Immigration Benefits: Additional Controls and a Sanctions Strategy Could Enhance DHS's Ability to Control Benefit Fraud
Published: 2006-03-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2002, GAO reported that immigration benefit fraud was pervasive and significant and the approach to controlling it was fragmented. Experts believe that individuals ineligible for these benefits, including terrorists and criminals, could use fraudulent means to enter or remain in the U.S. You asked that GAO evaluate U.S. Citizenship and Immigration Service's (USCIS) anti-fraud efforts. This report addresses the questions: (1) What do available data and information indicate regarding the nature and extent of fraud? (2) What actions has USCIS taken to improve its ability to detect fraud? (3) What actions does the Department of Homeland Security (DHS) take to sanction those who commit fraud?
section_title: What GAO Found
paragraphs: Although the full extent of benefit fraud is unknown, available evidence suggests that it is a serious problem. Several high-profile immigration benefit fraud cases shed light on aspects of its nature--particularly that it is accomplished by submitting fraudulent documents and can be facilitated by white collar and other criminals, with the potential for large profits. USCIS staff denied about 20,000 applications for fraud in fiscal year 2005. USCIS has established a focal point for immigration fraud, outlined a fraud control strategy that relies on the use of automation to detect fraud, and is performing risk assessments to identify the extent and nature of fraud for certain benefits. However, USCIS has not implemented important aspects of internal control standards established by GAO and fraud control best practices identified by leading audit organizations--particularly a comprehensive risk management approach, a mechanism to ensure ongoing monitoring during the course of normal activities, clear communication regarding how to balance multiple objectives, mechanisms to help ensure that staff have access to key information, and performance goals for fraud prevention. DHS does not have a strategy for sanctioning fraud. Best practices advise that a credible sanctions program, which includes a mechanism for evaluating effectiveness, is an integral part of fraud control. Because most immigration benefit fraud is not prosecuted criminally, the principal means of sanctioning it would be administrative penalties. Although immigration law gives DHS the authority to levy administrative penalties, the component of DHS that administers them does not consider them to be cost-effective and does not routinely impose them. However, DHS has not evaluated the costs and benefits of sanctions, including the value of potential deterrence. Without a credible sanctions program, DHS's efforts to deter fraud may be less effective, when applicants perceive little threat of punishment.

section_title: Letter
paragraphs: In fiscal year 2005, over 6 million applications were filed by those seeking  an immigration benefit—the ability of an alien to live and in some cases  work in the United States either permanently or on a temporary basis.  Most immigration benefits can be classified into two major categories— family-based and employment-based. Family-based applications are filed  by U.S. citizens or permanent resident aliens to establish their  relationships to certain alien relatives such as a spouse, parent, or minor  child who wish to immigrate to the United States. Employment-based  applications include applications filed by employers for aliens to come to  the United States temporarily to work or receive training or for alien  workers to work permanently in the United States. Other immigration  benefits include granting citizenship to resident aliens (called  naturalization), offering asylum to aliens who fear persecution in their  home countries, and authorizing international students to study in the  United States.
U.S. Citizenship and Immigration Services (USCIS) within the Department  of Homeland Security (DHS) is the agency primarily responsible for  processing applications for immigration benefits. The former Immigration  and Naturalization Service (INS) previously had this responsibility, which  USCIS assumed when DHS was created in March 2003. USCIS’s staff of  adjudicators process immigration benefits in 4 service centers and 33  district offices around the country. In some cases, applicants may try to  obtain a benefit illegally through fraud. USCIS adjudicators who suspect  fraud are to refer suspicious applications and supporting evidence to  USCIS’s Office of Fraud Detection and National Security (FDNS), created  in 2003. FDNS staff are responsible for reviewing these potential fraud  cases and determining whether to forward them to DHS’s Immigration and  Customs Enforcement (ICE)—which, among other things, is responsible  for investigating violations of immigration law, including immigration  benefit fraud. ICE may or may not decide to initiate a criminal  investigation, depending on the facts in the referral and on workloads and  priorities of its field offices.
DHS, terrorism experts, and federal law enforcement officials familiar  with immigration benefit fraud believe that individuals ineligible for  immigration benefits, including terrorists and criminals, could use  fraudulent means to enter or remain in the United States. In 2002, we  reported that immigration benefit fraud was pervasive and significant and  that INS’s approach to immigration benefit fraud was fragmented and  unfocused. A 2005 study by a former 9/11 Commission counsel found that  of the 94 foreign-born terrorists known to operate in the United States  between the early 1990s and 2004, 59 or two-thirds committed immigration  fraud including 6 of the September 11th hijackers. To determine what  actions have been taken since our 2002 report to address immigration  benefit fraud, you asked that we evaluate current anti-fraud efforts. This  report addresses the following questions:  (1) What do available data and information indicate regarding the nature  and extent of immigration benefit fraud?  (2) What actions has USCIS taken to improve its ability to detect  immigration benefit fraud?  (3) What actions does DHS take to sanction those who commit benefit  fraud?
To address these questions, we interviewed responsible officials at and  reviewed relevant documentation obtained from DHS and the  Departments of State, Justice, and Labor. Regarding the nature and extent  of immigration benefit fraud, we analyzed USCIS management data  contained in its Performance Analysis System (PAS), results from two  fraud assessments USCIS had completed before December 2005,  information reported by DHS and the U.S. Attorneys Offices based on  investigations and prosecutions of immigration benefit fraud, and  information in fraud bulletins prepared by one USCIS Service Center. We  evaluated the methodology used in USCIS’s fraud assessments and  determined that it provided a reasonable basis for projecting the frequency  with which fraud was committed within the time period from which the  samples were drawn. We assessed the data derived from PAS and  determined that these data were sufficiently reliable for the purposes of  this review. Because we selected investigations and prosecutions to  review based upon information that was available, the information  obtained from them is not necessarily representative or exhaustive of all  immigration benefits cases nationwide. Similarly, information contained in  the fraud bulletins is not necessarily representative of immigration benefit  fraud nationwide. To determine how USCIS detects fraud during the  adjudications process and to evaluate these efforts, we interviewed USCIS  headquarters officials and USCIS’s FDNS staff. We also interviewed 59  adjudicators at the 4 USCIS Service Centers and 2 USCIS district offices  with responsibility for and familiarity with adjudicating different types of  applications in a group setting, which allowed us to identify points of  consensus among these adjudicators. In addition we interviewed ICE  Office of Investigations officials from four ICE field offices. As we did not  select probability samples of adjudicators and ICE Office of Investigations  staff to interview, the results of these interviews may not be projected to  the views of all USCIS adjudicators and ICE Office of Investigations field  staff nationwide. Further, we compared the practices in place to the  Standards for Internal Control in the Federal Government and to guidance  from internationally recognized, leading organizations in fraud control,  including the American Institute of Certified Public Accountants and the  United Kingdom’s National Audit Office. To determine what measures  DHS has taken to sanction those who commit immigration fraud, we  interviewed knowledgeable officials at USCIS and ICE, examined fraud  investigation and prosecution statistics, and analyzed USCIS statistics  about the amount of fraud identified by its adjudicators. We conducted our  work from October 2004 to December 2005 in accordance with generally  accepted government auditing standards. Appendix I presents more details  about our objectives, scope, and methodology.
subsections: section_title: Background
paragraphs: USCIS is responsible for processing millions of immigration benefit  applications received each year for various types of immigration benefits,  determining whether applicants are eligible to receive immigration  benefits, and detecting suspicious information and evidence to refer for  fraud investigation and possible sanctioning by other components or  agencies. USCIS processes applications for about 50 types of immigration  benefits. In fiscal year 2005, USCIS received about 6.3 million applications  and adjudicated about 7.5 million applications. Figure 1 shows the  percentage of applications completed by type of application in fiscal year  2005.
To process these immigration benefit applications, in fiscal year 2005  USCIS had a staff of about 3,000 permanent adjudicators located in 4  service centers, where most applications are processed, and 33 district  offices. In fiscal year 2004, for example, service centers adjudicated about  67 percent of all applications, and districts about 33 percent. In general,  service centers adjudicate applications that do not require an interview  with the applicant, using the evidence submitted with the applications.  District offices generally adjudicate applications where USCIS requires an  interview with the applicant (e.g., naturalization). USCIS also has eight  offices that process applications for asylum in the United States. In fiscal  year 2005, USCIS’s budget amounted to just under $1.8 billion, of which  about $1.6 billion was expected from service fees and $160 million from  congressionally appropriated funds.
In fiscal year 2004, USCIS had a backlog of several million applications  and has developed a plan to eliminate it by the end of fiscal year 2006. In  June 2004, USCIS reported that it would have to increase production by  about 20 percent to achieve its goal of adjudicating all applications within  6 months or less by the end of fiscal year 2005. At that time, it estimated  that it would have to increase current annual processing from about 6  million to 7.2 million applications. Since USCIS did not plan for further  increases in staffing levels, reaching its backlog goal would require some  reduction in average application processing times, overtime hours, and  adjudicator reassignments.
With the creation of DHS in 2003, the immigration services and  enforcement functions of the former INS transitioned to different  organizations within DHS. USCIS assumed the immigration benefit  functions and ICE assumed INS’s investigative and detention and removal  of aliens functions. Within ICE’s Office of Investigations, the Identity and  Benefit Fraud unit now conducts immigration benefit fraud criminal  investigations and ICE’s Office of Detention and Removal Operations is  responsible for identifying and removing aliens illegally in the United  States.
