International Religious Freedom Act: State Department and Commission Are Implementing Responsibilities but Need to Improve Interaction
Published: 2013-03-26T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Congress passed the Act in 1998 to promote international religious freedom, among other purposes. The Act established within State the Office of International Religious Freedom, headed by an Ambassador-at-Large. The Act also established USCIRF, with the Ambassador-at-Large as an ex-officio member. In addition, the Act outlined primary responsibilities for both State and USCIRF.
The U.S. Commission on International Religious Freedom Reform and Reauthorization Act of 2011required GAO to report on matters related to the U.S. promotion of international religious freedom. This report assesses (1) States implementation of its primary responsibilities established in the Act, (2) USCIRFs implementation of its primary responsibilities established in the Act, (3) States and USCIRFs interaction to promote religious freedom, and (4) NGOs views on U.S. efforts to promote religious freedom.
GAO analyzed documents and interviewed officials from State, USCIRF, NGOs, and foreign governments. GAO conducted fieldwork in five countries, including CPCs, and surveyed 131 NGOs. The survey results reflect the views of survey respondents and cannot be generalized.
section_title: What GAO Found
paragraphs: The Department of State (State) is implementing the primary responsibilities outlined in the International Religious Freedom Act of 1998 (the Act) by undertaking numerous actions to promote religious freedom, engaging with foreign officials, and annually publishing its International Religious Freedom Report. The Ambassador-at-Large and the Office of International Religious Freedom assist the Secretary of State with certain responsibilities outlined in the Act, including the designation of Countries of Particular Concern (CPC) and the development of training.
The U.S. Commission on International Religious Freedom (USCIRF) is implementing its primary responsibilities outlined in the Act by conducting ongoing reviews of violations of religious freedom and issuing policy recommendations to the U.S. government. According to USCIRF officials, its primary responsibilities culminate in the release of its annual report. The report discusses the 20 to 30 countries that USCIRF considers the worst offenders against religious freedom, and it presents policy recommendations to the U.S. government. USCIRF has at times also provided technical assistance or recommendations to foreign officials.
Although the Act, as amended, directs State and USCIRF to cooperate, they have not defined how they should interact, which has at times created tensions with foreign-government officials. For example, in its 2012 report, USCIRF recommended that the Secretary of State designate Turkey as a CPC. Because the Ambassador-at-Large was not regularly attending USCIRF meetings at the time, State officials learned of the commissioners' intent shortly before USCIRF published its report. State officials explained that Turkey did not warrant CPC designation, as it had taken steps to improve religious freedom, but USCIRF proceeded with its recommendation. According to Turkish officials, USCIRF's report contradicted State's report and was therefore "null and void." State officials told GAO that they had to resolve the resulting tensions with the Turkish government.
Representatives of nongovernmental organizations (NGOs) whom GAO surveyed and interviewed generally viewed overall U.S. government efforts to promote international religious freedom positively, while raising some concerns and suggesting several improvements. To better promote international religious freedom, some NGOs suggested greater inclusion of civil society and other nonstate actors and further empowerment of U.S. government entities. Likewise, NGOs familiar with State's and USCIRF's annual reports generally viewed them positively, although several raised concerns that both reports lacked objectivity. Finally, NGOs generally viewed State's CPC designations positively, although some doubted how useful the designations or recommended designations were to their work. NGOs from GAO's five fieldwork countries provided similar opinions.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Secretary of State and the Chair of USCIRF jointly define how State and USCIRF should interact in their efforts to promote international religious freedom. State and USCIRF concurred with GAO's recommendation.

section_title: Letter
paragraphs: Because of concerns about increasing restrictions on religious rights  around the world, Congress passed the International Religious Freedom  Act of 1998 (the Act) to strengthen U.S. advocacy of individuals  persecuted in foreign countries on account of religion. According to the  Act, more than half of the world’s population was living under  governments that severely restricted or prohibited freedom of religion. In  2012, the Pew Research Center reported that approximately 75 percent  of the world’s population was living in countries with high or very high government restrictions on religion or with religious hostilities in society.The Act established an Office of International Religious Freedom (Office)  within the Department of State (State), headed by an Ambassador-at- Large, to promote international religious freedom. The Act also  established the U.S. Commission on International Religious Freedom  (USCIRF) to review the facts and circumstances of violations of religious  freedom and recommend policy actions to the President, Secretary of  State, and Congress.
The United States Commission on International Religious Freedom  Reform and Reauthorization Act of 2011 (the Reauthorization Act)  required us to report to the committees regarding several matters related  to U.S. promotion of international religious freedom. The Reauthorization  Act also included a specific requirement that we consult with  nongovernmental organizations (NGO) in preparing the report. In  addition, the Reauthorization Act required us to compare USCIRF with  other commissions. To respond to the mandate, we have assessed (1)  State’s implementation of its primary responsibilities established in the  Act; (2) USCIRF’s implementation of its primary responsibilities  established in the Act; (3) State’s and USCIRF’s interaction in their efforts  to promote religious freedom; and (4) NGOs’ views on U.S. efforts to  promote international religious freedom. Appendix II presents our  comparative analysis of USCIRF and other commissions.
To address our objectives, we analyzed documents from State and  USCIRF, including grant documents, cables, and annual reports. We also  met with officials from State and USCIRF, including all three  Ambassadors-at-Large—two former and one present—as well as all of  the current and more than half of the former USCIRF commissioners. We  also conducted fieldwork in Afghanistan, Indonesia, Turkey, Uzbekistan,  and Vietnam, meeting with U.S. officials and representatives from  relevant host-government agencies, NGOs, civil society, and religious  communities. The five countries we selected for fieldwork met at least two  of the following criteria: (1) State had funded an international religious  freedom program in the country; (2) the country was on USCIRF’s watch  list; (3) USCIRF had recommended designating the country, or State has  designated it, as a Country of Particular Concern (CPC); and (4) the  Ambassador-at-Large or USCIRF had visited the country in the past 3  years. We also conducted a survey of 131 NGOs that we identified from a  variety of sources as working on religious freedom issues. The results of  the survey, which had a 64 percent response rate, reflect only the views  of the respondents to our survey and cannot be generalized. See  appendix I for a more detailed discussion of our scope and methodology.
We conducted this performance audit from March 2012 to March 2013 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: The Act Established International Religious Freedom as a U.S. Foreign Policy Objective
paragraphs: In passing the Act, Congress noted that, at that time, more than half of  the world’s population lived under regimes that severely restricted or  prohibited citizens from freely observing their religious beliefs. In addition,  the Act describes government-sponsored and government-tolerated  violations to religious freedom that people faced, including slander  campaigns; confiscation of property; denial of the right to assemble; and  prohibitions against publishing, distributing, or possessing religious  literature. According to the Act, religious believers in many countries also  faced severe and violent forms of religious persecution, such as  imprisonment, torture, beatings, mass resettlement, and death for their  peaceful belief in, change of, or practice of their faith.
In its findings on religious freedom, the Act refers to the U.S. Constitution  and various principles of international law. The first amendment of the  U.S. Constitution established the right to freely exercise religious beliefs,  and according to the Act, “the right to freedom of religion undergirds the  very origin and existence of the United States.” In addition, the Act  highlights principles of international law, such as those outlined in the  United Nations (UN) Universal Declaration of Human Rights and the  International Covenant on Civil and Political Rights, which identify  religious freedom as a universal human right. For example, according to  the Universal Declaration of Human Rights, “Everyone has the right to  freedom of thought, conscience, and religion. This right includes freedom  to change his religion or belief, and freedom, either alone or in community  with others and in public or private, to manifest his religion or belief in  teaching, practice, worship, and observance.”
The Act states that it shall be the policy of the United States to condemn  violations of religious freedom and to promote and assist other  governments in the promotion of religious freedom. The Act describes  several actions that the United States shall take in accordance with this  policy objective, including the implementation of appropriate diplomatic,  political, commercial, and other tools to promote respect for religious  freedom by all governments and peoples. In July 2012, the Secretary of  State reiterated the U.S. government’s commitment to promote religious  freedom and said that the administration had elevated religious freedom  as a diplomatic priority. She also discussed her personal diplomatic  outreach around the world concerning religious freedom and the  appointment of the first envoy to the Organization of Islamic Cooperation.
section_title: The Act Established Two Separate Entities and Outlined Their Responsibilities
subsections: section_title: The Act Established State’s Office and Ambassador-at- Large for International Religious Freedom and Outlined State’s Responsibilities
paragraphs: In accordance with the Act, State created the Office of International  Religious Freedom (the Office) in 1999, headed by the Ambassador-at- Large for International Religious Freedom (the Ambassador). State  placed the Office within the Bureau of Democracy, Human Rights, and  Labor (DRL). Three individuals have served in this position (see fig. 1).The position has been vacant for approximately 4.5 of the 14 years since  the Act’s passage, primarily because of delays in the presidential  nomination process.
