned to follow up with staff on how best to utilize access 

to available case information in TECS. Obtaining information on lessons 

learned from CTCEU investigators could help provide SEVP with 

additional insights on such issues as characteristics of schools that have 

committed fraud and the nature of those schools’ fraudulent activities, 

which ICE could leverage in identifying and assessing programmatic 

risks.

 

29TECS is an automated enforcement and antiterrorism database that provides 

information for law enforcement and border security purposes, and can exchange 

information automatically with other U.S. government systems.
 

Page 18 GAO-12-572 Student and Exchange Visitor Program

certification and recertification, among other areas. Using the results from 

background research and interviews of subject matter experts, the 

contractor completed several deliverables, including identifying and 

defining preliminary program risks (e.g., non-accredited schools); 

developing a risk scorecard, which ICE plans to use to categorize schools 

by risk level (e.g. high, medium, low); and developing a risk-based testing 

plan to ensure that adequate internal controls exist and are followed. 

However, this methodology was limited because ICE does not have 

complete and reliable historical data on its schools, according to the 

contractor. In November 2011, the contractor reported that there are 

several key limitations to its ongoing analysis of risk factors in SEVP, 

including that it must rely on qualitative, rather than quantitative data. In 

particular, the contractor reported that it faced challenges in accessing 

compliance data, given that is it maintained in multiple data sources. 

SEVP’s Deputy Director stated that DHS’s Office of Risk Management 

Analysis has begun developing such quantitative data separate from its 

risk management contract. As of March 2012, ICE has not yet 

implemented any of the contractor’s recommendations because the 

contractor had just completed the work. Going forward, ICE plans to 

evaluate the results before determining actions for implementation.

SEVP revenues have increased in recent years, but ICE has not analyzed 

how to allocate its resources among mission areas, such as certification, 

compliance monitoring, and recertification. Once ICE has assessed risks 

in SEVP, analyzing how to allocate resources based on those risks could 

help ensure that SEVP is using its resources in a cost-effective manner. 

We have previously reported that homeland security resource 

investments should be informed by risk.30

 

30GAO, Strategic Budgeting: Risk Management Principles Can Help DHS Allocate 

Resources to Highest Priorities, 

In particular, we reported that 

DHS must carefully weigh the benefit of homeland security endeavors 

and allocate resources where the benefit of reducing risk is worth the 

additional cost. Additionally, risk-based, priority-driven decisions can help 

inform decision makers in allocating finite resources to the areas of 

greatest need. In the homeland security arena, this means determining 

which vulnerabilities should be addressed in what ways with available 

resources.

GAO-05-824T (Washington, D.C.: Jun. 29, 2005).

ICE Has Not Allocated 

SEVP Resources Based on 

Program Risks
 

Page 19 GAO-12-572 Student and Exchange Visitor Program

SEVP is funded entirely by the fees that ICE collects from schools and 

students. In fiscal year 2009, based on an internal fee study, application 

fees for students and schools increased, which contributed to 

approximately 60 percent increase in fee collection revenue from fiscal 

year 2008.31

Table 1: ICE’s Budget Authority, Obligations, and Fee Collections for SEVP, Fiscal Years 2006 through 2012 

As shown in table 1, fee collections for SEVP have 

increased from approximately $53 million in fiscal year 2006 to about 

$123 million in fiscal year 2011. Subsequent fee studies in 2009 and 2011 

projected that the program’s revenues would be sufficient to meet 

resource needs for the period covering fiscal years 2009 through 2013.

Dollars in millions

2006 2007 2008 2009 2010 2011 2012a

Enacted budget authority 66.6 54.3 56.2b 120.0 120.0 120.0 120.0

Fee collections 52.9 57.9 63.3 101.0 113.2 122.7 33.9c

Obligations 45.8 44.7 63.0 81.0 72.9 95.6 120.0

Source: GAO analysis of SEVP documentation and DHS budget data.

a

Based on fiscal year 2012 enacted budget authority. 

b

SEVP also received $9.7 million in supplemental funding in fiscal year 2008. 

c

Data as of March 2012. Also, SEVP’s forecast takes into account that the majority of some fee 

payments occur during the second half of the fiscal year. As a result, 73 percent, or $93 million, of 

SEVP’s revenue is forecast to be collected over the remaining months in 2012. 

With the exception of fiscal year 2011, ICE’s fee collections for SEVP 

since fiscal year 2009 have generally fallen short of its enacted budget 

authority.32

 

31In fiscal year 2009, student fees increased from $100 to $200; school certification and 

petitions for change in ownership fees increased from $230 to $1,700; school site-visit 

fees increased from $350 to $655; and additional campus site visit increased from $350 to 

$655.

ICE had intended to use the projected increases in fee 

collections to fund several initiatives, including developing SEVIS II, 

establishing field liaisons nationwide for school coordination and 

monitoring purposes, and hiring additional personnel for recertification. 

32Budget authority refers to the authority provided by federal law to enter into financial 

obligations that will result in immediate or future outlays involving federal government 

funds. The basic forms of budget authority include (1) appropriations, (2) borrowing 

authority, (3) contract authority, and (4) authority to obligate and expend offsetting receipts 

and collections. See GAO, A Glossary of Terms Used in the Federal Budget Process, 

GAO-05-734SP (Washington, D.C.: Sept. 2005).
 

Page 20 GAO-12-572 Student and Exchange Visitor Program

SEVP deferred funding these initiatives, however, for a number of 

reasons such as challenges in designing SEVIS II, delays in hiring 

additional staff members, and lower than expected fee collections. For 

example, based on the fiscal year 2009 fee increase, ICE planned to 

allocate approximately $3 million to hire additional staff for SEVP 

recertification; however, an SEVP official stated that they did not 

complete hiring these staff in fiscal year 2010 because of the 

unanticipated reduction in fee collections.33 A senior policy official 

indicated it is important to hire additional staff for recertification activities 

to help address school noncompliance and meet the statutory 

requirements for recertification as set forth in the Border Security Act. 

Although fee collections were lower than expected during this time frame, 

from October 2008 through October 2011, SEVP’s carryover cash 

balance increased from approximately $40 million to $105 million. SEVP’s 

Director stated that the program transferred staff from the Policy Branch 

to the compliance unit in 2011, and that there may be additional 

opportunities to target resources based on risk. SEVP is a fee-funded 

program, and revenues can and do fluctuate from fiscal year to fiscal year 

(see Table 1). However, SEVP’s director stated that SEVP has not 

conducted an analysis of its resource allocations based on risk to ensure 

that those resources are allocated in an efficient manner to high-risk 

activities. Additionally, in February 2012, SEVP’s Director realigned the 

organization into two main divisions, one focused on internal operations, 

such as information technology and human resources, and one focused 

on external operations, such as school certification. However, he stated 

that SEVP had not conducted a resource analysis or considered risk 

information to support this reorganization. By analyzing how to allocate its 

resources based on risk, SEVP could be better positioned to ensure that 

it is using those resources in a cost-effective manner to help address the 

program’s highest risk activities.

 

33SEVP plans to complete hiring additional staff for recertification activities by the end of 

fiscal year 2012.
 

