Summer Work Travel Program: State Department Has Taken Steps to Strengthen Program Requirements, but Additional Actions Could Further Enhance Oversight
Published: 2015-02-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Created under the Mutual Educational and Cultural Exchange Act of 1961, the SWT program is intended to further U.S. public diplomacy by giving foreign undergraduate students short-term opportunities to experience the people and way of life in the United States. In 2005, GAO found that State's oversight was insufficient to prevent abuse of the SWT program or its participants. Since 2010, some misuses of the program by participants and criminal organizations and abuses of participants—for example, low wages and substandard living conditions—have been reported. Also, State has noted that the program's work component has often overshadowed its cultural component.
GAO was asked to report on State's oversight and implementation of the SWT program. This report examines, among other things, steps that State has taken since 2010 to strengthen program requirements as well as State's oversight of sponsors and participants. GAO reviewed program regulations and other SWT documents. GAO also interviewed U.S. officials and others involved in the program in the United States and in Bulgaria, Ireland, Turkey, and Russia, countries that GAO selected on the basis of factors such as the number of SWT participants from each country.
section_title: What GAO Found
paragraphs: Each year, college and university students from all over the world participate in the Department of State's (State) Summer Work Travel (SWT) program. State records show that in 2014, about 79,000 participants from more than 120 countries worked up to 4 months in jobs such as lifeguard, cashier, and resort worker throughout the United States (see map). Participants are meant to experience U.S. culture by interacting with Americans during work and through cultural activities in their free time. State administers the program in partnership with U.S. private sector sponsors that serve as participants' primary contacts. Program funding comes primarily from fees paid by participants and sponsors.
State has taken several steps to strengthen SWT requirements since 2010. For example, in 2011, State began requiring sponsors to verify employers and job offers and prohibited jobs such as adult entertainment and domestic help. State also capped the number of participants at 109,000 until it could determine that it had addressed identified concerns; as of October 2014, State had no plans for lifting the cap. State made further changes in 2012, such as requiring—in response to allegations of excessive participant costs—that sponsors annually submit lists of fees that SWT participants pay them and their overseas agents. State also required sponsors to provide participants cultural opportunities outside the workplace.
State oversees sponsors through both general and targeted reviews of their compliance with program requirements. State oversees participants' welfare by periodically interviewing a small number of participants and investigating complaints and reports from participants and others. However, State does not have mechanisms to ensure that sponsors submit complete and consistent lists of fees that participants pay them and their overseas agents and that this information is made publicly available. State thus has limited ability to protect participants from excessive and unexpected costs. Further, State officials told GAO that it cannot assess the sufficiency and appropriateness of participants' cultural opportunities outside the workplace because the 2012 requirement lacks detailed criteria. As a result, State cannot be assured that SWT participants' experiences of U.S. culture align with its public diplomacy goals.
section_title: What GAO Recommends
paragraphs: State should establish mechanisms to ensure that sponsors submit complete and consistent lists of participant fees and that this information is made publicly available. State should also provide detailed criteria for assessing the sufficiency and appropriateness of participants' cultural opportunities. State agreed with GAO's recommendations.

section_title: Letter
paragraphs: Each year, thousands of college and university students from all over the  world spend their academic breaks living and working in the United States  through the Department of State’s (State) Summer Work Travel (SWT)  program. Established through the Mutual Educational and Cultural  Exchange Program Act of 1961 (commonly known as the Fulbright-Hays  Act), the SWT program is intended to further U.S. public diplomacy by  providing participants an opportunity to experience the people and way of  life in the United States and return home to share their experiences of  American culture.
In October 2005, we reported that State had not exerted sufficient  management and oversight over the SWT program to guard against  abuse of the program and of participants. We recommended that State  update its regulations, obtain and assess data on program abuses, and  implement a compliance unit to better monitor exchange program  activities and address deficiencies. State implemented all three of our  recommendations. However, since 2010, it has been reported that some  SWT program participants have abused the program—for instance, by  committing visa fraud and other criminal activities—and that some SWT  employers and other parties have abused participants—for example, by  charging high rent for substandard housing conditions or making  fraudulent job offers. According to State officials, such abuses are more  the exception than the norm; however, the abuses have brought notoriety  and disrepute to the SWT program, State, and the U.S. government and  created a public diplomacy challenge. Additionally, Members of Congress  have raised questions about whether, counter to the Fulbright-Hays Act’s  intent, the SWT program’s cultural exchange aspect was receiving  sufficient emphasis. In response to the reported abuses, State undertook  a program review in 2010 that led to changes in SWT program  requirements. In 2012, State noted that the SWT program’s work  component had often overshadowed the core cultural exchange  component necessary for the SWT program to be consistent with the  intent stated in the act. State also noted that the program’s foreign affairs  goals could be seriously jeopardized if even a single participant had an  abusive or harmful exchange experience.
You asked us to review State’s oversight and implementation of the SWT  program. This report examines (1) changes to program requirements that  State has made since 2010 to better protect the SWT program and  participants, (2) State’s oversight of SWT sponsors’ compliance with such  requirements and of participants’ welfare, and (3) efforts State has made  to strengthen the SWT program’s cultural exchange aspect and to further  State’s broader public diplomacy goals.
To identify changes that State has made to program requirements since  2010 to better protect the SWT program and participants, we reviewed  program regulations and guidance that State issued from 2011 through  2014. To evaluate State’s oversight of SWT sponsors’ compliance and  participants’ welfare, we reviewed State’s monitoring documentation and  reports and observed State conducting field site reviews in California,  New York, Pennsylvania, and Washington, D.C. We selected these sites  on the basis of the State office conducting the field site visit and the  number of SWT participants in each location. We also reviewed and  analyzed State data for complaints and incident reports about the  program from January 2010 to September 2014 and data submitted by  sponsors and their overseas agents regarding fees paid by program  participants in 2013. After reviewing the data and interviewing State  officials regarding the data, we determined that the data on complaints  and incident reports were sufficiently reliable for the purposes of this  report but the data on participant fees were not. To identify State efforts  to strengthen the program’s cultural exchange aspects and further its  broader public diplomacy goals, we reviewed a State strategy document  for fiscal years 2015 to 2017 and interviewed State officials responsible  for outreach to SWT alumni. To address each of our three objectives, we  met in Washington, D.C., with State officials and with officials from the  Department of Homeland Security, which is responsible for tracking SWT  participants’ entry into the United States, and the Department of Labor,  which is responsible for investigating any potential violation of U.S. labor  regulations by employers of SWT participants. We also met with five  program sponsors, which we selected on the basis of the number of  participants they sponsored, in various U.S. locations. In addition, in May  2014, we interviewed State officials; 19 overseas agents who worked with  the sponsors we interviewed; and 70 former participants in Bulgaria,  Ireland, Turkey, and Russia whom we selected from participants that the  overseas agents recommended. The results of our interviews with agents  and participants were not generalizable to all program agents and  participants but provided important insights about the SWT program. (See  app. I for further details of our scope and methodology.)
