Foreign Affairs: Agencies Have Improved the Intercountry Adoption Process, but Further Enhancements Are Needed
Published: 2005-10-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: U.S. intercountry adoptions nearly tripled from more than 8,000 to more than 22,000 between fiscal years 1994 and 2004. While the Department of State (State) and U.S. Citizenship and Immigration Services (USCIS) manage the process, factors ranging from corruption to inadequate legal frameworks in foreign countries could lead to abuses such as the abduction of children. GAO (1) describes the U.S. intercountry adoption process, (2) assesses the U.S. government's efforts to manage the intercountry adoption process, (3) assesses U.S. efforts to strengthen safeguards and mitigate against the potential for fraudulent adoptions, and (4) describes the Hague Convention (Convention) and the statuses of U.S. and top sending countries' implementation of the Convention.
section_title: What GAO Found
paragraphs: Adoptive parents must meet domestic and foreign government requirements to complete intercountry adoptions. However, factors such as foreign governments' procedures may contribute to varying time frames for adoptions. USCIS and State are the domestic agencies responsible for intercountry adoptions. USCIS and State made efforts to enhance the process by improving interagency coordination and communication with parents and developing additional guidance on adoptions. In addition, USCIS streamlined the intercountry adoption process by eliminating the application and fees for parents to obtain U.S. citizenship certificates for eligible children. While USCIS has taken measures to review the quality of the adoptions process, GAO found that the agency does not have a formal quality assurance program in place where results are summarized and reported to senior agency officials so that an assessment of the quality of the intercountry adoption process can be made over time. Factors in foreign countries' environments may allow for abuses in adoptions. To reduce the likelihood of such abuses, USCIS and State have taken such steps as holding diplomatic discussions with foreign governments and imposing additional U.S. procedural requirements. However, USCIS has not established a formal and systematic process for documenting specific incidents of problems in foreign countries. Such a process would allow for a systematic approach to analyze problematic trends and retain institutional knowledge. The Hague Convention governing intercountry adoptions establishes minimum standards designed to help alleviate some of the risk associated with the adoption process. The United States has signed the Convention and taken several steps toward implementing the Convention; however, key steps remain, including formal ratification of the Convention. Since its creation, 66 countries (which represented about 39 percent of all U.S. intercountry adoptions in fiscal year 2004) have ratified the Convention.

section_title: Letter
paragraphs: More and more U.S. citizens are starting and expanding their families by  adopting children from other countries. The number of children that  entered the United States through intercountry adoptions increased from  about 8,000 in fiscal year 1994 to about 22,000 in fiscal year 2004. The U.S.  intercountry adoption process is managed by the Department of Homeland  Security’s (DHS) U.S. Citizenship and Immigration Services (USCIS) and  the Department of State (State) and is complicated by a number of  domestic and foreign government requirements for adopting a child from  another country. Prospective parents often use the services of an adoption  agency to help guide them through this adoption process and identify  orphans that need families. To adopt a foreign-born child that will live in  the United States, the prospective parents must meet qualifications  outlined by U.S. immigration law. Additionally, the child and the  prospective parents must meet the legal requirements for adoption in the  child’s country of origin, and the child must meet requirements outlined by  U.S. immigration law to enter the United States. Despite the existence of  such U.S. and foreign government regulations, a number of factors in  foreign countries, such as corruption, may lead to abuses in intercountry  adoption procedures. In recent years, several countries have suspended  their intercountry adoption programs in response to concerns over abuses  in intercountry adoptions, as well as to review their intercountry adoption  processes and improve safeguards. The 1993 Hague Convention on  Protection of Children and Co-Operation in Respect of Intercountry  Adoption (Convention) provides additional safeguards by establishing  uniform standards for intercountry adoptions.
In response to your interest in intercountry adoptions, this report (1)  describes the U.S. intercountry adoption process, (2) assesses USCIS’ and  State’s efforts to manage the intercountry adoption process, (3) assesses  U.S. efforts to strengthen safeguards and mitigate against the potential for  fraudulent adoptions, and (4) describes the Hague Convention and the  statuses of U.S. and top sending countries’ implementation of the  Convention.
To address our objectives, in Washington, D.C., we interviewed USCIS and  State officials responsible for intercountry adoptions and reviewed  relevant agency documents on the U.S. intercountry adoption process. We  also visited USCIS offices in New York and Los Angeles to see how USCIS  implements domestic procedures related to intercountry adoptions. Both  of these offices ranked in the top 20 percent of domestic offices for the  number of intercountry adoption cases received in fiscal year 2004 and  demonstrate geographic diversity. In addition, we contacted U.S. adoption  organizations and agencies to understand their roles, as well as some  adoptive parents who belonged to national adoptive parent support groups  and were willing to respond to us, to hear about their experiences with the  U.S. intercountry adoption process. To understand the intercountry  adoption environment and U.S. processes and procedures in overseas  locations, we visited Guatemala and Russia. These two countries were  consistently ranked among the countries where the majority of children  adopted into the United States originated from in fiscal years 1994 to 2004.  In both countries, we met with USCIS and State Bureau of Consular Affairs  officials managing the U.S. intercountry adoption process, foreign  government officials, and private adoption facilitators, and visited  orphanages to learn about their respective roles in the adoption process.  We conducted research on the Convention by reviewing it, obtaining  information on countries’ current statuses, verifying that the Convention’s  Web site data was current through a discussion with a member of the  Convention, and discussing the implementation statuses with Guatemalan  and Russian government officials. Appendix I contains a more detailed  description of our scope and methodology.
We performed our work from February to October 2005 in accordance with  generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: The INA defines U.S. parameters for intercountry adoptions. INA  establishes criteria for children’s entry into the United States and eligibility  requirements for prospective adoptive parents of children from foreign  countries. A child is eligible for an immediate relative (IR) classification  under the INA if the child meets the definition of an “orphan,” as stipulated  in the act. In addition, adopting parents must meet certain requirements  related to their age, financial status, and medical condition.