Page 21 GAO-12-572 Student and Exchange Visitor Program

ICE has not consistently implemented certain controls to verify schools’ 

legitimacy and eligibility during initial SEVP-certification and ongoing 

monitoring processes. In particular, ICE has not consistently implemented 

policies that require schools offering flight training to have certain FAA 

certifications to remain eligible to enroll foreign nonimmigrant students. In 

addition, weaknesses in managing and sharing information on SEVPcertified schools among ICE stakeholders hinder the agency’s efforts to 

prevent and detect school certification fraud.

ICE has not consistently implemented its procedures to verify and monitor 

schools’ legitimacy and eligibility, hindering efforts to prevent and detect 

school fraud. Regulations require schools to establish that the schools are 

legitimate and meet other eligibility criteria for the program to obtain 

certification from ICE.34

Initial verification of evidence submitted in lieu of accreditation. ICE 

requires schools to present evidence demonstrating that the school is 

legitimate; is an established institution of learning or other recognized 

place of study; possesses the necessary facilities, personnel, and 

finances to conduct instruction in recognized courses; and is engaged in 

instruction in those courses. Non-accredited, post-secondary schools, in 

particular, must provide “in lieu of” letters, which are evidence provided by 

ICE’s policies and procedures direct SEVP 

officials to collect, validate, and maintain evidence of schools’ eligibility 

during the initial certification, recertification, and ongoing review 

processes. Internal control standards advise that controls should be 

generally designed to ensure that ongoing monitoring occurs in the 

course of normal operations. Further, according to fraud control practices, 

agencies should strengthen internal controls where needed for fraud 

prevention. However, ICE officials have not consistently implemented 

existing internal control procedures for SEVP in four areas: (1) initial 

verification of evidence submitted in lieu of accreditation, (2) 

recordkeeping to ensure schools’ continued eligibility, (3) ongoing 

compliance monitoring of school licensing and accreditation status, and 

(4) certification of schools offering flight training.

 

348 C.F.R. § 214.3(a)(3) states that a school, to be eligible for certification, must establish 

that it is bona fide. For the purposes of this report, we use the term “legitimate” 

synonymously with the term “bona fide.” 

Weaknesses in ICE’s 

Monitoring and 

Oversight of SEVPCertified Schools 

Contribute to Security 

and Fraud 

Vulnerabilities

Inconsistent 

Implementation of Certain 

Controls Impede ICE’s 

Efforts to Verify and 

Monitor Schools’ 

Legitimacy and Program 

Eligibility
 

Page 22 GAO-12-572 Student and Exchange Visitor Program

petitioning schools in lieu of accreditation by a Department of Educationrecognized accrediting agency. ICE policy and guidance require that 

SEVP adjudicators render an approval or denial of schools’ petitions 

based on such evidence and supporting documentation.35 This includes 

verifying that schools’ claims in the Form I-17—such as accreditation 

status and “in lieu of” letters are accurate. Verifying an “in lieu of” letter 

would generally involve contacting the letter’s source and confirming that 

the letter is legitimate and that the signee has authority to issue 

statements of the school’s acceptance of the petitioning school’s credits 

and students. Based on our review of SEVIS data on the approximately 

10,000 SEVP-certified schools, we estimate that approximately 1,250 

schools are non-accredited, post-secondary schools and, therefore, 

should have provided “in lieu of” letters to ICE.36

 

35SEVP adjudicators are federal government employees responsible for reviewing all 

school certification petitions, for researching and sending requests for additional evidence, 

and issuing a decision either certifying or denying schools’ SEVP-certification. 

However, SEVP 

adjudicators have not consistently verified “in lieu of” letters submitted by 

schools that demonstrate their legitimacy and eligibility. For example, 

according to SEVP’s School Certification Branch Chief, adjudicators have 

not verified all “in lieu of” letters submitted to ICE by the approximately 

1,250 non-accredited, post-secondary schools, as required by ICE’s 

policy. Rather, adjudicators use their discretion to determine whether to 

verify a letter’s source and the signatory authority of the signee based on 

any suspicions of the letters’ validity. Investigators at one of the eight ICE 

field offices we interviewed stated SEVP officials certified at least one 

illegitimate school—Tri-Valley University in California—because the 

program had not verified the evidence provided in the initial petition. 

These investigators directly attributed the initial certification of Tri-Valley 

University in California to the lack of verification of the school’s “in lieu of” 

letters. Investigators stated that if SEVP’s adjudicators had taken action 

to verify the letters, they may have discovered that the letters were 

manufactured by Tri-Valley University school officials to feign legitimacy 

and eligibility.

36To identify those schools that are post-secondary, we sorted SEVIS school data as of 

December 8, 2011, based on the “Type of Education” offered and excluded those schools 

that offered only elementary through high school education. From our list of postsecondary schools, we cross referenced each school’s reported accrediting agency (if 

any) against the Department of Education’s list of approved accrediting agencies. We 

considered schools non-accredited if they reported having no accreditation or reported an 

accrediting agency that was not approved by the Department of Education.
 

Page 23 GAO-12-572 Student and Exchange Visitor Program

Furthermore, CTCEU officials and investigators at five of the eight ICE 

field offices we interviewed stated that School Certification Branch 

officials should scrutinize non-accredited schools to a higher degree 

because such schools have demonstrated a higher risk of fraud than 

other schools. Subsequent to investigation, Tri-Valley University closed 

and the owner was indicted on 33 criminal counts, including charges of 

visa fraud, money laundering, and alien-harboring. In another case, the 

owner of an English language school in Georgia provided fraudulent 

documents to ICE, including forged or fraudulently obtained “in lieu of” 

letters supposedly issued by three educational institutions of higher 

learning. Following the English language school’s certification, the school 

began facilitating the issuance of student visas to foreign nationals and 

further manufactured and provided false documents, including resumes, 

school transcripts, diplomas, financial plans and statements, to those 

foreign nationals. Furthermore, in March 2012, CTCEU officials stated 

that several of their ongoing investigations involve schools that provided 

fraudulent evidence of accreditation or evidence in lieu of accreditation to 

ICE. SEVP adjudicators have not consistently verified all evidence 

submitted in lieu of accreditation, specifically “in lieu of” letters” that 

support non-accredited schools’ petitions for SEVP certification because, 

according to SEVP officials, the program has not historically focused 

enough attention on fraud prevention until the Tri-Valley University case 

demonstrated the program’s vulnerabilities. In analyzing the Tri-Valley 

University case, a senior official in SEVP’s Policy Branch reiterated that 

adjudicators should verify all “in lieu of” letters per the program’s current 

procedures. Consistent verification of these letters could help ICE ensure 

that schools are legitimate and detect potential fraud early in the 

certification process.

Recordkeeping to ensure continued eligibility of schools. ICE’s 

standard operating procedures for recordkeeping require SEVP officials 

to maintain records to document ongoing compliance. Our analysis of 

selected school case files indicates that ICE has not consistently 

maintained certain evidence of selected schools’ eligibility for the 

program. Based on our review of a stratified random sample of 50 SEVPcertified school case files, 30 files lacked at least one piece of evidence 

required by the program’s policies and procedures. In addition, ICE was 

unable to produce two schools’ case files that we requested as part of our 
 

Page 24 GAO-12-572 Student and Exchange Visitor Program

randomly selected sample.37

• 7 of the 48 school case files did not include reports of the required 

initial site visit;

The results of our analysis of the 48 

remaining case files are not generalizable, but the following summarizes 

these results.