The Act outlines four primary responsibilities for the Ambassador: (1)  promote religious freedom, (2) serve as a principal adviser to the  President and Secretary of State on religious freedom issues abroad, (3)  represent the U.S. government diplomatically in matters relevant to  religious freedom abroad, and (4) report on the status of international  religious freedom annually. Although the Act directs that the Ambassador  is the head of the Office, it does not explicitly outline responsibilities for  the Office. State officials said that the primary responsibilities of the Office  mirror those established for the Ambassador.
The Act also established USCIRF, comprising nine volunteer members  (commissioners); the President, the President pro tempore of the Senate,  and the Speaker of the House of Representatives each appoints three  members.  Moreover, the Act established that the Ambassador would  serve ex officio as a nonvoting member of the commission. USCIRF has  a professional staff and an executive director, in addition to the  commissioners.
Specifically, the Act states that of the three members of the commission that are  appointed by the President pro tempore of the Senate, two shall be appointed upon the  recommendation of the leader in the Senate of the political party that is not the political  party of the President, and one shall be appointed upon the recommendation of the leader  in the Senate of the other political party. Similarly, the Act states that of the three  members of the commission that are appointed by the Speaker of the House of  Representatives, two shall be appointed upon the recommendation of the leader in the  House of the political party that is not the political party of the President, and of which one  of the members shall be appointed upon the recommendation of the leader in the House  of the other political party. See Pub. L. No. 105-292, Sec. 201(b) and 22 U.S.C. §  6431(b)(1)(B). circumstances presented in State’s annual report and of information from  other sources where appropriate. The Act authorized USCIRF to hold  hearings, and a 1999 amendment to the Act authorized USCIRF to  conduct travel and to secure information from any federal agency as  necessary to carry out its duties. Since fiscal year 2000, Congress has  appropriated more than $42 million for USCIRF’s activities.
The Act established USCIRF as a 4-year commission, and the 1999  amendment to the Act established that USCIRF would terminate on May  14, 2003. The Act established a 2-year term of office for each  commissioner and also allowed for the reappointment of each  commissioner to a second term. In 2002, Congress amended the Act  again to extend USCIRF’s authority to September 30, 2011, but did not  establish term limits for commissioners. In 2011, Congress extended the  termination date to September 30, 2014, and implemented some  additional changes, including placing a limit of two 2-year terms on  commissioners. As a result of the term limits, 7 of the 9 commissioners  at that time were required to leave the commission. Since 1999, 33  commissioners have served on USCIRF; 9 have served for 5 or more  years, and 3 have served for 10 or more years.
section_title: State Is Implementing the Primary Responsibilities Established in the Act but Has Provided Inconsistent Reporting Policy and Guidance for the Ambassador
paragraphs: State, including the Ambassador and the Office, is implementing the  primary responsibilities outlined in the Act. The Ambassador, with the  support of the Office, promotes religious freedom, advises the President  and Secretary of State, represents the United States diplomatically on  international religious freedom issues, and annually publishes the  International Religious Freedom Report. Other entities in State, such as  other offices and embassies, also take actions to implement some of the  responsibilities outlined in the Act. In addition, the Ambassador and the  Office support the Secretary of State in implementing some of the  responsibilities that the Act establishes for the Secretary. However, the  Ambassadors-at-Large for International Religious Freedom have a lower  organizational status than State’s other Ambassadors-at-Large, and State  has provided inconsistent reporting policy and guidance to the  Ambassadors-at-Large for International Religious Freedom.
subsections: section_title: State Is Implementing the Primary Responsibilities Established in the Act
subsections: section_title: Ambassador and Office Are Implementing Primary Responsibilities Independently and Through Efforts of Other State Entities
paragraphs: The Ambassador and the Office are implementing the primary  responsibilities that the Act established—namely, promoting international  religious freedom, advising the President and Secretary of State,  diplomatically representing the United States with regard to religious  freedom issues, and publishing an annual report on the status of religious  freedom worldwide. The Ambassador carries out these responsibilities  both independently and with the assistance of other State entities,  including U.S. embassies abroad.
The Ambassador, the Office, and other State entities have undertaken  actions, in accordance with both the Act and U.S. foreign policy  objectives, to promote religious freedom. Examples of these activities  include the following:
Hosting and participating in events. The Ambassador and the Office  host, and participate in, events that promote religious freedom and  tolerance through dialogue. For example, in October 2012, the Office  and the U.S. Institute of Peace sponsored a public panel discussion  titled “Religion, Violence, and Coexistence,” at which the Ambassador  spoke. The event’s discussion focused on (1) civil society’s role in  preventing and addressing statements of religious bias and (2) ways  in which civil society and the U.S. government can collaborate to  advance peaceful religious coexistence, freedom, and security.
Working directly with foreign governments. State officials said that the  Ambassador and the Office work directly with foreign government  officials to promote religious freedom by discussing concerns and  assisting with the development of concrete steps a government might  take to improve religious freedom or with legislative changes. For  example, one Ambassador said that negotiations led to a formal  public statement in which the government of Saudi Arabia clarified  policies it had adopted and would pursue in order to improve religious  freedom for minority faiths and eliminate religiously intolerant material  from textbooks and other literature used in Saudi Arabia or exported  abroad.
Elevating religious freedom issues within State. According to Office  staff, the Office and the Ambassador continually work to elevate  religious freedom issues within State. A State official explained that  Office staff conduct numerous briefings for mid-level and executive  department officials concerning religious freedom in various countries,  as the situations warrant. In addition, another State official said that  Office staff prepare talking points and briefing memorandums for  senior State officials to use during meetings with foreign-government  officials, although they told us they do not always know whether the  officials use the talking points. According to a State official, the  Ambassador also disseminates religious freedom-related information  throughout DRL and across State.
Developing religious freedom–related grants. According to Office staff,  since 2007, the Office has developed 27 religious freedom–related  programs with $16.6 million in grants from DRL’s Human Rights and  Democracy Fund. These programs include global initiatives and  support the promotion of religious freedom across the six regions of  the world, with a focus on changing societal perceptions, attitudes,  and behaviors. For example, one program supported in-country  capacity building to establish teams to track, catalogue, and respond  to religious tensions within the country. Our review of 7 of the 27  program grants found that, in general, the grantees reported that they  are meeting their grant objectives, such as capacity building and  public awareness. See appendix I for detailed information concerning  our grant analysis.
Undertaking a variety of activities at U.S. embassies. U.S. embassies  have undertaken a variety of activities to promote religious freedom,  as indicated in our review of 178 cables that U.S. embassies sent  from January 2009 to October 2012 addressing religious freedom in  approximately 60 countries (see app. III for more detailed results of  our analysis). In addition, embassy officials in the five countries  where we conducted fieldwork described various embassy activities to  promote religious freedom. For example, some officials told us that  their embassies organized events to promote religious tolerance and  dialogue, such as speaker panels; hosted religious holiday dinners  and roundtable discussions; and met with foreign-government, NGO,  and religious officials to discuss religious freedom. Embassy officials  in two countries we visited stated that they do not receive funding  specifically for religious freedom activities; rather, the embassy uses  funds from its operational budget account when hosting events to  promote religious freedom.
Developing other religious freedom–related programs. Other State  offices have also undertaken activities to promote religious freedom.  For example, the Bureau of Educational and Cultural Affairs funds and  administers the International Visitor Leadership Program, which  connects current and emerging foreign leaders with their U.S.  counterparts through short-term professional-exchange programs.  According to State officials, the program has supported the exchange  of religious and civil society leaders. In addition, State’s Special  Representative to Muslim Communities and former Special Envoy to  Monitor and Combat Anti-Semitism launched a campaign, “2012  Hours Against Hate,” to promote respect across lines of culture,  religion, tradition, class, and gender.requests, via social media, to young people asking them to pledge 1  hour or more of their time to stop hate by helping someone who does  not look, live, or pray like them.