Over the past 5 years, there have been legislative developments in the U.S.  intercountry adoption process, with further changes proposed. The  Intercountry Adoption Act of 2000 (IAA) provides the domestic legislation  to implement the 1993 Hague Convention on Protection of Children and Co- operation in Respect of Intercountry Adoption, hereinafter referred to as  the Hague Convention or the Convention in this report. The IAA designates  State to serve as the Central Authority of the United States to carry out  most responsibilities of the Convention, including accreditation of  adoption service providers. Also in 2000, the United States enacted the  Child Citizenship Act to allow automatic citizenship for eligible adopted  children. Furthermore, in 2005 congressional legislation was introduced  regarding the U.S. intercountry adoption process.
subsections: section_title: Intercountry Adoptions Have Steadily Increased
paragraphs: Intercountry adoptions may be a viable alternative to domestic adoptions  for parents interested in adopting an infant, according to the National  Adoption Information Clearinghouse. In fiscal years 2002 to 2004, DHS  reported that at least 40 percent of children adopted by U.S. parents were  under age 1, and at least 42 percent were between the ages of 1 and 4. In the  past 10 years, the annual number of U.S. intercountry adoptions has  consistently increased and nearly tripled, from more than 8,000 in fiscal  year 1994 to more than 22,000 in fiscal year 2004 (see fig. 1).
The majority of children adopted into the United States between 1994 and  2004 have originated from four countries—China, Russia, South Korea, and  Guatemala—which consistently ranked among the top five sending  countries of children adopted by U.S. parents (see app. II for a listing of all  intercountry adoptions by country in fiscal year 2004). In total, adoptions  from these four countries accounted for over 70 percent of all U.S.  intercountry adoptions in the past 10 years (see fig. 2).
Adoptions from China, Russia, and Guatemala increased significantly  between fiscal years 1994 and 2004, accounting for the vast majority (92  percent) of the total increase (about 14,000) in U.S. intercountry adoptions  during this time. The number of adoptions from South Korea has remained  more consistent during this time (see fig. 3).
Although the United States is one of the world’s leading receiving countries  for intercountry adoptions, some U.S. children are adopted by foreigners.  Statistics on the number of U.S. children adopted by foreigners are not  currently collected on a national level, however, Canada, for example,  reports adoptions of over 700 U.S. children from 1993 to 2002.
section_title: Current Restrictions on Intercountry Adoptions
paragraphs: In recent years, several countries, including the United States, have  restricted intercountry adoptions from or to all or specified countries for  various reasons, including concerns of fraud, medical concerns,  natural disasters, and time allowed for a country to review safeguards in  its intercountry adoption process. Although some of these restrictions have  since been removed, such as those recently in China, Azerbaijan, and  Vietnam, several remain in effect. Currently, the United States has a  suspension on intercountry adoptions from Cambodia—the only U.S.- imposed suspension—which was issued in 2001 due to evidence of  widespread corruption. Additionally, several foreign governments currently  have restricted intercountry adoptions, in some cases because the  countries are examining their adoption process (see table 1).
section_title: USCIS and State Implement Law for U.S. Intercountry Adoptions, with Foreign Governments Playing a Role in the Process
paragraphs: The U.S. intercountry adoption process, which is defined by the INA and  primarily implemented by USCIS and State, is complicated by a number of  domestic and foreign government requirements and can be separated into  three phases. First, USCIS determines the parents’ eligibility and fitness to  adopt through its review of the prospective parents’ application, home  study reports, and background checks. Next, USCIS—or State, in countries  where USCIS has no offices—determines the child’s orphan status by  examining documents and, when warranted, conducting overseas  investigations. Finally, State’s overseas consular officers verify the child’s  orphan status and eligibility for an immigrant visa. (Fig. 4 illustrates the  three phases of the U.S. government’s process for intercountry adoptions.)  Depending on the type of visa issued, children admitted to the United  States may qualify for automatic citizenship. Various factors, such as  different foreign government’s requirements, contribute to varying lengths  of time required for the process and the varying costs incurred by adoptive  parents.
subsections: section_title: Phase I—Prospective Parents’ Suitability to Adopt Is Determined
paragraphs: In the first phase of the U.S. intercountry adoption process, USCIS  determines the potential parents’ suitability to adopt a child who resides  outside of the United States. The INA defines qualifications for prospective  adoptive parents. USCIS implements this requirement through its 68  domestic offices. Prospective parents submit to USCIS fingerprints; a  filing fee; home study; proof of compliance with preadoption  requirements of the prospective parent’s state of residence; other  documents such as proof of citizenship, age, marriage license, and divorce  decrees; and, in some cases, an Application for Advance Processing of  Orphan Petition (Form I-600A). The home study is completed by a party  approved under the laws of the prospective parent’s state of residence,  such as an adoption agency, and includes interviews with the family and an  assessment of the prospective parent’s suitability to adopt a child. After  USCIS receives all required documents from parents, the agency reviews  the documents, conducts background checks on all adult members living in  the household, and makes its determination. If USCIS determines that the  prospective parents are eligible to adopt and fit to provide the child with  proper care, then it sends them a Notice of Favorable Determination  Concerning Applications for Advance Processing of Orphan Petition (Form  I-171H or I-797C).
section_title: Phase II—Child’s Status as an Orphan Is Determined
paragraphs: The second phase in the process requires U.S. federal agencies to  determine the orphan status of the child to be adopted, as defined by the  INA. Depending upon the location of the child, either an USCIS officer or  State consular officer determines whether the prospective adoptive child  meets the U.S. immigration law definition of an orphan.
Once a child has been identified, adopting parents file a Petition to Classify  the Orphan as an Immediate Relative (Form I-600), provide proof of the  child’s age and identity, proof that the child is an orphan, and proof of a  foreign government-issued adoption decree or guardianship. In order to  obtain adoption decree or guardianship in the foreign country, parents  must meet the foreign government’s laws and requirements. Foreign  governments may place additional requirements on prospective parents,  including those regarding the prospective parents’ age and residency in  country, as well as the requirement for parents to agree to provide post  adoption information. The Russian government, for example, requires an  agreement from adoptive parents to provide periodic and on time  postplacement reports. However, Russian government officials have noted  that American adoptive parents have not always complied with this  requirement.
USCIS or State officials review the documentation for Form I-600 and,  depending on the specifics of the case, may also undertake a field  investigation. Sometimes officers interview birth mothers or visit  orphanages to verify the circumstances surrounding the child’s orphan  status. Following the completed review, USCIS or State officials make a  determination. If all documents are sufficient and the child has been  determined an orphan, USCIS or State officials approve the I-600 petition  and send parents a Notice of Approval of Relative Immigration Visa  Petition (Form I-171).
section_title: Phase III—Child’s Eligibility to Immigrate to the United States Is Determined
paragraphs: The third step of the process involves State’s issuance of an immigrant visa  to the child for admission into the United States. With respect to state law,  most states grant full recognition to a foreign adoption decree. In some  instances, states require adoptive parents to validate the foreign decree.