• 22 of the 48 school case files did not include proof of the designated 

school officials’ U.S. citizenship or lawful permanent residency;

• 7 of the 34 case files for non-flight schools and non-accredited 

schools lacked adequate evidence in lieu of accreditation (e.g. “in lieu 

of” letters); and

• 7 of the 11 case files for schools offering flight training included 

expired FAA certificates.

Without the schools’ information and evidence contained in these case 

files, including attestation statements, site visit reports, and designated 

school officials’ proof of citizenship, ICE does not have an institutional 

record to provide reasonable assurance that these schools were initially 

and continue to be legitimate and eligible for certification. The Mission 

Support Branch Chief indicated that school case files may be missing or 

may lack pieces of evidence because of the transition from the legacy 

Immigration and Naturalization Service (INS) to DHS in 2003. DHS 

initially delegated authority for school certification and monitoring to U.S. 

Citizenship and Immigration Services (USCIS), but DHS later delegated 

that responsibility to ICE in February 2005. The Mission Support Branch 

Chief stated that DHS attempted to facilitate a smooth transition from INS 

and USCIS by accepting schools’ prior certifications without additional 

review. Although the INS offices where school case files had been 

maintained were required to send the school case files to USCIS, which 

subsequently transferred files to SEVP, the Mission Support Branch Chief 

and School Certification Branch Chief stated that some files were 

completely or partially destroyed prior to the transfer. The School 

Certification Branch Chief told us that ICE has not followed up on the 

missing case files and that files may be available from former INS offices. 

Both officials stated that they have not conducted an analysis of the gaps 

in school information among case files and do not know the number of 

files that may be incomplete or missing. The Mission Support Branch 

Chief stated that they have not prioritized the analysis of the case files 

 

37Because ICE was unable to produce 2 schools’ case files, our results include the 48 files 

that we were able to analyze.
 

Page 25 GAO-12-572 Student and Exchange Visitor Program

because the program is relying on their various processes, including 

petition updates, compliance reviews, and recertification, to address 

previous deficiencies in information in case files. Based on our review of 

data on the initial certification dates of SEVP-certified schools, 7,130 of 

10,038 (71 percent) were certified prior to 2005, indicating that these 

schools were initially certified by INS or USCIS and then transferred to 

ICE. Internal control standards indicate that operating information, such 

as the evidence in school case files, is necessary to determine whether 

an agency is meeting its compliance requirements. Further, our analysis 

indicated that case files for schools that have been certified since 

February 2005 were also incomplete. Of the 30 schools that we identified 

as lacking at least one piece of evidence required by the program’s 

policies and procedures, 13 (46 percent) were certified from 2005 through 

2010. Therefore, gaps in the case files used to maintain evidence of 

schools’ eligibility affect those schools that ICE accepted from the former 

INS and USCIS as well as those that ICE certified after taking 

responsibility for the program.

According to ICE officials, the school recertification process would help 

address issues with incomplete and missing school files because schools 

are required to resubmit all evidence required by regulation when going 

through recertification. The School Certification Branch Chief and the 

Policy Branch Chief stated that recertification would also help ICE 

address noncompliant schools and withdraw those that may have 

become illegitimate and ineligible since initial certification. The Border 

Security Act required recertification for all SEVP-certified schools (as well 

as State’s program sponsors of exchange students) by May 2004 and 

every 2 years thereafter.38

 

38See 8 U.S.C. § 1762. The statute requires the review of institutions and other entities 

authorized to enroll or sponsor certain nonimmigrants. In addition to requiring DHS to 

review institutions certified to receive nonimmigrants under F and M visas, the act requires 

the Department of State to review entities designated to sponsor exchange visitor program 

participants under J visas. The Act requires that these reviews determine whether the 

institutions or entities are in compliance with recordkeeping and reporting requirements. 

However, ICE began the first recertification 

cycle in May 2010 and, according to senior SEVP officials, will not 

recertify all schools during this 2-year cycle, which ends in May 2012, 

because the process has taken longer than officials planned. As of March 

31, 2012, ICE reported to have recertified 1,870 schools (approximately 

19 percent of SEVP-certified schools) during the program’s first 

recertification cycle (see figure 3).
 

Page 26 GAO-12-572 Student and Exchange Visitor Program

Figure 3: ICE’s Recertification Milestones

Note: Border Security Act of 2002 required that INS recertify schools every 2 years; however, DHS 

assumed this responsibility when it took over management of SEVP in 2003. 

According to ICE, the program intended to complete approximately 450 

recertifications per month to finish the cycle in 2 years. However, it 

completed an average of 107 recertifications per month in 2011. 

According to SEVP’s Director and other senior officials, ICE delayed the 

recertification process until after SEVIS was deployed in 2003 and the 

program fee was increased in 2008 to support more staff in the program. 

SEVP senior management stated that the office is recruiting additional 

adjudicators, which may increase the program’s ability to recertify schools 

and potentially reach the program’s goal of recertifying 450 schools per 

month. Given the delays in completing the first recertification cycle, ICE is 

not positioned to address gaps in SEVP’s case files and cannot provide 

reasonable assurance that schools that were initially certified to accept 

foreign students are still compliant with SEVP regulations.
 

Page 27 GAO-12-572 Student and Exchange Visitor Program

Ongoing compliance monitoring of school licensing and 

accreditation status. ICE does not have a process to monitor the 

ongoing eligibility of licensed and accredited, non-language schools 

enrolling foreign students. ICE regulations require all certified schools to 

maintain state licensing (or exemption) and provide various forms of 

evidence to ICE supporting schools’ legitimacy and eligibility. ICE has 

taken action to monitor the accreditation status of English language 

schools; however, it does not have a process to monitor schools’ state 

licensing status and non-language schools’ accreditation status. For 

English language schools, ICE is enforcing a legislative change enacted 

in December 2010, which requires, as of June 2011, such schools to be 

accredited by a Department of Education-recognized accrediting agency 

to be eligible for SEVP certification.39

ICE does not have a similar process for monitoring the state licensing 

status of all schools and the accreditation of schools offering higher 

education or vocational training other than language training. If a school’s 

licensing or accreditation status changes after initial certification, ICE’s 

regulations and policy require designated school officials to report this 

change to ICE through SEVIS.

The act allows English language 

schools already certified on the date of enactment to continue issuing 

Forms I-20 until December 2014, as long as they apply for accreditation 

by December 14, 2011. Subsequent to this change, ICE took actions to 

coordinate with nationally recognized accrediting agencies to determine 

which English language schools applied for accreditation by the 

legislatively mandated date of December 14, 2011.

40

 

39See Act of Dec. 14, 2010, Pub. L. No. 111-306, 124 Stat. 3280.

