Refugees: Actions Needed by State Department and DHS to Further Strengthen Applicant Screening Process and Assess Fraud Risks
Released: 2017-07-31T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: Increases in the number of USRAP applicants approved for resettlement in the United States from countries where terrorists operate have raised questions about the adequacy of applicant screening.

GAO was asked to review the refugee screening process. This report (1) describes what State and DHS data indicate about the characteristics and outcomes of USRAP applications, (2) analyzes the extent to which State and RSCs have policies and procedures on refugee case processing and State oversees RSC activities, (3) analyzes the extent to which USCIS has policies and procedures for adjudicating refugee applications, and (4) analyzes the extent to which State and USCIS have mechanisms in place to detect and prevent applicant fraud. GAO reviewed State and DHS policies, analyzed refugee processing data and reports, observed a nongeneralizable sample of refugee screening interviews in four countries in 2016 (selected based on application data and other factors), and interviewed State and DHS officials and RSC staff.

section_title: What GAO Found
paragraphs: From fiscal year 2011 through June 2016, the U.S. Refugee Admission Program (USRAP) received about 655,000 applications and referrals—with most referrals coming from the United Nations High Commissioner for Refugees—and approximately 227,000 applicants were admitted to the United States (see figure). More than 75 percent of the applications and referrals were from refugees fleeing six countries—Iraq, Burma, Syria, Somalia, the Democratic Republic of Congo, and Bhutan. Nine Department of State- (State) funded Resettlement Support Centers (RSC) located abroad process applications by conducting prescreening interviews and initiating security checks, among other activities. Such information is subsequently used by the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS), which conducts in-person interviews with applicants and assesses eligibility for refugee status to determine whether to approve or deny them for resettlement.

a After receiving an application, USRAP partners determine whether the applicant qualifies for a U.S. Citizenship and Immigration Services (USCIS) interview.

b USCIS officers may place an application on hold after their interview if they determine that additional information is needed to adjudicate the application.

State and RSCs have policies and procedures for processing refugee applications, but State has not established outcome based-performance measures. For example, State's USRAP Overseas Processing Manual includes requirements for information RSCs should collect when prescreening applicants and initiating national security checks, among other things. GAO observed 27 prescreening interviews conducted by RSC caseworkers in four countries and found that they generally adhered to State requirements. Further, State has control activities in place to monitor how RSCs implement policies and procedures. However, State has not established outcome-based performance indicators for key activities—such as prescreening applicants and accurate case file preparation—or monitored RSC performance consistently across such indicators. Developing outcome-based performance indicators, and monitoring RSC performance against such indicators on a regular basis, would better position State to determine whether RSCs are processing refugee applications in accordance with their responsibilities.

USCIS has policies and procedures for adjudicating applications—including how its officers are to conduct interviews, review case files, and make decisions on refugee applications—but could improve training, the process for adjudicating applicants with national security concerns, and quality assurance assessments. For example, USCIS has developed an assessment tool that officers are to use when interviewing applicants. GAO observed 29 USCIS interviews and found that officers completed all parts of the assessment. USCIS also provides specialized training to all officers who adjudicate applications abroad, but could provide additional training for officers who work on a temporary basis, which would better prepare them to adjudicate applications. In addition, USCIS provides guidance to help officers identify national security concerns in applications and has taken steps to address challenges with adjudicating such cases. For example, in 2016, USCIS completed a pilot that included sending officers with national security expertise overseas to support interviewing officers in some locations. USCIS determined the pilot was successful and has taken steps to formalize it. However, USCIS has not developed and implemented a plan for deploying these additional officers, whose expertise could help improve the efficiency and effectiveness of the adjudication process. Further, USCIS does not conduct regular quality assurance assessments of refugee adjudications, consistent with federal internal control standards. Conducting regular assessments of refugee adjudications would allow USCIS to target training or guidance to areas of most need.

a All persons traveling to the United States by air are subject to standard U.S. government vetting practices.

State and USCIS have mechanisms in place to detect and prevent applicant fraud in USRAP, such as requiring DNA testing for certain applicants, but have not jointly assessed applicant fraud risks program-wide. Applicant fraud may include document and identity fraud, among other things. USCIS officers can encounter indicators of fraud while adjudicating refugee applications, and fraud has occurred in USRAP programs in the past. Because the management of USRAP involves several agencies, jointly and regularly assessing fraud risks program-wide, consistent with leading fraud risk management practices and federal internal control standards, could help State and USCIS ensure that fraud detection and prevention efforts across USRAP are targeted to those areas that are of highest risk.

This is a public version of a sensitive report issued in June 2017. Information that the Departments of Defense, Homeland Security, and State deemed to be sensitive is not included in this report.

section_title: What GAO Recommends
paragraphs: GAO recommends that State (1) develop outcome-based indicators to measure RSC performance and (2) monitor against these measures; USCIS (1) enhance training to temporary officers, (2) develop a plan to deploy additional officers with national security expertise, and (3) conduct regular quality assurance assessments; and State and DHS jointly conduct regular fraud risk assessments. State and DHS concurred with GAO's recommendations.

section_title: Letter
paragraphs: An estimated 34,000 people are forced to flee their homes each day  because of conflict, oppression, and persecution, according to the United  Nations High Commissioner for Refugees (UNHCR). U.S. immigration  law provides that qualified foreign nationals located outside of the United  States may be granted humanitarian protection in the form of refugee  status and resettlement in the United States if they demonstrate that they  are unable or unwilling to return to their home country because of past  persecution or a well-founded fear of future persecution based on their  race, religion, nationality, membership in a particular social group, or  political opinion. UNHCR reported that there were more than 21 million  refugees worldwide in 2015. In fiscal year 2016, the United States  admitted approximately 85,000 refugees for resettlement—the largest  yearly number in more than 15 years—through the U.S. Refugee  Admissions Program (USRAP).

Increases in the number of USRAP applicants approved for resettlement  in the United States—particularly from countries in the Middle East where  terrorist groups such as the Islamic State in Iraq and Syria (ISIS)  operate—have raised questions about the adequacy of screening for  refugee applicants to prevent access by persons who may be threats to  national security. There are also questions as to whether USRAP is  vulnerable to fraud because, for example, testimonial evidence alone,  without corroboration, may be sufficient for refugee applicants to meet the  burden of proof for establishing eligibility for resettlement in the United  States. Given the potential consequences that the outcomes of decisions  on refugee applications can have on the safety and security of both  vulnerable refugee populations and the United States, it is important that  the U.S. government have an effective refugee screening process to  allow for resettlement of qualified applicants while preventing persons  with malicious intent from using USRAP to gain entry into the country.

The Departments of State (State) and Homeland Security (DHS) have  joint responsibility for the admission of refugees to the United States.  Specifically, State’s Bureau of Population, Refugees, and Migration  coordinates and manages USRAP and makes decisions on which  individuals around the world are eligible for resettlement as refugees in  the United States. State coordinates with DHS and other agencies in  carrying out this responsibility. In particular, nine State-funded  Resettlement Support Centers (RSC) that are operated by international  and nongovernmental organizations and are located abroad with distinct  geographic areas of responsibility communicate directly with applicants to  process their applications, collect their information, and conduct in-person  prescreening interviews. After such prescreening is complete, DHS’s  U.S. Citizenship and Immigration Services (USCIS) has responsibility for  adjudicating applications from these individuals. In adjudicating such  applications, USCIS officers are to conduct individual, in-person  interviews with applicants overseas and use the results of these  interviews in conjunction with other relevant information, such as the  results of applicants’ security checks, to determine whether USCIS will  approve the applicants for resettlement in the United States as refugees.  Federal agencies within and outside of the intelligence community,  including the National Counterterrorism Center (NCTC), the Department  of Defense, and the Federal Bureau of Investigation (FBI), partner with  State and USCIS on security checks to identify and vet any potential  national security concerns associated with an applicant. Further, at U.S.  ports of entry, DHS’s U.S. Customs and Border Protection (CBP) is  responsible for inspecting all individuals, including refugees, to determine  if they will be admitted or otherwise permitted entry into the country.

Pursuant to a provision in the Joint Explanatory Statement accompanying  the Consolidated Appropriations Act, 2016, and congressional requests,  we were asked to review the refugee screening process. This report (1)  describes what State and DHS data indicate about the characteristics and  outcomes of USRAP applications, (2) analyzes the extent to which RSCs  and State have policies and procedures on refugee case processing and  State has overseen RSC activities, (3) analyzes the extent to which  USCIS has policies and procedures for adjudicating refugee applications,  and (4) analyzes the extent to which State and USCIS have mechanisms  in place to detect and prevent applicant fraud in USRAP. You also asked  us to provide specific information on the Central American Minors (CAM)  program, which is included in appendix I.

This report is a public version of a sensitive report that we issued in June  2017. The Departments of Homeland Security and State deemed some  of the information in our June report to be Sensitive But Unclassified or  For Official Use Only, which must be protected from public disclosure.  Therefore, this report omits sensitive information about USRAP security  check processes and results, as well as specific details about prior  incidences of fraud in the program. Although the information provided in  this report is more limited, the report addresses the same objectives as  the sensitive report and uses the same methodology.

To describe what State and DHS data indicate about the characteristics  and outcomes of USRAP applications, we analyzed record-level data  from State’s Worldwide Refugee Admissions Processing System  (WRAPS)—an interactive computer system that serves as a repository for  application information and tracks the status of all individual refugee  applications to USRAP—for all refugee applications that were received  from fiscal years 2011 through June 2016. We also obtained WRAPS  summary data on the CAM program from December 2014—when State  and DHS began accepting applications for the program—through March  2017. We assessed the reliability of the WRAPS data by, for example,  reviewing them for missing data or obvious errors and interviewing State  officials responsible for ensuring data quality. During our assessment, we  found some inconsistencies in the data field that indicates the status of  the application in USRAP when conducting our internal data checks. We  rounded the counts for the categories in this field to the nearest thousand  for the purposes of reporting USRAP summary data and to the nearest  hundred for the purposes of reporting CAM summary data. We found the  WRAPS data to be sufficiently reliable for the purposes of this report,  including determining the number of applications, their outcomes  (approved, closed or denied, or pending), the results of security checks,  timeframes associated with processing applications, and various  applicant characteristics such as gender and nationality.