Because the immigration service and enforcement functions are now  handled by separate DHS components, these components created two new  units to, among other things, help coordinate the referral of suspected  immigration benefit fraud uncovered by adjudicators to ICE’s Office of  Investigations. First, USCIS created FDNS in 2003 to, among other things,  receive fraud leads from adjudicators and determine which leads should  be referred to ICE’s Office of Investigations. To accomplish this task,  FDNS has Fraud Detection Units (FDU) at all four USCIS service centers  and the National Benefits Center. When fraud is suspected, the  applications are to be referred FDUs. The FDUs, comprised of Intelligence  Research Specialists and assistants, are responsible for further developing  suspected immigration fraud referrals to decide which leads should be  referred to ICE for possible investigation. FDU staff are also to refer to  ICE or other federal agencies applicants who may pose a threat to national  security or public safety or who are potentially deportable. FDUs are  responsible for following up on potential national security risks identified  during background checks of immigration benefit applicants. FDUs also  perform intelligence analysis to identify immigration fraud patterns and  major fraud schemes. In addition to establishing FDUs, in January 2005  FDNS assigned 100 new Immigration Officers to USCIS district offices,  service centers, and asylum offices to work directly with adjudicators to  handle fraud referrals and conduct limited field inquiries. Second, ICE’s  Office of Investigations created four new Benefit Fraud Units (BFU) in  Vermont, Texas, Nebraska, and California located either at or near the  four USCIS service centers. The ICE BFUs are responsible for reviewing,  assessing, developing, and when appropriate, referring to ICE field offices  for possible investigation immigration fraud leads and other public safety  leads received from the FDUs and elsewhere. Specifically, the ICE BFUs  are intended to identify those referrals that they believe warrant  investigation, such as organizations and facilitators engaged in large-scale  schemes or individuals who pose a threat to national security or public  safety, and refer them to ICE field offices. In turn, ICE field offices will  investigate and refer those cases they believe warrant prosecution to the  U.S. Attorneys Offices. Figure 2 illustrates the typical immigration benefit  fraud referral and coordination process.
The Homeland Security Act of 2002 created the office of the Citizenship  and Immigration Services Ombudsman. The ombudsman’s primary  function is to: assist individuals and employers in resolving problems with  USCIS; identify areas in which individuals and employers have problems in  dealing with USCIS; and propose changes in the administrative practices  of USCIS in an effort to mitigate problems. The ombudsman has issued  two annual reports that have highlighted issues related to prolonged  processing times, limited case status information, immigration benefit  fraud, insufficient standardization in processing, and inadequate  information technology and facilities.
Other federal agencies also play important roles in the immigration benefit  application process. The Department of State is responsible for approving  and issuing a visa allowing an alien to travel to the United States. The  Department of Labor’s (DOL) Division of Foreign Labor Certification  provides national leadership and policy guidance to carry out the  responsibilities of the Secretary of Labor under the Immigration and  Nationality Act (INA) concerning foreign workers seeking admission to  the United States for employment. DOL provides certifications for foreign  workers to work in the United States, on a permanent or temporary basis,  when there are insufficient qualified U.S. workers available to perform the  work at wages that meet or exceed the prevailing wage for the occupation  in the area of intended employment. The DOL Office of the Inspector  General’s Office of Labor Racketeering and Fraud Investigations is  responsible for investigating fraud related to these labor certifications.
section_title: Fraud Is A Serious Problem, But Its Full Extent Is Unknown
paragraphs: Fraudulent schemes used in several high-profile immigration benefit fraud  cases sheds light on some aspects of the nature of immigration benefit  fraud—particularly that it is accomplished by submitting fraudulent  documents, that it can be committed by organized white-collar and other  criminals, and that it has the potential to result in large profits for these  criminals. The benefit fraud cases we reviewed involved individuals  attempting to obtain benefits for which they were not eligible by  submitting fraudulent documents or making false claims as evidence to  support their applications. Fraudulent documents submitted included but  were not limited to birth and marriage certificates, tax returns, financial  statements, business plans, organizational charts, fictitious employee  resumes, and college transcripts. For example, in what ICE characterized  as one of the largest marriage fraud investigations ever undertaken, 44  individuals were indicted in November 2005 for their alleged role in an  elaborate scheme to obtain fraudulent immigrant visas for hundreds of  Chinese and Vietnamese nationals. According to a USCIS fraud bulletin,  this scheme may have been ongoing for 10 years. Another major  investigation revealed evidence that an attorney had filed about 350  applications on behalf of aliens seeking permanent employment as  religious workers at religious institutions in the United States.  Investigators found evidence that most of these aliens were unskilled  laborers who were not pastors or other religious workers and had little or  no previous affiliation with the religious institution. According to this  investigation, some religious institutions appeared to specialize in  obtaining legal status for aliens in the country who were not eligible for  religious worker immigration benefits. In another investigation involving  at least 2,800 apparently fraudulent marriage and fiancée applications  identified in 2002 and investigated through 2004, a U.S. citizen appeared to  have submitted multiple applications with as many as 11 different spouses.
One USCIS Service Center prepared fraud bulletins using information from  various State Department Consular posts overseas describing immigration  fraud uncovered by these posts. Our analysis of the bulletins issued from  July 2004 through December 2004 prepared by USCIS’s California Service  Center revealed that aliens from 23 different countries were believed to  have sought a variety of immigration benefits fraudulently. For example,  individuals apparently sought to enter the United States through fraud by  falsely claiming they were: (1) legitimately married to or a fiancé of a U.S.  citizen; (2) a religious worker; (3) a performer in an entertainment group;  (4) a person with extraordinary abilities, such as an artist, race car driver,  or award winning photographer; (5) an executive with a foreign company;  (6) a child or other relative of a citizen or permanent resident; or (7) a  domestic employee of an alien legally in the United States, such as a  diplomat or business executive. According to one of the bulletins, in one  case State Department consular officers suspected illegal aliens were  entering the United States under the guise of membership in a band.  According to another bulletin, two individuals were suspected of  smuggling children into the United States. In this case, the alleged parents  submitted a non-immigrant visa application for their “daughter,” and  provided a fraudulent birth certificate and passport for her. The “parents”  eventually admitted to taking children to the United States as their own to  reunite them with their illegally working family members.
Some individuals seeking immigration benefits pose a threat to national  security and public safety, and white collar and other criminals sometimes  facilitate immigration benefit fraud. For example, according to FDNS, each  year about 5,200 immigration benefit applicants are identified as potential  national security risks, because their personal information matches  information contained in U.S. Customs and Border Protection’s  Interagency Border Inspection System, a database of immigration law  violators and people of national security interest. Additionally, according  to federal prosecutors, immigration benefit fraud may involve other  criminal activity, such as income tax evasion, money laundering,  production of fraudulent documents, and conspiracy. Also, organized  crime groups have used sophisticated immigration fraud schemes, such as  creating shell companies, to bring in aliens ostensibly as employees of  these companies. In addition, a number of individuals linked to a hostile  foreign power’s intelligence service were found to have been employed as  temporary alien workers on military research.
Investigations have revealed that perpetrating fraud on behalf of aliens can  be a profitable enterprise. For instance, in 2003 and 2004, one USCIS  service center identified about 2,800 apparently fraudulent marriage  applications between low-income U.S. citizens and foreign nationals from  an Asian country. The U.S. citizens appeared to have been paid between  $5,000 and $10,000 for participating in the marriage fraud scheme. In  another example from an investigation by DOL’s Inspector General, to  fraudulently obtain the labor certifications needed to work in the United  States, at least 900 aliens allegedly paid a recruitment firm an average of  $35,000, with some aliens paying as much as $90,000, resulting in at least  $31 million in revenue for this firm. In one of the largest labor certification  fraud schemes ever uncovered, federal investigators found evidence that a  prominent immigration attorney in the Washington, D.C., area submitted at  least 1,436 and perhaps as many as 2,700 fraudulent employment  applications between 1998 and 2002. According to the sworn testimony of  a DOL special agent, this attorney and his associates are alleged to have  made at least $11.4 million for the 1,400 applications that the agent  reviewed, in all of which he found evidence of fraud, and perhaps as much  as $21.6 million if all 2,700 applications were fraudulent, as he strongly  suspected. In another case, an attorney allegedly charged aliens between  $8,000 and $30,000 to fraudulently obtain employment-based visas to work  in more than 200 businesses that included pizza parlors, auto parts stores,  and medical clinics.
Although the full extent of immigration benefit fraud is unknown, available  USCIS data indicate that it is a serious problem. According to USCIS PAS  data, in fiscal year 2005, USCIS denied just over 20,000 applications  because USCIS staff detected fraudulent application information or  supporting evidence during the course of adjudicating the benefit request.  Three application categories accounted for more than three-quarters of the  fraud denials: temporary work authorization (36 percent), application for  permanent residency (30 percent), and application for a spouse to  immigrate (14 percent). These three application types also accounted for  almost half of all applications adjudicated by USCIS in fiscal year 2005.  Moreover, in fiscal year 2005, USCIS denied approximately 800,000  applications for other reasons, such as ineligibility for the benefit sought  or failure to respond to information requests. USCIS adjudications staff  and officials told us that it is likely that some of these applications denied  for other reasons also involved fraud.