We conducted this performance audit from November 2013 to February  2015, in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  provide sufficient, appropriate evidence as a reasonable basis for the  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
paragraphs: The SWT program is a component of State’s Exchange Visitor Program,  known as the J-1 Visa Program, which was established to implement the  purposes of the Fulbright-Hays Act, including strengthening ties and  increasing mutual understanding between the people of the United States  and the people of other countries through educational and cultural  exchanges. The SWT program—one of the largest U.S. exchange  programs—offers young people who might otherwise lack the means to  visit the United States a unique opportunity to spend up to 4 months in  this country while working to defray program costs. To administer the  SWT program, State works in partnership with private sector sponsors,  who may contract with overseas and domestic agents to handle various  administrative functions. Over time, State has identified concerns about  the SWT program, such as abuses of some SWT participants by  employers, links between some SWT participants and organized crime,  and overshadowing of the program’s cultural exchange component by its  work component.
subsections: section_title: SWT Program Roles
paragraphs: Participants. To qualify for the program, exchange visitors under the  SWT program must meet certain criteria, including being full-time college  or university students. Participants from most countries are required to be  preplaced in a job before entering the United States. While in the United  States, SWT participants generally work in low-wage service positions  such as amusement park ride operator, cashier, lifeguard, resort worker,  restaurant worker, or retail sales assistant. Participants come from all  over the world and work throughout the United States year-round, based  on the timing of their major academic breaks. For example, State records  show that in 2014, approximately 79,000 SWT participants from more  than 120 countries worked in all 50 states and the District of Columbia.  Figure 1 shows SWT participants’ numbers, countries of origin, and U.S.  job locations from January to mid-November 2014.
Sponsors. SWT sponsors are U.S. organizations that bring participants  to the United States and facilitate their employment and cultural  exchange. To be eligible for designation as a sponsor, an organization  must demonstrate to State’s satisfaction its ability to comply, and remain  in continual compliance, with all program requirements and to maintain  certain financial obligations and responsibilities as an SWT sponsor.  State’s records show that as of November 2014, the SWT program had  41 active sponsors. Sponsors are the participants’ primary point of  contact and are responsible for addressing issues that affect the health,  safety, and welfare of participants while they are in the United States.  Other aspects of sponsors’ roles and responsibilities include the following:
Sponsors may recruit prospective SWT participants directly or through  overseas agents.
Sponsors are required to enter selected participants’ data in the  Student and Exchange Visitor Information System (SEVIS).
Sponsors are responsible for ensuring that participants have  employment in the United States and are required to vet potential  employers and their job offers by contacting each employer directly  and verifying the business owner’s or manager’s contact information  and location as well as the company’s line of business.
Before participants arrive in the United States, sponsors are required  to provide an orientation to prepare them for life in the United States  as well as information about what to do in an emergency.
After participants arrive in the United States, sponsors are required to  monitor participants’ health, safety, and welfare and ensure that  participants receive exposure to U.S. culture.
Overseas and domestic agents. Sponsors may contract with overseas  and domestic agents to carry out certain SWT program functions.
Overseas agents generally assist sponsors with recruiting participants  for the SWT program, assessing participants’ qualifications, and  identifying U.S. job placements for participants.
Domestic agents assist sponsors with functions such as arranging  cultural activities for participants, helping participants find housing,  identifying participant job placements, and providing participants with  transportation.
Employers. SWT employers are businesses in the United States that hire  SWT participants for positions that the sponsors confirm are seasonal or  temporary and do not displace U.S. workers. SWT employers have  typically included hotels, restaurants, retail stores, ski resorts, and theme  parks, among others.
State Department. State’s Bureau of Educational and Cultural Affairs  administers the SWT program through the Office of Private Sector  Exchange. In addition, State’s Bureau of Consular Affairs adjudicates  visas overseas and conducts domestic monitoring visits to SWT  participants. State’s Kentucky Consular Center, established to assist in  administering certain classes of visas, also provides a secondary check  on employers of SWT participants. For more information about individual  State offices’ roles and responsibilities related to the SWT program, see  appendix II.
section_title: SWT Program Funding
paragraphs: As a private sector exchange program, the SWT program is primarily  funded through fees paid by SWT sponsors and participants. For  example:
Participants pay sponsors or overseas agents program fees for  services such as assisting with job preplacement and acquiring airline  tickets and insurance. Participants also pay a visa application fee to  State.
Sponsors pay State a fee when they apply for designation or  redesignation as SWT sponsors. In addition, sponsors that hire  domestic agents may pay the agents for their services.
Overseas agents pay sponsors a portion of participants’ program  fees.
Figure 3 shows the flow of funds among the primary entities in the SWT  program.
section_title: Concerns about the SWT Program
paragraphs: Concerns about the SWT program have related primarily to abuses of  SWT participants by employers, links between SWT participants and  organized crime, and an overshadowing of the program’s cultural  exchange component by its work component.
Abuses of SWT participants by employers. In 2010, Consular sections  overseas raised concerns about the exploitation of some SWT  participants and fraud relating to employment offers in the United States.  In 2011, print and broadcast media reported further exploitation and  abuses of some SWT participants. For example, SWT participants  working full-time for a certain employer were reported to be earning only  $160 to $560 per month while paying $395—twice the market rate—for  company housing. State also acknowledged an increase in SWT-related  complaints regarding, for example, improper or unsafe job placements,  fraudulent job offers, post-arrival job cancellations, inappropriate work  hours, and problems regarding housing and transportation.
Links between participants and organized crime. Beginning in early  2010, law enforcement agencies identified an emerging relationship  between organized criminal activity and some SWT participants, who  were at risk of being recruited to organized crime because they were  eligible for Social Security numbers. U.S. law enforcement investigations  revealed that while some SWT participants may have been misled into  criminal activities, other participants willingly and deliberately engaged in  activities such as tax fraud, health care fraud, and illicit money transfer  schemes. In 2012, State also reported that criminal organizations had  involved SWT participants in incidents relating to illegal transfer of cash,  the creation of fraudulent businesses, and violations of immigration law.
Overshadowing of cultural exchange component. In 2012, State  reported that in recent years, the work component of SWT had often  overshadowed the core cultural exchange component of the program  necessary for the SWT program to be consistent with the intent stated by  the Fulbright-Hays Act. State attributed this imbalance to the attitudes of  some sponsors, employers, and participants. For example, State noted  that many participants viewed the program primarily as an opportunity to  work in different jobs and to earn more money than they would at home.
section_title: State Has Taken a Variety of Actions to Strengthen Program Requirements
paragraphs: To better protect the SWT program from misuse and participants from  abuse, State amended federal requirements in 2011 and 2012, imposing  tighter restrictions on participants and sponsors. State also capped the  size of the program to maintain it at a manageable size while State  addresses the identified concerns. Additionally, State expanded its  internal requirements and guidance for visa adjudication, with a goal of  better ensuring participants’ health, safety, and welfare after they arrive in  the United States.
subsections: section_title: State Updated Federal Requirements in 2011 and 2012
paragraphs: State issued interim final rules (IFR) in 2011 and 2012 that amended the  federal regulation for the SWT program.