To analyze the extent to which State and RSCs have policies and  procedures on refugee case processing and State’s oversight of RSC  activities, we analyzed State’s standard operating procedures (SOP) and  guidance to RSCs, including State’s USRAP Overseas Processing  Manual and SOPs pertaining to different phases of the refugee  application process. We also reviewed local SOPs developed by each  RSC. Additionally, we observed refugee processing and RSC  caseworkers conducting in-person prescreening interviews (27 interviews  in total) by visiting RSC offices in four locations—San Salvador, El  Salvador; Vienna, Austria; Amman, Jordan; and Nairobi, Kenya—from  June through September 2016. We selected these locations based on  various factors, including variations in the number of refugee applications  received, geographic variability (i.e., RSC locations), and the types of  applications processed at each office. The results from our visits are  specific to the processing and interviews observed at these locations  when we visited and cannot be generalized; however, we believe the site  visit results still provide important context and insights into how RSCs  implement USRAP policies and procedures. For the five RSCs we did not  visit in person, we conducted telephone interviews with RSC  management. In addition, we analyzed 107 summary reports USCIS team  supervisors completed following officers’ trips overseas to interview  USRAP applicants from the fourth quarter of 2014 through the third  quarter of 2016 (the most recent reports available at the time of our  review). We also spoke with 6 USCIS officers who conducted the  applicant interviews we observed during our site visits to obtain their  perspectives on RSC case processing, as well as 4 supervisory officers.  To assess the controls State has in place to monitor RSCs, we reviewed  RSC cooperative agreements and a memorandum of understanding  (MOU), and the most recent monitoring report State completed for each  RSC; questionnaires completed by RSC directors in advance of State  monitoring visits; and fiscal year 2015 quarterly reports RSCs submitted  to State—the most recent completed fiscal year for which data were  available when we were conducting our work. We obtained additional  information on how State monitors RSCs during our interviews with State  officials who manage the program. We compared State’s monitoring  efforts with requirements in State’s Performance Management  Guidebook, Federal Assistance Policy Directive, and the Government  Performance and Results Act of 1993 (GPRA), as updated by the GPRA  Modernization Act of 2010 (GPRAMA).

To analyze the extent to which USCIS has developed and implemented  policies and procedures for adjudicating refugee applications, we  analyzed USCIS SOPs on the refugee adjudication process, including  USCIS’s I-590 Refugee Application Assessment—the primary tool  refugee officers use to interview and screen refugees and document the  resulting adjudication decisions. Further, we observed 29 USCIS  interviews at the four RSCs we visited. Although these observations are  not generalizable across all USCIS interviews, they provided first-hand  observations on how USCIS officers adjudicate refugee applications and  insights into the implementation of USCIS’s policies and procedures. In  addition, we analyzed the aforementioned USCIS summary reports to  better understand how USCIS adjudicates applications overseas and any  associated challenges. We also reviewed USCIS training materials and  attended trainings that USCIS officers receive prior to traveling overseas  to interview a specific population of refugees. We also discussed USCIS  training and guidance with USCIS’s Refugee Affairs Division (RAD) and  International Operations (IO) Division and the 10 USCIS officers,  mentioned above, who we interviewed. In addition, we reviewed USCIS  workforce planning information and training requirements. We compared  all of this information to Standards for Internal Control in the Federal  Government and leading practices in federal strategic planning. Further,  we reviewed USCIS quality assurance policy documents, quality  assurance assessments from fiscal year 2015—the most recent year in  which USCIS assessed refugee adjudications—and spoke with USCIS  officials about quality assurance mechanisms for USRAP. We compared  USCIS’s quality assurance practices to USCIS’s memorandum on roles  and responsibilities with respect to refugee processing and federal  internal control standards and standard practices for program  management.

To analyze the extent to which State and USCIS have mechanisms in  place to detect and prevent applicant fraud in USRAP, we compared  State’s and USCIS’s fraud-related policies and procedures with standards  for federal internal control and leading practices in GAO’s A Framework  for Managing Fraud Risks in Federal Programs (Fraud Risk  Framework). For the purposes of this report, we define refugee fraud as  the willful misrepresentation of material facts, such as making false  statements, submitting forged or falsified documents, or conspiring to do  so, in support of a refugee claim with the United States. Regarding  USCIS, we reviewed policies and procedures on how to identify and  prevent fraud in USRAP, such as USCIS’s draft refugee fraud process  SOPs and fraud training materials that USCIS provides to its officers.  Regarding State, we reviewed memoranda on previously identified fraud  in USRAP programs as well as SOPs State developed to help RSCs  identify fraudulent applications. Further, we interviewed USCIS and State  headquarters officials and officials at all 9 RSCs about applicant fraud in  USRAP and their fraud identification and prevention procedures. In  addition, we analyzed WRAPS data on steps RSCs take to prevent  fraudulent applications. We also reviewed the 107 USCIS trip reports,  which contain information on fraud trends that officers encountered while  adjudicating cases in a particular location.

The performance audit upon which this report is based was conducted  from February 2016 to June 2017 in accordance with generally accepted  government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide  a reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives. We  subsequently worked with State, DHS, and the Department of Defense  from June to July 2017 to prepare this nonsensitive version of the original  sensitive report for public release. This public version was also prepared  in accordance with generally accepted government auditing standards.
subsections: section_title: Background
subsections: section_title: Refugee Eligibility Requirements and Admissions
paragraphs: The United States has a long history of refugee resettlement, but there  was no formal program for the resettlement and admission of refugees  until the Refugee Act of 1980 (Refugee Act) amended the Immigration  and Nationality Act (INA) to, among other purposes, establish a more  uniform basis for the provision of assistance to refugees. Under the INA,  as amended, an applicant seeking admission to the United States as a  refugee must (1) not be firmly resettled in any foreign country, (2) be  determined by the President to be of special humanitarian concern to the  United States, (3) meet the definition of refugee established in U.S.  immigration law, and (4) be otherwise admissible to the United States as  an immigrant under U.S. immigration law. Under USRAP, USCIS  officers determine an applicant’s eligibility for refugee status by assessing  whether the applicant has, among other things, credibly established that  he or she suffered past persecution, or has a well-founded fear of future  persecution, and that he or she is not otherwise statutorily barred from  being granted refugee status or admission to the United States. Among  other things, USCIS officers may not classify an applicant as a refugee or  approve an applicant for refugee resettlement in the United States if he or  she: has participated in the persecution of any person on account of race,  religion, nationality, membership in a particular social group or political  opinion; is inadmissible for having engaged in terrorist activity or  associating with terrorist organizations; is inadmissible on certain non- waivable criminal or security grounds; or is firmly resettled in a foreign  country. Under USRAP, cases may be presented for USCIS  adjudication with a single applicant or may include a principle applicant  with certain family members. All applicants on a case must be deemed  admissible, but only the principal applicant must prove his or her past  persecution or fear of future persecution.

Before the beginning of each fiscal year and after consultation with  Congress, the President is to establish the number of refugees who may  be admitted to the United States in the ensuing fiscal year (i.e., a  “ceiling”), with such admissions allocated among refugees of special  humanitarian concern to the United States (e.g., by region or country of  nationality). For example, for fiscal year 2016, the administration  proposed and met a ceiling of 85,000 refugees in fiscal year 2016  (including a goal of admitting 10,000 Syrian refugees) and established a  ceiling of 110,000 for fiscal year 2017. Since 2001, annual ceilings for  refugee admission have generally been between 70,000 and 80,000  admissions; in the early 1990s, the ceilings were at more than 100,000  admissions. Actual admissions of refugees into the country have been at  or below the ceiling in recent years. For example, the combined ceiling for fiscal years 2011 through 2016 was 451,000, during which the United  States admitted about 410,000 refugees. Figure 1 shows refugee  admissions by region during this time period.

section_title: Screening Process for Refugees Seeking to Resettle in the United States
paragraphs: There are a number of steps in the USRAP screening process for  applicants. Figure 2 provides an overview of the refugee screening  process.

Program access. First, State and USCIS make initial determinations  about whether an individual will be accepted into or excluded from  USRAP (referred to as program access) for subsequent screening and  interview by USCIS officers. There are multiple mechanisms by which  State and its partners receive USRAP applications. For example, most  applicants are referred to USRAP by UNHCR, but applicants who meet  certain criteria can apply directly. State has identified three categories of  individuals who are of special humanitarian concern and, therefore, can  qualify for access to USRAP:

Priority 1 (P1), or individuals specifically referred to USRAP generally  because they have a compelling need for protection;

Priority 2 (P2), or specific groups, often within certain nationalities or  ethnic groups in specified locations, whose members State and its  partners have identified as being in need of resettlement; and

Priority 3 (P3), or individuals from designated nationalities who have  immediate family members in the United States who initially entered  as refugees or who were granted asylum.

Access: Determination by the Department of  State and its U.S. Refugee Admissions  Program (USRAP) partners of whether the  applicant qualifies for the U.S. Citizenship and  Immigration Services (USCIS) adjudication  based on if he/she is of special humanitarian  concern (i.e., if he/she is within a Priority 1,  Priority 2, or Priority 3 category), among other  things.

Adjudication: USCIS’s process for deciding  whether to approve or deny an applicant for  refugee status. The adjudication process  includes, among other things, at least one in- person interview; security checks; and, in  some instances, additional review of the  applicant’s case to address national security  concerns.

Approved application: Determination by  USCIS officer that the applicant meets the  refugee definition and is otherwise eligible for  resettlement in the United States, and will  subsequently be processed for travel to the  United States. partners conduct biographic checks of certain applicants who are  members of groups or nationalities designated by the U.S.  government as requiring more thorough vetting.

Interagency Check. Partners, including NCTC and elements of the  intelligence community, screen biographic data of all refugee  applicants within a designated age range against intelligence and law  enforcement information within their databases and security holdings.  Specifically, all refugee applicants within certain ages are required to  undergo an Interagency Check. Further, security vetting partners are  to continuously check interagency refugee applicant data against their  security holdings through a refugee’s admission to the United States  and, in some instances, after an applicant’s arrival and admission to  the United States.