After parents have an approved Form I-600, they submit a completed  Immigrant Visa application (Form DS-230, Parts I and II) along with the  application fee and required documentation. The consular officer then  examines the documents, which include the following:   child’s birth certificate and passport (or other valid travel document);  evidence of adoption or legal custody for purposes of emigration and  adoption, as well as evidence of whether the adopting parents saw the  child prior to or during adoption proceedings (if applicable); and   record of medical exam from the embassy’s panel physician (this exam  is largely to ensure that children with communicable diseases do not  enter the United States; parents are advised by State to consult with  other professionals for complete physical or mental evaluations of the  orphan’s health). If significant health problems are uncovered, parents  may be asked to sign an affidavit acknowledging their desire to continue  with the case given the medical condition of the child and, in some  cases, parents may be requested to sign an affidavit regarding their  intent to obtain necessary vaccinations for the child upon entry to the  United States.
State consular officers then approve the child for an IR-3 or IR-4 immigrant  visa, if all documentation for the orphan is in order. State provides an  immigrant visa package for the child to be presented to the Customs and  Border Protection officer at the U.S. port of entry. According to State  officials, the visa issuance process usually takes about 1 or 2 days.
section_title: U.S. Citizenship Requirements Differ Depending on Visa Classification
paragraphs: The INA establishes the criteria by which foreign-born children adopted by  U.S. parents become U.S. citizens. Foreign-born children under the age of  18 admitted to the United States and residing permanently in the United  States based on an issued IR-3 visa automatically acquire U.S. citizenship as  of the date of admission to the United States. USCIS reviews IR-3 visa  packages and sends Certificates of Citizenship to eligible children without  requiring any additional forms or fees. In most cases, children that receive  IR-4 visas may automatically acquire U.S. citizenship at entry if there was a  final adoption abroad by a U.S. citizen parent and the state where the child  resides does not require readoption. Other children that receive IR-4 visas  acquire U.S. citizenship upon full and final adoption in the United States.
section_title: A Range of Factors Contribute to Varying Adoption Completion Times and Costs
paragraphs: Various factors make it difficult to generalize the length of time required  and exact costs incurred by adoptive parents for intercountry adoptions.  Country-specific adoption requirements, particularly in the top sending  countries of U.S. intercountry adoptions, may contribute to the different  time frames it may take to adopt a child. For example, the Russian  government requires adoptive parents to travel to Russia to meet the  prospective adoptive child. Since Russia also requires that the child remain  in Russia before the court hearing, adoptive parents may travel a second  time to Russia to attend the court hearing and adopt the child. In addition,  procedural requirements in the foreign country may be difficult to meet.  For instance, in Guatemala, birth certificates of the adopted child and  documents proving the identity of birth mothers may be difficult and time- consuming to locate. Other factors, such as the prospective parents’ ability  to provide adequate and timely information to meet U.S. intercountry  adoption requirements, may also contribute to the length of time it takes  for U.S. government officials to approve adoptions. For example,  prospective parents may file application forms for intercountry adoptions  to USCIS, which allows prospective parents up to 12 months to submit  supportive documentation, such as the home study. Estimated total  adoption costs incurred by adoptive parents may also vary depending on  the foreign country. Table 2 shows the variations on the estimated length  of time that foreign governments take to approve typical U.S. intercountry  adoption cases in country and estimated cost of an adoption incurred by  adoptive parents among the top sending countries of U.S. intercountry  adoptions.
section_title: U.S. Agencies Improved the U.S. Intercountry Adoption Process, but USCIS Lacks a Formal Quality Assurance Process
paragraphs: In 2002, an interagency task force on intercountry adoptions was created to  examine ways to improve the U.S. intercountry adoption process, and  USCIS and State implemented most of the priorities that the task force  identified as necessary for improving the adoption process. USCIS has  taken measures to review the quality of the adoptions process but lacks a  structured quality assurance program where results are summarized and  communicated to senior agency officials.
subsections: section_title: USCIS and State Improved the Intercountry Adoption Process
paragraphs: USCIS and State have taken several measures to improve the intercountry  adoptions process. The Commissioner of the Immigration and  Naturalization Service (INS) made intercountry adoptions a priority for  the agency in March 2002, after the Commissioner suspended orphan visa  processing for Cambodia. The INS created an adoptions task force with  State to comprehensively review the existing INS structure for handling  intercountry adoptions. The task force identified several priorities to  improve the intercountry adoption process, and the agencies have, over the  past 3 years, addressed many of the priorities by taking the following  actions:   Improved interagency coordination: The task force suggested that  coordination needed to continue and that USCIS consider how adoption  work should be distributed and coordinated between USCIS and State.  USCIS and State’s Bureau of Consular Affairs have established a  relationship to work together to address and resolve adoption issues.  For instance, the agencies hold quarterly meetings to coordinate  implementing changes to regulations, discuss challenges to the process,  and improve the forms used by officials in the process. In particular,  USCIS and State officials regularly discuss specific adoption cases and  issues that arise in overseas posts, as well as regulatory, administrative,  and policy matters related to intercountry adoptions. Moreover, in April  2005, USCIS and State’s Bureau of Consular Affairs officials met at a  USCIS field office to establish a mechanism for sharing information on  visa processing.
Improved efforts to communicate with parents: The adoptions task  force identified the need for USCIS and State to provide advisory  notices for prospective adoptive parents. The task force suggested that  emphasis should be placed on ensuring that parents were consistently  informed about procedures, as well as prohibitions related to child  buying in the process, and that parents receive the most current and  complete information available on issues identified in countries where  adoptions occur. To improve communications with parents, USCIS and  State’s Office of Children’s Issues in the Bureau of Consular Affairs  provide information on their Web sites, USCIS and State officials meet  with adoption organizations and parents to discuss various issues and  USCIS field offices have taken steps to provide customer service to  parents. For example, USCIS and State Web sites provide information  on the process in the United States and overseas, and the roles of both  agencies, and alert parents to potential concerns through advisory  notices about adoption procedures in other countries. USCIS and State’s  Office of Children’s Issues provide outreach to parents and the adoption  community by presenting information at regional and national  conferences. In the two domestic USCIS field offices we visited, we  found that officials had taken several actions to communicate with  prospective adoptive parents, such as establishing procedures to meet  prospective parents and providing telephone numbers for parents to  directly contact the Adoption Adjudication Officer.