Information provided by State Department and DOL officials also indicates  that fraud is a serious problem. Once USCIS approves a sponsor’s  application on behalf of an alien to immigrate, the application is sent to  the State Department’s National Visa Center, which forwards the  application to the appropriate State Department overseas consulate post,  which then interviews the alien to determine whether a visa should be  issued. According to National Visa Center officials, out of 2,400  applications returned on average each month to USCIS by the National  Visa Center, that are denied or withdrawn for various reasons, about 900  involve fraud or suspected fraud as determined by consular officers  overseas. When the DOL Inspector General audited labor certification  applications filed in 2001, it also found indications of a significant amount  of fraud. According to the Inspector General, of the approximate 214,000  applications filed from January 1, 2001, through April 30, 2001, and not  subsequently cancelled or withdrawn, 54 percent (about 130,000)  contained false—possibly fraudulent—information.
In June 2005, the FDNS completed the first in a series of fraud  assessments. The results from this assessment of religious worker  applications indicate that about 33 percent of the 220 sampled applications  resulted in a preliminary finding of potential fraud. Based on a 33 percent  rate, we estimate that, during the 6-month period of fiscal year 2004 from  which the sample was drawn, about 660 out of approximately 2,000  applications may have been fraudulent. Of the 72 potential fraud cases  discovered in the fraud assessment, about 54-percent (39 cases) showed  evidence of tampering or fabrication of supporting documents; 44-percent  (32 cases) of the petitioners’ addresses did not reveal a bona fide religious  institution; about 42-percent (30 cases) may have misrepresented the  beneficiaries’ qualifications; and 28-percent (20 cases) did not provide the  salary noted in the application. The assessment also uncovered one case  where law enforcement had identified an applicant as a suspected  terrorist.
Information from other investigations and prosecutions of benefit fraud  also reveal that, in some cases, applicants may have submitted fraudulent  documents and made false statements that were not detected before the  applicant obtained an immigration benefit. For example, while  investigating one fraud scheme, investigators identified more than 2,000  apparently fraudulent applications where there was evidence that some  aliens, fraudulently claiming to be managers and executives of foreign  companies with U.S. affiliates, acquired benefits that granted them the  ability to work in the United States. To execute this scheme, organizers  allegedly prepared application packages that included fraudulent business  and employee related documents including financial statements, business  plans, organizational charts, and fictitious employee resumes.
One joint law enforcement investigation, previously mentioned, uncovered  evidence that an attorney and his associate had filed at least 1,436  applications on behalf of legitimate companies—mostly local  restaurants—that did not actually request these workers. In this case there  was evidence that they forged the signatures of company management on  the applications. Another investigation involving marriage fraud found  evidence that U.S. citizens were recruited and paid to marry Vietnamese  nationals. The fraud organizers appeared to have assisted the U.S. citizens  in obtaining their passports, scheduled travel arrangements, and escorted  them to Vietnam where they arranged introductions with Vietnamese  nationals whom the citizens then married. These citizens then filed  applications that facilitated these Vietnamese nationals’ entry into the  United States as spouses even though it appeared that they did not intend  to live together as husband and wife.
Even when adjudicators rejected applications based on fraud, some of  these applicants had already received interim benefits while their  applications were pending final adjudication allowing them to live and  work in the United States, and in some cases obtain other official  documents, such as a driver’s license. Under current USCIS policy, for  example, if USCIS cannot adjudicate an application for permanent  residency and the accompanying application for work authorization within  90 days, the applicant is entitled to an interim work authorization, an  interim benefit designed to let applicants work while awaiting a decision  regarding permanent residency. According to the Citizenship and  Immigration Services Ombudsman’s fiscal year 2004 and 2005 annual  reports and our discussion with him, for many individuals the primary goal  is to obtain temporary work authorization regardless of the validity of  their application for permanent residency. That is, aliens can apply for  temporary work authorization, knowing that they do not qualify for  permanent residency, with the intent of exploiting the system to gain work  authorization under false pretenses.
Once a temporary work authorization is fraudulently obtained, an alien  can use it to obtain other valid identity documents such as a temporary  social security card and a driver’s license, thus facilitating their living and  working in the United States. According to the FDNS Director, once such  fraud scheme involved at least 2,500 individuals in Florida who allegedly  filed frivolous applications for employment authorization and then used  the receipt, showing they had filed an application, to obtain Florida State  driver’s licenses or identification cards. ICE agents we interviewed also  said that they suspected that many individuals apply for permanent  residency fraudulently simply to obtain a valid temporary work  authorization document. The interim benefit remains valid until it expires  or until it is revoked by USCIS.
In his 2005 report, the Ombudsman cites a DHS Office of Immigration  Statistics estimate—which the ombudsman’s office confirmed with  USCIS’s division of performance management—that about 85 percent of  applicants for permanent residency also apply for temporary work  authorization. As a result, according to the ombudsman, many aliens have  received temporary work authorizations, for which they were later found  to be ineligible. Our analysis of PAS data shows, for example, that from  fiscal year 2000 through 2004, USCIS denied 26,745 applications due to  fraud out of the approximately 3 million applications received for  permanent residency. These data illustrate that, if aliens that filed  fraudulent applications for permanent residency also requested temporary  work authorization at a rate consistent with the 85 percent cited by the  Office of Immigration Statistics, then thousands of aliens received  temporary work authorization based on their fraudulent claims for  permanent residency during fiscal year 2000 through 2004.
section_title: Although USCIS Has Taken Steps to promote Fraud Control, Additional Controls and Best Practices Could Improve Its Ability to Detect Fraud
paragraphs: To help it detect immigration benefit fraud, USCIS has taken some  important actions consistent with activities prescribed by the Standards  for Internal Control in the Federal Government and with recognized best  practices in fraud control. Specifically, it has established an internal unit  to act as its focal point for addressing immigration benefit fraud, outlined  a strategy for detecting immigration benefit fraud, and is undertaking a  series of fraud assessments to identify the extent and nature of fraud for  certain immigration benefits. However, USCIS has not applied some  aspects of internal control standards and fraud control best practices that  could further enhance its ability to detect fraud.
subsections: section_title: Internal Control Standards and Other Guidance Provide Direction for Establishing Good Fraud Control Practices
paragraphs: The Standards for Internal Control in the Federal Government provide an  overall framework to identify and address, among other things fraud,  waste, abuse, and mismanagement. Implementing good internal control  activities and establishing a positive control environment is central to an  agency’s efforts to detect and deter immigration benefit fraud. The  standards address various aspects of internal control that should be  continuous, built-in components of organizational operations, including  the control environment, risk assessment, control activities, information  and communications, and monitoring.
As with work we have previously published related to managing improper  payments, fraud control would typically require a continual interaction  among these components in keeping with an agency’s various objectives.  For example, internal controls that promote ongoing monitoring work  together with risk assessment controls to provide a foundation for  decision making. Also, as internal control standards advise, a precondition  to risk assessment is the establishment of clear, consistent agency  objectives. Once established, risk assessment controls must also work  together with information and communication controls to ensure that that  every level of the agency is cognizant of the commitment and approach to  both controlling fraud and meeting other agency objectives. Similarly,  conditions governing risk change frequently, and periodic updates are  required to ensure that risk information—including threats, vulnerabilities,  and consequences—stays current and relevant. Information collected  through periodic assessment, as well as daily operations can inform the  assessment, and particularly, the analysis of risk. As shown in figure 3, the  control environment surrounds and reinforces the other components, but  all components work in concert toward a central objective, which, in this  case, is to minimize immigration benefit fraud.
Other audit organizations have published guidance that includes  discussion of sound management practices for controlling fraud that  complement the internal control standards. Among these are the American  Institute of Certified Public Accountants (AICPA) guidance on  management of antifraud programs and controls to help prevent and deter  fraud and a fraud control practices guide developed by the United  Kingdom’s National Audit Office (NAO) entitled “Good Practices in  Tackling External Fraud.” The NAO guidance outlines a risk-based  strategic approach to combating fraud that also includes evaluating the  effectiveness of sanctions.
section_title: Consistent with Internal Control Standards and Fraud Control Best Practices, USCIS Has Established a Fraud Focal Point, Related Strategies, and a Fraud Assessment Program
paragraphs: According to internal control standards, factors leading to a positive  control environment include clearly defining key areas of authority and  responsibility, establishing appropriate lines of reporting, and  appropriately delegating authority and responsibility for operating  activities. Similarly, the NAO fraud control guidance advises agencies to  develop specific strategies to coordinate their fraud control efforts and to  ensure that someone is fully responsible for implementing the plans in the  way intended and that sufficient resources are in place. Consistent with  internal control and best practice guidance, USCIS established the FDNS  office to enhance its fraud control efforts by serving as its focal point for  addressing immigration benefit fraud.
Established in 2003, FDNS is intended to combat fraud and foster a  positive control environment by pursuing the following objectives:    develop, coordinate, and lead the national antifraud operations for    oversee and enhance policies and procedures pertaining to the  enforcement of law enforcement background checks on those applying  for immigration benefits;  identify and evaluate vulnerabilities in the various policies, practices  and procedures that threaten the legal immigration process;  recommend solutions and internal controls to address these  vulnerabilities; and    act as the primary USCIS conduit and liaison with ICE, U.S. Customs  and Border Protection (CBP), and other members of the law  enforcement and intelligence community.