Through these checks, applications are screened for indicators that they  might pose a national security or fraud concern or have immigration or  criminal violations, among other things. USCIS and FBI officials have  testified at congressional hearings that security checks are limited to the  records available in U.S. government databases (which may include  information provided by foreign governments and other information on  foreign nationals). According to State SOPs, security check responses  are communicated through WRAPS, and RSC staff include them in the  case file provided to the USCIS officer adjudicating the application. If at any time an applicant is identified as having a match for the Security  Advisory Opinion or Interagency Check, the case is to be placed on hold.  For Security Advisory Opinion results that are completed before the  USCIS interview, State officers are to review any matches to determine if  they relate to the applicant and should preclude the applicant from access  to the USRAP. USCIS is responsible for reviewing security check results  that are completed after the USCIS interview. Further, the CLASS check  may require a Security Advisory Opinion or additional DHS review. Once  prescreening is complete and RSC staff have received the results of  certain security checks, they are to notify State and USCIS that the  applicant is ready for interview and adjudication. DHS is to, based on  policy, conduct an additional review of Syrian and certain other applicants  prior to adjudication as part of prescreening.

USCIS Adjudication. Third, USCIS adjudicates applications. USCIS  coordinates with State to develop a schedule for refugee interviews each  quarter of the fiscal year. USCIS officers conduct individual, in-person  interviews overseas with applicants to help determine their eligibility for  refugee status. RAD and IO—within USCIS’s Refugee, Asylum, and  International Operations (RAIO) Directorate—share responsibility for  adjudicating USRAP cases. In 2005, USCIS created the Refugee Corps,  a cadre of USCIS officers within RAD who, according to USCIS officials,  are to adjudicate the majority of applications for refugee status. These  officers are based in Washington, D.C., but they travel to multiple  locations for 6 to 8 weeks at a time (called circuit rides), generally making  four trips per year, according to RAD officials. In addition, IO officers  posted at U.S. embassies overseas can conduct circuit rides and  interviews in embassies to adjudicate refugee applications, among other  responsibilities. Before or during the circuit ride, USCIS officials are to  take the applicants’ fingerprints, which are screened against DHS,  Department of Defense, and FBI biometric databases, and if new  information from the biometric check raises questions, USCIS officers  may ask additional questions at the interview, require additional  interviews, or deny the case. In addition, if USCIS officers identify new  biographic information during the interview, such as an alias that was previously unknown or not disclosed to RSC staff, that information is  vetted through the biographic security checks described above, per State  and DHS policy. The officers are to place these applications on hold,  pending the outcome of these checks. Further, consistent with USCIS  policy, officers are required to place a case on hold to do additional  research or investigation if, for example, the officer determines during the  interview that the applicant may pose a national security concern. Based  on the interviews and security checks conducted, USCIS officers will  either approve or deny an applicant’s case. USCIS supervisory officers  are to review 100 percent of officers’ adjudications, according to USCIS  policy.

Final processing and travel to the United States. If USCIS approves  an applicant’s refugee application, RSCs are to generally provide the  applicant with cultural orientation classes on adjusting to life in the United  States, facilitate medical checks, and prepare the applicant to travel. Prior  to admission to the United States, applicants are subject to the standard  CBP and Transportation Security Administration vetting and screening  processes applied to all travelers destined for the United States by air.  CBP is to inspect all refugees upon their arrival at one of seven U.S.  airports designated for refugee arrivals and make the final determination  about whether to admit the individual as a refugee to the United States.

section_title: USRAP Applicant Characteristics Vary; About One-third of Applicants from Fiscal Year 2011 through June 2016 Have Been Admitted to the United States, as of June 2016
subsections: section_title: USRAP Applicant Characteristics Vary by Country of Nationality, Processing Location, and Case Size
paragraphs: From fiscal year 2011 through June 2016, WRAPS data indicate that  USRAP received about 655,000 referrals and applications, associated  with about 288,000 cases. As figure 3 indicates, during this time frame,  more than 75 percent of applications were from refugees fleeing 6  countries—Iraq, Burma, Syria, Somalia, the Democratic Republic of  Congo, and Bhutan—and the number of applicants from certain countries  has changed over time. For example, the number of Bhutanese and  Burmese applications decreased, but the number of Syrian and  Congolese applications increased. State officials said that UNHCR  submitted a large number of P1 Syrian referrals to USRAP in fiscal year  2016 because more people were fleeing that country due to conflict and  the goal of admitting 10,000 Syrian refugees. From October 2015 through  June 2016, WRAPS data indicate that more than one-third of USRAP  applicants were Syrian.

In addition to nationality, USRAP applicants’ characteristics varied in  other ways. For example, as shown in figure 4, applications to USRAP  from fiscal year 2011 through June 2016 were largely split between the  P1 or P2 categories and about two-thirds were processed in one of three  RSCs (Middle East and North Africa, Africa, and East Asia). Further, 75  percent of applicants were associated with cases that included immediate  family members (which includes a spouse and unmarried children under  the age of 21), while 25 percent of cases included only 1 individual.

section_title: United States Admitted 35 Percent of Applicants from Fiscal Year 2011 to June 2016, and the Remaining Applications Were Closed or In Process, as of June 2016
paragraphs: At any given time, there are a number of applicants at different stages of  the USRAP process. According to State and RSC officials, State and  USCIS process applications in the general order they were received. For  example, table 1 shows that, of the applications received in fiscal year  2011, 56 percent were approved and admitted to the United States as of  June 2016, 13 percent were still in process (pending access to USRAP,  actively being processed, or on hold), and 31 percent of applications were  closed before the applicant completed the USRAP process, as of June  2016. By comparison, as of June 2016, almost 70 percent of  applications received in fiscal year 2015 were in process.

Program Access. Of the total number of applications received from fiscal  years 2011 through June 2016 (about 655,000), State and its USRAP  partners made access determinations for about 590,000 of that amount— 569,000 (or 96 percent) of which they accepted, as of June 2016. As  described earlier, State and its USRAP partners makes the initial  determination on whether to grant an applicant access (accept) to  USRAP for subsequent screening and interview by USCIS officers.  According to State officials, one reason the acceptance rate is high is  because State Refugee Coordinators stationed overseas provide  feedback to UNHCR on the types of P1 applications that are not likely to  be accepted or ultimately approved by USCIS officers. Further, according  to State officials, State coordinates with UNHCR and USCIS to develop  predefined eligibility criteria for certain P2 groups and applicants meeting  those criteria may access USRAP once UNHCR submits the application  to State. For example, State and UNHCR created a new P2 group in  2015 for Congolese who fled to Tanzania. To be part of the P2 group,  applicants must have registered with UNHCR and verified their residence  in the Nyaragusu refugee camp.

From fiscal year 2011 through June 2016, acceptance of applications to  USRAP for adjudication varied by nationality of the applicants. For  example, excluding pending applications, USRAP partners did not accept  8 percent of Iraqi applicants. USRAP partners also did not accept 4  percent of Syrian applicants, and did not accept less than 1 percent of  Burmese and Somali applicants. According to State officials, the most  common reason why applicants are not accepted is that they fail to meet  criteria to access USRAP. For example, according to State officials,  acceptance rates were lower for Iraqi applicants because some Iraqis  could not prove their association with the United States—a requirement  under various P2 programs. As part of the adjudication process, USCIS  officers are to confirm that applicants were appropriately granted access  to USRAP. WRAPS data from fiscal year 2011 through June 2016 show  that USCIS officers confirmed that over 99 percent (all but about 1,000  out of 351,000) of the applicants interviewed were appropriately granted  access to USRAP (i.e., qualify for adjudication by USCIS), as of June  2016.

USCIS Adjudications. According to WRAPS data, as of June 2016,  USCIS officers interviewed about 62 percent (351,000) of the applicants  who were granted access to USRAP from fiscal year 2011 through June  2016. USCIS officers approved 89 percent (314,000 of 351,000) and  denied 7 percent (24,000) of these applications. Approval rates varied  by RSC (see fig. 5).

Applications may also be put on hold for a number of reasons. For  example, holds may occur because of security check results, a USCIS  officer did not have sufficient information at the time of the interview to  approve or deny the applications associated with the case, or as a result  of new information that came to light after the interview. For applications  in our time period of analysis, WRAPS data indicate that 12 percent  (about 81,000) were on hold as of June 2016. USCIS officials stated that  they would make a final decision on these cases after receiving additional  information, which could include outstanding or additional security checks  results, information from family members’ cases, and conducting  additional interviews.

About 24 percent (138,000) of the applicants who were granted access to  USRAP from fiscal year 2011 through June 2016 were awaiting  interviews with USCIS (i.e., the applicant had an active case or a case  that was on hold but had not received an interview), as of June 2016.  RSC Middle East and North Africa (58,000) and RSC Africa (40,000) had  the largest number of applications awaiting interviews. Some applicants  have waited years to receive a USCIS interview. For example, according  to WRAPS data, about 9,000 applications submitted in fiscal years 2011  or 2012 were active in June 2016 and the applicants had not yet received  a USCIS interview. About 87 percent of these applications were  applicants from Iraq or Somalia. In addition, there were about 6,000  applications received in fiscal years 2011 and 2012 that were on hold and  had not received a USCIS interview, 93 percent of whom were from Iraq,  Somalia, or Burma. According to State officials, the security situations in  Iraq and a refugee camp on the border of Kenya and Somalia where  many Somali applicants are located have made it difficult to schedule  USCIS interviews at certain times in these locations, among other  reasons.

section_title: A Small Percentage of USRAP Applicants Were Not Admitted to the United States as a Result of Biographic and Biometric Checks
paragraphs: For applications received from fiscal year 2011 through June 2016 with  security check results noted in WRAPS, the Interagency Check was the  one that most often resulted in a result of “not clear” based on thresholds  set by an interagency process including the intelligence community and  law enforcement agencies. However, “not clear” results—meaning, the  checks identified security or fraud concerns—represented a small  percentage of all results for each of the three biographic checks and the  fingerprint check, as of June 2016. Further, of the applicants who were  admitted to the United States or had closed applications as of June 2016,  the median number of days from initiation of the biographic security  checks (at the time of the RSC prescreening interview) through the last  completed Interagency Check (which is often the last check prior to  departure for the United States) was 247 days.