At initial certification, ICE requires 

designated school officials to report which agencies license or accredit 

their school in SEVIS, but the system allows school officials to list any 

response. For example, a school may list an accrediting agency that is 

not Department of Education-recognized in an attempt to fulfill SEVP 

requirements. Because schools may enter any information in this field, 

SEVP officials cannot easily query the number of schools that are 

accredited by Department of Education-recognized agencies or sort such 

data by the accrediting agencies. According to SEVP Information 

Technology officials, the planned November 2014 deployment of SEVIS II 

is intended to improve the program’s analytical capabilities by addressing 

408 C.F.R. § 214.3(g)(2)(i).
 

Page 28 GAO-12-572 Student and Exchange Visitor Program

the variation in self-reported licensing and accreditation statuses.41

SEVP’s Policy Branch Chief and Deputy Director stated that they rely on 

the recertification process in addition to other methods, such as 

information-sharing with CTCEU and compliance reviews by the 

compliance unit, to verify that schools are self-reporting changes in their 

status consistent with ICE policies. However, ICE has not yet completed 

its first round of recertification of all certified schools. Moreover, since ICE 

is mandated to conduct recertification on schools every two years, a 

Specifically, SEVIS II is intended to provide drop-down menus or other 

multiple choice selections for state licensing agencies as well as 

Department of Education-recognized accrediting agencies. These data 

collection tools are intended to address the inconsistent reporting of 

licensing or accrediting agencies’ names but not the issue of inaccurate 

(both intentional and unintentional) self-reporting by schools. Therefore, 

even with the planned SEVIS II deployment in 2014, ICE does not have 

reasonable assurance that SEVIS data on schools’ licensing or 

accreditation status is accurate following initial certification. If a school 

loses its state license, the school would be unable to operate legally as a 

school within that state. However, ICE does not have controls to ensure 

that SEVP compliance unit officials would be aware of this issue; 

therefore, a school without a proper business license may remain certified 

to enroll foreign students and the school’s designated school officials may 

continue to access SEVIS. For example, SEVP had been notified by ICE 

investigators that a religious school was closed in September 2011; as of 

March 2012, the school remained SEVP-certified. In another example, 

SEVP officials learned in May 2011 that a flight school had closed; as of 

March 2012, the school remained SEVP-certified. After we brought these 

issues to attention of ICE officials in March 2012, they stated that, while 

they initially thought these two schools had been withdrawn, the schools 

were SEVP-certified. ICE officials stated that they are working on 

withdrawing the schools.

 

41ICE is developing the functional requirements for SEVIS II, a second generation version 

of the data system that is intended to be more technologically advanced and user-friendly 

and to streamline the process of students obtaining student visas and studying in the 

United States. Initially planned for deployment in September 2009, SEVIS II has been 

delayed until November 2014 due to difficulties in system design. ICE terminated the 

original contractor based on its challenges in developing an accurate and complete set of 

functional requirements for the system, which required the agency to hire a new contractor 

for system design. ICE also plans to hire a contractor for SEVIS II development and 

implementation.
 

Page 29 GAO-12-572 Student and Exchange Visitor Program

process to monitor the ongoing status of schools would help ensure their 

continuous eligibility. For example, this process could include notification 

from Department of Education-recognized accrediting agencies regarding 

changes in schools’ accreditation status. In addition to recertification, the 

SEVP Director stated that the planned field liaison initiative will improve 

school compliance, as well as data integrity in SEVIS. SEVP’s Director 

stated that the field liaisons will establish a more proactive relationship 

with schools and provide additional resources for schools and designated 

school officials to access to better understand and comply with 

immigration laws, regulations, and SEVP policies and procedures. 

However, the initiative remains under development and ICE has not 

deployed any liaisons as of March 2012. Developing and implementing a 

process to monitor the ongoing status of schools enrolling foreign 

students could better position ICE to reduce the risk of fraud and ensure 

schools’ legitimacy and eligibility.

Certification of schools offering flight training. ICE’s policies and 

procedures require flight schools to have FAA Part 141 or 142 

certification to be eligible for SEVP certification; however, ICE has 

certified schools offering flight training without such FAA certifications. As 

the federal agency responsible for regulating safety of civil aviation in the 

United States, FAA administers pilot certification (licensing) and conducts 

safety oversight of pilot training.42 FAA’s regulations for pilot training and 

certification can be found in three parts—Parts 61, 141, and 142.43

 

42For more information on FAA’s oversight of pilot training, see GAO, Initial Pilot Training: 

Better Management Controls Are Needed to Improve FAA Oversight, 

 Part 

61 relates to individual providers/instructors that are not subject to direct 

FAA oversight beyond the initial certification and subsequent renewal of 

each flight instructor’s certificate. Parts 141 and 142 outline requirements 

for flight schools and training centers. FAA oversees these Part 141 and 

142 flight schools and training centers with annual inspections and by 

reviewing and approving the schools’ facilities and programs. FAA 

requires the flight training programs to include, among other things, 

detailed training course outlines or curriculums for approval. ICE 

established a policy that requires Part 141 and 142 for eligibility in 

SEVP—and excluded Part 61 providers—because FAA directly oversees 

GAO-12-117 

(Washington, D.C.: Nov. 15, 2011). 

43Federal aviation regulations are found under title 14 of the United States Code of 

Federal Regulations (14 C.F.R. pts. 61, 141, and 142).
 

Page 30 GAO-12-572 Student and Exchange Visitor Program

Part 141 and 142 flight schools and training centers on an ongoing basis. 

The Form I-17 petition for certification specifies that only FAA Part 141 

flight schools are eligible to apply for certification to enroll foreign 

students.

We identified 434 SEVP-certified schools that, as of December 2011, 

offer flight training to foreign students.44 However, 167 (38 percent) of 

these flight training providers do not have FAA Part 141 or 142 

certification. SEVP’s Director, Policy Branch Chief, and Compliance Unit 

Chief acknowledged that all SEVP-certified schools offering flight training 

do not have FAA Part 141 or 142 certification even though the program 

requires it. In 2011, SEVP’s compliance unit initially identified schools 

offering flight training that appeared to not have Part 141 or 142 

certification and began determining those schools’ statuses by contacting 

designated school officials and FAA Flight Standard District Offices.45

During the course of our review, the SEVP Director stated that they plan 

to take action to address these noncompliant flight schools. Specifically, 

he stated that his office plans to notify all SEVP-certified schools that do 

not have the required FAA certification that they must re-obtain Part 141 

or 142 certification. Moreover, SEVP School Certification Branch officials 

stated that they plan to coordinate directly with FAA to determine which 

schools have not met the requirements by the deadlines and will take 

withdrawal actions against such schools. While these are positive steps, 

SEVP officials have not yet established target time frames for 

implementing and completing these planned actions. Program 

management standards state that successful execution of any program 

includes developing plans that include a time line for program 

deliverables.46

 

44This is a relatively small percentage of providers nationwide that offer flight training.

Setting target time frames to notify certified flight schools 

that lack FAA certifications that they must re-obtain Part 141 or 142 

certification could help ICE hold SEVP accountable for taking such 

45As of April 2012, SEVP’s compliance unit identified 469 SEVP-certified schools that offer 

flight training and determined that 153 of those may not be Part 141 or 142 certified. The 

discrepancy in the population that we identified and the population that SEVP identified is 

due to the fact that SEVP’s compliance unit included schools that have issued Forms I-20 

for flight training without having flight training approved through the Form I-17 petition. 

46The Project Management Institute, The Standard for Program Management © (Newton 

Square, Pa., 2006). 
 

Page 31 GAO-12-572 Student and Exchange Visitor Program

actions and better position ICE to reduce the risk of fraud and ensure all 

flight schools’ legitimacy and eligibility.