Developed standard operating procedures: Another priority of the  adoptions task force was for USCIS to provide consistent guidance for  its field officers adjudicating orphan petitions by developing standard  operating procedures on how to determine parents’ suitability to adopt  and a child’s orphan status. The task force pointed out that, in some  cases, an adjudicator may be the only person in the field office that  handles adoptions and may have a supervisor reviewing their work who  does not have expertise in adoptions. The task force also reported that,  even among the best adjudicators, there was little procedural  consistency in adjudicating adoptions and no centralized guidance from  headquarters. To address this priority, in 2003, USCIS developed  standard operating procedures on adoption adjudications and made  them available to their staff electronically. We reviewed the standard  operating procedures and found that they described in a very detailed  manner the process for adjudicating orphan petitions. Furthermore,  State provides guidance to consular officers on how to process orphan  visa cases in its Foreign Affairs Manual.
Conducted agency training: The task force noted that both USCIS and  State officials sometimes lacked the training necessary to determine  orphan status. In response, USCIS developed training materials for its  domestic and overseas field adjudicators for determining orphan status  and conducted an intercountry adoptions training course in 2002, which  some State officials attended. We reviewed the training materials and  found that they re-emphasized INA statutes for defining orphan status,  defined the agency’s role and responsibilities for adjudicating orphan  petitions, and provided details for conducting orphan investigations. In  addition, to assist consular officers in their orphan investigations, State  offers fraud training to help its officers ascertain whether information in  documents for determining orphan status, such as birth certificates, is  false or whether documents have been altered or falsified. According to  a State official, State increased the frequency of the course from twice a  year to 8 to 10 times per year in 2005.
Streamlined the intercountry adoption process: The task force  emphasized that the agency continue to demonstrate its commitment to  maintaining the intercountry adoption process as a priority. USCIS  streamlined some of its intercountry adoption procedures as a result. A  USCIS official acknowledged that the agency is challenged to balance  the prospective parents’ interest in creating their new family as quickly  as possible with the need to review and process each application and  the required documents in accordance with U.S. law. To address issues  relating to timeliness, the agency has instituted a policy requiring  completion of all immigration related applications within 6 months.  Between October 2003 and July 2005, the agency has processed  adoption applications in less than 4 months, on average. According to  USCIS officials, many petitioners file an incomplete Advanced Orphan  Petition (Form I-600A) or Orphan Petition (Form I-600) while they are in  the process of completing their home study. Regulations allow the  petitioner(s) up to 12 months to submit supportive documentation. The  agency strives to process completed applications within 30 days of  receiving all required documentation, according to USCIS officials.
In addition, in November 2003, USCIS made efforts to eliminate its  backlog of U.S. citizenship certificates by centralizing the process.  USCIS advised its field offices that, if they needed assistance with their  backlog, to send these cases to a central location for processing.  According to a USCIS official, from November through December 2003,  this central office processed 671 of the 700 backlogged cases—the  remaining cases were either denied or returned to the field office for  additional follow-up. In addition, to streamline and simplify the  issuance of Certificates of Citizenship for adopted children who receive  IR-3 visas and have their adoption finalized overseas, USCIS created the  IR-3 Entrant Program in January 2004. The program eliminates the  application and fee for citizenship certificates for about 70 percent of  children adopted by U.S. citizens. A USCIS official noted that the  agency has consistently met its goal to provide certificates within 45  days after the family has entered the United States.
Further, in the intercountry adoption process, a system of checks and  balances has developed that allows State, in the visa issuance phase, to  review USCIS paperwork before issuing the visa to the child.  Additionally, as a part of the streamlined process for issuing the  citizenship certificates to adopted children, USCIS reviews IR-3  immigrant visa packages to verify that the child acquired automatic  U.S. citizenship upon admission to the United States as required under  the INA. Since April 2005, USCIS and State have established procedures  to specifically address issues in visa classification decisions.
section_title: USCIS Has Taken Measures to Review the Quality of the Adoptions Process, but a Structured Quality Assurance Program Is Not in Place
paragraphs: The adoptions task force reported that USCIS should adopt a quality  assurance program for orphan adjudications. Although USCIS has taken  measures to review the quality of the adoptions process, we found that  USCIS has not developed a formal quality assurance process, similar to the  programs used in other areas of the agency. The activities of the quality  assurance program could include such procedures as the review of random  cases adjudicated by field officers to determine whether they are following  agency guidance and procedures, as well as the evaluation of statistics to  determine average processing times of orphan petitions by field offices.
The task force reported that, even among the best officers, there was little  procedural or substantive consistency in approach or a centralized source  of guidance from headquarters. In 2003, USCIS developed standard  operating procedures that detailed a step by step approach for adjudicating  orphan petitions with the goal of improved consistency among its  adjudications, but the agency has not provided training to adjudicating  officers on these new procedures. The task force also reported that  problems in adjudicating orphan petitions can be traced to the fact that  individuals train their successors as best as they can, but there is no routine  mechanism for obtaining feedback on written work from someone with  specialized adoption expertise. In the field offices we visited, we found that  the adjudicators had learned the process for adjudicating adoption  petitions mostly through on-the-job training and mentoring. USCIS held  intercountry adoptions training in 2002 as a result of the task force’s  suggestion; however, not all adjudicators who process adoption cases  attended the training. A USCIS official stated that the agency plans to hold  similar training in fiscal year 2006, but no dates have been set.