According to WRAPS data, the overwhelming majority of the about  227,000 applicants from fiscal year 2011 through June 2016 who were  admitted to the United States as refugees had “clear” security check  results, as of June 2016. However, one applicant who was admitted to the  United States in 2012 had his security check status change from “clear” to  “not clear” days before his planned travel. The security vetting process at  that time did not account for responses from a vetting agency that had not  been specifically requested and, therefore, an additional check of security  vetting responses after receipt of a final response of “clear” had not been  conducted. According to State officials, when the RSC realized the  applicant had a “not clear” response, it notified local USCIS officials  immediately. USCIS data show that the refugee has since adjusted to  legal permanent resident status. According to a USCIS branch chief, at  the time of the individual’s adjustment application, the derogatory  information (which predicated the “not clear”) had been resolved and  there was no basis for USCIS to deny the individual’s adjustment  application. State has since updated security SOPs to require RSCs to  run daily reports to check if any applicants with imminent travel plans  have received an unsolicited Interagency Check “not clear.”

section_title: USRAP Process Took 1 Year or Longer to Complete from Case Creation through Arrival in the United States for About Three Quarters of Applicants Whom USCIS Approved
paragraphs: The length of time to process a USRAP application varies. For example,  of the applicants who applied from fiscal year 2011 through June 2016  and had been admitted to the United States, as of June 2016, 27 percent  were processed in less than 1 year, 47 percent between 1 and 2 years,  and 26 percent in more than 2 years. Figure 6 shows the cumulative  length of time (median number of days) of key phases in the USRAP  process. The lengthiest phase was from the time USCIS approved the  applicant through arrival in the United States (a median of 189 days).

section_title: State and RSCs Have Policies and Procedures for Processing Refugees, but State Could Improve Efforts to Monitor RSC Performance
subsections: section_title: State and RSCs Have Policies and Procedures on Refugee Case Processing and Prescreening
paragraphs: State and RSCs have various policies and SOPs, trainings, and quality  checks related to refugee case processing and prescreening.

Policies and SOPs for USRAP. State’s USRAP Overseas Processing  Manual provides an outline of the policies and procedures involved in  overseas processing for USRAP, including instructions for using WRAPS,  requirements for what information RSCs should collect during  prescreening, and instructions and requirements for initiating certain  national security checks, among other things. In addition, State  developed SOPs for processing and prescreening refugee applications at  RSCs, which State officials indicated provide baseline standards for RSC  operations. Further, all four of the RSCs we visited provided us with their  own local SOPs that incorporated the topics covered in State’s SOPs.  Directors at the remaining five RSCs also told us that they had developed  local SOPs that covered the overarching USRAP requirements.

We observed how RSC staff implemented State’s case processing and  prescreening policies and procedures during our site visits to four RSCs  from June 2016 to September 2016. Specifically, we observed 27  prescreening interviews conducted by RSC caseworkers at the four RSCs  we visited and found that these caseworkers generally adhered to State  requirements during these interviews. For example, RSC caseworkers we  observed reviewed applicants’ identification documents (e.g. passport,  birth certificate, or marriage certificate) and recorded name variations  (e.g. alternate spellings to confirm identity and for use in security checks);  recorded “family tree” information (for security checks and to confirm  family relationships for subsequent applicants); and recorded the  applicants’ flight paths and persecution stories (to be used by USCIS  officers in their interviews and to determine if the applicant qualifies as a  refugee). In one location, we observed that RSC caseworkers were not  consistently asking applicants during the prescreening interviews if they  had any other aliases or nicknames. Further, USCIS officers identified the  same issue in three separate RSCs, during circuit rides in fiscal years  2014, 2015, and 2016, according to RAD trip reports. Asking about  aliases and nicknames is an expected practice for all RSC staff  conducting prescreening interviews, according to State and RSC officials,  because the information could be useful and important during an  applicant’s biographic national security checks. Further, State officials  said that if aliases are not identified prior to USCIS interview, it may delay  processing because when USCIS officers identify additional names the  RSCs must resubmit security checks. We brought the issue to the  attention of RSC and State management, and, in response to our  observations, the RSC revised its local SOPs to more clearly instruct  RSC caseworkers to ask applicants if they had any aliases or nicknames,  and State revised its prescreening SOPs and informed all other RSCs of  the change.

In addition, we observed how RSC staff in all four locations implemented  additional required procedures during our site visits, such as initiating  required security checks through WRAPS and compiling case file  information for USCIS interviewing officers, and found that these RSC  staff were complying with SOPs. Further, all nine RSC directors we  interviewed stated that they were familiar with State’s requirements for  their location and reported implementing them.

Training on USRAP requirements. On the basis of our analysis of  State’s cooperative agreements, RSC monitoring documents submitted to  State, and interviews with State headquarters’ officials and all nine RSC  directors, we found that these RSCs reported having various trainings for  their staff. According to State officials, they have not developed specific  training requirements for all RSCs because each RSC has different needs  and conditions requiring individualized training programs. All nine RSC  directors with whom we spoke said they have training programs ranging  from technical trainings (e.g., WRAPS or interview training) to shadowing  programs in which newly-hired staff observe more experienced RSC  employees performing their duties. During our September 2016 site visit  to RSC Africa, for example, we observed new-hire training for RSC  caseworkers, as well as more experienced caseworkers mentoring and  coaching the newer staff. At RSC Latin America, according to the director,  new staff receive 1 week of WRAPS training and observe more  experienced caseworkers conduct prescreening interviews until the new  staff member is able to conduct the interviews alone.

Quality control checks. On the basis of our analysis of RSC monitoring  documents submitted to State, cooperative agreements, observations at  the four RSCs we visited, and interviews with State headquarters’ officials  and all nine RSC directors, RSCs have quality control checks to oversee  case processing and prescreening to help ensure that RSC staff collect  accurate and reliable information. For example, at all four RSCs we  visited, we observed staff conducting both electronic and manual quality  control checks of case information. Specifically, after the prescreening  interview, RSC staff in all four locations reviewed the hard copy case file  and ran checks in WRAPS for errors or omissions. Further, all four RSCs  we visited had a dedicated quality control unit that is to monitor data  quality and review regular data monitoring reports. Moreover, RSC  directors in the other five locations stated that they have similar quality  control checks in place, and all nine RSC directors stated that there are  quality control checks at every stage of the USRAP process from case  creation in WRAPS to when refugees are about to depart for the United  States.

According to USCIS officials we interviewed at headquarters and in the  field, RSCs generally provide the information that USCIS officers needed  to adjudicate applications, but they also identified areas for improvement  during some circuit rides. For example, all 10 USCIS officers that we  interviewed who participated in the circuit rides associated with our site  visits stated that the information gathered by RSCs during the  prescreening process was generally accurate, complete, and useful.  However, 4 of these officers stated that they have encountered some  errors when RSCs provided case files with missing documents or  information. In addition, 70 out of the 107 RAD trip reports we analyzed  contained feedback on RSC activities. Of these 70 reports, 10 reports  stated that RSCs generally prepared the cases well, but 45 reports  identified concerns with the quality of certain case files, including missing  documentation. According to USCIS officials, missing documentation  can lead to delays during the circuit ride while RSC staff obtain and  provide copies of the missing documents or USCIS officers obtain the  missing information during the interview. In addition, USCIS officers may  need to place the application on hold until the missing documentation can  be obtained. USCIS officers and State officials we interviewed stated  that some of the missing information could only have been obtained  during the USCIS interviews with applicants, while others stated that  applicants can forget or neglect to give RSC staff all of their  documentation despite repeated reminders from RSC staff. Further, five  of the nine RSC managers stated that they request USCIS officers submit  feedback at the end of circuit rides on the quality of the case file content  and interpreters, and three of these RSC managers stated that they take  action based on USCIS’s feedback. For example, RSC managers in two  locations stated that they have excluded certain interpreters—who are  hired on daily contracts—from subsequent circuit rides based on the  feedback from USCIS officers. Additionally, USCIS officials stated that  their supervisory officers often meet with RSC staff throughout and at the  conclusion of a circuit ride to offer feedback on case preparation, among  other things. USCIS headquarters officials also offer feedback to State  headquarters officials on RSC operations after circuit ride teams return to  Washington, D.C.

section_title: State Has Controls in Place to Monitor RSCs, but Does Not Have Outcome-based Indicators to Assess RSC Performance across Key Activities
paragraphs: State has control activities in place to monitor how RSCs implement  policies and procedures for USRAP, but it does not have outcome-based  performance indicators to assess whether RSCs are meeting their  objectives under USRAP. Consistent with State’s January 2016 Federal  Assistance Policy Directive, and according to State officials, State is  required to monitor the RSCs it funds, whether through cooperative  agreements or voluntary contributions. State funds four RSCs through  cooperative agreements, four through a voluntary contribution to the  International Organization for Migration (IOM), and self-operates the final  RSC (RSC Cuba). On the basis of our interviews with State officials and  as reflected in documentation from all nine RSCs, including quarterly  reports to State, all RSCs have generally undergone the same monitoring  regime regardless of funding mechanism. The four cooperative  agreements and MOU with IOM establish objectives for the RSCs, which  include interviewing applicants to obtain relevant information for the  adjudication and ensuring the accuracy of information in WRAPS and the  case files. State also establishes annual targets for the number of  refugees who depart for the United States from each RSC.

In addition, the cooperative agreements between the RSCs and State  specify that State will periodically visit and evaluate the general  performance of RSC operations. They also require RSCs to provide State  with regular written reports on whether performance is in compliance with  all the terms and conditions of the agreement. Consistent with funding  requirements, the four RSCs with cooperative agreements submitted  quarterly reports to State in fiscal year 2015, for example, that included  information on how each RSC is addressing USRAP objectives. The  reports included the number of applicants prescreened each quarter, the  number of approved applicants who received cultural orientation training,  and how RSCs compile applicant information. In addition, the four RSCs  operated by IOM submitted quarterly reports using the same template.

Further, according to State officials, the department has dedicated  Program Officers located in Washington, D.C., and Refugee Coordinators  based in U.S. embassies worldwide, who are responsible for providing  support to RSCs and monitoring their activities. State headquarters  officials and Refugee Coordinators we met with at the four RSC locations  we visited told us that they have daily, informal interaction—via  telephone, e-mail, or in-person—with the RSCs. State’s Program Officers  also stated that they coordinate regularly with RSCs and conduct annual  monitoring visits at RSCs to assess RSCs’ performance and complete  monitoring reports based on their visits. We reviewed monitoring reports  from eight State site visits to RSCs completed between 2015 and 2016  and found that some included narrative discussions of RSC case  processing and timeframes, records management, coordination with other  USRAP partners, and other topics. However, not all monitoring reports  included consistent information on the same topics. For example, four of  the eight monitoring reports we analyzed did not contain information on  RSC case processing, prescreening interviews, and security check  activities. Further, Program Officers are to complete separate monitoring  reports for RSCs funded through cooperative agreements that assess the  degree to which RSCs are making progress towards objectives based on  project indicators. The indicators for RSCs, according to two fiscal year  2016 reports we reviewed, include the number of individuals prescreened  and presented to USCIS for interview, the number of individuals who  received cultural orientation training, the number of refugees that  departed from those RSCs to the United States, and whether the RSCs  ran security checks on all applicants. According to State officials, they  also conduct daily monitoring of RSC activities through WRAPS data,  which may be useful for monitoring RSC workload or data quality issues.