There are various reasons why ICE has certified or allowed non-Part 141 

or 142 schools to remain in the program. For example, a DHS flight 

training working group conducted a flight study that found that many FAA 

Part 61 schools were providing equal if not superior instruction than Part 

141 schools. Based on that finding, the DHS flight training working group 

recommended that ICE re-examine the program’s requirement for Part 

141 or 142 certification for flight schools to enroll foreign students. Based 

on the DHS group’s recommendation, ICE conducted a preliminary 

review and certified a limited number of non-Part 141 or 142 flight 

schools. Specifically, ICE certified one Part 61 provider following a site 

visit during which SEVP officials determined that the provider was equally 

qualified as a Part 141 or 142 flight school. Subsequent to this 

certification, additional Part 61 providers petitioned for SEVP certification, 

resulting in the certification of at least two additional flight providers that 

did not meet SEVP’s policy requiring Part 141 or 142 certification. SEVP 

officials in the Policy Branch stated that the program certified these 

providers because, in their view, there is no difference in quality between 

Part 61 providers and Part 141 or 142 flight schools.

ICE also indicated that in most of the cases, it may have initially certified 

flight schools with Part 141 or 142 certification but the schools allowed 

their FAA certification to expire, and ICE did not identify or take 

compliance action against these schools. Further, a senior SEVP 

compliance official stated that ICE may also be unaware of flight schools 

that have had their FAA certification revoked. We identified one school 

that offers flight training that remains SEVP-certified (as of February

2012) after FAA revoked its Part 141 certification in 2007 for multiple 

violations, including certifying and graduating students who have not 

completed the required curriculum and training as well as not following 

FAA-approved courses of training. Senior SEVP officials stated that the 

school officials have never updated the school’s petition in SEVIS 

following its initial certification in 2003; thus, ICE was unaware of this 

revocation. Additionally, ICE was unable to locate the school’s case file 

upon our request. We also identified a previous case of school 

certification fraud involving a flight school in El Cajon, California. This 

school lost its FAA certification to train commercial pilots but remained 

SEVP-certified, continued to issue Forms I-20 and enroll foreign 

nonimmigrant students, and illegally hired such students as flight 

instructors. Specifically, school officials issued Forms I-20 in SEVIS for 

more than 100 foreign students in 3 months and illegally hired 11 such 
 

Page 32 GAO-12-572 Student and Exchange Visitor Program

students as flight training instructors from 2001 through 2008. According 

to ICE field investigators, the actions taken by the school and its officials 

posed a significant security threat, especially considering the schools 

involvement in flight training. In particular, CTCEU recommended in 2011 

that SEVP should not allow Part 61 providers into the program. In 

November 2011, we reported that FAA rarely uses punitive means such 

as revoking licenses and assessing penalties against Part 141 schools, 

having revoked certificates in three cases.47

ICE has not consistently verified and maintained all evidence submitted in 

support of schools’ petitions and has not monitored schools’ state 

licensing, accreditation, and FAA certification status because, according 

to SEVP officials, ICE has not historically focused enough attention on 

fraud prevention and detection. To effectively prevent and detect fraud, 

Standards for Internal Control in the Federal Government, as well as the 

U.K. National Audit Office’s Good Practice in Tackling External Fraud, 

suggest agencies clearly define key areas of authority and responsibility 

for operating activities and develop specific strategies to coordinate their 

fraud control efforts, ensuring that someone is fully responsible for 

implementing the plans as intended. Following the case of Tri-Valley 

University, ICE created the SEVP compliance unit in August 2011 to 

target more of the program’s resources on school oversight and to 

strengthen compliance monitoring. The SEVP Director stated that his 

office’s branches historically operated in an autonomous manner, which 

has created past coordination challenges when responding to compliance 

cases, and the newly established compliance unit aims to correct these 

issues. However, SEVP has drafted but not finalized the unit’s standard 

operating procedures as of April 2012. The SEVP official in charge of the 

compliance unit stated that SEVP has not finalized the compliance unit’s 

procedures because the unit was established quickly in response to TriValley University and has relied upon previous compliance procedures 

Because ICE has certified or 

maintained certification of schools that provide flight training without the 

required FAA certification and oversight, the program is vulnerable to 

security and fraud risks.

 

47GAO-12-117. In addition, we plan to report later in 2012 on general aviation security, 

including the Alien Flight Student Program, which is a program administered by the 

Transportation Security Administration to screen foreign nationals applying for flight 

training in the United States. We are conducting this work at the request of the House of 

Representatives Committee on Homeland Security and Subcommittee on Transportation 

Security. 
 

Page 33 GAO-12-572 Student and Exchange Visitor Program

when the process was managed by the School Certification Branch. 

Specifically, the compliance unit is responsible for addressing the 

deficiencies in SEVP’s ongoing monitoring of schools’ licensing and 

accreditation, as well as flight schools’ FAA certification. Because the 

compliance unit operates without clearly defined parameters, the majority 

of its fraud control efforts are reactionary and performed on an ad hoc 

basis. For example, SEVP’s compliance staff began comparing the 

number of Forms I-20 issued to the schools’ reported number of students 

in reaction to the Tri-Valley University case, which highlighted that 

schools issuing Forms I-20 well above the schools’ reported average 

number of students is a potential fraud indicator. SEVP officials stated 

that they plan to finalize their procedures by summer 2012. Completing 

procedures by which the compliance unit monitors school compliance 

could better position ICE to conduct fraud control efforts on a systematic 

basis, which could help provide ICE with reasonable assurance that 

previously certified schools remain legitimate and eligible on an ongoing 

basis.

ICE has not consistently followed the standard operating procedures that 

govern the communication and coordination process between SEVP, 

CTCEU, and ICE field offices. Specifically, these procedures delineate 

roles and responsibilities on criminal investigations and establish 

protocols for SEVP taking administrative actions against schools during 

and following a criminal investigation. In some instances, SEVP 

management has not followed CTCEU requests to take or cease

administrative actions and has not referred potentially criminal cases to 

CTCEU in accordance with ICE’s procedures. ICE’s standard operating 

procedure for coordination requires SEVP to defer to CTCEU regarding 

whether to proceed with administrative actions during ongoing criminal 

investigations because criminal investigations take precedence over 

administrative actions. Additionally, this procedure states that ICE field 

offices determine the timing and extent of SEVP engagement in criminal 

investigations based on the needs of those investigations, which includes 

requesting SEVP to take administrative action in SEVIS to remove 

designated school officials’ access to the system and to withdraw school 

certification. ICE’s procedure also directs SEVP to refer allegations or 

leads revealing possible criminal violations to CTCEU in a timely manner, 

but it does not include criteria for determining when a compliance-type 

case under SEVP’s review becomes a potentially criminal case. Internal 

control standards advise agencies to develop strategies for coordinating 

fraud prevention and control efforts, including establishing means of 

Weaknesses in Managing 

and Sharing Key 

Information Impede ICE’s 

Prevention and Detection 

of School Fraud
 

Page 34 GAO-12-572 Student and Exchange Visitor Program

information exchange and developing approaches to identifying and 

addressing potential fraud.