2011 Interim Final Rule. In 2011, State issued an IFR amending the  SWT regulation, which went into effect in July 2011. These changes,  which expanded on a pilot program that State had announced for the  2011 summer season, were intended to impose tighter controls and  restrictions on all SWT participants and sponsors. The 2011 IFR specified  the following, among other things.
All applicants from countries that do not participate in the Visa Waiver  Program must have prearranged jobs before entering the United  States.
Sponsors must vet all potential host employers to confirm that they  are ongoing and viable business entities; must fully vet all job offers,  including verifying the terms and conditions of such employment;  and must not place participants in any prohibited position, such as  adult entertainment or domestic help.
Sponsors must fully vet all overseas agents whom they engage to  assist in functions such as screening, selecting, and monitoring  participants.
Sponsors must contact participants on a monthly basis to monitor  their welfare and physical location. 2012 Interim Final Rule. In May 2012, State published its 2012 IFR,  which, according to State, was intended to expand on the 2011 changes  to further protect the health, safety, and welfare of SWT participants.  Most of the regulatory changes announced in the 2012 IFR took effect in  May, and the changes remained in effect as of December 2014. The 2012  IFR explained that the 2012 regulatory changes included, among  others,  increased language requirements for participants, requiring them to  have sufficient English not only to perform their jobs, as previously  required, but also to protect themselves as they navigate daily life; an expanded list of job placement requirements and prohibitions—for  example, placements must be seasonal or temporary, must provide  opportunities for participants to interact regularly with U.S. citizens,  and must not displace U.S. citizen workers; and requirements that sponsors submit annual participant price lists to  provide itemized breakdowns of costs that participants must pay to  both overseas agents and sponsors; assist participants in arranging  housing and transportation when needed; and vet domestic agents.
section_title: State Capped SWT Program to Maintain Manageable Size
paragraphs: In November 2011, given continuing reported problems in the SWT  program, State issued a notice in the Federal Register that capped the  maximum number of participants and imposed a moratorium on  designation of new sponsors. State noted that it intended to strengthen  and expand its oversight, consult more closely with key stakeholders, and  develop new program regulations, among other things, while the  restrictions were in place. According to the 2012 IFR, the restriction on  program size would remain until State was confident that the program  regulations were sufficient to remedy identified concerns. State officials  told us that as of October 2014, State had no current plans for lifting the  program cap.
As a result of State’s 2011 restrictions, the number of program  participants dropped by about 20 percent from 2011 to 2013. State  capped at 2011 levels the participants allotted to each sponsor, effectively  restricting the total number of participants to 109,000. State’s moratorium  on designating new sponsors resulted in further reductions in the actual  number of participants. Figure 4 shows the numbers of SWT program  participants and sponsors in 2011 through 2014.
section_title: State Expanded Internal Requirements and Guidance for SWT Program
paragraphs: In addition to increasing the federal requirements for the SWT program, in  2012 State updated its Foreign Affairs Manual requirements for visa  adjudication to help safeguard SWT participants’ health, safety, and  welfare. State’s 2012 revision of the Foreign Affairs Manual sections  providing guidance for the SWT program indicate the following:
Consular officers can deny visas to SWT applicants who do not  demonstrate sufficient English proficiency to enable them to, for  example, interact effectively with law enforcement authorities and  medical personnel, read rental agreements, and carry on non-work- related conversations. At all five of the posts we visited, we observed  State officials conducting SWT visa interviews in English and verifying  that participants had sufficient English proficiency to participate in the  program. Consular officers told us that they try to ensure that  applicants can be understood in the United States and can  communicate with U.S. law enforcement officers about their own  health, safety, and welfare.
Consular officers must confirm that applicants understand a pamphlet  specifying their legal rights with regard to federal immigration, labor,  and employment laws in the United States. At each post that we  visited, we observed consular officers asking applicants questions to  confirm that they understood these rights.
section_title: State Conducts Oversight of Sponsors, Employers, and Participants but Has Limited Information about Program Costs
paragraphs: State has several mechanisms for monitoring and enforcing compliance  with SWT regulations intended to prevent abuse of the program and of  participants. State reviews sponsors’ compliance with SWT regulations  and may sanction sponsors found to be in violation. In addition, sponsors  vet potential employers and jobs and State conducts a secondary check  of these employers, gathering information that it uses to help ensure  participants’ health, safety, and welfare; sponsors also vet their overseas  and domestic agents. State oversees participants through field site  reviews and through complaints and incident reports. However, State has  not ensured that the annual lists of participant fees that it requires  sponsors to provide are complete, consistent, and publicly available. As a  result, State has limited ability to protect participants from excessive and  unexpected costs that could negate their otherwise positive experiences.
subsections: section_title: State Reviews Sponsors’ Compliance with Program Regulations and Sanctions Violations
paragraphs: State monitors SWT sponsors’ compliance with program regulations  through biennial redesignation reviews and through on-site reviews and  compliance reviews. If it determines that a sponsor has violated program  regulations, State may impose sanctions.
Redesignation reviews. Every 2 years, State reviews each sponsor’s  application for redesignation, checking the sponsor’s record of  compliance with certain program regulations as well as its ability to  meet the financial obligations and responsibilities involved in SWT  sponsorship. For example, during the redesignation reviews, State  checks sponsors’ annual reports; their financial records, including  external audits; their SEVIS records; and any recorded incidents or  complaints involving the sponsor. If a redesignation review identifies  concerns about a sponsor’s compliance with program regulations,  State may recommend sanctions. According to a State official, State  conducted 57 redesignation reviews from 2011 through 2014.
On-site reviews. State’s on-site reviews of sponsors involve a  comprehensive assessment of the sponsors’ compliance with  program regulations. State conducts each review at the sponsor’s  place of business, examining the sponsor’s records and holding  discussions with the sponsor. To document the reviews, State officials  complete a questionnaire covering topics such as verification of  participants’ jobs and host employers, participant monitoring,  complaints analysis, maintenance of SEVIS, use of partners, internal  controls and training, and supervision of staff. State officials told us  that State may sanction sponsors when on-site reviews identify  noncompliance with SWT regulations and that State also uses on-site  review results to develop recommendations to strengthen or make  regulatory changes to the program. In 2011 through 2014, State  conducted on-site reviews of 18 sponsors that were active during this  period.