Although State has established objectives and monitors several  quantitative goals for RSCs—including the number of refugees that  depart each year for the United States and the number of applicants who  receive cultural orientation training—it has not established outcome- based performance indicators for key RSC activities such as  prescreening applicants or accurate case file preparation, or monitored  RSC performance consistently across such indicators. Specifically,  neither the quarterly reports nor other monitoring reports we examined  have or use consistent outcome-based performance indicators from  which State Program Officers could evaluate whether RSCs were  consistently and effectively prescreening applicants and preparing case  files—key RSC activities that have important implications for timely and  effective USCIS interviews and security checks. RSCs collect  performance information from USCIS officers through surveys or in- person feedback sessions at the end of circuit rides, which could help  inform the development of outcome-based performance indicators. For  example, the survey asks USCIS officers to rate the quality of the RSC  staff’s documentation of the applicants’ persecution claim. State could  develop an indicator from this information and measure progress against  it.

According to State’s January 2016 policy directive, all assistance awards  made by bureaus, offices, and posts—both domestic and overseas— within the department with assistance-awarding authority should have a  monitoring plan that includes goals, objectives, and indicators that are  outcome-oriented and capable of measuring the recipient’s progress in  meeting these goals. In addition, according to State’s Performance  Management Guidebook, a program requires a systematic process for  monitoring the achievement of program activities; analyzing performance  to track progress toward planned results; and using performance  information and evaluations to influence program implementation and  results. The guidebook states that each bureau, program, or project  should establish goals; have specific measurable, outcome-oriented  objectives; and develop and monitor performance indicators that focus on  the results or effects caused. Moreover, in accordance with GPRA, as  updated by GPRAMA, performance measurement is the ongoing  monitoring and reporting of program accomplishments, particularly  towards pre-established goals, and agencies are to establish  performance measures to assess progress towards goals. These  measures should link program efforts to desired outcomes. While  GPRAMA is applicable to the department or agency level, performance  goals and measures are important management tools to all levels of an  agency.

State officials said that in September 2016 they began to staff a new  policy section within State’s Office of Admissions, and staff within this  section are to begin standardizing the reporting of monitoring efforts,  among other things. In addition, as of March 2017, according to State  officials, the department and IOM were in the process of revising the  MOU to include, among other things, new monitoring and reporting  requirements that includes performance indicators. These officials also  stated that, in future cooperative agreements, they plan to build on  performance indicators developed by IOM while ensuring outcome-based  results. However, as of March 2017, State did not have documentation or  timelines for its plans to develop outcome-based performance indicators.  Developing outcome-based performance indicators, as required by State  policy and performance management guidance, and monitoring RSC  performance against such indicators on a regular basis, would better  position State to determine whether all RSCs are processing refugee  applications in accordance with their responsibilities under USRAP.

section_title: USCIS Has Policies and Procedures for Adjudicating Refugee Applications, but Could Improve Training and Quality Assurance
subsections: section_title: USCIS Has Policies and Procedures to Assign Officers and Adjudicate Refugee Applications
subsections: section_title: Staffing USCIS Circuit Rides
paragraphs: USCIS has policies and procedures to determine how to assign officers— RAD, IO, and temporary duty officers from other USCIS divisions—on  circuit rides to adjudicate USRAP applications. According to USCIS  officials, each fiscal year, based on State’s determination of the estimated  number of cases that will be ready for USCIS interviews, RAD and IO  divide responsibility for the anticipated workload. In general, RAD officers  adjudicate refugee applications in locations where the caseload is large,  such as Jordan and Kenya. According to USCIS officials, IO officers  generally adjudicate refugee applications in locations where the refugee  caseload is small, such as Pakistan, or where IO has a permanent office  presence, such as Moscow, Russia. In fiscal year 2016, USCIS  interviewed 43,705 refugee cases comprising 120,919 individuals. RAD  interviewed 36,706 and, IO interviewed 6,999 of these cases.

USCIS solicits a pool of temporary duty (temporary) officers from offices  throughout USCIS who have volunteered to adjudicate refugee  applications on circuit rides, contingent upon receiving additional training,  when RAD or IO do not have sufficient staff capacity to meet the workload  demands. According to RAD headquarters officials, there are no  restrictions on assigning temporary officers to particular circuit rides. RAD  officials stated that they generally assign RAD and temporary officers  based on officers’ availability and interview experience. Additionally,  temporary officers may commit to doing one or more circuit rides over one  or more fiscal years. USCIS headquarters officials acknowledged that  applications in some locations are more difficult to adjudicate than others  and some temporary officers may not be as proficient or experienced at  adjudicating applications as permanent RAD and IO officers. As a result,  as resources permit, RAD and IO officials stated that they try to place  temporary officers on circuit rides with caseloads that are best suited for  their experience level. RAD headquarters officials also stated that,  historically, they have planned for temporary officers to conduct  approximately 15 to 25 percent of RAD’s refugee interviews and expect  temporary officers to continue to be part of their workforce plan. When the  refugee ceiling increased to 85,000 in fiscal year 2016, RAD increased  the number of temporary officers on circuit rides to meet immediate  mission needs while also working to hire additional refugee officers. RAD  officials stated that, in fiscal year 2016, temporary staff completed 41  percent of RAD’s interviews. As of March 2017, RAD officials stated that  they have undertaken significant hiring efforts in the past year, reducing  the need for temporary officers. In addition, IO officials stated that fewer  than 25 percent of the officers who participated in IO circuit rides in fiscal  year 2016 were temporary officers. As of March 2017, IO officials stated  that they do not plan to use temporary officers to adjudicate refugee  applications for the remainder of fiscal year 2017.

section_title: Adjudication Policies and Procedures
paragraphs: USCIS has developed policies and procedures for adjudicating refugee  applications. These policies and procedures apply to RAD, IO, and  temporary officers and include policies and procedures for how officers  are to review the case file before the interview and conduct the interview  as well as how supervisors are to review applications to ensure they are  legally sufficient. For example, USCIS has developed a refugee  application assessment tool that all officers are to use when interviewing  the applicant to determine if the applicant was appropriately granted  access to USRAP, had past persecution or a well-founded fear of  persecution, is credible, is not a persecutor, and is admissible to the  United States—including whether the applicant might be inadmissible due  to national security or terrorism-related concerns. According to the  assessment tool, at the time of interview, the USCIS officer is responsible  for ensuring that appropriate security checks have been completed before  making a decision on the application. Further, after receiving a completed  refugee case file, supervisors are to review all forms and documents in  the file that are relevant to establishing eligibility for refugee resettlement,  including any documents provided by UNHCR or the RSC and those  completed by the interviewing officer. Supervisors are to review the case  file completed by the interviewing officer to ensure that the officer’s  decision is legally sufficient, that the officer has reviewed security check  results, and that all sections of the refugee application assessment are  accurate and complete. In addition, USCIS has developed policies and  procedures for determining when to place applications on hold.  Specifically, officers may place an application on hold when the officer  cannot make a final decision at the time of the interview—for example, if  the outcomes of all required security checks are not yet available or if  national security indicators requiring additional research become known  to the officer at any point during the interview.

We observed 29 USCIS RAD refugee interviews (including interviews by  RAD officers and temporary officers) at four RSCs that we visited from  June 2016 to September 2016 and found that the interviewing officers  completed all parts of the assessment tool and placed cases that had  pending security checks on hold, as required. We also observed that the  USCIS officers documented the questions they asked and the answers  the applicants provided. We also observed RAD supervisors while they  reviewed officers’ initial decisions, interview transcripts, and case file  documentation, consistent with RAD policy, at two of the sites we  visited. Further, all six of the USCIS officers that we met with stated that  supervisors conducted the required supervisory case file review during  their circuit rides and the four supervisory officers we met with were  aware of the requirements and stated that they conducted the supervisory  reviews.

section_title: USCIS Provides Specialized Training to All Officers Who Adjudicate Refugee Applications, but Could Improve Training for Temporary Officers
paragraphs: According to USCIS policy, all USCIS officers who adjudicate refugee  applications must complete specialized training, and the training varies  based on the USCIS division of the officer (for example, Asylum or  Refugee Affairs). However, temporary officers receive a condensed (or  shortened) version of the trainings received by full time refugee officers  and do not receive infield training. Figure 7 shows the training USCIS  officers receive depending on whether they are in RAD, IO, or another  USCIS division (i.e., a temporary officer).

Protection Training. RAD training requirements for refugee officers state  that officers are to attend a 4 week, in-person training (referred to as  refugee basic training) that is specific to the refugee adjudication process,  including classroom sessions, a written exam, and at least three mock  interviews. IO headquarters officials stated that IO officers are to attend  refugee basic training before adjudicating refugee applications. To  adjudicate refugee applications, temporary officers are to have received  “protection training,” the content of which varies based on the experience  and qualifications of the temporary officer. Specifically, RAD’s training  requirements for temporary officers state that officers who have not  interviewed refugees in the past year are to receive an abbreviated in- person training that is either 3 days (if the temporary officer has recent  interviewing experience for RAIO directorates, such as an asylum officer)  or 20 days (if the temporary officer does not have recent interviewing  experience for RAIO directorates). On the basis of our review of training  syllabi, topics in refugee basic training, and temporary officer trainings  include, at a minimum, applicable refugee and other immigration laws,  refugee case file review, national security concerns, bars to refugee  admission to the United States, and credibility assessment.

Middle East Refugee Processing Training. Further, since October  2014, all officers (including temporary officers) who adjudicate  applications that include applicants from Iraq and Syria are required to  take the week-long Middle East Refugee Processing training. This  training provides information to officers on the region’s history, specific  country conditions, and additional training on indicators of potential  national security concerns—such as military service history—for refugee  applicants from Iran, Iraq, and Syria. This training includes briefings from  law enforcement and the intelligence community.