In September 2003, in support of its objectives, FDNS outlined a strategy  for detecting immigration benefit fraud in USCIS’s National Benefit Fraud  Strategy. According to the strategy, because most immigration benefit  fraud begins with the filing of an application, a sound approach to fraud  prevention begins at the earliest point in the process—the time an  application is received. Accordingly, USCIS established FDNS Fraud  Detection Units (FDU) in each of the service centers in order to help  identify potential fraud and process adjudicator referrals. Subsequently,  FDNS appointed staff to serve as Immigration Officers working directly  with adjudicators at the service centers and district offices to identify  potential fraud and, to some extent, verify fraud through administrative  inquiries—once it was determined that ICE had declined to investigate a  referral—in order to assist adjudicators in making eligibility  determinations.
The strategy also discusses various technological tools to help the FDUs  detect fraud early in the process—in particular, by enabling FDNS staff to  check databases to confirm applicant information and by developing new  automated tools to analyze application system data using known fraud  indicators and patterns to help identify potential cases of fraud. USCIS has  hired a contractor to develop for FDNS an automated capability to screen  incoming applications against known fraud indicators, such as multiple  applications received from the same person. According to FDNS, it plans  to deploy an initial data analysis capability by the third quarter of fiscal  year 2006 and release additional data analyses capabilities at later dates,  but could not predict when these latter capabilities would be achieved.  However, according to an FDNS operations manager, the near and  midterm plans are not aimed at providing a full data mining capability. In  the long term, USCIS plans to integrate these data analyses tools for fraud  detection into a new application management system being developed as  part of USCIS’s efforts to transform its business processes for adjudicating  immigration benefits, which includes developing the information  technology needed to support these business processes. Also, in the long  term, according to the FDNS Director, a new USCIS application  management system would ideally include fraud filters to screen  applications and remove suspicious applications from the processing  stream before they are seen by adjudicators.
FDNS has adopted as one of its objectives the identification and  evaluation of vulnerabilities in USCIS policies, practices, and procedures  that threaten the immigration benefit process. Consistent with this  objective and good internal control practices, in February 2005, FDNS  began to conduct a series of fraud assessments aimed at determining the  extent and nature (i.e., how it is committed) of fraud for several  immigration benefits that FDNS staff determined, based on past studies  and experience, benefit fraud may be a problem. To conduct these  assessments, FDNS first selected a statistically valid sample of  applications.  FDNS field staff then attempted to verify whether key  information on the applications was true. They did this by doing such  things as comparing information contained in benefit applications with  information in USCIS data systems and law enforcement and commercial  databases, conducting interviews with applicants, and, in some cases,  visiting locations to verify, for example, whether a business actually  existed. As of December 2005, FDNS had completed its assessment of the  religious worker application and replacement of permanent resident card  applications, and was in the process of completing the assessment of two  immigrant worker application subcategories. As of December 2005, FDNS  planned to initiate two other assessments in January 2006 and another at a  later time.
section_title: Additional Internal Controls and Use of Other Best Practices Could Further Improve USCIS’s Ability to Detect Benefit Fraud
paragraphs: Although USCIS has taken some important steps consistent with internal  control standards and other good fraud control practices, it has not yet  implemented some aspects of internal control standards and fraud control  best practices that could further enhance its ability to detect fraud.  Specifically, it lacks (1) a comprehensive approach for managing risk, (2) a  monitoring mechanism to ensure that knowledge arising from routine  operations informs the assessment of policies and procedures, (3) clear  communication regarding how to balance multiple agency objectives, (4) a  mechanism to help ensure that adjudicators staff have access to important  information, and (5) performance goals related to fraud prevention.
subsections: section_title: USCIS Has Not Adopted a Comprehensive Risk Management Approach to Help Guide Its Fraud Control Efforts
paragraphs: Although FDNS has initiated a fraud assessment program that identifies  vulnerabilities for the specific benefit being assessed, it does not employ a  comprehensive risk management approach to help guide its fraud control  efforts. That is, FDNS has not (1) developed a plan for assessing the  majority of benefits that USCIS administers, (2) fully incorporated threat  and consequence information as part of the assessment process, and (3)  applied a risk-based approach to evaluating alternatives for mitigating  identified vulnerabilities.
A central component of the Standards for Internal Control in the Federal  Government is risk assessment, which includes identifying and analyzing  risks that agencies face from internal and external sources and deciding  what actions should be taken to manage these risks. NAO’s fraud control  guide also advises that in the fraud context, risk assessment involves such  things as assessing the size of the threat from external fraud, the areas  most vulnerable to fraud, and the characteristics of those who commit  fraud. Moreover, we have consistently advocated a model of risk  management that takes place in the context of clearly articulated goals  and objectives and includes comprehensive assessments of threats,  vulnerabilities, and consequences to help agencies evaluate and select  among alternatives for mitigating risk in light of the potential for a given  activity to be effective, the related cost of implementing the activity, and  other relevant management concerns (including its impact on other  agency objectives).
FDNS fraud assessments are an initial step toward adopting a risk  management approach. However, FDNS has no specific plans to assess the  majority of the benefit types that it administers. FDNS’s current plan calls  for assessing benefit types that represent only about 25 percent of the  applications USCIS received in fiscal year 2004, for example, and do not  include benefits like temporary work authorization which accounted for  almost 30 percent of applications received in 2004, and which the CIS  Ombudsman suspects may be a high risk for fraud, and for which PAS data  show a high denial rate for fraud. FDNS officials told us that, although the  fraud assessments have been valuable, they have taken more time and  effort than originally planned. Likewise, FDNS has not established a  strategy and methodology for prioritizing any future fraud assessments.  Until it extends the assessments to additional benefit types, the fraud  assessments offer only limited information about vulnerabilities to the  immigration benefits system  Moreover, the approach to risk management that we advocate calls for the  assessment of threats and consequences, in addition to the vulnerability  information provided by the current approach to fraud assessment.  Currently, the fraud assessments do not incorporate a comprehensive  threat assessment—that is, they do not draw on all available sources of  threat information—for example, information that might be available from  such sources as ICE’s Office of Intelligence and other DHS intelligence  gathering efforts. Threat assessment might help FDNS identify, for  example, whether terrorists might be more likely to try to exploit certain  immigration benefits. Neither do the fraud assessments include an  assessment of the consequences of granting a particular benefit to a  fraudulent filer. Such an assessment might help USCIS determine the  relative harm that granting such a benefit might pose to the United States  and its immigration benefit system. Although ultimately any benefit  obtained under false pretenses undermines the system established by U.S.  immigration law, consideration of whether, for example, granting a  specific benefit may also facilitate easier access for potential terrorists to  critical infrastructure or pose a greater detriment to the U.S. economy  could inform sound risk-based decision making.
Equipped with a more comprehensive understanding of the risks it faces— particularly which benefits represent the highest risk, USCIS management  would then be in a better position to select appropriate risk mitigation  strategies and actions, particularly in situations where it is necessary to  make resource trade-offs or to balance multiple agency objectives. For  example, an obvious vulnerability to the immigration benefit system is the  submission of false eligibility evidence. Currently, however, USCIS  procedures do not include the verification of any eligibility evidence for  any benefit, despite its potential to help mitigate vulnerability to fraud.  Verification of such evidence—by comparing it to other information in  USCIS databases, by checking it against external sources of information,  or by interviewing applicants—is the most direct and effective strategy for  mitigating this vulnerability. Employer wage data reported to state labor  agencies, for example, could be a useful source of information to help  determine if an employer has paid prevailing wages. Data from state motor  vehicle departments can be used to verify that the two individuals claiming  to be married live at the same address. We previously reported that USCIS  could benefit from verifying employer related information with the  Internal Revenue Service. USCIS adjudicators told us that access to  commercial databases that provide identification and credential  verification would be helpful in verifying information contained in benefit  applications. Additionally, district office adjudicators told us that it was  often only during interviews that fraud became evident, even when their  earlier review had not raised suspicions. A successful State Department  effort offers further evidence that the practice of verifying key information  can be an effective mitigation strategy. Due to a high incidence of fraud in  a program that allows foreign companies to bring executives into the  United States, one State Department consular post in Latin America began  verifying with local authorities two key pieces of evidence that applicants  were required to submit. According to the post, it subsequently noticed a  decrease in the number of potentially fraudulent applications for this  benefit.
On the other hand, verifying any applicant-submitted evidence in pursuit  of its fraud-prevention objectives represents a resource commitment for  USCIS and a potential trade-off with its production and customer service- related objectives. In fiscal year 2004, USCIS had a backlog of several  million applications and has developed a plan to eliminate it by the end of  fiscal year 2006. In June 2004, USCIS reported that it would have to  increase monthly production by about 20 percent to achieve its  legislatively mandated goal of adjudicating all applications within 6  months or less by the end of fiscal year 2006. According to USCIS, because  it does not plan to increase its current overall staffing level, meeting its  backlog reduction goal will require some combination of reductions in the  standard processing time for various applications, overtime hours, and  adjudicator reassignments. It would be impossible for USCIS to verify all  of the key information or interview all individuals related to the millions of  applications it adjudicates each year—approximately 7.5 million  applications in fiscal year 2005—without seriously compromising its  service-related objectives. Identifying situations and benefits that  represent the highest risk to USCIS could help its management determine  whether and under what circumstances verification is so vital to  maintaining the integrity of the immigration benefits system that it  outweighs any potential increase in processing time and costs. In this  example, such an approach to risk management would inform selection  among alternative verification strategies by considering (1) the risk of  failing to detect fraud based on information provided by assessments of  vulnerabilities, threats, and consequences, (2) the cost of conducting the  verification (including its effect on other organizational objectives like  service), and (3) the potential for the verification activities, given the  current tools and information available, to actually detect fraud.