In January 2004, as part of the Child Citizenship Act Program, the USCIS  Buffalo office began its review of adoption documents for children who  received IR-3 visas to help ensure the accuracy and completeness of the  information relating to the adoption process. This review process accounts  for about 70 percent of the adoption cases, with the remaining 30 percent  not included. The USCIS Buffalo office has an informal process for  addressing individual cases by sending e-mails to relevant officials at  USCIS and State. We reviewed several of the e-mails sent by the USCIS  Buffalo office, which identified issues such as insufficient documentation,  misclassifications of visas, and inconsistent interpretation of INA  regulations. While USCIS Buffalo’s review process has merits, the results of  the review are not summarized and formally reported to either senior  USCIS or State officials. Moreover, USCIS does not have a structured  approach that would allow the agencies to assess the quality of the  intercountry adoption process over time, ensure that senior officials from  USCIS and State are aware of the results, and identify opportunities where  additional training or guidance may be warranted.
section_title: USCIS and State Have Taken Steps to Strengthen Safeguards to the Process in Foreign Environments, but USCIS Does Not Systematically Document Incidents of Potential Abuses
paragraphs: The conditions in foreign environments can contribute to potential abuses  in the intercountry adoptions process. USCIS and State have taken steps to  increase safeguards and mitigate the potential for fraudulent adoptions,  though USCIS has not formally and systematically documented specific  problematic incidents to help USCIS adjudicators better understand the  potential pitfalls in some intercountry adoptions.
subsections: section_title: Factors in Some Foreign Countries May Contribute to Abuses in U.S. Intercountry Adoptions
paragraphs: While the U.S. immigration law covering intercountry adoptions is designed  to ensure that adopting parents are suitable and fit to provide proper care  of the child and that the foreign-born child is an orphan, conditions in some  countries—such as corruption and the lack of a legal framework over  intercountry adoptions—may lead to abuses in the intercountry adoption  process. According to the United Nations Children’s Fund (UNICEF),  such abuses are more likely to occur in countries where legislative  provisions are nonexistent, inadequate, or plagued with gaps and  loopholes. UNICEF research also identified that risk for abuses  significantly increased when government entities that oversee the adoption  process are absent, insufficient, or when the prospective parents act  through intermediaries that may not be licensed. For example, State has  received a growing number of complaints concerning adoption facilitators  operating in various countries. Licensing of agents and facilitators is done  in accordance with local law. However, not all foreign governments require  that agents and facilitators be licensed. Accordingly, it can be difficult to  hold facilitators accountable for fraud, malfeasance, or other bad practices  in general.
According to USCIS, State, and UNICEF, there have been some known  cases of abuse in intercountry adoptions, which include  exchanging a child for financial or material rewards to the birth family,  or “child buying”;  deliberately providing misleading information to birth parents to obtain   providing false information to prospective adopters;  obtaining favorable adoption decisions from corrupt local or central  government officials.
Past difficulties with intercountry adoptions in foreign countries, most  notably in Cambodia, illustrate the potential effect of high-risk adoption  environments. The United States issued a suspension on intercountry  adoptions from Cambodia in December 2001 after receiving complaints  from nongovernmental organizations in Cambodia that criminals were  involved in “baby buying” for adoptions. From 1997 to 2001, the  conspirators operated a scheme to defraud U.S. citizens who adopted some  700 children from Cambodia. The conspirators received approximately $8  million dollars from adoptive parents in the United States. The conspiracy  involved assorted crimes, including alien smuggling, visa fraud, and money  laundering, and included schemes such as the use of baby buyers obtaining  children from birth parents by informing the birth parents that they may  have their child back at any time, then obtaining false Cambodian  passports to enable the children to leave the country. In 2004, after a DHS  investigation, a U.S. adoption facilitator pled guilty to conspiracy to  commit visa fraud and conspiracy to launder money.
The United States has also noted ongoing concerns with intercountry  adoptions in certain countries, as of the date of this report. These countries  include Guatemala, where a large number of U.S. adopted children  originate from, as well as Nepal, Nigeria, and Sierra Leone. In Guatemala,  USCIS and State noted on their Web sites that the use of a false birth  mother to release her child is the usual method chosen by unscrupulous  operators to create a paper trail for an illegally obtained child. USCIS and  State officials acknowledged the known problems in Guatemala of birth  mothers who are paid by private adoption attorneys to relinquish their  children for adoption. According to State, problematic cases may further be  complicated by high incidence of corruption and civil document fraud in  Guatemala. In Nepal, visa fraud is a significant problem facing potential  adoptive parents, according to State’s Web site. State also emphasized that  document and identity fraud related to adoptions are serious concerns in  Nigeria, and a high rate of adoption fraud has been uncovered in Sierra  Leone.
section_title: Both Agencies Have Taken Steps to Strengthen Intercountry Adoption Safeguards in Foreign Countries, but USCIS Has Not Formally and Systematically Documented Incidents of Potential Abuses
paragraphs: USCIS and State have taken various steps to strengthen safeguards against  abuses associated with adoptions from foreign countries. USCIS and  State’s Office of Children’s Issues coordinate to provide publicly available  information to alert prospective adoptive parents to country-specific  adoption processes and serious problems that may develop or already exist  in foreign adoption processes State officials also hold diplomatic  discussions with foreign countries regarding intercountry adoptions.  Through discussions between the United States and Vietnam, for example,  intercountry adoptions, which had been suspended, resumed after the two  countries signed an agreement of cooperation in June 2005. In addition,  USCIS has established written guidance for ways to identify fraud in  intercountry adoption cases. The guidance provides that USCIS officers  consider specific fraud indicators, such as documentary deficiencies and  delays in registering birth certificates. Furthermore, State has provided  fraud prevention management training to State consular officers, and  USCIS officials said that all USCIS officers receive training, which includes  an antifraud segment, when hired.
USCIS and State have established procedures for determining the orphan  status of the child based on the conditions that exist in the country relating  to the intercountry adoption process. These procedures may add to the  length of time for the adoption process. For example, in countries where  the adoption process is clear and transparent, and when officers deal with  adoption agencies with high standards, USCIS allows the field investigation  to be completed through a documentary review. In some instances,  however, deficiencies or inconsistencies in the documentation presented  will require in-depth field investigations. In certain countries, these  investigations can include additional steps, such as interviews with the  birth mother, DNA testing when necessary and feasible, and interviews  with adoption entities such as facilitators, orphanage directors, and local  officials. In Guatemala, for example, USCIS requires DNA testing in all  cases where the child is released by an identified birth mother due to  concerns over the use of false birth mothers to release illegally obtained  children. In Nigeria, where document and identity fraud related to  adoptions are serious concerns, all adoptions are required to undergo full  field investigations to verify the authenticity of the information provided in  the adoption decrees and U.S. orphan petitions. These added steps in the  process may contribute to a lengthier completion time for intercountry  adoptions, but may also help the U.S. government in ensuring the  legitimacy of information provided on the adopted child and in detecting  fraud.