According to the Act, the Ambassador “shall be a principal adviser to the  President and the Secretary of State regarding matters affecting religious  freedom abroad.” The former Ambassadors and State officials told us that  the three Ambassadors-at-Large for International Religious Freedom  have served as a principal adviser to the President primarily by  communicating with National Security Staff. For example, the  Ambassadors and Office staff said that the Ambassadors communicated  with National Security Staff to discuss religious freedom, including  potential CPC designations. According to State officials, the current  Ambassador also participates in the National Security Council’s  Interagency Policy Committee meetings when religion is a topic of focus.
The three Ambassadors reported having advised the Secretary of State in  a number of ways. For example, the first Ambassador said that, in  addition to meeting with the Secretary of State in person, he provided her  with notes from his trips to update her on religious freedom in the  countries he visited. In addition, the Secretary of State occasionally asked  him for specific advice on interacting with various religious communities.  Similarly, the second Ambassador said he met occasionally with the  Secretary of State to discuss religious freedom issues and at times  participated in the Secretary’s meetings with foreign officials or religious  leaders. The second and third Ambassadors told us that they also  provided the Secretary of State with talking points and trip summaries. In  addition, the current Ambassador said that she has served as an adviser  to the Secretary of State through her role as a co-chair of the Religion  and Foreign Policy Working Group, which was part of the former  Secretary’s Strategic Dialogue with Civil Society.
See “Resolution adopted by the UN Human Rights Council, 16/18, Combating  intolerance, negative stereotyping and stigmatization of, and discrimination, incitement to  violence and violence against, persons based on religion or belief,” A/HRC/RES/16/18. officials of foreign governments, religious organizations, and NGOs to  discuss religious freedom on behalf of State.
Furthermore, other State officials discuss religious freedom with foreign- government and NGO officials and with civil-society and religious leaders.  For example, when visiting Turkey in 2011, the Secretary of State urged  the Turkish government to reopen the Halki Seminary in Istanbul as a  symbol of Turkey’s commitment to religious freedom. In addition, many  of the 178 cables State provided to us described activities that the  Ambassador or other embassy officials undertook to engage with foreign- government and NGO officials and with civil-society and religious leaders  regarding religious freedom.
Although State has published the International Religious Freedom Report every year  since 1999, the time period covered by the reports has changed over time. The 1999  report covered an 18-month period from January 1, 1998, to June 30, 1999. The  subsequent 11 annual reports covered 12-month periods from July 1 of the year before  the report was issued to June 30 of the year in which the report was issued. In 2010, to  shift to a calendar-year reporting period, State published a second report covering the 6  months from July 1, 2010, through December 31, 2010. The 2011 report thus represented  the first report to correspond to the full calendar year. State expects reports for 2012 and  subsequent years to continue on the full-year schedule. significant additional resources in Washington, D.C., and in the field. For  example, while other mandated reports are based largely on regular  embassy reporting, embassies must obtain additional information to write  the International Religious Freedom Report. State officials told us that  the Office works with Foreign Service officers worldwide to write the  report and that drafting and publication of the report involves a number  of review phases. According to Foreign Service officers in our five  fieldwork countries, they undertake a number of activities—such as  monitoring court cases related to religious freedom and maintaining  relationships with religious communities, religious leaders, civil society,  NGOs, and foreign-government officials throughout the year—to gather  information for the report. After they complete the initial drafts, numerous  offices and bureaus in Washington review and revise the draft country  reports through an iterative process. Before finalizing the report,  embassies and various State offices approve each country report and  relevant sections.
The Act establishes several responsibilities that the Secretary of State  conducts with the assistance of the Ambassador and the Office. These  include designating CPCs, developing religious freedom–related training for Foreign Service officers, including chiefs of mission, and establishing  an international religious freedom website.
In response to the Act, the Secretary of State has reviewed the status of  religious freedom in each foreign country and designated those countries  whose government has engaged in, or tolerated, particularly severe  violations of religious freedom as CPCs. State officials said that the  Secretary of State tasks the Office with the development of CPC  recommendations. State does not designate CPCs every year, and  according to State officials, the Act does not require the agency to do so.  A State official said that the Office develops the recommendations based  on its assessment of many factors, including (1) whether the government  is restricting rights or is complicit in allowing certain groups to be targeted  and (2) whether issues are systematic, egregious, and ongoing.  According to State officials, the Office reviews the International Religious  Freedom Report and consults with the Ambassador, DRL management,  and others within and outside State when developing recommendations  for the CPC list. For example, the Office meets with USCIRF officials and  considers their recommendations. The Office also discusses the CPC  recommendations with National Security Staff. On the basis of the  Office’s recommendations, the Ambassador and DRL management  determine the final list of countries they will recommend for CPC  designation to the Secretary of State.
The Secretary of State periodically designates CPCs after reviewing the  recommendations that the Ambassador and DRL management provide.  Since 1999, Secretaries of State have designated CPCs at least nine  times, designating 10 countries as CPCs: Burma, China, Eritrea, Iran,  Iraq, North Korea, Saudi Arabia, Sudan, Vietnam, and Uzbekistan (see  fig. 2). In addition, the Secretary of State designated two regimes as  particularly severe violators of religious freedom—the Milošević regime in  Serbia and the Taliban regime in Afghanistan. To date, Iraq, Vietnam, the  Milošević regime, and the Taliban regime are the only entities that State  has removed from the CPC list.CPC in 2004, the Ambassador negotiated an action plan with the  Vietnamese government whereby the government, among other things,  would pass a law to reduce religious persecution. On the basis of  subsequent actions by the Vietnamese government, State removed  Vietnam from the list in 2006. Similarly, the current Ambassador and her  staff recently developed an action plan to help the government of another  designated country identify actions that, if taken, could support the  removal of the country from the CPC list.
section_title: USCIRF Is Implementing Its Primary Responsibilities as Outlined in the Act and Has Undertaken Other Activities
paragraphs: USCIRF is implementing its primary responsibilities as outlined in the Act  by conducting an ongoing review of violations of religious freedom  throughout the world and issuing policy recommendations to the  President, the Secretary of State, and Congress. According to USCIRF  officials, the culmination of these activities is the release of its own annual  report on international religious freedom, which the Act also requires.Based on USCIRF’s ongoing reviews, the report discusses the 20 to 30  countries that USCIRF considers the worst offenders of religious freedom  and presents policy recommendations to the U.S. government. In addition  to performing these activities, USCIRF has at times provided technical  assistance or recommendations to foreign officials through meetings,  letters, press releases, or editorials.
subsections: section_title: USCIRF Conducts Ongoing Review of the Circumstances of Religious Freedom Violations
paragraphs: In accordance with the Act, USCIRF conducts an ongoing review of  violations of religious freedom throughout the world by undertaking  independent research and reviewing State’s annual International  Religious Freedom Report. USCIRF staff members are responsible for  specific regions of the world or thematic areas and information collection  from a range of sources, including religious communities, NGOs, and  U.S. and foreign-government officials as well as from documentation and  media reports on those countries. USCIRF officials stated that they  interact with a network of NGOs through various international religious  freedom working groups, roundtables, seminars, and conferences as well  as through State contacts. USCIRF officials also travel abroad to observe  conditions and meet with U.S. embassy and foreign-government officials  and NGO officials and members of religious communities. For example,  according to USCIRF staff, at their request State officials in Turkey  organized a roundtable of NGOs to brief USCIRF commissioners on  religious freedom issues during their 2011 visit to the country. Similarly, in  the United States, USCIRF officials meet with members of religious  communities, including diaspora communities, NGOs, human rights  activists, dissidents, victims of religious freedom violations, academics,  experts, and U.S. and foreign-government officials. USCIRF staff engage  with their counterparts in State’s Office of International Religious Freedom  and the relevant officers in State’s regional bureaus to understand the  conditions of religious freedom in various countries and U.S. government  efforts to promote religious freedom in those countries. According to  USCIRF staff, they also review and independently verify the  characterization of facts and the status of religious freedom in State’s  annual report.