Predeparture briefings. In addition, prior to each RAD circuit ride, all  officers, including temporary officers, who will adjudicate applications on  that circuit ride are to receive a predeparture briefing that includes,  among other things, any updated information on national security  concerns and caseload trends for the particular circuit ride population. IO  officials stated that their circuit rides are smaller and they do not always  have formal predeparture briefings. However, IO officials told us their  officers spend time before circuit rides reviewing case files and  researching any country conditions or policy updates that officers deem  relevant to their cases. All 10 RAD or temporary officers we interviewed  who adjudicated applications or reviewed cases on the RAD circuit rides  we observed stated that the USCIS trainings—particularly the  predeparture briefings—were valuable and helpful.

In-field training. RAD officers receive 10 days of “in-field training” from a  dedicated trainer on their first circuit ride. According to RAD training  requirements and circuit ride trip reports, during the in-field training  period, new officers are to observe experienced interviewers, conduct  interviews on a reduced schedule, receive individual guidance and  performance feedback, and discuss case-specific issues with the trainers.  In particular, 3 of the 107 trip reports we analyzed covered circuit rides  with in-field training and noted that the in-field training period was  valuable for new officers. For example, one report stated that new  refugee officers benefited greatly from the in-field trainer’s knowledge and  ability to be fully available for training and development. IO officials stated  that they do not require formal in-field training for all new officers. Some  new IO officers receive formal in-field training on RAD circuit rides, while  others on smaller circuit rides may be paired with a more experienced  officer and receive in-field mentoring on their first circuit ride. However,  temporary officers do not receive in-field training.

Although temporary officers receive training prior to participating in circuit  rides, we found that they sometimes face challenges adjudicating refugee  applications. For example, we analyzed the 44 available trip reports  completed from July 2014 through June 2016 from RAD circuit rides that  included temporary officers. In 15 of the 44 reports (about one-third), the  RAD circuit ride supervisors noted that temporary officers faced  challenges adjudicating refugee applications on the circuit ride. For  example, one report indicated that although temporary officers completed the required training and predeparture briefing, they seemed not to have  retained much information. Other reports indicated that temporary officers  stated that they did not feel prepared to conduct some aspects of  administrative and interview processes or that most temporary staff on  the circuit ride only began to grasp the full range of law, policy, and  procedures after 4 to 5 weeks on the circuit ride. One report also noted  that temporary officers required de-facto mentoring on a daily basis.  Further, USCIS headquarters officials and two interviewing officers we  spoke with told us that some temporary officers make more errors than  experienced officers, which contributes to inefficiencies, such as extra  hours worked by supervisors. In addition, one temporary officer we  observed stated that, despite the training she received, she felt  unprepared to adjudicate cases on the first few days of her circuit ride.  According to USCIS officials, all adjudications that are finalized have  been determined by a supervisor to be legally sufficient. Consistent with  USCIS policy, a supervisor is to review each case file and determine that  the officer’s decision on the application is legally sufficient, among other  things, before the decision is finalized. The supervisor may agree with the  officer’s decision, request a reinterview for more information, or overturn  the officer’s decision.

On the basis of their review of trip reports, USCIS headquarters officials  stated that in 2016, they revised the Refugee Processing Overview  training (which is required for temporary officers with recent RAIO  interviewing experience, such as asylum officers) and the predeparture  briefing content (up to 8 days) to include mock interviews and more  practical exercises about the refugee adjudication process. We reviewed  syllabi for the Refugee Processing Overview training and found that the  training increased from 1 day, without mock interviews, in April 2015 to 3  days, with two mock interviews and additional practical exercises about  national security and terrorism-related concerns, in March 2016.  However, unlike RAD officers and IO officers, USCIS has not offered in- field training for temporary officers.

Standards for Internal Control in the Federal Government states that  management should demonstrate a commitment to recruit, develop, and  retain competent individuals. The standards also note that competence is  the qualification to carry out assigned responsibilities, and requires  relevant knowledge, skills, and abilities, which are gained largely from  professional experience, training, and certifications. USCIS officials told us that temporary officers receive a number of accommodations to help  them adjudicate applications—including a reduced ramp-up schedule on  their first days of interviewing and a compilation of frequently used  adjudication tools and guidance—but that USCIS is unable to offer in-field  training to temporary officers due to resource constraints.

In March 2017, RAD officials also stated that they have undertaken  significant hiring efforts in the past year, reducing the need for temporary  officers. IO officials also said IO does not plan to use temporary officers  for the remainder of fiscal year 2017. Nevertheless, interviewing officers,  including temporary officers, play a critical role in the refugee adjudication  process, and USCIS may use temporary officers to meet workload  demands in the future. Some temporary officers have committed to  working on three circuit rides in a 2-year period, and may interview  hundreds of refugee cases over that time frame. Further, while enhancing  training for temporary officers may require additional resources, the lack  of experience and preparation among temporary officers has led to  inefficiencies, as described by some USCIS supervisors. To the extent  that USCIS uses temporary officers on future circuit rides, providing them  with additional training, such as in-field training, would help better prepare  them to interview refugees and adjudicate their applications, increase the  quality and efficiency of their work, and potentially reduce the supervisory  burden on those who oversee temporary officers.

section_title: USCIS Has Resources to Help Officers Identify Applicants with National Security Concerns, but Has Not Documented Plans for Deploying Officers with National Security Expertise on Circuit Rides
paragraphs: In addition to training, USCIS has developed guidance documents and  tools to help officers identify USRAP applicants with potential national  security concerns. However, USCIS could strengthen its efforts by  developing and implementing a plan for deploying officers with national  security expertise on selected circuit rides. USCIS provides a number of  resources to officers to help them identify and address potential national  security-related concerns in USRAP applications. Further, security  check results (provided by interagency vetting partners) may help officers  identify security concerns before the refugee interview. In addition,  USCIS’s national security policies and operating procedures require that  cases with national security concerns be placed on hold by interviewing  officers. These cases are then reviewed by USCIS headquarters staff  who have additional specialized training and expertise in vetting national  security issues. These headquarters staff can clear the hold, deny the  case, or refer the case back to USCIS officers for reinterview with  suggested lines of questioning. Further, RAD maintains training lesson  plans, guidance on particular issues (such as terrorism-related  inadmissibilities), and country conditions information that is accessible to  interviewing officers overseas. As discussed above, USCIS provides the  most up-to-date guidance to interviewing officers during its predeparture  briefings.

While USCIS has training and guidance to adjudicate cases with national  security-related concerns, USCIS trip reports and officers we interviewed  indicated that it can be challenging to adjudicate such applications. About  half of the trip reports we analyzed (52 of 107) identified national security  concerns as a training need for future circuit rides or made policy or  guidance requests regarding national security concerns. Of these 52  reports, 33 were from circuit rides with no temporary officers and 19 were  from circuit rides with a mix of temporary officers and refugee officers. For  example, some trip reports generally noted that officers had difficulty  identifying what applicant characteristics would be considered potential  national security concerns among certain populations being interviewed.  In addition, one trip report stated that officers required repeated  reminders to elicit all of the necessary details that headquarters reviewers  would need to determine whether an applicant posed a national security  concern. Further, one supervisor we spoke with during a site visit stated  that guidance about identifying cases with national security indicators is  ambiguous and, at times, contradictory. Moreover, both RAD and IO  headquarters officials we met with stated that interviewing officers are  hesitant to make decisions regarding cases with national security  concerns, and, as a result, often place cases on hold that are ultimately  determined not to have national security concerns. USCIS officials  identified several reasons why it is challenging to provide training and  guidance on how to adjudicate cases with potential national security  concerns. For example, according to RAD and IO headquarters officials,  indicators of national security concerns and the country conditions that  give rise to them evolve and change; as a result, USCIS guidance on how  to address those concerns also changes over time.

To further help interviewing officers adjudicate cases with national  security concerns, RAD initiated a pilot program in the second and third  quarters of fiscal year 2016, through which it sent headquarters USCIS  Security, Vetting, and Program Integrity (SVPI) unit officers with national  security-related expertise to support interviewing officers on select circuit  rides. During these circuit rides, according to RAD and SVPI officials,  SVPI officers’ tasks included prescreening case files and applications for  national security concerns, flagging those concerns, and recommending  lines of questions for USCIS interviewing officers. During our August 2016  visit to Amman, Jordan, we observed 16 interviews of applicants whose  case files the SVPI officer had prescreened for potential national security- related issues; interviewing officers used notes that the SVPI officer  provided to inform the questions they asked applicants. In some  instances, the SVPI officer stated that he met with the interviewing officer  before the interview to discuss potential questions on issues of national  security concern that the SVPI officer anticipated might arise. Further,  during the interview, the SVPI officer was available for real-time webchats  to answer officers’ questions as they arose.

The SVPI officer, circuit ride supervisor, and interviewing officers we  spoke with in Amman all stated that having SVPI present on the circuit  ride was valuable. For example, one temporary officer, who was on her first circuit ride, stated that she could not imagine resolving cases with  national security concerns without the in-field help of SVPI. USCIS  headquarters officials stated sending an SVPI officer resulted in a  decrease in cases requiring headquarters review, although other factors  also played a role in this decrease. For example, the on-site SVPI officer  was able to resolve some cases with potential national security concerns  in the field and was also able to prioritize cases requiring headquarters’  review due to potential national security concerns.

In December 2016, RAIO and SVPI officials said they had determined  that the SVPI in-field pilot was successful and that they plan to make it a  formal part of select circuit rides in the future. These officials stated that  they plan to continue to send SVPI officers on select circuit rides with  caseloads high in potential national security-related issues, as resources  permit. The officials stated that RAD selects which circuit rides will have  on-site SVPI support based on several factors, including the number of  cases placed on hold for national security-related concerns during  previous circuit rides to certain locations and the availability of SVPI staff.