Compliance reviews. State conducts compliance reviews when it  believes that sponsors may have grossly violated SWT regulations. In  contrast to on-site reviews, compliance reviews are narrowly focused  on specific concerns, such as the sponsor’s administration of job  placements or ongoing complaints against a sponsor. State  completed 2 SWT compliance reviews in 2011 and 2013, respectively,  and as of March 2014 was conducting 6 additional SWT compliance  reviews, according to State officials.
State imposes lesser or greater sanctions on sponsors depending on the  nature of misconduct. According to a State document, State may impose  any or all of four lesser sanctions if it believes a sponsor can be  rehabilitated: (1) a letter of reprimand, (2) probation for 1 or 2 years, (3) a  corrective action plan, and (4) a reduction of up to 15 percent in the  number of participants allotted to the sponsor. If sponsors are involved in  more egregious violations of the regulations, State can impose three  greater sanctions: (1) suspension for a maximum of 120 days, (2) denial  of redesignation, or (3) revocation of designation. As of November 2014,  5 of the on-site reviews and both compliance reviews that State  conducted from 2011 through 2014 had resulted in sanctions of the  sponsors reviewed. Table 1 provides information about State’s sanctions  of seven of these sponsors.
section_title: Sponsors Vet Employers, and State Conducts Some Secondary Verification
paragraphs: To ensure that SWT participants work only for suitable employers in  legitimate jobs, sponsors are to vet potential employers and jobs before  the participants begin to work in preplaced positions. State also verifies  most employers through the Kentucky Consular Center (KCC), although  this secondary verification is not required by SWT regulations.
State documents show that sponsors vet employers by, among other  things, contacting each employer, obtaining a copy of the employer’s  business license and employer identification number, verifying that the  employer has a worker’s compensation insurance policy or the state’s  equivalent, and confirming that the employer has not experienced  layoffs in the past 120 days. Sponsors place participants in jobs that are  either seasonal (i.e., tied to the time of year by an event or pattern and  requiring labor levels above and beyond existing worker levels) or  temporary (i.e., to be performed as a one-time occurrence or to meet a  peak load need or an intermittent need). In addition, sponsors maintain  files documenting employer verification. All of the sponsors we spoke with  said that they had conducted the required employer and job vetting, and  all 15 of the on-site reviews that we examined included checks to ensure  that sponsors were conducting the required vetting.
State uses KCC to conduct a secondary verification of employers to  ensure employers’ legitimacy and participants’ safety. KCC verifies  employers of participants from non-visa-waiver countries as well as  participants from visa waiver countries in preplaced jobs. Complementary  to sponsors’ vetting, KCC’s verification focuses on potential concerns  such as law enforcement issues; criminal records; and financial problems  that could jeopardize participants’ health, safety, or welfare. State officials  said that in addition to contacting SWT employers directly, KCC staff use  a variety of databases as well as other public sources, such as the  Internet and social media, to vet the employers. When KCC’s verification  identifies a concern, State may recommend that a sponsor conduct  additional monitoring of the participant or move the participant to a  different employer or housing location. In 2014, as of September, State  had recommended that sponsors move at least 47 participants involving  26 employers.
section_title: Sponsors Vet Overseas and Domestic Agents
paragraphs: SWT sponsors vet potential overseas agents that assist them with core  programmatic functions such as participant screening, selection, and  orientation, according to State documents. Our review of State’s on-site  review records found that the sponsors examined, among other things,  the agents’ proof of business licensing, disclosure of any previous  bankruptcy or pending legal action, and criminal background check  reports for owners and officers of the organization. Sponsors also report  to State all active overseas agents’ names, addresses, and contact  information, which State compiles in a list that it shares with bureaus and  with posts to assist them in scheduling visa adjudications. State may  remove an overseas agent from the list for reasons including overall  problems or derogatory information, such as evidence of fraud in visa  applications that the agent helped to prepare. When it removes an  overseas agent from the list, State notifies all other sponsors so that they  will not work with the agent. As of November 2014, State had removed  two overseas agents from the list since 2010, according to State officials.  In addition, sponsors ensure that domestic agents’ involved in providing  orientation or opportunities for participants to engage in cultural  opportunities are qualified to perform these activities and have sufficient  liability insurance, if appropriate.
section_title: State Oversees Participants’ Welfare through Field Site Reviews and Complaints and Incident Reports
paragraphs: State oversees participants’ welfare through field site reviews, which  allow it to learn first-hand about participants’ experiences with the SWT  program. State also oversees participants’ welfare through complaints  that it receives from participants, the general public, and State officials  and through incident reports from sponsors.
subsections: section_title: Field Site Reviews
paragraphs: State has conducted field site reviews since 2012, in part to strengthen its  oversight of SWT participants’ health, safety, and welfare. During field site  reviews, teams of State officials visit participant job sites and interview  participants and employers about their experience with the SWT program.  According to State officials, they typically select sites that are in areas  with more than 15,000 SWT participants and that, for example, have  historically high rates of complaints or have not been selected previously.  The State officials explained that at the end of each season, they  communicate the review findings to the participants’ sponsors and may  meet with sponsors individually to discuss any problems identified.
In the summer of 2014, field site review teams conducted interviews in 33  states and the District of Columbia. According to a November 2014 report  summarizing field site review findings for the 2014 summer season, State  interviewed 2,505, or approximately 3 percent, of the more than 79,000  participants that year. Of those participants, about 90 percent indicated  that they were satisfied with their program experience and were pleased  with their sponsors. According to the report, housing was a primary  concern among participants—specifically, lack of sponsor support in  finding housing and a shortage of suitable and affordable housing. The  report also states that many participants expressed concerns about  program expenses and high program fees.
During field site reviews, State also verifies the accuracy of SEVIS data,  which State uses to locate participants at their places of employment and  their homes, according to State officials. State guidance requires  sponsors to keep these data current, in accordance with federal law. If  State finds gaps or notices errors in the SEVIS data or identifies trends of  concern, State may provide feedback and may issue a letter of concern to  the sponsor.
section_title: Complaints and Incident Reports
paragraphs: Since 2009, State has provided oversight of SWT participants’ welfare  through complaints and incident reports, which State receives through e- mail, the U.S. mail, telephone, and a toll-free hotline. State may also  receive complaints from participants or employers during its field site  reviews. State established standard operating procedures for addressing  complaints and incident reports related to the SWT program and, in  March 2014, implemented a new database for tracking them.
Complaints. State’s standard operating procedures define a  complaint as any expression of concern about a participant or a  sponsor’s actions from any source other than the sponsor. According  to State’s procedures, complaints have been received from, among  others, former and current participants, employers, overseas and  domestic agents, Congress, members of the media, and participant  family members. The procedures note that in general, State is to refer  complaints to sponsors and resolve the complaints in coordination  with the complainant (for complaints) and the sponsor. The  procedures list 40 complaint categories for the SWT program, ranging  from “accident” to “insufficient funds” to “workplace discrimination.”  State’s procedures lay out criteria and steps for referring serious  complaints to senior State officials. State may provide information  about sponsorship best practices to help the sponsor improve its  program. If a complaint about a sponsor identifies serious regulatory  concerns and potential violations, State may draft a letter of concern  as part of its process for closing out the complaint; State may also  sanction the sponsor, depending on the degree of misconduct. Figure  5 shows State’s process for addressing complaints.