Under the standard operating procedure, CTCEU is to inform SEVP 

officials of a pending criminal investigation of school fraud (or other 

fraudulent activity) to prevent SEVP from unknowingly compromising 

such investigations through conducting compliance reviews or other 

administrative processes. The procedure requires that SEVP officials 

defer to the judgment of the CTCEU Unit Chief regarding whether to 

proceed with an administrative action or review during an ongoing 

criminal investigation. However, in our interviews with eight ICE field 

offices, field investigators at two offices gave examples of SEVP officials 

continuing administrative activities when asked to cease such activity. In 

one case, investigators stated that the target (an owner of a flight school) 

became suspicious of increased attention by SEVP officials and fled the 

United States in 2011 to avoid prosecution. Our review of the December 

2012 compliance case log confirms that the SEVP office was aware of 

this specific criminal investigation and continued to take administrative 

actions. SEVP officials indicated that there were mitigating circumstances 

related to this case, including challenges in communicating with the ICE 

field office. SEVP officials also stated that SEVP and CTCEU 

management later agreed that the investigation was not compromised by 

SEVP’s administrative activities. In another ongoing case in California, 

field investigators stated that SEVP officials conducted a site visit to an 

institution following the owner’s indictment after the local ICE field office 

investigators instructed SEVP to stop administrative activities. SEVP’s 

Director stated that, in some cases, they believe it is necessary to 

communicate with or conduct routine activities related to schools under 

investigation in order to not alert these schools to a potential 

investigation. The SEVP Director stated that these two examples were 

outliers and that the program typically works well with the field office 

investigators, fully supporting criminal investigations and abiding by 

investigator directions to cease activity.

The standard operating procedure also allows CTCEU and ICE field 

offices to request that SEVP take administrative action in SEVIS to 

support criminal investigations either while the investigation is ongoing or 

following the investigation. Such administrative actions may include the 

removal of designated school officials from SEVIS access or withdrawal 

of a school’s certification. Because each criminal investigation is unique, 

the procedures state that the ICE field office determines the timing and 

extent of SEVP engagement based on the needs of the investigation. 

However, an ICE field office provided us with an example of SEVP 
 

Page 35 GAO-12-572 Student and Exchange Visitor Program

officials not complying with this administrative action protocol. According 

to this field office, as of February 2012, although CTCEU requested 

withdrawal of a school, SEVP had not begun withdrawal procedures for 

the school or denied SEVIS access to a school owner, following the 

owner’s indictment in May 2011 on charges including conspiracy and 

false statements. SEVP officials stated that they revoked the school 

owner’s SEVIS access following the indictment, but accidently restored 

his access following the owner’s call to SEVP’s response center. SEVP 

officials stated that the compliance unit immediately terminated the 

owner’s access after becoming aware of the situation. SEVP officials 

stated that, as of March 2012, the compliance unit is preparing the notice 

of intent to withdraw the school.

SEVP officials stated that staff typically will follow instruction from CTCEU 

or field investigators regarding either ceasing or taking administrative 

action, but the SEVP office may not know which schools are under 

investigation and CTCEU and field offices may not be fully informed on 

SEVP’s policies and procedures. SEVP officials stated that they may 

conduct administrative activities on schools that are not known to be 

under investigation because CTCEU and field office investigators have 

not routinely shared information regarding which schools are under 

investigation. However, the SEVP Director stated that his compliance unit 

staff have access to the TECS database, which includes information on

ongoing investigations being directed by CTCEU and field office 

investigators. He also stated that it is important for all program branches 

to coordinate to assure that those responsible for administrative activities 

do not continue activities when CTCEU or ICE field office investigators 

have requested such activity to cease. SEVP officials in the School 

Certification and Policy Branches stated that the program has previously 

taken administrative actions requested by CTCEU and ICE field offices in 

support of criminal investigations. However, these officials stated that 

because SEVP is responsible for taking administrative actions, the 

program officials need details on why the school is being withdrawn to 

include in the notice of withdrawal letters to protect the program against 

appeals and potential lawsuits. The SEVP Director stated that the 

standard operating procedure is a high-level document that does not 

account for the mitigating factors that may influence how his staff should 

respond to ongoing criminal investigations. According to the Director, the 

intent of the procedure, given past coordination issues, is to ensure his 

office receives ample notification from CTCEU of criminal investigations 

so that SEVP can take appropriate and timely administrative actions. The 

standard operating procedure does not specifically state what information 

CTCEU or field office investigators should provide to SEVP. Without 
 

Page 36 GAO-12-572 Student and Exchange Visitor Program

specification of this information, it will be difficult for CTCEU, field office 

investigators, and SEVP officials to share a clear of understanding of 

information needs for taking administrative action. Revising the standard 

operating procedure that governs the communication and coordination 

process between SEVP, CTCEU, and ICE field offices to more 

specifically delineate what information to share among the stakeholders 

during a criminal investigation could better position ICE to conduct 

criminal investigations and to better prevent and detect school fraud.

In addition, while the coordination standard operating procedure for 

SEVP, CTCEU, and ICE field offices requires that SEVP refer allegations 

or leads revealing possible criminal violations to CTCEU in a timely 

manner, the procedure does not have criteria for determining when 

certain noncompliant activity becomes potentially criminal. The SEVP 

compliance unit first shared its compliance case log with CTCEU in 

October 2011, during the course of our review. Upon review of this 

information, CTCEU officials stated that several of the compliance cases 

could involve potential criminal violations. CTCEU officials identified 

examples of potentially criminal violations, including designated school 

officials sharing SEVIS passwords, a school not holding classes but 

reporting attendance, a school reporting its own address as students’ 

addresses, and a school charging additional fees for showing students as 

compliant. CTCEU officials stated that SEVP officials had not previously 

shared these cases with them; therefore, CTCEU had not distributed the 

information to ICE field offices as potential leads for further investigation. 

Officials at six of the eight ICE field offices that we interviewed reported 

not having opened any school fraud investigations based on leads from 

SEVP and have relied on locally generated leads. According to officials at 

all eight ICE field offices that we interviewed, referrals of schools that may 

exhibit criminal behavior within the offices’ area of responsibility would 

prove useful in that agents could better target these potentially fraudulent 

schools for further review or investigation. The Compliance Unit Chief and 

the Policy Branch Chief stated that the program had not previously 

shared its compliance case log or other information regarding the 

program’s compliance monitoring activities with CTCEU because the unit 

has never asked for such information. However, the coordination 

standard operating procedures as well as internal control guidance 

indicate that agencies could benefit from sharing internally generated 

information with key stakeholders, which may help with fraud 

management efforts. By establishing criteria for identifying potentially 

criminal activity, SEVP would be better positioned to adhere to existing 

requirements of referring criminal cases to CTCEU for investigation.
 

Page 37 GAO-12-572 Student and Exchange Visitor Program

ICE aims to facilitate study in the United States for hundreds of thousands 

of foreign students each year. Effective oversight of SEVP entails 

balancing this objective against the program’s potential risks, including 

security vulnerabilities and opportunities for criminal exploitation. To find 

this balance, ICE is responsible for identifying the risks posed by schools, 

and being in a position to mitigate them. ICE has taken initial actions to 

identify program risks; however, it has not analyzed available information 

to identify and assess programwide risks, and make resource allocation 

decisions based on identified risks. Identifying and assessing program 

risks based on various factors, including information on prior and 

suspected cases of school noncompliance and fraud, and information 

from CTCEU and field office investigations and outreach events, could 

better position ICE to determine actions to help prevent school 

noncompliance and fraud and to address noncompliance and fraud when 

they occur. Further, developing and implementing a process to identify 

and assess risks could allow ICE to identify and address program 

weaknesses, take actions to strengthen school oversight, and allocate 

program resources in a more efficient and effective manner.