To increase SVPI’s ability to support circuit rides, in December 2016,  USCIS posted an SVPI job announcement with eight potential vacancies.  The announcement stated that the job may require travel of up to 180  days per year on overseas circuit rides. The USCIS officials told us that,  as of March 2017, they continue to work to fill these positions and are  drafting an SOP that will have guidance about roles and responsibilities  for SVPI officers providing on-site support to RAD circuit rides, which they  intend to finalize later in 2017. As of April 2017, USCIS reported having  filled five of the eight positions. Further, according to USCIS officials,  SVPI initiated a test of the operational aspects of the draft SOP by  deploying a supervisory SVPI officer on a RAD circuit ride in March 2017.  USCIS officials reported in March 2017 that the draft SOP had not yet  undergone a legal review. According to these officials, they expect to  issue the SOP by July 2017. However, USCIS did not provide  documentation or timelines for its plans to expand the use of SVPI  officers on selected circuit rides.

We have previously reported that, in developing new initiatives, agencies  can benefit from following leading practices for strategic planning.  Congress enacted GPRAMA to improve the efficiency and accountability  of federal programs and, among other things, to update the requirement  that federal agencies develop long-term strategic plans that include  agencywide goals and strategies for achieving those goals. The Office  of Management and Budget (OMB) has provided guidance in Circular A- 11 to agencies on how to prepare these plans in accordance with  GPRAMA requirements. We have reported in the past that, taken  together, the strategic planning elements established under GPRA, as  updated by GPRAMA, and associated OMB guidance, along with  practices we have identified, provide a framework of leading practices  that can be used for strategic planning at lower levels within federal  agencies, such as planning for individual divisions, programs, or  initiatives. One of these leading practices is to define strategies and  identify resources needed to achieve goals. Strategies should be  designed to align activities, core processes, and resources to support the  mission. Further, strategies should include milestones as well as a  description of the resources needed to meet established goals.

RAIO officials stated that they plan to deploy SVPI officers on additional  circuit rides in the future. While these plans are a positive step for helping  officers address potential national security concerns on circuit rides,  USCIS has not yet documented these plans or completed an SOP. Given  SVPI’s lack of documentation for future plans and challenges identified by  USCIS staff in adjudicating cases with potential national security  concerns, it is unclear how or when RAIO will fulfill its plans to send  national security experts on circuit rides to support interviewing officers. In  light of the evolving and significant nature of national security concerns,  developing and implementing a plan to deploy additional SVPI officers  with national security expertise on circuit rides—including timeframes for  deployment and how USCIS will select circuit rides for SVPI  deployment—would better ensure that USCIS provides interviewing  officers with the resources needed to efficiently and effectively adjudicate  cases with national security concerns.

section_title: USCIS Has Not Conducted Quality Assurance Assessments of Refugee Adjudications since Fiscal Year 2015 Despite Significant Changes to the Program Since That Time
paragraphs: USCIS has not conducted quality assurance assessments of refugee  adjudications since fiscal year 2015 and has not developed plans for  subsequent assessments, which help ensure that case files are  completed accurately and that decisions by RAD, IO, and temporary  officers are well-documented and legally sufficient. The RAIO Directorate  conducted a quality assurance review of refugee adjudications in fiscal  year 2015. The RAIO Directorate’s 2015 review included a sample of  applications adjudicated by RAD and IO during one quarter of the fiscal  year, which was not representative of all RAD and IO applications for the  fiscal year. The 2015 quality assurance review found that most cases in  the sample were legally sufficient.  However, the review indicated that  there were differences between RAD and IO adjudications. Specifically,  the review rated 69 of 80 RAD case files (86 percent) as good or  excellent, and rated 36 of 73 IO case files (49 percent) as good or  excellent. Two of 80 RAD case files (less than 3 percent) in the review  and 17 of 73 IO case files (23 percent) were rated as not legally  sufficient. According to the assessment, USCIS placed these cases on  hold or requested that RSCs schedule the applicants for reinterview.  Among cases rated not legally sufficient, the most common deficiency  identified was that interviewing officers did not fully develop the interview  record with respect to possible inadmissibilities. Other deficiencies  reported included interview records not being fully developed with respect  to well-founded fear of persecution, improper documentation and analysis  of terrorism-related inadmissibility concerns, incorrect hold determination,  and required sections of the assessment leading to the adjudication  decision that were incomplete. RAIO identified issues related to training  and guidance for IO officers as well as supervisory review that may have  led to these deficiencies.

RAIO developed six high-priority action items to address the identified  deficiencies in the quality assurance review and, as of November 2016,  RAD and IO officials have made progress toward implementing them. For  example, in 2016, IO issued a memorandum with required qualifications  for IO officers who conduct supervisory review of refugee applications  and provided additional guidance on which questions officers must ask  during the interview in specific locations to ensure legal sufficiency. RAD  and IO officials stated that they have taken steps to implement other  action items identified in the 2015 review, such as incorporating more  national security-related research, as appropriate, into the case file  reviews that IO officers complete as part of their circuit ride predeparture  preparation.

RAIO officials stated that they have not completed a quality assurance  review since fiscal year 2015, and, as of March 2017, do not know  whether they will do so in fiscal year 2017. USCIS officials stated that  they did not conduct a review in fiscal year 2016 for two reasons. First, in  fiscal year 2016, RAIO officials stated that they faced resource  constraints because they were focused on hiring and training new staff,  and training and quality assurance are handled by the same team within  RAIO. Second, the officials stated that there was value in allowing time  for the action steps identified after the 2015 review to be implemented before conducting another review to identify if the action steps addressed  the deficiencies noted in the prior review. RAIO officials also stated that  even though they do not yet know whether they will conduct a quality  assessment in fiscal year 2017, supervisors continue to review each  refugee case file for legal sufficiency and completeness at the time of the  interview. While supervisory review is an important quality control step, it  does not position USCIS to identify systematic quality concerns, such as  those identified in the fiscal year 2015 quality assessment results.

USCIS’s January 2015 RAD and IO Roles and Responsibilities with  Respect to Refugee Processing memorandum states that RAD is to  establish quality assurance criteria and design the quality assurance  program for refugee adjudications, in consultation with IO. The 2015  memorandum further states that RAD will conduct quality assurance  reviews of refugee cases adjudicated by temporary officers, IO staff, and  permanent RAD staff. Further, Standards for Internal Control in the  Federal Government states that management should establish and  operate monitoring activities to monitor the internal control system and  evaluate the results. The scope and frequency of evaluations are to  depend on the assessment of risks, effectiveness of ongoing monitoring,  and rate of change within the entity and its environment. In addition,  standard practices for program management state that program quality  should be monitored on a regular basis to provide confidence that the  program will comply with the relevant quality policies and standards.

Although there have been significant changes in the refugee caseload in  the past 2 years (such as the increase in Syrian refugees), an increased  use of temporary staff to conduct refugee adjudications in fiscal year  2016, and the difference in quality between RAD and IO adjudications  noted in the 2015 quality assurance review, USCIS did not conduct  quality reviews in 2016 and has no plans to conduct them in 2017.  Regular quality assurance reviews could help provide USCIS reasonable  assurance that RAD officers, IO officers, and temporary officers are  consistently, accurately, and sufficiently documenting their adjudication  decisions. Conducting regular quality assurance assessments of refugee  adjudications would also provide USCIS officials with key information  about the quality of USCIS refugee adjudications and allow them to  identify any areas where officers face challenges, allowing RAD and IO to  target training or guidance to areas where it may be most needed.

section_title: State and USCIS Have Mechanisms to Help Detect and Prevent Applicant Fraud, but Could Jointly Assess Applicant Fraud Risks
subsections: section_title: State, RSCs, and USCIS Have Implemented Mechanisms to Help Detect and Prevent Fraud Committed by USRAP Applicants
paragraphs: Fraud can occur in the refugee process in a number of ways, and State,  RSCs, and USCIS have implemented certain mechanisms to help detect  and prevent fraud by USRAP applicants. In general, immigration benefit  fraud often involves the willful misrepresentation of material fact for the  purpose of obtaining an immigration benefit, such as refugee status.  Immigration benefit fraud is often facilitated by document and identity  fraud. Document fraud includes forging, counterfeiting, altering, or falsely  making any document, or using, possessing, obtaining, accepting, or  receiving such falsified documents in order to satisfy any requirement of,  or to obtain a benefit under, U.S. law. Identity fraud refers to the  fraudulent use of others’ valid documents. In the context of USRAP,  applicants may attempt to apply for refugee status after having been  denied refugee status or another immigration benefit, such as a visa,  using another identity. Or, applicants may falsely present themselves as a  national of a country eligible for resettlement to gain access to USRAP.  Further, applicants may present false marriage claims or attempt to  include unrelated children on their case. USCIS officers can encounter  indicators of fraud while adjudicating refugee applications, and State has  suspended USRAP programs in the past because of fraud. Examples  include the following:

Of the 107 RAD circuit ride trip reports we analyzed, 30 reports  identified instances in which officers denied applications for fraud or  misrepresentation. According to an SVPI official, applications with  indicators of fraud may also be denied on other grounds, such as  ineligibility, inadmissibility, and security check results, among others.

In 2008, State suspended the P3 program, a family reunification  program between a family member in the United States and the  refugee applicant, because of widespread fraud, as discussed below.

In 2015, State suspended a P2 program after discovering that two  individuals who had been approved as refugees and admitted to the  United States had submitted fraudulent documents gain access to  USRAP. During the suspension period from March to December  2015, State and RSC officials reviewed all cases that they were  processing for this P2 program. According to State officials, this  review found additional applicants with fraudulent documents.

State, RSCs, and USCIS have put mechanisms in place to help detect  and prevent fraud by USRAP applicants.

State. State has guidance intended to help RSC staff identify fraudulent  refugee applicants, and State has strengthened access controls for some  refugee applicants. For example, State SOPs require that, when entering  a new case into WRAPS for prescreening, RSC staff verify that a  duplicate record does not already exist in WRAPS for the applicants.  According to State SOPs, one of the purposes of this step is to identify  individuals who attempt to fraudulently access USRAP. RSC officials at  all four locations we visited stated that they complete this procedure and  our analysis of WRAPS data showed that RSCs have identified duplicate  applicant records. State has also strengthened its controls for granting  access to USRAP for some groups of refugee applicants. For example,  after suspending the P3 program due to fraud in 2008, State restarted the  P3 program in 2012 with additional controls in place, including a  requirement for DNA testing for all claimed parent and child biological  relationships. In addition, when State initiated the P2 Central American  Minors program in 2014—which, like the P3 program, requires a familial  relationship between someone residing in the United States and the  refugee applicant—State instituted a requirement for DNA testing of all  claimed biological relationships between the qualifying child and the  qualifying parent.  Further, after finding fraud in 2015 in a P2 program,  as discussed above, State strengthened the mechanism for verifying  access to USRAP.