Both USCIS and State publicize general knowledge of the risk environment  in foreign countries. However, while State has documented specific  concerns via cable communication, USCIS has not established a procedure  to systematically document instances of individual problematic situations  identified through its intercountry adoption work in foreign countries,  including its staff’s knowledge of unscrupulous adoption attorneys and  facilitators, as well as disreputable orphanages and adoption agencies.  Although USCIS officials informed us that they discuss the risk  environment in foreign countries with overseas staff on a periodic and  informal basis, agency officials’ knowledge of specific incidents of concern  may be better captured in a systematically documented method. In  Guatemala, for example, USCIS staff informed us of instances where  facilitators may have provided substantial funds to birth mothers who have  relinquished their children for adoption. A USCIS official had also banned  specific adoption attorneys in Guatemala from submitting intercountry  adoption cases due to the USCIS official’s suspicions of the attorneys’  fraudulent practices. This information, however, is communicated  anecdotally to other USCIS officials without being specifically and  systematically documented. In addition, while USCIS provides information  for State’s publicly available notices documenting country conditions,  individual and detailed accounts of concern are not systematically  captured. USCIS officials also noted that they have access to cables  prepared by State officials that discuss concerns with intercountry  adoptions in foreign countries. Contents in State’s documented cables  range from documentation of general risks to intercountry adoptions in  foreign countries to findings during orphan investigations in specific  adoption cases.
GAO internal control standards specify that agencies consider adequate  mechanisms to identify risks arising from external factors, including  careful considerations of the risks resulting from interactions with other  federal entities and parties outside the government. Our standards also  note that agency management should establish a formal process to analyze  these risks. Documentation by USCIS staff of specific problematic  incidents would provide a systematic method to retain institutional  knowledge, analyze trends in the occurrence of these problems, and share  critical information.
section_title: United States and Some U.S. Top Sending Countries Have Not Ratified Multilateral Convention That Establishes Minimum Intercountry Adoption Standards
paragraphs: The Hague Convention, which governs intercountry adoptions, establishes  minimum standards designed to help alleviate some of the risk associated  with foreign governments’ adoption processes. The United States has  signed the Convention and taken key steps toward implementation but has  not yet formally ratified it, while some U.S. top sending countries have also  not ratified the Convention.
subsections: section_title: Hague Convention Establishes Minimum Standards for Intercountry Adoptions
paragraphs: The Hague Convention on Protection of Children and Co-operation in  Respect of Intercountry Adoptions is designed to help alleviate some of the  risks associated with the adoption process by establishing international  minimum standards that sending and receiving countries must abide by.  In particular, the objectives of the Convention are (1) to establish  safeguards to ensure that intercountry adoptions take place in the best  interests of the child and with respect for his or her fundamental rights as  recognized in international law; (2) to establish a system of cooperation  among Contracting States to ensure that those safeguards are respected  and thereby prevent the abduction, the sale of, or traffic in children; and  (3) to secure the recognition in Contracting States of adoptions made in  accordance with the Convention. Standards of the Convention will only be  applicable for intercountry adoptions in which both the sending and  receiving country have ratified the Convention.
More specifically, the Convention’s safeguards include the required  designation of a Central Authority in each country to implement  Convention procedures, as well as requirements regarding prospective  parents, adoptable children, and other involved entities. These Central  Authorities must coordinate with each other, provide evaluation reports on  their country’s adoption experiences to other countries, and take the  appropriate measures to prevent improper financial gain from an  intercountry adoption, among other responsibilities. Additionally, under a  Hague adoption, a prospective adoptive parent must apply for an adoption  through the sending country’s Central Authority. To meet these  requirements, the sending country must establish that a child is eligible for  adoption by ensuring that adoption is in the best interest of the child and  that appropriate counseling and consents, not induced by payment, have  been provided, while the receiving country must determine that the  prospective parents are eligible and suitable to adopt. Moreover, the  Convention requires the receiving country to ensure that the child will be  authorized to enter and permanently reside in the country before the  adoption takes place, though this is not a prerequisite to parent-child  contact. Under the Convention, the Central Authority may delegate certain  functions to a public authority or an accredited body, as long as this body  pursues only nonprofit objectives, is staffed by qualified persons, and is  subject to supervision. The Convention also permits many Central  Authority functions to be performed by other bodies or persons who meet  certain ethical, training, and experience standards.
Although the Convention establishes minimum standards, it does not  establish formal means to determine whether countries are complying with  them. The United States has monitoring mechanisms, outlined in the IAA,  to ensure it adheres to the standards of the Convention. However, the  Convention does not include mechanisms to determine whether other  countries are doing so as well. For example, although the Convention  requires the sending countries to prepare a report for each child, it is up to  the sending country to ensure that its report is factual.
section_title: United States and Some Top Sending Countries Have Yet to Ratify the Convention
paragraphs: Although State has taken some key steps to implement the Convention,  several remain. The United States signed the Convention in 1994. In 2000,  the Senate gave its advice and consent, but the United States will not  formally ratify the Convention until it is able to carry out the obligations  required of it by the Convention. That same year, the United States passed  the implementing legislation, the IAA, which established State as the U.S.  Central Authority for intercountry adoptions. Following passage of the  legislation, State has taken several steps to prepare for implementation,  including drafting and issuing regulations for comment as required by  IAA, hiring staff to carry out some of the responsibilities of the  Convention, and requesting applications for accrediting entities, which  under IAA are responsible for accrediting adoption service providers.  However, some key steps remain, which include finalizing regulations,  deploying case registry software to track adoption cases, and signing  agreements with accredited entities. Implementation of the Convention is  one of State’s highest priorities, according to State officials. Figure 5  provides a detailed time line of the United States’ implementation of the  Convention.