section_title: USCIRF Provides Policy Recommendations
paragraphs: In accordance with the Act, USCIRF provides policy recommendations to  the President, the Secretary of State, and Congress through various  means. According to USCIRF officials, the primary mechanism for  providing recommendations is its annual report. Specifically, the chapter  for each country in the USCIRF report contains a list of recommendations  for U.S. government action with regard to religious freedom in that  country. For example, in the 2010 report’s chapter on Eritrea, USCIRF  made 20 recommendations, including that the U.S. government should  continue to designate Eritrea as a CPC, should impose targeted  sanctions against individuals and institutions identified as responsible for,  or complicit in, serious human rights abuses, and should prohibit any  foreign company’s raising capital or listing its securities in the United  States while engaged in developing Eritrea’s mineral resources.  USCIRF also provides recommendations to the U.S. government through  correspondence, congressional testimony, press releases, editorials, and  policy briefs. In addition, USCIRF officials stated that they provide  recommendations during meetings with State and other executive branch  officials and their staff and members of Congress and their staff. For  example, in a July 2012 letter to the Secretary of State, USCIRF  recommended that the U.S. government work with the new Egyptian  government to (1) ensure that a portion of U.S. military assistance is used  to help Egyptian police assess security needs for protecting religious  minority communities and (2) undertake reforms to promote religious  freedom. USCIRF staff first draft these documents and recommendations,  which the commissioners then review and approve with a majority vote.
section_title: USCIRF’s Annual Report Focuses on Countries That USCIRF Considers the Worst Offenders
paragraphs: According to USCIRF officials, the culmination of USCIRF’s primary  responsibilities is the release of its annual report. The report, based on  USCIRF’s ongoing reviews, discusses the 20 to 30 countries that  USCIRF considers the worst offenders of religious freedom. The report  also presents policy recommendations to the U.S. government with  regard to religious freedom in each of those countries. USCIRF officials  stated that the annual report covers a smaller number of countries than  the State report because the USCIRF report focuses only on countries in  which religious freedom violations occur and because USCIRF does not  have the resources needed to report on the status of religious freedom in  every country. According to USCIRF officials, staff first provide  recommendations to the commissioners regarding the countries that  should be included in the report, on the basis of (1) the staff’s ongoing  monitoring of religious freedom and (2) trends or changes in countries  that USCIRF observed in its prior-year report. Commissioners then  discuss and vote on which countries to include, on the basis of the staff  recommendations and the commissioners’ interests, knowledge, and  deliberations. The report contains three sections that, respectively, highlight the countries that USCIRF recommends that the Secretary of  State designate as CPCs for particularly severe violations of religious  freedom;  focus on the countries USCIRF has placed on a watch list for serious  violations of religious freedom that do not meet the CPC threshold but  require very close attention; and discuss other countries and issues of concern.
The CPC and watch list sections of the report are divided by country and  includes a summary of religious freedom conditions in that country, U.S.  government policies and actions taken in the country, and policy  recommendations for the U.S. government.
USCIRF officials stated that the policy directors, the executive director,  and commissioners review the report for accuracy and tone. USCIRF staff  said that they verify information in the report with State officials, NGOs,  and religious communities. Commissioners deliberate and vote on which  countries they want to categorize as CPCs, place on the watch list, or  identify as additional countries of concern. After commissioners make a  determination for each country, staff members prepare the country  chapters and circulate them to the commissioners for review.  Commissioners’ dissenting opinions are included in the report when  voting is not unanimous. For example, in USCIRF’s 2012 annual report, a  commissioner dissented from the CPC recommendation for Iraq, stating  that USCIRF’s report, among other things, did “not establish either that  the government  engaged itself in severe violations or that it  tolerated them.” Further, the commissioner stated that USCIRF’s report  “only establishes the existence of such violations and the inability of the  government to prevent them always (or prevent them often).”
section_title: USCIRF Has Provided Technical Assistance and Recommendations to Foreign Officials
paragraphs: In addition to carrying out the primary responsibilities laid out in the Act,  USCIRF at times has provided technical assistance and  recommendations to foreign officials through meetings, letters, press  releases, and editorials. Examples of these activities include the  following.
Meetings with foreign officials. During meetings abroad, USCIRF has  provided assistance to foreign governments and at times has called  directly for policy changes. For instance, according to USCIRF’s 2011  annual report, USCIRF worked with members of the Indonesian  House of Representatives and civil society groups to introduce  measures to strengthen criminal code provisions regarding attacks on  religious gatherings and to amend laws governing the building of  religious venues. Further, during its 2011 visit to Saudi Arabia,  USCIRF said that it called on high-level Saudi officials to release long- term religious prisoner Hadi Al-Mutif from prison and raised concerns  about six young Shi’a Muslim prisoners.
Writing letters to foreign officials. USCIRF provided policy  recommendations to foreign officials through letters. In June 2010,  USCIRF wrote a letter to the Ambassador of the Republic of Turkey  about reports of Turkish government interference in the election of the  Armenian Orthodox Patriarch, requesting additional information and  urging the removal of governmental constraints on such internal  church matters. In June 2011, USCIRF wrote to the Head of Mission  of the Government of South Sudan, providing a review of the draft of  the Government of South Sudan’s interim constitution and offering  suggestions to strengthen the freedom of religion or belief provisions.
Writing press releases. According to USCIRF officials, it issues press  releases in response to current events and at times has used press  releases to urge foreign officials to take actions. For example, in a  May 2011 press release, USCIRF provided recommendations to the  government of Egypt. USCIRF recommended, among other things,  that the government establish a special unit in the Office of the Public  Prosecutor that would be dedicated to investigating acts of violence  against Egyptian citizens on the basis of religion or belief, particularly  Coptic Orthodox Christians; vigorously prosecuting, and bringing to  justice, perpetrators of these acts; and ensuring compensation for  victims. In addition, in a July 2012 press release, USCIRF urged  China’s government to lift its restrictions on all peaceful religious  activities in the Xinjiang Uighur Autonomous Region, especially during  the Muslim holy month of Ramadan.
Writing editorials. USCIRF commissioners have written editorials that  also urge foreign officials to take actions related to religious freedom.  For example in a November 2011 editorial, USCIRF commissioners  stated that Pakistan’s government should replace current public  school textbooks with ones that exclude messages of intolerance,  hatred, or violence based on religious or other differences. Also, in a  January 2012 editorial, USCIRF commissioners wrote that “Nigeria’s  political establishment, including President Goodluck Jonathan and  other leaders, should muster the will and courage not only to curb the  strife but to bring all perpetrators to justice.”
section_title: State and USCIRF Have Not Defined How They Should Interact, Which Has at Times Created Foreign Policy Tensions
paragraphs: Although the Act, as amended, directs State and USCIRF to cooperate,  they have not defined how they should interact. As a result, their level of  interaction has fluctuated over the years, although it has recently  increased after a period of little interaction. In addition, State and USCIRF  have at times conveyed inconsistent information to foreign-government  officials on U.S. foreign policy, creating tensions that State has had to  mitigate.
subsections: section_title: Act Directs State Office and USCIRF to Cooperate, but Agencies Have Not Defined How They Should Interact
paragraphs: The Act created two separate entities that are to cooperate and work on  behalf of international religious freedom, yet the Act does not prescribe  how State and USCIRF should interact and coordinate their efforts. The  Act establishes the Ambassador as an ex-officio member of USCIRF and  states that the Ambassador is to consider USCIRF’s advice in making  policy recommendations. In addition, the Act states that the Secretary of  State is to consider USCIRF’s recommendations in preparing the annual  report on international religious freedom. A 1999 amendment to the Act  directs USCIRF to cooperate with State, stating that “he commission  shall seek to effectively and freely cooperate with all entities engaged in  the promotion of religious freedom abroad, governmental and  nongovernmental, in the performance of the commission’s duties,”  specifically listing State among those entities. At the same time, the Act  originally directed that the commission would terminate four years after  the initial appointment of all of the commissioners.
According to USCIRF, the commission is independent, bipartisan, and dedicated to  defending the universal right to freedom of religion or belief abroad. of a country’s religious freedom situation can create a line of  communication for State if, for instance, that country’s officials then  decide they want to work with State to determine how they can stay off of  the official CPC list. The Act also requires USCIRF to conduct an “annual  and ongoing review of the facts and circumstances of violations of  religious freedom presented ” as well as make policy  recommendations to the Secretary of State, among others. At the same  time, the Ambassador, as an ex-officio member of USCIRF, sits on a  commission that gives recommendations to the Ambassador’s agency.
All of the Ambassadors and many of the commissioners we spoke with  said that they have never jointly defined how they should interact. Former  and current commissioners expressed various ideas about the ex-officio  role of the Ambassador; for example, commissioners stated that the  Ambassador should participate in every USCIRF meeting and share  information, that the Ambassador’s role was irrelevant to USCIRF’s work,  and that the Ambassador should not participate in USCIRF discussions.  Some former commissioners said that without the Ambassador’s regular  participation, USCIRF had difficulty getting access to State policymakers  to discuss religious freedom. One former commissioner said that such  access would have enriched USCIRF’s recommendations. At the same  time, two of the current commissioners said that USCIRF could improve  its efforts to understand State’s diplomatic efforts with regard to religious  freedom.