In addition to procedural vulnerabilities like the verification example, a  risk management approach could also guide USCIS in the evaluation of  policies that strike a balance between two or more agency objectives and  organizational priorities. For example, as previously discussed, USCIS’s  policy of granting interim employment authorization documents to  applicants whose adjustment of status applications have not been  adjudicated within 90 days can be exploited by aliens seeking to gain work  authorization under false pretenses and to use work authorization to  obtain valid identity documents such as temporary social security cards  and drivers licenses. In his 2004 and 2005 annual reports, the CIS  Ombudsman identified this policy as a significant vulnerability in the  immigration benefits process, because he contends that for many  individuals the primary goal is to obtain temporary work authorization  regardless of the validity of their applications for permanent residency. On  the other hand, as we have previously reported, the reason for issuing  temporary work authorization is to allow legitimate applicants to work as  soon as possible, which according to USCIS, can serve to reduce the  negative effects of delay on applicants and their families. Using more  comprehensive risk information to evaluate policies that represent trade- offs between fraud control and other agency objectives may help USCIS  management determine whether and to what extent unintended policy  consequences like in this example place the integrity of the immigration  benefits system at risk. This kind of risk management approach also would  provide USCIS management an opportunity to evaluate and select among  various approaches to balancing fraud control with other agency  objectives. In the temporary work authorization example, USCIS could  evaluate a variety of alternative strategies and select among them on the  basis of all available information, including risk. These strategies might  include: (1) maintaining the current policy if it is found to pose a tolerable  level of risk, (2) seeking applicable regulatory changes, or (3) applying the  policy disparately, to the extent allowed by law, across benefit types based  on the level of risk each represents. In commenting on a draft of this  report, DHS stated that a proposed regulatory change would clarify  USCIS’s ability to withhold the adjudication of an application for  employment authorization pending an ongoing investigation.
section_title: USCIS Lacks a Mechanism to Ensure That Ongoing Monitoring Occurs in the Course of Normal Operations
paragraphs: Internal control standards advise that controls should be generally  designed to ensure that ongoing monitoring occurs in the course of normal  operations and is ingrained in the agency’s operations. FDNS’s fraud  assessment program provides some information about how fraud is  committed in the form of concentrated periodic assessments. However,  currently USCIS does not have a mechanism to ensure routine feedback to  FDNS about vulnerabilities identified during the course of normal  operations and to incorporate it into adjudication policies and procedures.
Besides information about vulnerabilities obtained from its operational  experience adjudicating applications, additional information might be  available to FDNS from external entities that also have responsibility for  some aspect of controlling benefit fraud. One external source of fraud  information that might inform USCIS operations is the U.S. Attorneys  Office, which prosecutes immigration benefit fraud cases. For example,  one U.S. Attorney, based on cases his office has prosecuted, has issued  memoranda showing how underlying regulatory and adjudication  processes have invited abuse of the immigration system. A March 2005  memorandum prepared by this office explained how a recent investigation  revealed significant weaknesses in the asylum process that allowed  ineligible aliens to obtain asylum, and made suggestions for reforming the  process. The memorandum stated that these suggestions were intended to  start a discussion among federal agencies with immigration  responsibilities that could lead to needed reforms. In commenting on a  draft of this report, DHS stated that USCIS is developing a plan of action to  work with other DHS entities and the Executive Office of Immigration  Review within the Department of Justice to respond to specific  recommendations made by the U.S. Attorney that prepared the  memorandum on asylum program weaknesses.
Another source of information available to USCIS about fraud  vulnerabilities are the criminal investigations conducted by ICE, DOL, and  the DHS Office of Inspector General, which could reveal such  information as the characteristics of those who commit fraud and how  these individuals exploited weaknesses in the immigration benefit process  to obtain benefits illegally. USCIS’s National Benefit Fraud Strategy does  not mention incorporating lessons learned from investigative and  prosecutorial activities into its fraud control efforts—specifically, how the  knowledge ICE, DOL, and DHS investigators and U.S. Attorneys gained  during the course of investigations and prosecutions could be collected  and analyzed in order to become aware of opportunities to reduce fraud  vulnerabilities. A mechanism to help ensure that information from these  and related sources results in appropriate refinements to policies and  procedures could enhance USCIS’s efforts to address fraud vulnerabilities.
DOL, which plays an important role in the benefits process for some  permanent employment benefits, has used external information to refine  its procedures in this way. Specifically, it analyzed the results of major  criminal investigations and prosecutions to evaluate and establish new  procedures that require verifying key application information, such as the  existence of a business. DOL found it was necessary to change its  permanent labor certification procedures to require verification of basic  application information in order to mitigate the risk of mistakenly  approving permanent labor certification applications, and protect the  fundamental integrity of the labor certification process from blatant  abuse.
section_title: USCIS May Not Clearly Communicate the Importance of Fraud Control and How Adjudicators Are to Balance It with Other Objectives
paragraphs: Internal control standards advise that for agencies to manage their  operations, they must have relevant, reliable, and timely communications.  Furthermore, establishing a positive fraud control environment is central  to an agency’s efforts to detect and deter immigration benefit fraud. The  NAO guidance also advises management to ensure that all levels of the  organization are made to share a concern about fraud. It is the stated  mission of USCIS to provide the right benefit, to the right person, at the  right time, and no benefit to the wrong person. Specifically, it aims to  adjudicate all benefit requests within 6 months of receipt, without  compromising the integrity of the process, nor significantly increasing  staff. These objectives—speed, quality, and cost—are inherently in tension  with one another. Therefore, it is particularly important, given USCIS’s  multiple objectives, that it clearly communicates the importance of each of  the objectives at every level of the organization, and provides clear  guidance to adjudicators about how to balance them in the course of their  daily duties.
Although USCIS’s backlog elimination plan acknowledges the need to  balance its focus on reducing the backlog with efforts to ensure  adjudicative quality, some USCIS adjudicators we interviewed indicated  that it was not clear to them how the agency expected them to balance  fraud detection efforts and production goals during the course of their  duties. Adjudicators we spoke with said that communications from  management emphasized meeting production backlog goals almost  exclusively. They said that management’s focused attention on reducing  the backlog placed additional pressure on them to process applications  faster, thereby increasing the risk of making incorrect decisions, including  approving potentially fraudulent applications. For example, adjudicators  at all four service centers we spoke with told us that operations  management seemed to be almost exclusively focused on reducing the  backlog in order to meet production goals. USCIS headquarters  operations management responsible for overseeing adjudications at  service centers and district offices told us that the adjudications operation  is a “high-pressure” production environment and that they are seeking to  increase production, but it was not their intention that this should come at  the expense of making incorrect adjudication decisions.
The FDNS Director told us that he had also discussed with operations  management the need to strike a more balanced approach to meeting  production goals and ensuring that the right eligibility decision is made.  He acknowledged that until FDNS establishes an ability to proactively  identify fraud through its automated analysis tools, adjudicators will  continue to play a primary role in detecting fraud. Therefore, he  acknowledged the importance of clear and balanced communications  from operations management to adjudicators in support of USCIS’s new  fraud detection process and the shared responsibilities in this regard.
Nevertheless, adjudicators we interviewed told us that they have received  guidance from different parts of the agency regarding the lengths to which  they should go in confirming suspected fraud that they were uncertain  how to interpret. For example, in December 2004, the FDNS Director  issued guidance stating that adjudicators should obtain the evidence  needed to support their suspicions of fraud before making a referral,  including, if necessary, requesting additional evidence from applicants.  According to adjudicators and FDU staff we interviewed, this guidance  appears to conflict with a subsequent January 2005 memorandum, issued  by the Director of Service Center Operations, which states that adjudicator  requests for information should not be used as a device simply to  “investigate” suspected fraud. Adjudicators we interviewed at one service  center said that whenever operations management communicated with  them about practicing more discretion in issuing requests for additional  evidence, they believed it was primarily intended to put more pressure on  them to process applications faster, which in turn they said puts additional  pressure on them to not to request additional evidence when making  eligibility decisions. Consequently, they were concerned about having to  approve applications with less confidence in the correctness of their  determinations. An FDNS Immigration Officer working in a service center  echoed the adjudicators concerns about seemingly conflicting guidance,  saying that interpreting such guidance from management made the job of  adjudicators more difficult. However, he said that adjudicators and local  managers would more likely heed the direction of USCIS operations  management, their direct supervisors, rather than FDNS. Clear  communications about the importance of both fraud prevention-related  and service-related objectives and how they are to be balanced may help  adjudicators ensure that they are appropriately supporting USCIS’s  multiple objectives as they carry out their duties. In commenting on a draft  of this report, DHS stated that the USCIS Director moved FDNS to a new  directorate that reports directly to the USCIS Deputy Director. This will  allow FDNS to provide focus and guidance to all USCIS operations.
section_title: Adjudicators and FDNS Staff Lack Access to Important Information and Information Tools
paragraphs: USCIS does not have a mechanism to help ensure that adjudicators have  access to information related to detecting fraud they may need to carry out  their responsibilities. Information regarding fraud trends can be provided  in various forms including e-mails, intranet Web pages, and bulletin board  notices. The adjudicators at the service centers and district offices we  visited received some fraud-related information or training subsequent to  their initial hire.  Our interviews indicated, however, that the frequency  and method for distributing ongoing information about fraud detection is  not uniform across the service centers and district offices we visited; some  adjudicators reported that more information or a more centralized  information management system would better prepare them to detect  fraud. At two service centers, adjudicators we interviewed told us that,  after their initial training, they were provided with some information  regarding fraud trends via e-mail. However, these adjudicators also  reported difficulty with managing the information in this format. They said  that providing this information through a different means—either through  a Web-based system or through a training course that would summarize  new knowledge related to fraud trends—would be easier and quicker to  use. One of the service centers provided adjudicators with operating  manuals—developed for specific benefit application types—that included  information regarding typical fraud trends encountered by the service  center, which adjudicators said they found useful in their efforts to detect  fraud.