State officials said the implementation of the Convention is a long-term  project and attributed its lengthiness to several challenges. First, IAA  required that State consider the standards or procedures developed or  proposed by the adoption community before issuing regulations. Once  regulations were issued to the public for comment, State received about  1,500 comments from more than 200 entities expressing a wide range of  views, some calling for more stringent standards and others for less  stringent. State revised the regulations, including responses to comments,  and sent them to Office of Management and Budget. Second, State is  further challenged in drafting agreements with accrediting entities because  such entities could be either state licensing bodies or nonprofits, both of  which entail a variety of different restrictions, such as state laws. Finally,  State must complete some steps in sequential order. For example,  agreements with accrediting entities can not be signed until the regulations  are finalized. Further, although State’s target date for implementation is  fiscal year 2007, agency officials stated that they could not predict how  long it will take accrediting entities to approve adoption service agencies.  According to officials, State will have completed its work needed to  implement the Convention by the end of 2005, at which time the adoption  service providers will have to apply for accreditation. In addition, USCIS  must revise regulations to implement the Convention, and, according to  USCIS, they are currently in the process of making the revisions.
Since its creation, 66 countries (which represented about 39 percent of all  U.S. intercountry adoptions in fiscal year 2004) have ratified the  Convention. Three out of four top sending countries for U.S. intercountry  adoptions—Guatemala, Russia, and South Korea—have not ratified the  Convention. In September 2005, China, the top sending country of U.S.  adoptions, ratified the Convention. State officials said that Russia is  working toward ratification of the Convention. Guatemala acceded to the  Convention in 2002, but, in 2003, the Guatemalan court ruled the accession  to be unconstitutional based on technicalities. South Korea has not signed  the Convention. See appendix IV for the countries that have implemented  the Convention, as well as the total number of U.S. intercountry adoptions  in fiscal year 2004 from these countries, as well as the top four sending  countries.
Following implementation of the Convention, the United States plans to  continue adoptions with non-Hague Convention countries, according to  State officials. However, State officials told us that prior to U.S.  implementation of the Convention, other Hague Convention countries  could potentially suspend adoptions with the United States. For example,  Costa Rica announced the suspension of non-Hague adoptions in 2003,  though the country has continued to allow some adoptions by U.S. citizens,  according to State officials.
section_title: Conclusions
paragraphs: With more and more U.S. citizens expanding their families by adopting  children who live in other countries, it is important for the U.S. government  to have procedures in place that provide prospective parents with  transparent and accessible information on adoptions, coordination  between the two primary agencies responsible for implementing U.S.  immigration law on intercountry adoptions, and mechanisms to evaluate  the suitability of prospective parents and to determine the child’s status as  an orphan and eligibility to immigrate to the United States. The United  States has such procedures in place, and the designated agencies have  worked to improve them. While U.S. adoptive parents desire a smooth and  expedited adoption process, agency officials are challenged to balance the  importance of prioritizing and expediting intercountry adoption cases with  the need to conduct thorough investigations to ensure the legitimacy of  each adoption.
In recent years, State and USCIS have taken measures to enhance the  intercountry adoption process. However, the development of an  intercountry adoptions quality assurance program would help to ensure  that U.S. intercountry adoption procedures are consistently followed  domestically and worldwide. Moreover, because foreign governments play  a prominent role in U.S. intercountry adoptions, the U.S. government is  limited in its ability to mitigate against abuses that take place abroad.  Although the U.S. government has taken measures to address some risks to  intercountry adoptions, a systematic documentation of such incidents in  foreign countries would allow for a formal mechanism for retaining and  sharing specific information among staff working on adoption cases.
section_title: Recommendations for Executive Action
paragraphs: To improve the management of the U.S. intercountry adoption process, we  recommend that the Secretary of Homeland Security take the following  actions working with the Director of USCIS to  formalize its quality assurance mechanisms so that the agency can  assess the quality of the intercountry adoption process over time, ensure  that senior officials from USCIS and State are aware of the outcomes of  the quality assurance process, and identify opportunities where  additional training or guidance may be warranted; and  consider establishing a formal and systematic approach to document  specific incidents of problems in intercountry adoptions that it has  identified in foreign countries to retain institutional knowledge and  analyze trends of individuals or organizations involved in improper  activities.
section_title: Agency Comments and Our Evaluation
paragraphs: The Departments of Homeland Security and State provided written  comments on a draft of this report (see apps. V and VI). GAO incorporated  technical comments from both agencies as appropriate. Both DHS and  State generally agreed with the report draft’s observations and conclusions.  DHS agreed with our two recommendations for USCIS to formalize its  quality assurance mechanisms and for USCIS to consider establishing a  formal and systematic approach to document specific incidents of  problems in intercountry adoptions identified in foreign countries. DHS  also commented that the report accurately describes the process and  responsibilities of both agencies in the intercountry adoption process. DHS  noted that both agencies have improved interagency coordination and  efforts to communicate with parents, developed standard operations  procedures, conducted training, and streamlined the process.
State commented that the department and USCIS have established  procedures that provide prospective adoptive parents with transparent and  accessible information, ensure coordination between their distinct  supportive roles, and meet the requirements of U.S. law. State also noted  that the report outlines the separate responsibilities of each agency and  recognizes the steps that both agencies have taken to ensure that  intercountry adoptions take place within the context of strong safeguards.  State replied that it is deeply concerned about the welfare of children  around the world and regards the Hague Convention as an important  means of promoting strong safeguards and ensuring that intercountry  adoption remains a viable option for children around the world who seek  permanent family placements. The department also discussed its action on  implementing the Hague Convention and indicated that it plans to complete  the tasks necessary to ratify the Convention in 2005 and to enable adoption  service providers to be accredited in time for the United States to be able to  ratify the Convention in 2007. Also, State provided additional information  regarding its outreach efforts to the adoption community that we added to  the report and provided supplementary information on Department of State  Actions on Intercountry Adoptions in Selected Countries.
We will send copies of this report to appropriate Members of Congress, the  Secretaries of the Departments of Homeland Security and State, and the  Director of U.S. Citizenship and Immigration Services. We also will make  copies available to others upon request. In addition, the report will be  available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-4128 or fordj@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 major contributions to this report are  listed in appendix VII.
section_title: Scope and Methodology
paragraphs: To describe the U.S. intercountry adoption process, we met with  Department of Homeland Security (DHS) U.S. Citizenship and Immigration  Services (USCIS) and Department of State (State) officials in Washington,  D.C., with responsibilities for managing intercountry adoptions cases.  Specifically, we met with officials in USCIS’ Offices of Field Operations and  International Operations, and State’s Bureau of Consular Affairs’ Offices of  Children’s Issues and Visa Services. We reviewed documents on U.S.  intercountry adoptions, including information on USCIS and State Web  sites, which outlined specific procedures for prospective adoptive parents  to complete during the intercountry adoption process, as well as  information on the child’s eligibility for citizenship. Furthermore, we  reported on the varying intercountry adoption completion times and costs  incurred by adoptive parents in the top four sending countries based on  discussions with officials from State’s Office of Children’s Issues, who  obtained this information from State’s Bureau of Consular Affairs officers  handling intercountry adoption cases in the four overseas locations. These  Bureau of Consular Affairs officers provided approximate time frames  based on their experiences in reviewing intercountry adoption cases. We  did not test the reliability of this data.