Moreover, there are opportunities for ICE to improve its ability to prevent 

and detect fraud through the initial certification and ongoing monitoring of 

schools. By implementing existing fraud control practices, ICE could 

enhance its ability to detect school certification fraud and gain greater 

assurance that its operations are designed to protect the integrity of the 

system, even as it strives to enhance service and address work backlogs, 

such as in the recertification process. Specifically, establishing 

procedures for verifying and ensuring the completeness of school 

evidence; addressing missing case files; monitoring the licensing, 

accreditation status, and FAA certification status of schools; and setting 

target time frames for completing procedures to address SEVP-certified 

flight schools that do not have, or have not maintained, required FAA 

certifications, could help ICE ensure that legitimate institutions participate 

in SEVP. Further, by strengthening coordination and communication 

between SEVP and CTCEU, ICE could better ensure that SEVP, CTCEU, 

and ICE field offices understand information to be shared with regarding 

whether to take administrative actions during criminal investigations and 

that clear criteria exist for referring cases from CTCEU based upon 

potentially criminal behavior.

Conclusions 
 

Page 38 GAO-12-572 Student and Exchange Visitor Program

To enhance ICE’s ability to assess program risks, prevent and detect 

school certification fraud, and improve the controls over SEVP, we 

recommend that the Assistant Secretary of Immigration and Customs 

Enforcement take the following eight actions:

• Develop and implement a process to identify and assess risks in 

SEVP, including

o evaluating prior and suspected cases of school noncompliance 

and fraud to identify potential trends, and

o obtaining and assessing information from CTCEU and ICE field 

office investigative and outreach efforts.

• Once a risk assessment process is in place, conduct an analysis of 

how to allocate SEVP’s resources based on risk and use the results of 

that analysis in making resource allocation decisions.

• Consistently implement procedures for ensuring schools’ eligibility, 

including consistently verifying “in lieu of” letters.

• Establish a process to identify and address all missing school case 

files, including determining the magnitude of the problem; obtaining 

required documentation for schools whose case files are missing 

evidence, as appropriate; and taking necessary compliance actions.

• Develop and implement a process to monitor state licensing and 

accreditation status of all SEVP-certified schools.

• Establish target time frames for notifying SEVP-certified flight schools 

that lack required FAA certification that they must re-obtain FAA 

certification.

• Revise the standard operating procedure that governs coordination 

among SEVP, CTCEU, and ICE field offices to specify what 

information to share among stakeholders during criminal 

investigations.

• Establish criteria for referring cases of a potentially criminal nature 

from SEVP to CTCEU.

We provided a draft of this report to DHS and the Department of State for 

their review and comment. DHS provided written comments, which are 

reproduced in full in appendix II. DHS concurred with our eight 

recommendations and described actions under way or planned to 

address them. DHS indicated that ICE plans to develop and complete a 

process to identify and assess risks in SEVP, as well as conduct an 

organizational analysis to determine if resources are properly allocated by 

risk. In addition, DHS indicated that ICE is developing a quality assurance 

process to ensure the completeness of records associated with school 

certification. DHS also indicated that SEVP personnel are developing 

procedures to ensure frequent validation of license or accreditation 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 39 GAO-12-572 Student and Exchange Visitor Program

information on SEVP-certified schools. These actions should help 

address the intent of our recommendations. DHS also provided technical 

comments, which we incorporated as appropriate.

The Department of State did not have formal comments on our draft 

report, but provided technical comments, which we incorporated as 

appropriate.

As agreed with your offices, 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 of this report to the 

Secretaries of Homeland Security and State, and appropriate 

congressional committees. 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 

have any questions concerning this report, please contact me at (202) 

512-6912, or gamblerr@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 are listed in appendix III.

Rebecca Gambler

Acting Director, Homeland Security and Justice Issues
 

Page 40 GAO-12-572 Student and Exchange Visitor Program

List of Requesters

The Honorable Charles E. Grassley

Ranking Member

Committee on the Judiciary

United States Senate

The Honorable Charles E. Schumer

Chairman

Subcommittee on Immigration, Refugees and Border Security

Committee on the Judiciary

United States Senate

The Honorable Dianne Feinstein

United States Senate

The Honorable Claire McCaskill

United States Senate
Appendix I: Scope and Methodology

Page 41 GAO-12-572 Student and Exchange Visitor Program

This report examines the extent to which U.S. Immigration and Customs 

Enforcement (ICE) has (1) identified and assessed risks in Student and 

Exchange Visitor Program (SEVP), and (2) developed and implemented 

policies and procedures to prevent and detect fraud during the initial 

school certification process and once schools begin accepting foreign 

students.

To determine the extent to which ICE identifies and assesses risk in the 

SEVP, we analyzed program documentation, collected and analyzed data 

on the population of SEVP-certified schools as of December 8, 2011, and 

interviewed officials from the Department of Homeland Security (DHS) 

and its components. We evaluated the extent to which ICE’s practices 

were consistent with Standards for Internal Control in the Federal 

Government and DHS’s Policy for Integrated Risk Management.

1

 

1

GAO, Standards for Internal Control in the Federal Government, 

In 

particular, we analyzed ICE and SEVP documentation, such as standard 

operating procedures, policy statements, and guidance for adjudicators, 

to determine how ICE’s processes and systems identify and assess risk 

in SEVP. To understand the magnitude of previous cases of fraud, we 

collected and evaluated information on previous cases of fraud through 

analyzing ICE press releases, as well as collecting documents and 

interviewing investigators from ICE’s Counterterrorism and Criminal 

Exploitation Unit (CTCEU). We reviewed publicly available information on 

12 cases of fraud dating from 2006 to 2011. The information obtained 

from these cases is not representative of all school fraud cases 

nationwide, but provided us with examples of school fraud. We also 

collected information from ICE on resources for SEVP, including budget 

data since fiscal year 2006, and information from ICE on SEVP’s contract 

to develop a risk-based approach for overseeing SEVP-certified schools. 

To evaluate ICE’s ability to identify and assess risk in SEVP, we 

examined information on SEVP’s data management systems, including 

the Student and Exchange Visitor Information System (SEVIS), SEVP 

Automated Management System (SEVPAMS), and I-17 Tracking and 

GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999) and Department of Homeland Security, DHS Policy for 

Integrated Risk Management (Washington, D.C.: May 27, 2010).

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 42 GAO-12-572 Student and Exchange Visitor Program

Reporting System.2 We analyzed SEVP’s compliance case log, which 

identifies specific SEVP-certified schools that are under additional review 

for suspected noncompliant activity. We analyzed these schools for 

specific school attributes—such as the type of school—of the potentially 

noncompliant schools. To determine the potential threat posed by 

designated school officials, who issue the Forms I-20 to the students and 

oversee all enrolled foreign students, we cross-referenced SEVP’s list of 

primary designated school officials (as of December 2011) with the 

Department of Justice’s National Security Division list of individuals 

convicted as a result of terrorism-related investigations through March 

2010, which was previously used in GAO’s work on criminal alien 

statistics, and found no matches.3

Moreover, we interviewed SEVP officials to evaluate the extent to which 

the program identifies and assesses risk. We met with senior officials 

from SEVP, including SEVP’s Director, Deputy Directors, and 

management for all branches—School Certification, Response, Policy, 

Analysis and Operations Center, Field Representative Program, Mission 

Support, and Information Technology. We also interviewed officials from 

CTCEU and criminal investigators from 8 of the 26 ICE field offices. We 

visited ICE field offices located in Atlanta, Georgia; Dallas, Texas; Miami, 

Florida; New York, New York; and Washington, D.C. We conducted 

telephone interviews with the ICE field offices in Los Angeles, San Diego, 

and San Francisco, California. We selected these locations based on a 

mix of criteria, including whether the office had any of the following 

characteristics: (1) investigated a case of school fraud; (2) had previous 

or current experience with school fraud based on CTCEU referrals; and 

(3) was investigating a school according to SEVP’s compliance case log 

during the period of this review. As we did not select a probability sample 

of ICE field offices to interview, the results of these interviews cannot be 

projected to all of ICE’s 26 field offices. However, the interviews provided 

 

2

SEVIS is a web-based application that is used by SEVP-certified schools to submit 

petitions for certification and recertification, update petition information, issue forms to 

students, and update student data. SEVIS is used by SEVP to certify and recertify 

schools, track students, and monitor schools’ program compliance. SEVPAMS is a system 

used by SEVP and intended to store and create documents associated with SEVPcertified schools such as documentation of initial petition, compliance review activity, and 

school information updates. The I-17 Tracking and Reporting System is a system used by 

SEVP and is intended to track the progress of schools applying for SEVP-certification. 