At two other service centers, adjudicators we interviewed told us that they  were not provided any fraud e-mail updates but received some limited  information about fraud during general group meetings. Adjudicators at  these two centers told us that receiving more specific and detailed  information about fraud trends and practices would enhance their ability  to detect fraud. At one service center, adjudicators suggested that having a  method by which to incorporate the knowledge and lessons learned from  experienced adjudicators would also help them to better detect fraud.  Additionally, one of the district offices we visited provided an additional 2- day training course that included techniques for detecting fraud during an  interview. Adjudicators we interviewed at this district office told us that  the course helped prepare them to better detect fraud. USCIS  headquarters officials responsible for field operations told us that there is  no standard training regarding fraud trends and that fraud-related training  varied across field offices.
In addition to calling for relevant information to be shared internally,  internal control standards require that management ensure that there are  adequate means of communicating with and obtaining from external  stakeholders information that may have a significant impact on achieving  agency goals. During our audit work, USCIS and ICE, had not yet  established a feedback mechanism for the timely sharing of information  related to the status and outcomes of fraud referrals that is essential to the  fraud referral process shared by USCIS and ICE. According to FDNS field  staff we interviewed, information from ICE field offices on the status of  USCIS referrals—for example, whether ICE has initiated an investigation  in response to a referral—was sporadic and incomplete in some cases and  non-existent in other cases. In addition, when ICE fails to accept a referral,  FDNS may initiate an administrative inquiry to resolve an adjudicator’s  suspicions of fraud. However, because ICE did not routinely provide  information about its investigative decisions, it was difficult for FDNS to  know when to initiate such inquiries or to plan for the staff time needed to  conduct them. Moreover, according to FDNS staff and adjudicators we  interviewed, without timely feedback about the investigative status of their  referrals, adjudicators lacked the information needed to make more timely  eligibility determinations, whether or not an investigation is opened by  ICE. In November 2005, ICE and USCIS officials told us that ICE  investigators were recently assigned to each of the FDUs, which may help  increase communication and information sharing between USCIS and ICE.
Additionally, according to the FDNS Director, having direct access to  information stored in ICE’s case management information system, the  Treasury Enforcement Communication System (TECS) maintained by  Customs and Border Protection (CBP), would allow FDNS staff to  determine with greater certainty whether someone who has filed for an  immigration benefit is connected to any ongoing ICE criminal  investigation. However, ICE officials told us they opposed allowing FDNS  access to sensitive case management information. They said that there  was a need to segregate sensitive law enforcement data about ongoing  cases from non-law enforcement agencies like FDNS.
In commenting on a draft of this report, DHS provided us with a February  14, 2006, memorandum of agreement between ICE and USCIS that  established a mechanism for the sharing of information related to the  status and outcomes of fraud referrals. In addition the agreement provides  USCIS staff with access to TECS data so USCIS can determine whether  someone who has filed for an immigration benefit is connected to any  ongoing ICE criminal investigation. If properly implemented, this  agreement should resolve USCIS’s concerns regarding the status and  outcome of fraud referrals to ICE and access to TECS data.
section_title: DHS Lacks Performance Goals for USCIS’s Antifraud Efforts
paragraphs: Internal control standards call for agencies to establish performance  measures to monitor performance related to agency objectives. Measuring  performance allows an organization to track progress made toward  achieving its objectives and provides managers with crucial information  on which to base management decisions. The Government Performance  and Results Act (GPRA) of 1993 also requires that agencies establish long- term strategic and annual goals, measure performance against these goals,  and report on the progress made toward meeting their missions and  objectives. It calls for agencies to assess specific outcomes related to their  missions and objectives, in addition to designing output measures to  describe attributes of the goods and services produced by the agencies’  programs.
USCIS’s 2005 Strategic Plan includes both a prevention theme—ensuring  the integrity of the system, and a service theme—providing efficient and  customer oriented services, along with related goals and objectives.  However, DHS and USCIS have not established specific performance goals  to assess benefit fraud activities. In fiscal year 2004 USCIS reported  performance goals related to naturalization, legal permanent residency,  and temporary residency to DHS for its annual Performance and  Accountability Report. The objective for each of these three performance  goals was to “provide information and benefits in a timely, accurate,  consistent, courteous, and professional manner; and prevent ineligible  individuals from receiving” the benefit. Although the objective includes  preventing ineligible individuals from receiving the benefit, the related  measure—achieve and maintain a 6-month cycle time goal—does not.
There is no discussion in the strategic plan of how to balance its  prevention objectives with its service objectives. Instead, USCIS’s long- term strategic approach appears to rely heavily on the development of an  enhanced case management system, new fraud databases and data  analyses tools, and automated information services to overcome the  inherent tension between these prevention and services themes as they  relate to the prevention of benefit fraud and reducing the backlog of  immigration applications. Establishing output measures—for example, the  number of cases referred to and accepted by FDNS—and outcome  measures—for example, the percentage of fraudulent applications  detected relative to targets established using baseline data from fraud  assessments—could provide USCIS with more complete information  about the effectiveness of its fraud control efforts in meeting its strategic  goal objective to ensure the security and integrity of the immigration  system.
FDNS officials told us that they are now participating in USCIS’s Office of  Policy and Strategy Performance Measurement Team’s efforts to develop  performance metrics, and that FDNS is leading an effort to develop  metrics related to USCIS’s strategic goal to ensure the security and  integrity of the immigration system by increasing the detection of  attempted immigration benefit fraud. However, specific DHS metrics  regarding USCIS’s antifraud efforts have yet to be developed and approved  by DHS.
section_title: Most Benefit Fraud Is Not Criminally Prosecuted, but DHS Does Not Have an Administrative Sanctions Program
paragraphs: Although best practice guidance suggests that sanctions for those who  commit benefit fraud are central to a strong fraud control environment,  and the INA provides for criminal and administrative sanctioning, DHS  does not currently actively use the administrative sanctions available to it.  Fraud control best practices advise that a credible sanctions program,  which incorporates a mechanism for evaluating its effectiveness, including  the wider value of deterrence, is an integral part of fraud control.  According to the AICPA’s fraud guidance, the way an entity reacts to fraud  can send a strong message that helps reduce the number of future  occurrences. Therefore, taking appropriate and consistent actions against  violators is an important element of fraud control and deterrence. The  guide further advises that a strong emphasis on fraud deterrence has the  effect of persuading individuals that they should not commit fraud  because of the likelihood of punishment. Similarly, the NAO guide states  that a key element of a good fraud control program is to impose penalties  and sanctions on those who commit fraud in order to penalize those who  commit fraud and deter others from carrying out similar types of fraud.
Data provided by USCIS indicates that most benefit fraud it uncovers and  refers to ICE is not prosecuted. In fiscal year 2005, USCIS referred 2,289  immigration benefit fraud cases to ICE BFUs. However, 598, about 26  percent were accepted by the BFUs. Neither USCIS nor ICE provided us  with information about which of the FDNS referrals accepted by the BFUs  resulted in an ICE investigation. However, ICE officials said that the  majority of ICE’s immigration benefit fraud investigations do not originate  with USCIS referrals, but from other investigative sources. Given limits on  its resources, ICE officials told us that they generally prioritize their  investigative resources and assign them to cases involving individuals who  are filing large numbers of fraudulent applications for profit, because  these cases generally have a greater probability of being prosecuted by the  U.S. Attorneys Offices. Therefore, the principal means of imposing  sanctions on most immigration benefit fraud would be through  administrative penalties.
The INA provides both criminal and administrative sanctions for those  who commit immigration benefit fraud. The act’s criminal provisions  provide for fines and/or imprisonment for up to 5 years for a person who  fails to disclose that they have, for a fee, assisted in preparing an  application for an immigration benefit that was falsely made, and  monetary fines and/or imprisonment for up to 15 years for a second such  conviction. The act also provides for administrative penalties for  applicants who make false statements or submit a fraudulent document to  obtain an immigration benefit or enter into a marriage solely to obtain an  immigration benefit. For document fraud committed after 1999, it  provides monetary fines ranging from $275 to $2,200 per document subject  to a violation for a first offense and from $2,200 to $5,500 per document for  those who have previously been fined. Monetary penalties collected are to  be deposited into the Immigration Enforcement Account within the  Department of the Treasury. Funds from this account can be used for  activities that enhance enforcement of provisions of the INA including: (1)  the identification, investigation, apprehension, detention, and removal of  criminal aliens; (2) the maintenance and updating of a system to identify  and track criminal aliens, deportable aliens, inadmissible aliens, and aliens  illegally entering the United States; and (3) for the repair, maintenance, or  construction of border facilities to deter illegal entry along the border. In  addition, under certain circumstances, individuals determined through the  adjudication process to have committed fraud, are deemed inadmissible  should they later try to file another immigration application. In some  cases, aliens who are determined in a formal hearing to have committed  fraud can be removed from the United States and be barred from entering  in the future.