Incident reports. Sponsors are required to promptly inform State of  any serious problem or controversy that could be expected to bring  State or the SWT program into notoriety or disrepute. Sponsors  submit this information in incident reports. According to State, most  incident reports involve matters such as deaths, accidents, crimes or  arrests, medical issues, sexual abuse, or missing persons. State’s  process for handling incident reports is similar to its process for  handling complaints, and State uses the same procedures to escalate  incidents as it uses to escalate complaints. State logs and maintains  information about each incident report, using the same database that  it uses for registering complaints. According to State’s procedures,  State maintains contact with the sponsor regarding the incident until it  is resolved. For example, if the incident report involved the death of  an SWT participant, State would follow up with the sponsor until the  participant’s body was repatriated, or if a participant was hospitalized,  until the participant was released from the hospital. If a sponsor fails  to submit an incident report about a serious problem or controversy,  State notes the failure as a potential regulatory violation and may  sanction the sponsor.
State provided data showing that in 2013, State received relatively few  complaints and incidents—592 and 143, respectively—given the  approximately 86,500 participants in the SWT program that year.  Examples of the 2013 complaints range from participant problems with  pay or living conditions to lack of response from sponsors. Examples of  incidents in 2013 include participants’ arrests for theft, involvement in car  and bicycle accidents, and deaths. According to State, approximately 38  percent of 2013 complaints and incident reports resulted from field site  reviews, 22 percent were called in by sponsors, 20 percent came into  State’s hotline, 14 percent were sent to State’s e-mail in-box, and 7  percent came from unspecified sources.
State’s procedures do not specify response time frames but require that  all complaints and incident reports be handled quickly and efficiently.  While State does not track the time between receipt of a complaint or  incident report and State’s initial response, State officials said that a  response is generally initiated within 1 or 2 days. According to State data,  in 2013, an average of 46 days elapsed between receipt and closeout of  a complaint and an average of 73 days elapsed between receipt and  closeout of an incident report. State officials told us that the time between  receipt and closeout of a complaint or incident report may include, for  example, delays in receiving police and hospital reports.
section_title: State Requires Sponsors to Provide Data on Program Fees but Has Not Ensured That the Data Are Complete, Consistent, and Publicly Available
paragraphs: Although State requires SWT sponsors to annually submit participant  price lists itemizing fees that participants pay to sponsors and overseas  agents, State does not have a mechanism for ensuring that the  sponsors provide complete and consistent data. Moreover, despite a  2013 recommendation by State’s Office of Inspector General (OIG) that  sponsors be required to publicly disclose all fees that participants pay  them and their overseas agents, State has not established a mechanism  to ensure that this information is made publicly available. According to the  2012 IFR, recent criticism of the program had included alleged exorbitant  fees charged to SWT participants, and State requested the information  about participant fees to protect participants, sponsors, and the integrity  of the program. Because State has not established mechanisms to  ensure, respectively, that sponsors provide complete and consistent lists  of participant fees and that this information is made publicly available,  State’s ability to protect participants from excessive and unexpected  program costs is limited.
The fees that participants pay vary by sponsor, agent, and services  provided. According to the State OIG’s 2013 report, sponsors and  overseas agents can charge participants whatever fees they deem  appropriate and State sets no limits on the fees that can be charged.  State officials estimated that participant fees in each country, excluding  airfare, range from $1,500 to $5,000 and often include a program fee, job  placement fees, and health insurance, in addition to the visa application  fee and SEVIS fee, which participants generally pay to State and the  Department of Homeland Security, respectively. However, according to  the State OIG’s 2013 report, participants do not always have a clear  sense of what the fees cover and frequently pay additional, unanticipated  expenses such as interview fees and registration fees.
Although State solicited information about sponsors’ and overseas  agents’ fees in 2013, the data it received were incomplete and  inconsistent, and State did not solicit or obtain this information in 2014.  Standards for internal control in the federal government call for managers  to ensure that there are adequate means of obtaining relevant, reliable,  and timely information from external stakeholders that may have an  impact on the agency’s ability to achieve its goals. In January 2013,  State sent sponsors an approved template itemizing the fees that they  were required to report as well as instructions for completing the  template. However, State did not receive responses in 2013 from all  sponsors, according to a senior State official. Moreover, our analysis  showed that the lists of fees that State received were not complete or  consistent. For example, some sponsors listed a flat program fee, others  listed a range of fees with no explanation of what the ranges covered, and  others provided no information about their fees. Our review of the  instructions that State sent sponsors for filling out the fee template  showed that the instructions did not specify the information requirements;  according to two of the five sponsors we interviewed, the instructions  were difficult for them and their overseas agents to follow. In 2014, State  did not solicit the required data and sponsors did not provide these data.
In reports published in February 2012 and September 2013, respectively,  State’s OIG made recommendations related to the transparency of SWT  fees. In its 2012 report, the OIG recommended that State revise its  regulations to establish maximum fees that sponsors and their overseas  agents can charge. In response, State reported in 2012 that it had begun  meeting with sponsors to discuss ways to establish an open and  transparent process for capturing fees that they and their overseas  agents may charge participants. In its 2013 report, the OIG changed its  2012 recommendation to say that State should revise regulations for  SWT and other private sector exchange programs to require that  sponsors publicly disclose all fees that they and their overseas agents  charge program participants.
State officials told us that, in response to the OIG’s 2013  recommendation, State is considering regulatory changes that would  require SWT sponsors to post online the fees that they and their overseas  agents charge, to ensure that participants are aware of the costs of  participation in the program. State officials noted that the changes being  considered, as well as State’s effort to collect fee data, would allow  prospective students to review costs among various sponsors, programs,  and countries and would also allow State to compare fees across all  sponsors and countries and identify anomalies or unusually high fees.  However, State officials said in November 2014 that the regulatory  changes were still under consideration, with no projected time frame for  completion. Moreover, according to State officials, State has not  established a mechanism for ensuring that information about sponsors’  and overseas agents’ fees is made publicly available. Standards for  internal control in the federal government state that ongoing monitoring  should occur in the course of operations. Without a mechanism to  ensure that complete and consistent information about participant fees is  made publicly available, State has limited ability to protect participants  from being charged excessive and unexpected fees that might negate  their otherwise positive experiences of the program.
section_title: State Has Taken Steps to Strengthen the Program’s Cultural Exchange Aspect but Has Limited Ability to Enforce a 2012 Cultural Requirement
paragraphs: To strengthen the SWT program’s cultural exchange aspect, State has  taken steps to emphasize the program’s cultural component relative to its  work component, including adding cultural requirements to the program  regulation. However, State officials indicated that because the  requirement that sponsors provide participants opportunities for cultural  activities outside the workplace does not include detailed criteria for  sufficient and appropriate opportunities, State has limited ability to assess  and enforce compliance. As a result, State lacks assurance that SWT  participants’ experiences of U.S. culture further State’s public diplomacy  goals. Since 2013, State has taken initial steps to leverage the SWT  program’s long-term public diplomacy value by including a small number  of SWT alumni in its broader activities involving exchange program  alumni.
subsections: section_title: State Added a Cultural Component to Program Regulation but Has Limited Ability to Assess and Enforce Compliance with the Cultural Activity Requirement
paragraphs: ensure that all participants have opportunities to work alongside U.S.