3

GAO, Criminal Alien Statistics: Information on Incarcerations, Arrests and Costs, 

GAO-11-187 (Washington, D.C.: Mar. 24, 2011).
Appendix I: Scope and Methodology

Page 43 GAO-12-572 Student and Exchange Visitor Program

us with the perspectives of ICE officials responsible for conducting school 

fraud investigations, including their views on the processes SEVP has 

established for certifying and monitoring these schools and any 

challenges field offices have faced in their investigations.

To determine the extent to which DHS has implemented policies and 

procedures to prevent and detect fraud, we analyzed the processes 

SEVP uses to (1) initially certify schools to enroll nonimmigrant foreign 

students; (2) maintain records to ensure schools’ continued eligibility; (3) 

monitor schools’ eligibility once certified; and (4) oversee schools offering 

flight training. We also analyzed the processes SEVP uses to manage 

and share key information with other ICE stakeholders, including CTCEU 

and ICE field offices. As part of our effort to evaluate these processes, we 

reviewed applicable laws and regulations, such as the Border Security 

Act and regulations governing nonimmigrant visa classes.4 We also 

reviewed ICE’s standard operating procedures for certifying and 

recertifying schools, recordkeeping, compliance reviews, and informationsharing during criminal investigations. In addition, we reviewed SEVP’s 

internal policies and guidance specifically concerning English language 

and flight schools and the recertification process. We compared these 

processes to criteria established in laws and regulations, as well as to 

criteria in the Standards for Internal Control in the Federal Government, 

the U.K. National Audit Office’s Good Practice in Tackling External Fraud, 

and the Project Management Institute’s The Standard for Program 

Management.

5

We collected and analyzed data from ICE’s SEVIS (as of December 8, 

2011) to identify schools certified by SEVP to enroll nonimmigrant foreign 

students under F and M visas. We assessed the reliability of these data 

by (1) reviewing existing documentation on the controls in the system and 

the policies for ensuring data reliability; and (2) interviewing agency 

officials about the data’s sources, the system’s built-in internal controls, 

and any quality assurance steps performed after data are entered into the 

system. We identified several limitations to the data due to ICE’s reliance 

 

4

8 U.S.C. § 1762. The regulations governing nonimmigrant classes are found in 8 C.F.R. 

pt. 214.

5

U.K. National Audit Office, Good Practice in Tackling External Fraud (London, England: 

2008) and Project Management Institute’s The Standard for Program Management © 

(2006). 
Appendix I: Scope and Methodology

Page 44 GAO-12-572 Student and Exchange Visitor Program

on school officials for data entry and updates. SEVIS is used by school 

officials to apply for and receive certification as well as to keep records of 

individual students who enter the United States on F and M visas. 

Although SEVP officials may allow a designated school official to make 

edits to the school’s petition, all data or information corrections are 

incumbent upon those school officials. Therefore, invalid data elements 

appear in the data, including entries for school names, as well as for 

mailing and physical location addresses, cities, and states. While we 

identified such limitations, we found the data sufficiently reliable for 

providing general background information on the population of SEVPcertified schools and selecting a sample of schools for which to conduct a 

case file review. We used SEVIS school data as the population from 

which to select a nongeneralizable stratified random sample of 50 SEVPcertified schools’ case files. To select the sample, we relied upon the data 

on certified schools (as of December 8, 2011) provided by SEVP. We 

focused our analysis on post-secondary schools that reported either 

being unaccredited or not being accredited by a Department of 

Education-recognized accrediting agency. We then stratified the 

population of post-secondary, unaccredited schools based on the 

schools’ reported type of education provided. These five strata included 

flight training, language training, religious training, combination of 

flight/language/religious training, and general post-secondary education. 

Our random sample of 50 SEVP-certified schools included at least one of 

each strata indicated. We analyzed the schools’ case files to evaluate 

SEVP maintenance of school records per program requirements found in 

SEVP’s recordkeeping standard operating procedure. Specifically, we 

verified that SEVP maintained historic and more current records of the 

schools’ accreditation or evidence provided in lieu of accreditation, school 

officials’ proof of citizenship or residency, school officials’ attestation 

statements, and flight schools’ FAA certification.

Further, we used the SEVIS data to identify all SEVP-certified schools 

that offer flight training by querying the following SEVIS categories: Type 

of Education and Nature of Subject Matter. We cross-referenced the list 

of schools that reported offering flight training to FAA’s lists of Part 141 

and Part 142 schools. We also cross-referenced the list of SEVP-certified 

schools offering flight training to information on FAA certificate 

revocations. We previously used FAA’s data on Part 141 and 142 flight 
Appendix I: Scope and Methodology

Page 45 GAO-12-572 Student and Exchange Visitor Program

schools and revocations in work on pilot training in the United States and 

found such data reliable.6

In addition to document and data collection and analysis, we interviewed 

the SEVP Director, Deputy Directors, and officials from SEVP’s branches 

as well as officials from CTCEU and our selected 8 SAC field offices to 

determine the extent to which ICE has policies and procedures to prevent 

and detect fraud within SEVP and to discuss SEVP’s management and 

information-sharing practices with CTCEU and SAC field offices. We also 

interviewed officials from Department of State to obtain officials’ views on 

State’s redesignation of exchange visitor sponsors and SEVP’s 

recertification of certified schools, which were both mandated in the 

Border Security Act. 

We conducted this performance audit from September 2011 through June

2012, in accordance with 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 on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 

6

GAO, Initial Pilot Training: Better Management Controls Are Needed to Improve FAA 

Oversight, GAO-12-117 (Washington, D.C.: Nov. 15, 2011).
Appendix II: Comments from the Department 

of Homeland Security

Page 46 GAO-12-572 Student and Exchange Visitor Program

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department 

of Homeland Security

Page 47 GAO-12-572 Student and Exchange Visitor Program
Appendix II: Comments from the Department 

of Homeland Security

Page 48 GAO-12-572 Student and Exchange Visitor Program
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 49 GAO-12-572 Student and Exchange Visitor Program

Rebecca Gambler, (202) 512-6912 or gamblerr@gao.gov

In addition to the contact named above, Kathryn H. Bernet, Assistant 

Director; Frances Cook, Mike Dino, Elizabeth Dunn, Anthony Fernandez, 

David Greyer, Kirsten Lauber, Lara Miklozek, Richard Stana, and Julia 

Vieweg made significant contributions to this work.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(441005)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.