DHS does not currently have a clear and comprehensive strategy for  imposing sanctions or evaluating their effectiveness and is not actively  enforcing the administrative penalties provided for by the INA. This is  largely due to a 1998 federal appeals court ruling upholding a nationwide  permanent injunction against the procedures used by INS to institute civil  document fraud charges under the INA. The court found that INS  provided insufficient notice to aliens regarding their right to request a  hearing on the imposition of monetary fines and the immigration  consequences of failing to do so, and that until proper notifications were  included on the fine and hearing waiver forms, INS was enjoined from  implementing civil penalties for document fraud. According to the  Director of Field Operations for ICE’s Office of Principal Legal Advisor,  after the court ruling, the government’s cost to investigate and prosecute  an immigration fraud case administratively, including appeals costs, would  not be offset by the monetary sum that might be obtained. Moreover, the  director stated that even if successful, there was no guarantee that the  government could collect its fine from the alien. Therefore, according to  the director, ICE does not consider implementing the administrative  penalties for document fraud to be cost-effective. Accordingly, DHS has  not made updating the forms in response to the ruling a priority. Similarly,  another USCIS attorney told us that the provision of INA that pertains to  marriage fraud is rarely used because, due to the significant commitment  of resources necessary to establish a finding of fraud, enforcing it might  not be cost-effective. However, DHS has not conducted a formal analysis,  which includes an attempt to value the benefit of deterrence, to determine  the total costs and benefits of imposing sanctions.
Senior USCIS officials we spoke with, however, told us that administrative  sanctions are important to their fraud control efforts. According to the  FDNS Director, without the credible threat of a penalty, individuals have  no fear of filing future fraudulent applications. In this regard, he said that  FDNS administrative investigations of fraud referrals not investigated by  ICE are critical, and, in his estimation, the resulting denial of a benefit and  potential removal of an alien offer an effective deterrent to immigration  benefit fraud. However, the director said that although an alien who  commits immigration benefit fraud might be removable from the United  States and, therefore, has some disincentive to commit fraud, U.S. citizens,  if they are not prosecuted criminally, have little disincentive because  without the enforcement of administrative sanctions they are not likely to  be penalized, even if their violations are detected. Additionally, according  to the Chief of Staff for USCIS, a strategy for administratively sanctioning  those who commit fraud is necessary for controlling and deterring fraud.
Although DHS does not actively use its authorities to impose  administrative penalties, Congress has continued to support the concept in  legislation. In particular, the Real ID Act of 2005 allows the Secretary of  Homeland Security, after notice and an opportunity for a hearing, to  impose an administrative fine of up to $10,000 per violation on an  employer for a substantial failure to meet any of the conditions of a  petition for certain non-immigrant workers or a willful misrepresentation  of a material fact in such a petition, and allows the secretary to deny  petitions filed with respect to that employer for at least 1 year and not  more than 5 years. However, without a strategy that includes a  mechanism for assessing the effectiveness of sanctions and considers both  the monetary value of fines collected and the value of deterrence, DHS will  not be able to determine how and under what circumstances to best use  the authority provided by the INA and other legislation to promote a  credible threat of punishment in order to deter fraudulent filers.
Although it lacks a strategy for imposing criminal and administrative  sanctions, DHS, along with DOL, has proposed administrative rule changes  that will help sanction those who commit fraud. Among other things, DHS  has proposed that USCIS be able to deny, for a period of time, all  applications from employers that DOL or DHS has found, respectively, to  have submitted false information about meeting regulatory requirements  or provided statements in their applications that were inaccurate,  fraudulent or misrepresented a material fact. Final rules have not yet been  published.
section_title: Conclusions
paragraphs: In light of competing organizational priorities, institutionalizing fraud  detection—so that it is a built-in part of the adjudications process and  always a central part of USCIS’s planning, procedures, and methods—is  vital to USCIS’s ability to accomplish its goals and objectives, particularly  protecting the integrity of the immigration benefit system. USCIS has  taken some important steps to implement internal controls, primarily  through the activities of the Office of Fraud Detection and National  Security. By strengthening existing controls and implementing additional  fraud control practices, USCIS could enhance its ability to detect benefit  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 meet its backlog reduction goals. Specifically, expanding the types of  benefits it assesses, including assessments of consequence, and drawing  on all available sources of threat information to develop current fraud  assessment activities into a more comprehensive risk management  approach would provide additional knowledge about fraud risks and put  the agency in a better position to make risk-based evaluations of its  policies, procedures, and programmatic activities. Also, a mechanism to  ensure that information uncovered during the course of normal  operations—in USCIS and related agencies—feeds back into USCIS  policies and procedures would help to ensure that it addresses loopholes  and procedural weaknesses. In addition, clear communication of the  importance of fraud prevention-related objectives and how they are to be  balanced, in practice, with service-related objectives would help USCIS  adjudicators to ensure that they are supporting the agency’s multiple  objectives as they carry out their duties. Moreover, the provision of the  tools and the relevant information that its adjudicators need to help them  detect fraud could help them make eligibility determinations with greater  confidence of their accuracy. Finally, performance goals—that include  output and outcome measures, along with associated targets—reflecting  the status of fraud control efforts would provide valuable information for  USCIS management to evaluate its various policies, procedures, and  programmatic activities and a better understanding of both the progress  made and areas requiring more focused management attention to enhance  fraud prevention.
By demonstrating sufficiently adverse consequences for individuals who  perpetrate fraud, sanctions serve to discourage future fraudulent filings, as  individuals observe that the potential costs of engaging in fraud are likely  to outweigh the potential gains. It is important to any program that  encounters fraud to have a credible sanctions program to penalize those  who engage in fraud and deter others from doing so. Currently, DHS’s  sanctions program for immigration fraud is not a threat to most  perpetrators because relatively few are prosecuted criminally and  administrative sanctions are not actively being used. Although DHS  officials told us that administrative sanctions are not cost-effective,  comparing only the costs of administering sanctions with the potential  return from the collection of fines may undervalue their potential  deterrent effects. Although developing a sound methodology to establish  and determine the value of deterrence provided by sanctions will require  effort, best practices call for cost-effective sanctions, and consideration of  the full range of costs and benefits, financial and nonfinancial, is central to  making a valid determination of cost-effectiveness. Developing and  implementing a strategy for imposing sanctions that includes a mechanism  for assessing effectiveness and that more fully evaluates costs and  benefits, including nonfinancial benefits like the value of deterrence, could  give DHS a better indication of how and under what circumstances  administrative sanctions should be employed to enhance USCIS’s fraud  deterrence efforts.
section_title: Recommendations for Executive Action
paragraphs: In order to enhance USCIS’s overall immigration benefit fraud control  environment, we recommend that the Secretary of Homeland Security  direct the Director of USCIS to take the following five actions, which are  consistent with internal control standards and best practices in the area of  fraud control:    Enhance its risk management approach by (1) expanding its fraud  assessment program to cover more immigration application types; (2)  fully incorporating threat and consequence assessments into its fraud  assessment activities; and (3) using risk analysis to evaluate  management alternatives to mitigate identified vulnerabilities.
Implement a mechanism to help USCIS ensure that information about  fraud vulnerabilities uncovered during the course of normal  operations—by USCIS and related agencies—feeds back into and  contributes to changes in policies and procedures when needed to  ensure that identified vulnerabilities result in appropriate corrective  actions.
Communicate clearly to USCIS adjudicators the importance USCIS’s  fraud-prevention objectives and how they are to be balanced with  service-oriented objectives to help adjudicators ensure that both  objectives are supported as they carry out their duties.
Provide USCIS’s adjudicator staff with access to relevant internal and  external information that bears on their ability to detect fraud, make  correct eligibility determinations, and support the new fraud referral  process—particularly ongoing updates regarding fraud trends and  other information related to fraud detection.
Establish output and outcome based performance goals—along with  associated measures and targets—to assess the effectiveness of fraud  control efforts and provide more complete performance information to  guide management decisions about the need for any corrective action  to improve the ability to detect fraud.
In addition, in order to enhance DHS’s ability to sanction immigration  benefit fraud, we recommend the Secretary of Homeland Security direct  the Director of USCIS and the Assistant Secretary of ICE to:    Develop a strategy for implementing a sanctions program that includes  mechanisms for assessing its effectiveness and for determining its  associated costs and benefits, including its deterrence value.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Departments of Homeland  Security, State, Justice, and Labor for review. On March 1, 2006, we  received written comments on the draft report from the Department of  Homeland Security, which are reproduced in full in appendix II. The  Departments of State, Justice, and Labor had no comments on our draft  report. In its written comments, DHS stated that our report generally  provided a good overview of the complexities associated with pursuing  immigration benefit fraud and the need to have a program in place that  proactively assesses vulnerabilities within the myriad of immigration  processes. However, DHS stated that our report did not fully portray  USCIS’s efforts to address immigration benefit fraud and provided other  examples of efforts USCIS has undertaken or plans to undertake. Where  appropriate, we revised the draft report to recognize these additional  efforts by USCIS to address immigration benefit fraud. DHS noted that  USCIS used GAO’s 2002 report on immigration benefit fraud as the  foundation to build its antifraud program and believes that USCIS is on the  right track to creating an effective antifraud program. We believe that  USCIS is moving in the right direction and recognize that FDNS is in the  beginning stages of developing and implementing a new antifraud program  for USCIS.