To assess the U.S. government agencies’ efforts to manage the intercountry  adoption process, we interviewed USCIS and State officials in Washington,  D.C. We reviewed a USCIS task force report from June 2002, which  assessed the U.S. intercountry adoption process and identified areas for  improvements. We discussed actions taken to address these issues with  USCIS officials. We further reviewed USCIS and State documents to  understand their procedures for handling intercountry adoptions cases and  their management of the process. These documents include USCIS  Standard Operating Procedures and Adjudicator’s Field Manual, as well  as State’s Foreign Affairs Manual. Additionally, we reviewed USCIS and  State’s caseload data, documentation of communication and coordination  between the two agencies, as well as training materials provided to USCIS  and State officials related to intercountry adoptions. The estimate of the  time that USCIS officials took to process intercountry adoption  applications relies on their Performance Analysis System (PAS). GAO  tested the reliability of the PAS data and found that it was sufficiently  reliable at the aggregate level to identify overall trends. We also visited  USCIS offices in New York and Los Angeles to see how USCIS implements  domestic procedures related to intercountry adoptions. Both of these  offices ranked in the top 20 percent of domestic offices for the number of  adoption cases received in fiscal year 2004 and demonstrate geographic  diversity. Additionally, we visited Guatemala City, Guatemala, and Moscow,  Russia, to see how USCIS and State implement intercountry adoption  procedures overseas. Our reasons for selecting those two countries are  discussed below. Furthermore, we contacted U.S. adoption organizations  and agencies to understand their roles, as well as some adoptive parents  who belonged to national adoptive parent support groups and were willing  to respond to us, to hear about their experiences with the U.S. intercountry  adoption process.
To understand the intercountry adoption process and the adoption  environment in overseas locations, we visited Guatemala City and Moscow;  we selected these locations for various reasons. Both countries were  consistently ranked among the top five sending countries for U.S.  intercountry adoptions from fiscal year 1994 to fiscal year 2004. In  Guatemala City, USCIS officials adjudicate all orphan petitions to  determine the eligibility of the adopted children while State officials issue  visas to the adopted children. In contrast, State officials with designated  responsibility in Moscow approve the eligibility of the adopted children and  issue their visas. In addition, USCIS and State officials noted concerns with  intercountry adoptions abuses in Guatemala, which research conducted for  United Nations Children’s Fund (UNICEF) corroborated. In both countries,  we interviewed USCIS and State Bureau of Consular Affairs officials  managing the U.S. intercountry adoption process. We also met with foreign  government officials and private adoption facilitators and visited  orphanages to learn about their respective roles in the adoption process  and their views on the risks associated with intercountry adoptions in  Guatemala and Russia. The information on foreign law in this report does  not reflect our independent legal analysis, but is based on interviews and  secondary sources.
To describe the Hague Convention and the statuses of U.S. and top sending  countries’ implementation of the Convention, we analyzed the text of the  Convention on the Protection of Children and Co-operation in Respect of  Intercountry Adoption to identify the purpose and standards of the  Convention. We also analyzed the U.S. Intercountry Adoption Act of 2000,  which provides for the implementation of the Convention by the United  States. We also reviewed State’s Web sites and documents regarding the  status of its implementation of the Convention, including comments on  draft regulations and State’s Fiscal Year 2006 Performance Summary. In  addition, we interviewed USCIS and State officials to determine the status  of the U.S. implementation of the Convention. Finally, we obtained data on  other countries’ ratification of the Convention from the Web site of The  Hague Conference on Private International Law, which tracks the statuses  of countries that have signed and ratified the Convention. To verify that this  data on the Web site was current, we interviewed an official from the  member of the permanent bureau of the Convention. Furthermore, we  discussed the implementation statuses of the Convention in their own  countries with Guatemalan and Russian government officials.
We performed our work from February to October 2005 in accordance with  generally accepted government auditing standards.
section_title: Total Number of U.S. Intercountry Adoptions by Country, Fiscal Year 2004
paragraphs: Congo, Democratic Republic of the 13 (Continued From Previous Page)
Great Britain and Northern Ireland Hong Kong  S.A.R.
Macedonia, The Former Yugoslav Rep. of Marshall Islands, Republic of the 32 (Continued From Previous Page)
Saint Vincent and the Grenadines 17 (Continued From Previous Page)
section_title: List of USCIS Overseas District and Sub Offices
paragraphs: Sub Office under Bangkok District Office Sub Office under Bangkok District Office Sub Office under Bangkok District Office Sub Office under Bangkok District Office Sub Office under Bangkok District Office Sub Office under Bangkok District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Mexico City District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Sub Office under Rome District Office Although USCIS has a Sub Office in Moscow, Russia, USCIS officials in Moscow do not handle U.S.  intercountry adoption cases. Instead, State’s consular officers approve these cases in Moscow.
section_title: Comments from the Department of Homeland Security
section_title: Comments from the Department of State
paragraphs: The following are GAO’s comments on the letter from the Department of  State dated October 12, 2005.
subsections: section_title: GAO Comments
paragraphs: 1. State commented that the draft report’s table of countries that currently  maintain restrictions on intercountry adoptions included countries  affected by the 2004 South Asian tsunami. The department did not  believe that it was appropriate to do so because the region was  following accepted international practices rather than imposing  restrictions on intercountry adoptions in contrast to the other countries  included in the table. We removed this listing from the table. 2. State provided additional information regarding its outreach efforts to  the adoption community, which we added to the report.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Phyllis Anderson, Assistant  Director; Joe Carney; Tracey Cross; Mark Dowling; Joel Grossman; Rhonda  Horried; and Victoria Lin made key contributions to this report.