State reported efforts to elevate the  visibility of the cultural exchange aspect  of the Summer Work Travel (SWT)  program. For example, State officials  reported that in the summer of 2014,  they travelled around the United States,  meeting exchange participants and  highlighting their “true American  experience,” including cooking  demonstrations, holiday celebrations,  and community volunteering. In addition,  State officials said that State has worked  with community support groups around  the country that have assisted with  various aspects of the SWT program,  including providing opportunities for  participants to engage in cultural  activities. citizens and interact regularly with U.S. citizens to experience U.S.  culture during the workday; and ensure that all participants have opportunities to engage in cultural  activities or events outside of work, by planning, initiating, and  carrying out events or other activities that provide participants  exposure to U.S. culture.
Lifeguard Olympics for Summer Work  Travel Program Participants  Summer Work Travel program (SWT)  alumni whom we met with overseas  discussed cultural experiences while in  the United States, such as going to  amusement parks, attending theater  performances, and visiting national  parks. Additionally, the sponsors we  interviewed indicated that they had  provided opportunities for participants to  engage in cultural activities, such the  Lifeguard Olympics. This event involved  swimming relays, diving competitions,  and other aquatic challenges to win  money for local charities. About 150  lifeguards, including Americans and  SWT participants from three different  sponsors, were gathered at the event in  Virginia.
State provided guidance for meeting the cultural component requirement,  in the 2012 IFR and a guide that State sent to sponsors in 2013. For  example, according to the 2012 IFR, if a participant works at an  amusement park, then amusement parks are not an acceptable cultural  offering. The 2012 IFR also offers examples of ways that sponsors can  meet the requirement, such as activities to acquaint participants with  recognized features of U.S. culture and history—for instance, national  parks, historic sites, major cities, or scenic areas—or to engage  participants with the communities in which they work and live. In  addition, the 2013 guide offers resources for sponsors to develop cultural  programming that aligns with State’s public diplomacy goal.
State monitors compliance with the SWT cultural component requirement  during its redesignation, on-site, compliance, and field site reviews.  During redesignation reviews, State reviews sponsors’ annual reports to  ensure that sponsors have provided opportunities for participants to  engage in cultural exchange activities. During on-site reviews and  compliance reviews, State may request copies of the sponsor’s  documentation of its required monthly monitoring of participants, including  records of participants’ involvement in cultural activities. During field site  reviews, State asks participants about their cultural experiences. State’s  summer 2014 field site review report notes that roughly 60 percent of the  participants interviewed indicated that they had participated in cultural  activities planned by their sponsors or employers, whereas in 2013 State  reported that nearly 60 percent of participants indicated they would  welcome more involvement from sponsors in arranging cultural activities.  Since 2011, State has sanctioned two sponsors, in part for failing to  provide any cultural programming, according to a State official and  documentation that we examined.
However, according to State officials, because the cultural component  requirement does not include detailed criteria, State is unable to sanction  sponsors for providing insufficient or inappropriate opportunities for  cultural activities outside the workplace. State officials said that they can  issue a sanction if a sponsor provides no cultural component. In  November 2014, State officials indicated that they were considering  regulatory changes that would establish grounds for sanctioning sponsors  that do not provide sufficient or appropriate cultural programming;  however, the officials could not tell us when a decision about these  regulatory changes was expected. Without detailed criteria that would  allow State to assess the sufficiency or appropriateness of the cultural  component, State lacks assurance that SWT participants’ experiences of  U.S. culture further State’s public diplomacy goals.
section_title: State Has Taken Initial Steps to Leverage the SWT Program’s Long- Term Public Diplomacy Value
paragraphs: State has taken initial steps to leverage the SWT program’s long-term  public diplomacy value by reaching out to a limited number of SWT  alumni. State engages systematically with alumni of various other cultural  exchange programs with the goal of strengthening U.S. relationships with  current and emerging leaders, according to State officials. State officials  noted that SWT alumni are active in their communities and promote  ideals and values, such as entrepreneurship and volunteerism, that they  learned about in the United States.
In contrast to its nascent efforts to engage with alumni of the private  sector-funded SWT program, State’s engagement with alumni of most  U.S.-government-funded cultural exchange programs—for example, the  Fulbright, International Visitors, and Academic Exchange programs— began in 2001, according to State officials. Recognizing the potential  value of maintaining connections with exchange visitor alumni, in 2005  State began developing an archive of all alumni of U.S.-government- funded exchange programs; previously, State did not maintain  connections with former exchange program alumni because it lacked their  contact information. State officials explained that State also developed a  network that allows exchange program alumni to access networking tools,  grants, career development aids, and research tools. Alumni of U.S.- government-funded exchange programs receive an automatically  generated e-mail invitation to join this network.
State has recently taken several steps toward including SWT in its alumni  network. In January 2013, State hired a special assistant to coordinate  outreach to SWT and other private sector–funded exchange program  alumni. In 2013, State also began, on a pilot basis, to include a limited  number of SWT alumni in State’s archive of exchange visitor alumni.  State selected these SWT alumni for inclusion in the archive because of  their involvement with sponsor-led leadership conferences or involvement  with local grassroots alumni group at posts. In November 2014, as part of  a State pilot, sponsors were asked to provide contact information for 5  percent of their 2014 SWT alumni for automatic registration in State’s  exchange visitor alumni archive and to give SWT alumni access to  material on the alumni affairs website. State officials noted that State will  review the initial effort before expanding the pilot.