Overall, DHS agreed with and plans to take action to implement four of  our six recommendations, and cited actions it has already taken to  indicate that aspects of our other two recommendations are already in  place. Specifically, regarding our recommendation that DHS enhance its  risk management approach, DHS agreed that USCIS can enhance its risk  management approach by expanding its fraud assessment program to  cover more application types and plans to do so. DHS stated that its initial  fraud assessments focused on benefits that were high risk, but that given  existing resources it was not possible to conduct assessments on all  benefit types within the first years of operation. DHS stated that USCIS  believes that the benefit fraud assessments currently underway do provide  a comprehensive risk analysis to identify vulnerabilities and measures to  mitigate such vulnerabilities. DHS cites FDNS involvement in interagency  anti-fraud efforts and that FDNS staff are assigned to various intelligence  units as support that its fraud assessments draws on sources of strategic  threat information. However, DHS did not provide evidence or explain  how, if at all, these efforts systematically incorporated threat and  consequences into its fraud assessment process. In addition, DHS did not  explain or provide us with evidence of how USCIS will use the results of  the fraud assessments as part of a continuous, built-in component of its  operations to evaluate and adjust, as necessary, policies and procedures.
Regarding our recommendation that DHS provide USCIS adjudicator staff  relevant information, DHS agreed that it needs to provide USCIS staff  access to relevant internal and external information and is initiating  training for supervisory adjudication officers and is planning to provide  adjudicators selective access to the State Department’s Consolidated  Consular Database and other open source databases.
Regarding our recommendation that DHS establish performance goals to  assess the effectiveness of fraud control efforts, DHS stated that FDNS has  created performance goals for the number of benefit fraud assessments  conducted during the year and the number of recommended policy,  procedural and regulatory changes. DHS agreed that additional output and  outcome based performance goals and measures are needed but did not  specify what action(s) they were planning to take.
Regarding our recommendation that DHS develop a strategy for  implementing a sanctions program, DHS agreed to study the costs and  benefits of an administrative sanctions program though DHS believes that  the process it has established to place aliens determined to have  committed immigration fraud in removal proceedings is an effective  deterrent. While this process may deter aliens from committing  immigration fraud, this process does not impact citizens who may commit  fraud and therefore a sanctions strategy for citizens is still needed.
DHS stated that with regard to two of our recommendations, it has already  take actions that are consistent with these two recommendations.  Regarding our recommendation that USCIS implement a mechanism to  feed back information uncovered during the course of its normal  operations and those of related agencies about fraud vulnerabilities, DHS  stated that it believes such a feedback loop already exists within the  process. DHS stated that FDNS is currently developing its back-end  processes, which include sharing information/lessons learned from routine  operations and addressing shortcomings. For all major conspiracy cases, a  report is to be prepared summarizing among other things, factors that lead  to fraudulent applications being approved. USCIS also stated that based  upon meetings that FDNS leadership had with a U.S. Attorneys Office  regarding vulnerabilities in the asylum process, USCIS is developing a plan  of action to respond to the recommendations made by the U.S. Attorney’s  office. DHS also stated that USCIS is developing regulatory changes to  mitigate vulnerabilities identified during the religious worker fraud  assessment. Although these are all positive efforts, USCIS does not yet  have policies and procedures that specify how information about fraud  vulnerabilities uncovered during the course of normal operations—by  USCIS and related agencies—is to be gathered—from which internal and  external sources—and the process for evaluating this information and  making decisions about appropriate corrective actions. Therefore, we  continue to believe that USCIS needs to institutionalize through policies  and procedures a feedback mechanism.
Regarding our recommendation that USCIS clearly communicate the  importance of USCIS’ fraud-prevention activities, DHS stated USCIS  leadership clearly advocates balancing objectives related to timely and  quality processing of immigration benefits. DHS stated that creation of  FDNS and the recent move of FDNS to a new directorate that reports  directly to the Deputy Director of USCIS allowing FDNS to provide focus  and guidance to all USCIS operations as support that USCIS is focused on  the integrity of USCIS’s data and processes. Although USCIS management  believes these efforts demonstrate the importance of fraud prevention, our  interviews with adjudicators in service centers and district offices indicate  that this message may not be reaching USCIS’s adjudications staff.  Therefore, we continue to believe that more is needed to clearly  communicate the importance of fraud prevention and more specific  guidance on how USCIS staff are to balance the fraud prevention and  service oriented objectives. DHS disagreed with our recommendation that  USCIS and ICE establish a mechanism for the sharing of information  related to the status and outcomes of USCIS fraud referrals to ICE. DHS  provided us a February 2006 memorandum of agreement between ICE and  USCIS that establishes a mechanism for the sharing of information related  to the status and outcomes of fraud referrals; therefore, we withdrew this  recommendation.
We are sending copies of this report to the Secretaries of Homeland  Security, State, and Labor; the Attorney General; and other interested  congressional committees. We will also make copies available to others  upon request. In addition, the report will be available at no charge on  GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-8777 or Jonespl@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on the  last page of this report. Key contributors to this report are listed in  appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To examine the extent and nature of immigration fraud, we reviewed the  results of the Office of Fraud Detection and National Security’s (FDNS)  ongoing fraud assessments. Regarding the fraud assessments, we  interviewed the FDNS managers responsible for administering the  assessment, reviewed documentation outlining the assessment’s design,  implementation and initial results from two fraud assessments. To better  understand the nature of immigration benefit fraud and to identify  common fraud patterns, we analyzed examples of fraud case histories for  several petition types planned to be assessed by FDNS. In addition, we  analyzed information contained in fraud bulletins prepared by U.S. Citizen  Immigration Services’ (USCIS) California Service Center that contained  reports by various State Department overseas consular posts on  immigration fraud these posts had uncovered. We also analyzed USCIS’s  Performance Analysis System (PAS) data to determine trends in the  volume of applications being processed, approved, and denied. We  assessed the data derived from PAS and determined that these data were  sufficiently reliable for the purposes of this review. We interviewed  adjudications staff and field managers to evaluate the extent to which  internal controls and practices for detecting fraud were incorporated into  USCIS policies, procedures, and tools. We met with headquarters officials  from USCIS operations and FDNS, as well as officials from the  Departments of Labor and State responsible for fraud detection efforts.  We conducted site visits or contacted staff at all four USCIS services  centers—we visited three USCIS service centers in Laguna Niguel,  California; Dallas, Texas; and St. Albans, Vermont; and conducted  telephone interviews with USCIS staff at the Lincoln, Nebraska, service  center. We also interviewed 59 adjudicators at the four USCIS service  centers and two USCIS district offices with responsibility for and  familiarity with adjudicating different types of applications in a group  setting, which allowed us to identify points of consensus among the  adjudicators. We also visited USCIS district offices in Dallas and Boston  responsible for coordinating their fraud referrals with two of the four  service centers we visited. USCIS service center and district office officials  selected the adjudicators we interviewed based upon our request that we  meet with adjudicators that had responsibility for and familiarity with  adjudicating different types of applications. We also interviewed FDNS  staff assigned to work with the four service centers and two district offices  we visited or contacted. We also interviewed staff from Immigration and  Custom Enforcement’s (ICE) Identity and Benefit Fraud Unit in  Washington, D.C., and those agents assigned to Benefit Fraud Units (BFU)  in California, Texas, and Vermont. As we did not select a probability  sample of USCIS staff and ICE Office of Investigations agents to interview,  the results of these interviews cannot be projected to all USCIS staff and  ICE Office of Investigations officials nationwide. In addition, we reviewed  efforts by the Department of Labor’s Inspector General to determine the  extent of immigration fraud in the Permanent Labor Certification Program.  We also met with the CIS Ombudsman to discuss his fiscal year 2004 and  fiscal year 2005 reports.
To determine what actions USCIS has taken to improve its ability to detect  immigration benefit fraud, we reviewed USCIS’s efforts to improve its  fraud detection capabilities, including resources devoted specifically to  detecting fraud by FDNS. We also reviewed USCIS’s policies, adjudication  procedures, and fraud detection processes as well as the tools used by  adjudicators to detect fraudulent immigration benefit applications. To  determine what actions have been taken to sanction those who commit  fraud, we interviewed USCIS and ICE attorneys, identified the  investigative resources that ICE had made available for immigration fraud  investigations, and determined how USCIS and ICE coordinate the  investigation of potential fraud. In addition, we examined fraud  investigation and prosecution statistics, and analyzed USCIS statistics  about the amount of fraud identified by its adjudicators. We also  determined how ICE investigative efforts are coordinated with the U.S.  Attorneys Offices and how their priorities affect the investigation and  prosecution of immigration benefit fraud schemes of various types. For  this portion of our review, we met with headquarters officials from ICE,  and interviewed agents in four ICE field offices based in Boston, Dallas,  Los Angeles, and San Antonio. We also interviewed representatives from  the U.S. Attorneys Office for the Eastern District of Virginia and the  Executive Office of the U.S. Attorneys within the Department of Justice.  Finally, we examined the current sanctions for those who commit  immigration benefit fraud and reviewed proposed fraud regulatory  changes. To evaluate DHS efforts to detect and sanction immigration  benefit fraud, we used the Standards for Internal Control in the Federal  Government and with best practices advocated by the American Institute  of Certified Public Accountants (AICPA) and by the United Kingdom’s  National Audit Office (NAO).
We conducted our work between October 2004 and December 2005 in  accordance with generally accepted government auditing standards.
section_title: Appendix II: Comments from the Department of Homeland Security
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgements
paragraphs: In addition to the above, Joel Aldape, David Alexander, Jenny Chanley,  Frances Cook, Michael P. Dino, Nancy Finley, Carlos Garcia, Kathryn  Godfrey, Larry Harrell, and David Nicholson were key contributors to this  report.