The Ambassadors also provided varying interpretations of the ex-officio  role. They said, for example, that the Ambassador should be an active  participant at USCIRF meetings during every discussion, short of voting;  that the Ambassador’s role was to explain State activities and actions to  USCIRF and that USCIRF, conversely, should include the Ambassador  on e-mails and other forms of internal communication; and that the  Ambassador has no clear role on USCIRF but should try to attend as  many USCIRF commissioner meetings as possible. One of the  Ambassadors said that commissioners did not always include him in e- mail conversations and exchanges, resulting in a loss of communication.  For example, he said that at times commissioners withheld documents  and e-mail communications from the Ambassador’s office or only shared  drafts of press releases at the last minute, thereby inhibiting the  Ambassador’s ability to convey State’s perspective or correct factual  errors.
section_title: State and USCIRF’s Interaction Has Fluctuated
paragraphs: The level of interaction between the Ambassador and USCIRF has varied  greatly over the years. According to the first Ambassador and USCIRF  officials, the first Ambassador attended USCIRF’s monthly meetings,  participated in their monthly teleconferences, and traveled overseas with  the USCIRF chair on one occasion. However, that Ambassador said he  had discussed his ex-officio role with USCIRF only once, during a debate,  when a commissioner told him he should not be participating. State and  USCIRF officials told us that the second Ambassador began his tenure by  regularly attending the monthly USCIRF meetings, but he attended less  frequently over time. Former State officials and USCIRF officials said that  both entities considerably decreased their official communication, in part  because of disagreement over how they should work together.
As the level of interaction between the Ambassador and commissioners  has varied over the years, so has the level of interaction between their  staffs. According to State and USCIRF officials, when the Ambassador  and commissioners had little official interaction, their staffs had little  interaction as well, although they did try to maintain some informal  collaboration. For example, according to one former Office staff member,  during a period of little official interaction and even discouragement of  staff interaction, he and the USCIRF executive director began meeting for  lunch to maintain a line of communication. In addition, a former  commissioner noted that when the Ambassador’s position was vacant for  2 ½ years, USCIRF’s contact with State was primarily at the staff level.
More recently, according to the current Ambassador and USCIRF  officials, they have increased their interaction from its previously low level,  with both a new Ambassador and a largely new commission in place. For  example, from 2009 to 2011, USCIRF and State officials, including  officials from the Office of International Religious Freedom, collaborated  on efforts that led to the passage of UN Resolution 16/18 to combat  religious intolerance. The Ambassador now participates in the lunchtime  portions of discussions during some of the monthly meetings, although  she generally does not participate in USCIRF’s monthly teleconferences.  The Ambassador and the current USCIRF chair also have been joint  presenters at various forums, both in the United States and abroad. In  October 2012, for example, they gave a joint speech on religious freedom  at Europe’s largest annual human rights and democracy conference,  sponsored by the Organization for Security and Co-operation in Europe.  In addition, staff from the Office and USCIRF staff stated that they share  information with each other more now than in the past. State and USCIRF  officials told us that this information sharing recently helped USCIRF  determine whether to elevate a country from its watch list to its CPC  recommendation list. State and USCIRF officials discussed the issues as  well as actions that State would take with the country’s officials. Their  interaction resulted in USCIRF’s keeping the country on its watch list  rather moving it to the CPC list.
section_title: State and USCIRF’s Limited Interaction Created Foreign Policy Tensions That State Had to Mitigate
paragraphs: All three Ambassadors and a few commissioners told us that the limited  interaction between State and USCIRF, arising from a lack of a definition  of how they should interact, had sometimes created tensions with foreign- government officials. For example, USCIRF recommended in its 2012  annual report that the Secretary of State designate Turkey as a CPC. The  Ambassador was not regularly attending USCIRF meetings at the time,  and State officials learned of USCIRF’s intent to recommend Turkey only  shortly before USCIRF published its report in March 2012. State officials  tried to engage the commissioners and explain State’s position against  such a recommendation, but USCIRF proceeded to recommend Turkey  for CPC designation. Turkish officials from the Ministry of Foreign Affairs  said in a press release that USCIRF’s report directly contradicted State’s  annual report on religious freedom, and called the USCIRF report “null  and void.” State officials told us that they had to resolve the resulting  tensions with the Turkish government. In June 2012, a senior State  official briefed USCIRF regarding State’s position on Turkey, namely, that  because the Turkish government had taken actions to improve religious  freedom in the country, Turkey did not deserve CPC designation.
In addition, according to State officials, because the Ambassador and  commissioners have not defined how they should interact, they have at  times communicated conflicting information to foreign governments on  behalf of the United States. For example, 5 days after USCIRF  recommended Turkey for CPC designation in March 2012, the President  publicly congratulated the Turkish prime minister on efforts he had made  to protect religious minorities in Turkey. In addition, one Ambassador said  that in meetings with foreign-government officials, he sometimes not only  had to explain the function of USCIRF, but—because some statements  by commissioners were not in line with U.S. foreign policy—he also had  to clarify that USCIRF did not speak for him, even as an ex-officio  member of the commission, or for the U.S. government.
All three Ambassadors cited instances when USCIRF’s approach with  foreign-government officials created bilateral tensions. For example, the  first Ambassador recounted helping to bring a delegation of high-level  Laotian officials to the United States to tour, meet with government  officials and religious communities, and view examples of religious  freedom.they freed 34 of 37 people imprisoned for their religious beliefs. The  Ambassador told us that as a result, he had judged that Laos was making  progress in instituting some real changes in the area of religious freedom;  however, USCIRF recommended Laos for CPC designation shortly  thereafter. The Ambassador said that USCIRF’s recommendation almost  ruined State’s diplomatic efforts to address religious freedom in Laos. In  another example, in 2005, the second Ambassador negotiated an action  plan with the Vietnamese government including actions that, if taken by  the government, could support its case for removal from the CPC list.  According to State officials, Vietnam took the necessary steps and the  Secretary of State removed the country’s CPC designation in 2006.  However, when USCIRF commissioners visited Vietnam later that year,  according to State and Vietnamese officials, they offended the  Vietnamese officials by their conduct in high-level meetings. State officials  told us that this was damaging to some of the progress made with  Vietnamese officials and necessitated efforts to repair the U.S.  relationship with Vietnam.
According to the Ambassador, when the delegation returned,  Some State, USCIRF, and NGO officials we spoke with raised other  concerns about the role USCIRF has played with respect to U.S. foreign  policy. According to a former commissioner, during her tenure on  USCIRF, commissioners became bolder in speaking out in letters or  during meetings with foreign officials, and it was unclear to her whether  these activities were within the bounds of the Act. Also, USCIRF officials  told us that the commission has at times applied an expansive  interpretation of the Act, questioning whether the responsibilities in the  Act were a “floor or a ceiling.” They also said that, under USCIRF’s  mandate to provide recommendations to the U.S. government on  religious freedom, USCIRF has the obligation to help foreign  governments take actions to address U.S. critiques. Some former  commissioners said that foreign governments have at times requested  advice or assistance from USCIRF and that, in general, USCIRF urged or  made recommendations to foreign officials when it thought the  recommendations were consistent with U.S. foreign policy. At the same  time, some USCIRF officials noted that without active participation from  the Ambassador, they risk not fully understanding U.S. foreign policy in a  particular situation or country.
section_title: NGOs Generally Rated Overall U.S. Government Efforts Positively While Raising Some Concerns and Suggesting Several Improvements
paragraphs: The NGOs—religious organizations and other civil society groups—that  we surveyed, as well as NGO representatives whom we interviewed,  generally rated overall U.S. government, State, and USCIRF efforts to  promote international religious freedom positively. At the same time, they  raised some concerns and suggested several improvements, such as  including more civil society and other nonstate actors and making the  promotion of international religious freedom a higher foreign-policy  priority. Likewise, NGOs that were familiar with State’s and USCIRF’s  annual reports generally viewed both reports positively, although several  raised concerns about a lack of objectivity in each report. Finally, NGOs  generally viewed CPC designations positively, although some doubted  the helpfulness of the designations to their own religious freedom work.
subsections: section_title: NGOs Generally Rated Overall U.S. Government Progress Positively While Suggesting Improvements
subsections: section_title: Overall Progress
paragraphs: The NGOs that we surveyed and NGO representatives whom we  interviewed indicated that they generally rated overall U.S. progress in  promoting international religious freedom positively, although most  provided specific suggestions to improve U.S. government efforts.  Among the 84 NGOs that responded to our survey, 63 NGOs (75 percent)  said that the U.S. government had made at least some progress in  promoting religious freedom overall. The responding NGOs also  generally said that the U.S. government had made progress in promoting  specific international religious freedom activities, such as engaging in  dialogue with foreign governments to effect changes in policy (59 of 83  NGOs, or 71 percent) and engaging in dialogue with NGOs and civil  society groups regarding international religious freedom (65 of 84 NGOs,  or 77 percent). For additional survey results, see appendix IV.