In addition, State has encouraged SWT alumni to engage with one  another and encouraged several posts to engage with SWT alumni. In  Macedonia, State connected a grass-roots- organized SWT alumni  group—the only formal SWT alumni network as of September 2014—with  resources at the embassy and through its alumni affairs network. State  officials reported that State was also beginning to support the embassy in  Serbia to launch similar alumni groups. State noted that some embassies  currently undertake outreach to SWT alumni on an ad hoc basis. For  example, the U.S. Ambassador in Kazakhstan held a picnic for SWT  alumni at the embassy, partly to promote the EducationUSA program in  2013, and the embassies in Bulgaria, Poland, and Hungary hosted SWT  photo contests for alumni in 2013 and 2014. Among the five posts we  visited, the post in Sofia, Bulgaria, had engaged in an SWT alumni activity  and reported plans to assist in establishing an SWT alumni network.  Some SWT sponsors in the United States also maintain alumni networks,  although State does not require them to do so. Of the five sponsors we  met with, three sponsors reported that they maintain SWT alumni  networks.
section_title: Conclusions
paragraphs: By allowing large numbers of young, educated people—approximately  79,000 in 2014—to experience life in the United States each year and  return home to share their experiences, the SWT program offers the  potential to strengthen U.S. relationships abroad and further U.S. public  diplomacy. However, if even one participant has a harmful or abusive  experience, the potential also exists for notoriety and disrepute to the  program, State, and the country. Moreover, unless participants receive  sufficient and appropriate exposure to U.S. culture, they will not receive  the full intended benefits of the program.
In the past several years, State has strengthened program requirements  and expanded its oversight with the intention of better ensuring the  health, safety, and welfare of SWT participants. For example, State  required sponsors to ensure that all employers are legitimate and all  wages paid to participants meet certain criteria and has sanctioned  sponsors for violating regulations. In addition, responding to allegations of  exorbitant fees charged to program participants, State required sponsors  to provide annual lists of fees that participants must pay sponsors and  overseas agents. Moreover, noting that participants did not always have a  clear sense of what sponsors’ and overseas agents’ fees cover, State’s  OIG recommended in 2013 that sponsors be required to publicly disclose  all fees that they and their overseas agents charge participants. However,  State has not established mechanisms for ensuring that the price lists it  receives are consistent and complete and that this information is made  publicly available. As a result, State has limited ability to protect  participants from excessive or unexpected fees that might negate their  otherwise positive experiences of the program.
State has also taken steps to emphasize the SWT program’s cultural  component relative to its work component and to strengthen the SWT  program’s value for public diplomacy. However, a lack of detailed criteria  for the cultural opportunities that sponsors are required to provide limits  State’s ability to ensure that participants have sufficient and appropriate  opportunities to experience American culture outside the workplace. As a  result, State lacks assurance that SWT participants engage in cultural  exchanges that will benefit the participants and align with its public  diplomacy goals.
section_title: Recommendations for Executive Action
paragraphs: To enhance State’s efforts to protect SWT participants from abuse and  the SWT program from misuse, we recommend that the Secretary of  State direct the Bureau of Education and Cultural Affairs to take the  following three actions: establish a mechanism to ensure that sponsors provide complete and  consistent lists of fees that participants must pay, establish a mechanism to ensure that information about these  participant fees is made publicly available, and establish detailed criteria that will allow State to assess the sufficiency  and appropriateness of opportunities for cultural activities outside the  workplace that sponsors provide to SWT participants.
section_title: Agency Comments and Our Evaluation
paragraphs: State provided written comments about a draft of this report, which are  reproduced in appendix III. In addition, State provided technical  comments, which we incorporated as appropriate. In response to a  suggestion in State’s written comments, we also adjusted the wording of  our first recommendation to more clearly convey that State should identify  a mechanism to ensure that sponsors’ price lists reflect all fees that  participants must pay.
In its written comments, State agreed with our recommendations and  indicated that it is considering actions that address them. For example,  responding to our first recommendation, State wrote that it is considering  developing a template to facilitate program sponsors’ public release of fee  and cost information in a consistent format. According to State, this will  enable it to check the completeness and consistency of the price lists that  sponsors are required to submit, by comparing the lists with the  information that sponsors disclose to program participants. Regarding our  second and third recommendations, State wrote that it is considering,  respectively, additional and more-specific fee and cost transparency  requirements and cross-cultural requirements for SWT sponsors.  Moreover, State pointed to recent updates to its regulation governing all  private sector exchange visitor programs, including the SWT program,  that went into effect on January 5, 2015, and that may enhance State’s  ability to provide oversight for the SWT program. However, we believe  that further actions are needed to address our recommendations related  to the fee and cross-cultural components of the SWT program.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to interested congressional  committees and the Secretary of State. In addition, the report will be  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) 512-8980 or CourtsM@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Individuals who contributed to this report are  listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines (1) changes to program requirements that the  Department of State (State) has made since 2010 to better protect the  Summer Work Travel (SWT) program and participants, (2) State’s  oversight of SWT sponsors’ compliance with program regulations and of  participants’ welfare, and (3) efforts State has made to strengthen the  program’s cultural exchange aspect and further its broader public  diplomacy goals.
To address these objectives, we reviewed and analyzed rules and  regulations and State documents related to the SWT program. We  interviewed officials from State’s Bureau of Education and Cultural Affairs  (ECA), which is responsible for administering the SWT program, and  Bureau of Consular Affairs; the Department of Labor; and the Department  of Homeland Security. We also interviewed a nongeneralizable sample  of five U.S. sponsors in various locations—American Work Adventures,  the Council on International Educational Exchange, Cultural Homestay  International, Geovisions, and Intrax—which we selected on the basis of  the number of participants they sponsored. We also interviewed  representatives of an association representing many SWT sponsors—the  Alliance for International Educational and Cultural Exchange—and one  nonprofit focused in part on labor rights, the Southern Poverty Law  Center. We conducted fieldwork at five posts—Dublin, Ireland; Istanbul,  Turkey; Moscow, Russia; Sofia, Bulgaria; and St. Petersburg, Russia— where we met with State officials adjudicating visas for the SWT program.  Our findings from these site visits are not generalizable. We selected  these locations based on a variety of factors, including the number of  SWT participants from each country, the post’s involvement in the 2011  pilot project, and the post’s involvement in the Visa Waiver Program. At  posts, we observed the SWT visa adjudication process for the 2014 SWT  summer season. We also interviewed a total of 19 overseas agents in  Dublin, Istanbul, Sofia, and St. Petersburg who worked with the sponsors  we interviewed, including overseas agents in Moscow whom State also  interviewed. In addition, we interviewed 12 groups comprising a total of  70 previous participants, whom we selected from participants that the  overseas agents recommended. We focused our review on the period  between 2010 and 2014, because State took steps during this period to  strengthen the SWT program; implement regulatory changes addressing  program concerns; strengthen its monitoring and oversight in response to  our recommendation in 2005; and strengthen the program’s cultural  component.
To understand the steps that State has taken since 2010 to strengthen  SWT requirements, we interviewed State officials about the pilot program  and ensuing changes to SWT regulations, reviewed State’s 2011 Pilot  Program guidelines; 2011 and 2012 interim final rules; and relevant  changes in the Federal Register, State’s Foreign Affairs Manual, State  cables, and State’s Guidance Directives. We also analyzed State data  about the size of the program from 2011 through 2014.