One of the NGO survey responses stated, “I believe that it is very helpful  that the U.S. government emphasizes religious freedom as a key foreign  policy issue. This keeps the issue on the international agenda.” NGO  representatives whom we spoke with on our field visits echoed these  views, and a few told us that, in their opinion, the United States is the only  country actively encouraging other governments to improve religious  freedom. For example, some NGO representatives in four of our five  fieldwork countries told us that they communicated with the U.S. embassy  regularly, both on their own initiative and in response to information  requests from the embassy’s human rights officer. Representatives of  other NGOs, in Turkey and Vietnam, said that the U.S. embassies have  invited them to interfaith discussions hosted by the embassies and that  they were free to contact the embassies to raise specific issues regarding  religious freedom situations. However, a representative from a religious  group in Afghanistan told us that although he had met with U.S. officials  on multiple occasions over the past few years and had described to them  the various challenges facing his religious community, he had not seen  any action taken.
While the NGO responses to our survey generally expressed positive  views of U.S. government efforts to promote international religious  freedom, they also raised some concerns and identified several areas  where they believed the U.S. government could improve its efforts.
In response to our survey’s request for elaboration on ratings of progress  made, the NGOs’ most common concern was that international religious  freedom was not as high a priority for the U.S. government as it should be  and that this hindered overall efforts to promote international religious  freedom (9 of the 27 NGOs that elaborated on their responses expressed  this view). For example, one NGO stated, “Too often, religious freedom  appears to be an afterthought.” Other NGOs commented that State has  not made international religious freedom a priority and that the Office is  not valued within State’s structure. Other NGOs expressed in the survey  the perception that the U.S. government has had limited success in  promoting international religious freedom in general, including through the  use of the CPC designation, or in obtaining the release of prisoners of  conscience. When asked to list their organization’s top suggestions to  improve U.S. government efforts to promote international religious  freedom, 27 of the 69 NGOs (39 percent) that responded to the question  suggested greater inclusion of, and consultation with, civil society and  nonstate actors, both in the United States and abroad. One NGO  responding to the survey pointed to State’s Religious Freedom and  Foreign Policy Working Group as a positive development toward  addressing this concern.
Other frequently suggested improvements included making international  religious freedom a higher priority in U.S. foreign policy and empowering  State—and to a lesser extent, USCIRF—with greater resources and  authority to promote international religious freedom. For example, an  NGO responding to our survey suggested that the U.S. government  “include the promotion of international religious freedom as a greater  aspect of formulating foreign policy toward a particular country or region.”  Another NGO responded that “funding should be substantially increased  for both the Office and USCIRF. They have a tiny amount of resources  with which to investigate an issue affecting billions of individuals.”
section_title: NGOs Generally Rated Both State’s and USCIRF’s Annual Reports Positively but Raised Some Concerns about Lack of Objectivity
subsections: section_title: State’s Annual Report
paragraphs: Most of the NGOs that responded to our survey questions about State’s  annual report on international religious freedom rated the report  positively. The NGOs responding to the survey and the NGO  representatives we interviewed in Indonesia, Turkey, Vietnam, and  Uzbekistan were largely familiar with the State report. Of the 84 NGOs  that responded to our survey, 70 (83 percent) stated that they were  familiar with the report. Representatives from several NGOs and religious  organizations whom we met with in Indonesia, Turkey, Vietnam, and  Uzbekistan told us that State’s annual report raises awareness of  religious freedom issues in their countries and around the world. For  example, one NGO representative told us that the report is a useful tool  for disseminating information about the situation in her country and helps  raise awareness of the issues to the government of her country and to the  world. A leader of a religious organization in another country explained  that the publication of the State report proves to his country’s government  that the U.S. government is aware of the restrictions placed on his  religious community. He said that this knowledge has influenced his  government’s decision making in some cases, such as in the early  release of a prisoner, jailed for conscientious objection to military service,  whom State listed in its report.
These results reflect NGO responses rating State’s annual report as extremely or very  useful and as useful or somewhat useful. groups we met with during our field visits tended to identify State as the  U.S. actor most responsible for promoting international religious freedom.
Additionally, of the 70 NGOs that were familiar with State’s annual report,  61 NGOs (87 percent) said that the report was credible overall and 58  NGOs (83 percent) said that it was accurate. Several NGO  representatives whom we spoke with overseas said that they could vouch  only for information they provided to the embassy and were hesitant to  judge the reports’ degree of accuracy and comprehensiveness.
However, 16 of the 70 NGOs familiar with the State report (23 percent)  rated its objectivity as only fair or poor. In addition, 11 of 28 NGOs that  elaborated on their responses to questions about State’s report raised  concerns about a perceived lack of objectivity in State’s report. One NGO  noted, “There is a perception of the report, by the international civil  society, American NGOs, and State Department personnel that the  conclusions of the report are politically predetermined.” NGOs had a  similar concern when responding about the usefulness of State’s report.  Five of the 11 survey respondents who elaborated on their response said  that they perceive State’s report to be influenced by U.S. policy. One  NGO wrote, “The State Department tends to undervalue religious  freedom issues in countries where there are significant U.S. economic or  security interests.”
Most of the NGOs that responded to our survey expressed positive views  of USCIRF’s annual report on international religious freedom. Of the 84  respondents, 64 NGOs (76 percent) were familiar with the USCIRF  report. Fifty-one of the 64 NGOs familiar with the report (80 percent) said  that it was at least somewhat useful in affecting religious freedom in a  country and 49 of the 64 NGOs (77 percent) said that it was at least  somewhat useful in affecting U.S. policy.representatives whom we interviewed in Afghanistan, Indonesia,  Uzbekistan, and Vietnam were not aware of USCIRF’s report—for  example, none of the 9 representatives of NGOs, religious or in civil  society, whom we interviewed in Uzbekistan were familiar with the report.
Many of the NGO  Of the 64 respondents that were familiar with USCIRF’s annual report, 59  NGOs (92 percent) said the report was credible and 57 NGOs (89  percent) said it was accurate. One NGO commented further that “the  IRF report is a credible source of information which accurately highlights  challenges in countries.” Another NGO commented, “USCIRF made an  effort to talk directly to victims of religious persecution and to verify the  facts they presented.”
Nine of the 64 respondents that were familiar with the USCIRF report  rated its objectivity as “fair” or “poor,” and 5 of 14 NGOs that elaborated  on their responses about USCIRF’s annual report reported a perceived  lack of objectivity of the report. For example, one NGO commented, “The  USCIRF report can feel more overtly steered by U.S. diplomatic and  political interests.” Another stated that the report has, “in some cases,  been more representative of individual concerns of the appointed  commissioners, rather than a comprehensive and evenhanded analysis of  IRF  concerns and abuses worldwide.” An  additional 4 of the 14 NGOs commented that USCIRF’s report was not  always comprehensive, omitting some countries and focusing on CPC  countries, and said that it reflected individual commissioners’ concerns.  This observation was further echoed when NGOs were asked to provide  suggestions for improving the USCIRF report. Other groups echoed one  NGO’s suggestion of “more global coverage and better documentation of  incidents reported.”
section_title: NGOs Had Generally Positive Views about CPC Designations, but Some Questioned the Designations’ Usefulness to Their Work
subsections: section_title: State’s CPC Designations
paragraphs: NGOs expressed somewhat mixed opinions about whether the Secretary  of State’s CPC designations helped or hindered their work. Of the 84  respondents to our survey, 38 NGOs (45 percent) said that the CPC  designation helped their work, 26 NGOs (31 percent) said that it neither  helped nor hindered, and 6 NGOs (7 percent) said that it hindered their  work. The remaining 14 NGOs (17 percent) had no opinion. For example,  one NGO explained, “Other nations take notice of U.S. government  religious freedom concerns raised in the report but since there are few  negative consequences even if given a CPC designation, those nations  may be inclined to ignore U.S. human rights criticisms.” Other  government-sanctioned groups, such as those we spoke with in  Uzbekistan, said the CPC designation of their country was not justified  and did not affect them or their communities. In contrast, several NGO  representatives whom we interviewed in Vietnam said that the CPC  designation of the country from 2004 through 2006 put pressure on the  Vietnamese government to institute religious freedom reforms. Further,  some said that the removal of Vietnam from the CPC list had slowed  progress and had lessened pressure on the Vietnamese government to  protect religious freedom. However, some also said that redesignating  Vietnam as a CPC was unwarranted, given the progress that the country  has made.
Similarly, NGOs expressed somewhat mixed opinions about whether  USCIRF’s CPC or watch list recommendations helped or hindered their  work. Of the 84 respondents to our survey, 40 NGOs (48 percent) said  that USCIRF’s CPC recommendations had helped their work, 21 NGOs  (25 percent) said that the designations neither helped nor hindered, and 5  NGOs (6 percent) said the designations hindered their work. The  remaining 16 NGOs (19 percent) expressed no opinion.perceptions of the watch list that USCIRF compiles, in addition to  providing its CPC recommendations, were similar to respondents’  perceptions of both the State and USCIRF CPC lists. Of the 84 survey  respondents, 37 NGOs (44 percent) said that USCIRF’s watch list  recommendations helped their work, 26 NGOs (31 percent) said that the  designations neither helped nor hindered, and 5 NGOs (6 percent) said   The NGOs’  that the designations hindered their work. The remaining 15 NGOs (18  percent) expressed no opinion.
Fifty-two of the 84 NGOs that responded to our survey (62 percent) said  that they agreed with USCIRF’s recommendations to designate 25 to 30  countries as CPCs or for its watch list. neither agreed nor disagreed, 5 of the NGOs (6 percent) disagreed, and  17 of the NGOs (20 percent) had no opinion. An additional 26 NGOs  responded with specific suggestions for improving the USCIRF annual  report—for example, taking a more comprehensive approach to reporting  globally, soliciting additional input from other sources, and providing  constructive examples of how countries can improve religious freedom.
Ten of the 84 NGOs (12 percent)
section_title: Conclusions
paragraphs: Both State and USCIRF have implemented their primary responsibilities  outlined in the Act, and each has undertaken a variety of activities in  response to increased restrictions on religious freedom around the world.  In general, NGOs that we surveyed and NGO representatives whom we  interviewed expressed positive perceptions of these activities, including  State’s and USCIRF’s annual reports on international religious freedom.  However, the lack of a definition regarding how the two entities are to  interact has created foreign policy tensions that State has had to mitigate.  These tensions have resulted in part from the fact that the Ambassadors  and USCIRF have not defined the Ambassador’s role as an ex-officio  member of the commission. Guidance that would clarify how State and  USCIRF are to cooperate would strengthen each entity’s unique  contribution to promoting international religious freedom. It would also  institutionalize their information sharing and help ensure that the U.S.  government presents a more consistent foreign policy message with  respect to religious freedom.
section_title: Recommendation for Executive Action
paragraphs: These results reflect NGO responses of “strongly agree” and “somewhat agree” to  USCIRF’s annual CPC recommendations. ex-officio role of the Ambassador-at-Large for International Religious  Freedom as a nonvoting USCIRF member.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the State and USCIRF for comment.  We received written comments from both entities, which are reproduced  in full in appendices V and VI, respectively. State and USCIRF agreed  with our recommendation and both expressed willingness to take action.  We also received technical comments from each, which we incorporated  throughout our report as appropriate.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of State, and the Chair of USCIRF. In addition,  the report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-9601 or MelitoT@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix VII.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The United States Commission on International Religious Freedom  Reform and Reauthorization Act of 2011 mandated that we report to the  Senate Committee on Foreign Relations and the House Committee on  Foreign Affairs on several matters related to U.S. promotion of  international religious freedom. In addition, the mandate included a  specific requirement that we consult with nongovernmental organizations  (NGO) in preparing the report. In response to the mandate, this report  assesses (1) the Department of State’s (State) implementation of its  primary responsibilities established in the International Religious Freedom  Act of 1998 (the Act); (2) the U.S. Commission on International Religious  Freedom’s (USCIRF) implementation of its primary responsibilities  established in the Act; (3) State’s and USCIRF’s interaction in their efforts  to promote religious freedom; and (4) NGOs’ views on U.S. efforts to  promote international religious freedom. The mandate also directed us to  compare USCIRF with other advisory commissions; for this analysis, we  summarized a previous Congressional Research Service report (see app.  II).
To address our four objectives, we conducted fieldwork in five countries— Afghanistan, Indonesia, Turkey, Uzbekistan, and Vietnam. We selected  these countries on the basis of their meeting at least two of the following  criteria: (1) State had funded international religious freedom programs in  the country; (2) the country was on USCIRF’s watch list; (3) USCIRF had  recommended the country for designation as a Country of Particular  Concern (CPC) or State had designated it as a CPC; and (4) the  Ambassador-at-Large for International Religious Freedom (the  Ambassador) or USCIRF had visited the country in the previous 3 years.  Specifically:
Afghanistan. State had funded international religious freedom  programs in the country. In addition, USCIRF had included  Afghanistan on its watch list for several years and visited the country  in 2010.
Indonesia. State had funded international religious freedom programs  in the country, and USCIRF had included Indonesia on its watch list  for several years.
Turkey. USCIRF recommended Turkey for CPC designation for the  first time in 2012, but according to State officials, State did not agree  with the recommendation. The Ambassador and USCIRF had both  traveled to Turkey in the previous 3 years.
Uzbekistan. State had designated Uzbekistan as a CPC for several  years and had waived sanctions against it. The Ambassador had  traveled to Uzbekistan in the last year.
Vietnam. State had funded an international religious freedom program  in the country. State removed Vietnam from the CPC list in 2006,  making it one of only two countries that State had ever removed from  the CPC list. The Ambassador had traveled there in the last year.
While in each country, we interviewed State embassy officials, including  the U.S. Ambassador to the country and the International Religious  Freedom officer. We also interviewed representatives from host  governments, NGOs, and religious communities. In two countries we  visited, we also met with officials from third-country embassies.
To address our first objective, we reviewed the provisions of the Act and  identified the primary responsibilities that the Act established for State.  We also analyzed State documents, including cables, grant materials,  State’s annual International Religious Freedom Report, the 2003 State  Inspector General’s Report of Inspection: Bureau for Democracy, Human  Rights and Labor, and the Inspector General’s 2005 Compliance Follow- up Review on the Bureau for Democracy, Human Rights and Labor. We  also met with State officials, including staff from the Office of International  Religious Freedom, all three Ambassadors-at-Large for International  Religious Freedom—two former and one present—and senior level  officials such as an Assistant Secretary and two Under Secretaries in  Washington, D.C. We requested that State provide us with cables to  demonstrate the type of activities it undertook from January 2009 through  October 2012 to (1) promote or improve international religious freedom  and (2) document international religious freedom issues. State provided  us with 183 unclassified cables, five of which were duplicates. State also  identified more than 100 additional classified cables that pertained to  CPCs, but State did not provide those cables to us in time for us to  analyze them for this report. This analysis does not provide a full list of all  religious freedom–related activities that State conducted worldwide during  this time period, because (1) not all activities are reported in cables; (2)  State may not have located all the relevant cables sent during this time  period; and (3) we did not receive the classified cables in time for us to  analyze them for this report. See appendix III for a summary of our  analysis of the cables.
In response to our request that State identify all of its grants related to  international religious freedom, State provided us with a list of 27 grants  that it had grouped either globally or by region of the world. For our  analysis, we selected seven grants that generally represented the largest  award amount in each region of the world and that included both ongoing  and completed grants as well as a grant in one of our fieldwork countries.  We also selected a seventh grant that was not country specific from the  global programs category. For each of these seven grants, we reviewed  the grant’s goals and objectives, how the grant implementer measured  progress toward those goals, and whether the implementer reported  meeting the goals.
To address our second objective, we reviewed the provisions of the Act,  identified the primary responsibilities that the Act established for USCIRF,  and analyzed USCIRF documents such as its annual report on  international religious freedom, letters to U.S. government officials,  editorials, and press releases. To determine how USCIRF implemented  its primary responsibilities, we also interviewed USCIRF staff and 20 of  the 33 commissioners appointed to USCIRF, including all of the current  commissioners. In addition, we also interviewed all three Ambassadors- at-Large—two former and one present—who serve as ex-officio members  of USCIRF. We conducted these interviews in or near Washington, D.C.