To examine State’s oversight of SWT sponsors and participants, we  interviewed program officials from various ECA offices responsible for  monitoring and oversight of the SWT program, including the Offices of  Private Sector Exchange Administration, Compliance, and Designation.  We also interviewed officials of the Bureau of Consular Affairs’ Offices of  Passport Services and Visa Services. We reviewed State’s standard  operating procedures published between 2011 and 2014 related to  implementing, monitoring, and overseeing the program. To understand  how State evaluates sponsors, we analyzed documentation for 15 on-site  reviews, 2 compliance reviews, and 4 letters imposing sanctions on SWT  sponsors that State has completed since 2011. We also reviewed State’s  process for conducting secondary employee verification through the  Kentucky Consular Center to understand its changing role in the visa  adjudication process and State’s process for reprogramming participants.  We analyzed State’s documentation of its monitoring of sponsors through  the designation process. To evaluate the quality of the fee data that State  collects from sponsors and overseas agents, we obtained and reviewed  data collected in 2013. We interviewed ECA officials regarding the 2013  data as well as ECA’s reason for not collecting these data in 2014. We  determined that the 2013 fee data were not sufficiently reliable for  reporting on the fees that overseas agents and sponsors charge  participants, as discussed earlier in the report. We reviewed State’s  analysis of its field site reviews for the SWT 2013 and 2014 summer and  2013 winter programs, along with the questionnaires that State officials  used on the monitoring visits, to determine how State ensures the health,  safety, and welfare of SWT participants and to ascertain what participants  thought about the program. We did not review the methodology that State  used to analyze the interview results, and we present some of State’s  reported results for context only. We also observed State officials  interviewing a total of 21 SWT participants and four SWT employers  during field site visits conducted by ECA’s Private Sector Exchange Office  of the Private Sector Exchange Administration in San Francisco,  California; New York, New York; and Washington, D.C., as well as field  site visits conducted by Consular Affair’s Office of Passport Services in  Philadelphia, Pennsylvania. We selected these sites on the basis of the  State office conducting the field site visit and the number of SWT  participants in each location. Finally, we reviewed State’s process for  handling complaints and incident reports and analyzed complaints and  incident reports that State received from 2010 to September 2014, to  understand the types of concerns reported and State’s manner of  responding to them. We determined that the complaints and incident data  from 2013 were sufficiently reliable for our purposes by interviewing State  officials responsible for compiling and maintaining the data. We asked  these officials about procedures for data entry, edit checks and controls,  safeguards against inconsistent entries, procedures for following up on  identified errors, among other things.
To identify State’s efforts to strengthen the cultural component of the  SWT program and further its broader public diplomacy goals, we  reviewed the regulatory requirement that sponsors ensure that all  participants have opportunities to engage in cultural activities or events  outside of work by planning, initiating, and carrying out events or other  activities that provide participants’ exposure to U.S. culture. We also  reviewed State’s efforts to collect information on the cultural component  of the program through its field site review reports and by witnessing field  site reviews. To identify the extent to which the SWT program is furthering  U.S. public diplomacy goals and leveraging alumni resources within ECA,  we reviewed ECA’s Bureau Strategy Document for fiscal years 2015 to  2017. We also interviewed ECA officials responsible for implementing the  SWT program, officials in the Office of Alumni Affairs, and the Deputy  Assistant Secretary and reviewed State’s efforts to monitor the cultural  component of the program.
We conducted our review from November 2013 to February 2015 in  accordance with generally accepted U.S. 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: State Department Entities with Responsibilities for the Summer Work Travel Program
paragraphs: The following State Department (State) entities have responsibilities for  administering the Summer Work Travel (SWT) program.
State’s Bureau of Educational and Cultural Affairs (ECA) administers  the SWT program through the Office of Private Sector Exchange,  which expanded from two to four offices and nearly doubled its staff  size from 2012 through 2013. Within the Office of Private Sector  Exchange are four offices with responsibilities for the Summer Work  Travel program: the Offices of Designation, Exchange Coordination  and Compliance, Private Sector Exchange Administration, and Policy  and Program Support. These offices also oversee the other exchange  visitor programs that ECA administers.
The Office of Designation is responsible for designating new sponsors  to the SWT program and redesignating current sponsors on a  biannual basis. Designated sponsors are given access to the Student  and Exchange Visitor Information System (SEVIS) in order to maintain  accurate information on participants throughout their stay in the  United States. The Office of Designation also conducts outreach to  sponsors and helps them stay compliant with regulations through  timely advice and ongoing communication.
The Office of Exchange Coordination and Compliance investigates  concerns about sponsors, including alleged violations of the SWT  regulations. It has the authority to sanction sponsors in a variety of  ways and liaises with State’s Bureau of Diplomatic Security and other  law enforcement agencies when appropriate. It also conducts on-site  reviews of sponsors in all J-1 Visa categories to ensure that the  sponsors are complying with regulations.
The Office of Private Sector Exchange Administration, established in  2013, manages issues, crises, and complaints within the SWT  program. It maintains a hotline and e-mail in box that participants and  the public can use to make contact if issues arise, and, according to  State officials, sustains contact with complainants until issues are  resolved. Similarly, the office works with sponsors to resolve reported  incidents. It also conducts field site reviews interviewing SWT  participants at their workplaces to assess SWT participants’ overall  program experiences and identify any recurring problems.
The Office of Policy and Program Support, established in 2013,  develops SWT regulations. According to State, the office is currently  considering regulatory changes to strengthen provisions aimed at  enhancing the safety, health, and welfare of exchange visitors and  strengthening overall exchange visitor program experiences; establish  the Office of Private Sector Exchange’s strategic focus to ensure that  its 14 private sector programs are linked to its mission; ensure  budgetary responsibility; and guide the private sector’s alumni  expansion effort.
State’s Bureau of Consular Affairs consular officers overseas  adjudicate visa applications after determining whether applicants are  eligible for the SWT program based on factors such as English  language proficiency, intent to return to their home countries, and  sufficient funds to cover expenses. In addition, the bureau’s domestic  passport offices, located throughout the United States, assist ECA in  conducting field site reviews.
The Kentucky Consular Center (KCC) verifies, using various  databases, the legitimacy of SWT employers for participants from  countries that are not part of State’s Visa Waiver Program. Each day,  KCC produces a report for ECA that indicates whether it identified any  employers that may be of concern to the health, safety, and welfare of  participants.
section_title: Appendix III: Comments from the Department of State
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgements
paragraphs: In addition to the contact named above, Hynek Kalkus (Assistant  Director), Julie Hirshen (Analyst-in-Charge), Sada Aksartova, Carly  Gerbig, Etana Finkler, Reid Lowe, Alana Miller, and Anthony Moran made  key contributions to this report. Other assistance was provided by Martin  de Alteriis and Grace Lui.