To address our third objective, we met with officials from State and  USCIRF, including all three Ambassadors-at-Large—two former and one  present—and all of the current and approximately half of the former  USCIRF commissioners. We also interviewed State and foreign- government officials in our fieldwork countries, as well as NGO officials  both in the United States and abroad who have worked closely with both  entities. In addition, we analyzed State cables as well as documents from  USCIRF, including press releases, editorials, and their annual reports.
To address our fourth objective, we conducted a survey of NGOs that we  identified from five sources: (1) State’s Office of International Religious  Freedom’s list of 30 most-consulted NGOs; (2) USCIRF’s list of NGOs  that the commission has worked, or been in contact, with; (3) members of  the Secretary of State’s Religion and Foreign Policy Working Group; (4) a  list of NGOs participating in the International Religious Freedom  Roundtable in Washington, D.C.; and (5) the Pew Online Directory of  Religious Advocacy Groups, which the Pew Research Center’s Pew  Forum on Religion and Public Life developed. These sources produced a  list of 317 unique NGOs. To determine the universe of NGOs from our  five sources, we contacted each NGO and identified 137 that had  conducted work related to international religious freedom. We developed  a web-based survey instrument in August 2012 and pretested it with 6  NGOs. The survey contained closed- and open-ended questions in four  general areas: (1) demographics, (2) State’s international religious  freedom activities, (3) USCIRF’s international religious freedom activities,  and (4) general U.S. policy on international religious freedom. We sent  the web-based survey to all 137 NGOs via e-mail in September 2012.  However, we removed six NGOs from our universe of 137, resulting in a  universe of 131 NGOs, after 5 NGOs responded that they did not conduct  work related to religious freedom and we determined that one NGO was a  duplicate. We received 84 responses to our survey, or a 64 percent  response rate. The results of the survey reflect the views of only the  respondents to our survey and cannot be generalized either to the  universe of 131 organizations or to any other organizations that are  involved in these types of issues. See appendix IV for selected survey  results.
We administered the web-based survey from September 5 to October 18,  2012. We sent each NGO an e-mail invitation to complete the survey on a  GAO web server using a unique username and password. During the  data collection period, we sent reminder e-mails and made phone calls to  nonresponding NGOs. Because this was not a sample survey, it had no  sampling errors; however, the practical difficulties of conducting any  survey may introduce nonsampling errors, such as difficulties in  interpreting a particular question, which can introduce unwanted  variability in the survey results. We took steps to minimize nonsampling  errors by pretesting the questionnaire with six NGOs representing  different religious traditions or no religious affiliation. We conducted  pretests to ensure that the questions were clear and unbiased, that the  data and information were readily obtainable, and that the questionnaire  did not place an undue burden on respondents. Additionally, a senior  GAO methodologist independently reviewed a draft of the questionnaire  prior to its administration. We made appropriate revisions to the content  and format of the questionnaire after the pretests. All data analysis of  survey results were independently verified for accuracy.
In addition, we conducted a limited content analysis of open-ended  responses to five survey questions. We developed initial categories for  selected questions with open-ended responses, to characterize the  general theme of the response. For responses to questions asking about  the credibility of each report, we developed the following categories:  Timeliness (described as the frequency and/or timing of the reports);  Effectiveness; Specific; CPC; Lack of Objectivity (initially coded as  “Bias”); Lack of Input; Composition/Format; Contrast; and Lack of  Resources. For questions elaborating on the perception of the usefulness  of each report, we developed the following categories: Specific; Policy  (regarding the formulation/motivation of U.S. international religious  freedom policy); CPC; Contrast; Limited (meaning the State or USCIRF  report has a circumscribed impact); and Not Applicable. For the question  asking NGOs to provide their suggestions on ways to improve U.S.  promotion of international religious freedom, we developed the following  categories: Inclusion; Measurement; Enforcement; Empowerment;  Awareness; Prioritize; Specific; and Not Applicable. One analyst coded  the responses with at least one category, with an optional second  category. After the initial coding, a second analyst independently  assigned categories to the same responses. The analysts then reconciled  the two sets of coding, assigning a final determination to each response.  A methodologist then reviewed the categories, making language changes  as needed. These results were then tabulated.
We conducted this performance audit from March 2012 to March 2013 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comparison of the U.S. Commission on International Religious Freedom with Other Select Congressional Commissions
paragraphs: The United States Commission on International Religious Freedom  Reform and Reauthorization Act of 2011 directed us to, among other  things, conduct a comparative analysis of the structure of the U.S.  Commission on International Religious Freedom (USCIRF) in relation to  other U.S. advisory commissions. To conduct this analysis, we relied on  the Congressional Research Service’s (CRS) compilation of  Congressional Advisory Boards and Commissions to which Congress has  a direct appointing role.
In 2013, CRS reported on the 85 permanent and temporary congressional  commissions whose members Congress participates in appointing. CRS  defines a congressional commission as a multi-member independent  entity that (1) is established by Congress, (2) exists temporarily, (3)  serves in an advisory capacity, (4) is appointed in part or whole by  members of Congress, and (5) reports to Congress. CRS grouped the  current 85 congressional commissions in four categories: (1) policy  advisory bodies, (2) commemorative advisory bodies, (3) operational  advisory bodies, and (4) diplomatic advisory bodies. Given that CRS  categorized USCIRF as a policy advisory body, we focused our  comparative analysis on the 26 advisory bodies that CRS classified as  policy advisory bodies.
Our analysis shows that USCIRF does not appear to be unique among  policy advisory bodies in duration limit, membership numbers, or  appointment terms. USCIRF comprises 10 members known as  commissioners, with 2-year appointments and a limit of two terms. Following are characteristics of the 26 policy advisory bodies:
Seven of the advisory bodies had a statutory duration limit, while 19  did not.
Membership ranged from 4 to 37 members.
Appointments ranged from 1 to 6 years for advisory bodies that had  delineated term limits; five of the advisory bodies had term limits for  the life of the body; two of the advisory bodies had term limits for the  duration of the Congress from which they were appointed; and one  advisory body had a statutorily unclear term of appointment.
section_title: Appendix III: Analysis of Department of State Cables Concerning International Religious Freedom
paragraphs: We asked the Department of State (State) to provide us with cables  concerning international religious freedom sent from January 2009  through October 2012. State provided 183 cables, 5 of which were  duplicates. We analyzed the cables to obtain information on the activities  U.S. embassies and other U.S. government entities conduct to promote  religious freedom. However, because not all activities are reported in  cables, and because State might not have located all the relevant cables  sent during this time period, this analysis does not provide a full list of all  religious freedom–related activities that State performed globally during  this time period. We developed 10 categories to analyze, or code, the  activities described in the cables. We included a category for duplicate  cables within the list of 10 categories and a category titled “other” for  cables that did not fit into any one of the 9 categories. Because many of  the cables covered a variety of topics, our coding rules allowed multiple  codes to be applied to each cable. Two analysts independently coded  each cable and then reconciled any differences in their coding.
section_title: Appendix IV: Selected Results from Survey of Nongovernmental Organizations
paragraphs: We conducted a survey of 131 nongovernmental organizations (NGO)  that we identified as having conducted work related to international  religious freedom. Of the 131 NGOs, 84 responded to the survey. The  survey addressed the Department of State’s (State) and the U.S.  Commission on International Religious Freedom’s (USCIRF) international  religious freedom activities, including their respective annual reports;  State’s designations, and USCIRF’s recommendations for designations,  of Countries of Particular Concern (CPC); overall U.S. government  progress on international religious freedom; and U.S. international  religious freedom policy. For a full description of the survey’s  methodology, see appendix I. Figures 4 through 11 summarize selected  results of the NGO responses to our survey. We selected these survey  results because they add additional detail to the information summarized  in the report.
section_title: Appendix V: Comments from the Department of State
section_title: Appendix VI: Comments from the U.S. Commission on International Religious Freedom
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Cheryl Goodman and Michael  Rohrback (Assistant Directors), Judith Williams, Sushmita Srikanth, Juan  P. Avila, Amanda Bartine, and Kathryn Crosby made key contributions to  this report. Jessica Bull, Lynn Cothern, Martin De Alteriis, Etana Finkler,  Rachel Girshick, Heather Hampton, David Hancock, Brandon Hunt, Jill  Lacey, Reid Lowe, Mary Moutsos, Elizabeth Repko, and Jeremy Sebest  also provided substantial assistance.