RSCs. RSCs have also implemented a variety of controls to help detect  and prevent fraud among refugee applicants to USRAP. For example,  according to all nine RSC directors, each RSC has a designated anti- fraud official or entity, consistent with GAO’s Fraud Risk Framework.  Officials at all nine RSCs stated that they provide staff with training or  information on applicant fraud trends. Further, RSC officials in two RSCs  stated that they conduct their own research to detect potential applicant  fraud. In addition, two of the four RSCs we visited conduct two  prescreening interviews for each applicant rather than one. According to  RSC officials, conducting more than one interview serves as a fraud  deterrent because it allows the RSC staff to check for consistency across  interviews and identify false information. Further, these RSCs require,  where possible, that different interpreters participate in each interview to  decrease the likelihood that applicants collude with interpreters.

USCIS. Within USCIS, SVPI and adjudicators are responsible for  antifraud activities related to the adjudication of the refugee application.  USCIS has implemented a number of control activities to detect and  prevent refugee applicant fraud. Through biometric checks, USCIS may  identify that a USRAP applicant has multiple identities. According to SVPI  officials, SVPI analyzes the results of the checks, identifies fraud  indicators, and may complete a fraud referral so that the applicant can be  interviewed or re-interviewed by an officer overseas to address the fraud  concern. SVPI also receives fraud referrals from other sources, such as  refugee officers and the RSCs, although SVPI officials stated that the number of such referrals is small. USCIS officials stated that, in many  instances, interviewing officers deny an application with indicators of  fraud on other grounds, which does not require the involvement of SVPI  or a fraud referral. Interviewing officers may also place a case with  indicators of fraud on hold for additional SVPI research. According to  USCIS officials and training materials that we reviewed, USCIS officers  who adjudicate refugee applications receive training in identifying fraud  and processing cases with fraud indicators during basic training and  predeparture briefings. We observed discussions about fraud trends at  three of the four predeparture briefings that we attended.

Additionally, the RAD trip report guide states that supervisors are to  document any suspected fraud trends from the circuit ride, including how  the fraud trend was identified, any actions taken in response to the trend,  whether the trend was expected to continue, and examples of any  suspected fraud. Of the 107 trip reports we analyzed, 72 contained  information about applicant fraud or fraud trends. The information varied,  ranging from detailed descriptions of individual cases denied due to  misrepresentation or fraud to a more general description of potential fraud  trends in certain populations, such as a lack of reliable marriage  documentation. The remaining 35 reports stated that there were no fraud  trends or left the section of the report about fraud trends blank, which  indicates that the author of the trip report did not identify fraud trends on  the circuit ride.

section_title: State and USCIS Have Not Jointly Assessed Applicant Fraud Risks Across USRAP
paragraphs: State and USCIS have not jointly assessed applicant fraud risks across  USRAP. Our Fraud Risk Framework calls for program managers to plan  and conduct regular fraud risk assessments. According to our Fraud Risk  Framework, there is no universally accepted approach for conducting  fraud risk assessments, since circumstances among programs vary;  however, assessing fraud risks generally involves five actions: (1)  identifying inherent fraud risks affecting the program, (2) assessing the  likelihood and impact of those fraud risks, (3) determining fraud risk  tolerance, (4) examining the suitability of existing fraud controls and  prioritizing residual fraud risks, and (5) documenting the program’s fraud  risk profile. The framework provides managers with flexibility in deciding  whether to carry out this and other aspects of fraud risk management at  the program or agency level. In addition, Standards for Internal Control in  the Federal Government states that management should consider the  potential for fraud when identifying, analyzing, and responding to risks,  and analyze and respond to identified fraud risks, through a risk analysis  process, so that they are effectively mitigated.

Although State and USCIS perform a number of fraud risk management  activities and have responded to individual instances of applicant fraud,  these efforts do not position State and USCIS to assess fraud risks  program-wide for USRAP or know if their controls are appropriately  targeted to the areas of highest risk in the program. State and USCIS  officials told us that each agency has discrete areas of responsibility in  the refugee admissions process, and each agency’s antifraud activities  are largely directed at their portions of the process. State is responsible  for managing USRAP at a programmatic level and, according to State  officials, State has responded to instances of fraud in USRAP. State  officials said that they have not conducted an assessment of the risks  associated with applications to USRAP because, according to these  officials, such an assessment is USCIS’s responsibility. However, USCIS  officials told us that SVPI—USCIS’s antifraud entity for refugee applicant  fraud—only has authority over antifraud activities related to the  adjudication of the refugee application, including security checks. USCIS  officials stated that they are not responsible for, and do not have the  authority to respond to, applicant fraud program-wide in USRAP, although  they coordinate with State when fraud is brought to the attention of SVPI.  As of March 2017, SVPI has a draft Fraud Process SOP, which identifies  three main types of applicant fraud in USRAP—individuals who are using  multiple identities; individuals who are claiming false family composition,  such as marriage fraud; and individuals who are claiming a false country  of nationality. In addition, the draft SOP identifies the main sources by  which USCIS detects fraud in the USRAP application process—results  from biometric checks and testimony and evidence from the USRAP  applicant. However, USCIS and State have not jointly conducted a fraud  risk assessment of the risks associated with applications to USRAP or  determined a fraud risk tolerance for the program.

Because the management of USRAP involves several agencies, without  jointly and regularly assessing applicant fraud risks and determining the  fraud risk tolerance of the entirety of USRAP, in accordance with leading  practices, State and USCIS do not have comprehensive information on  the inherent fraud risks that may affect the integrity of the refugee  application process and therefore do not have reasonable assurance that  State, USCIS, and other program partners have implemented controls to  mitigate those risks. Moreover, regularly assessing applicant fraud risks  program-wide could help State and USCIS ensure that fraud prevention  and detection efforts across USRAP are targeted to those areas that are  of highest risk, in accordance with the program’s fraud risk tolerance.

section_title: Conclusions
paragraphs: Screening and adjudicating refugee applicants and applications are  challenging tasks that involve entities across the U.S. government. RSCs  have an important role in the refugee admissions process because they  collect applicants’ information and conduct in-person prescreening  interviews that USCIS officers use to help determine applicants’ eligibility  and credibility. Developing outcome-based performance indicators, as  required by State policy and performance management guidance, and  monitoring RSC performance against such indicators on a regular basis,  would better position State to determine whether RSCs are processing  refugee applications in accordance with their responsibilities under  USRAP.

In addition, adjudicating refugee applications can be challenging. During a  face-to-face interview, USCIS officers must, among other things,  determine if the applicant meets the definition of a refugee; is  inadmissible because of, for example, national security concerns or  criminal activities; and is credible. Further, indicators of national security  concerns (and the country conditions that give rise to them) evolve and  change. To the extent that USCIS uses temporary officers on future  circuit rides, providing them with additional training, such as in-field  training, would help better prepare them to interview refugees and  adjudicate their applications, increase the quality and efficiency of their  work, and potentially reduce the supervisory burden on those who  oversee temporary officers. Moreover, developing and implementing a  plan to deploy additional USCIS SVPI officers with national security  expertise on select circuit rides would better ensure that USCIS provides  interviewing officers with the resources needed to efficiently and  effectively adjudicate cases with national security concerns. In addition,  conducting regular quality assurance assessments of refugee  adjudications would also provide USCIS officials with key information  about the quality of USCIS refugee adjudications and allow them to  identify any areas where officers face challenges, allowing RAD and IO to  target training or guidance to areas where it may be most needed.

Given that USCIS officers encounter indicators of fraud while adjudicating  refugee applications and fraud has occurred in USRAP programs in the  past, it is important that USCIS and State implement leading practices to  combat fraud. Without jointly and regularly assessing applicant fraud risks  and determining the fraud risk tolerance of USRAP, in accordance with  leading practices, State and USCIS do not have comprehensive  information on the inherent fraud risks that may affect the integrity of the  refugee application process. Moreover, regularly assessing applicant  fraud risks program-wide could help State and USCIS ensure that fraud  prevention and detection efforts across USRAP are targeted to those  areas that are of highest risk.

section_title: Recommendations for Executive Action
paragraphs: To better assess whether RSCs are meeting USRAP objectives, the  Assistant Secretary of State for Population, Refugees, and Migration  should take the following two actions: develop outcome-based indicators, as required by State policy; and monitor RSC performance against such indicators on a regular basis.

To better ensure that USCIS officers effectively adjudicate applications for  refugee status, the Director of USCIS should take the following three  actions: provide additional training, such as infield training, for any temporary  officers who adjudicate refugee applications on future circuit rides; develop and implement a plan to deploy officers with national security  expertise on circuit rides; and  conduct regular quality assurance assessments of refugee application  adjudications across RAD and IO.

To provide reasonable assurance that USRAP applicant fraud prevention  and detection controls are adequate and effectively implemented, we  recommend that the Secretaries of Homeland Security and State conduct  regular joint assessments of applicant fraud risk across USRAP.

section_title: Agency Comments
paragraphs: We provided a draft of the sensitive version of this report to the  Departments of Homeland Security, State, Defense, and Justice, as well  as the Office of Director of National Intelligence, for their review and  comment. State and DHS provided written comments stating that they  concurred with our recommendations, which are reproduced in full in  appendixes III and IV, respectively. In emails, a Director in the Office of  the Under Secretary of Defense for Policy at the Departments of Defense  and the Legislative Liaison Officer at the Office of Director of National  Intelligence stated that these agencies did not have any written  comments on our draft report. State, DHS, the Department of Justice, and  the FBI provided technical comments, which we incorporated as  appropriate.

We are sending copies of this report to interested congressional  committees; the Secretaries of Homeland Security, State, and Defense;  the Attorney General of the United States; and, the Director for National  Intelligence. In addition, the report is available at no charge on the GAO  website at http://gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-8777 or gamblerr@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Key contributors to this report are listed in  appendix V.

section_title: Appendix I: Central American Minors Program
paragraphs: The Central American Minors (CAM) Program was established in  November 2014 to promote safe, legal, and orderly migration of certain  vulnerable children to the United States and began accepting applications  on December 1, 2014. This family reunification program aims to deter  children from El Salvador, Guatemala, and Honduras from undertaking a  risky journey in an attempt to be reunited with a parent residing in the  United States. CAM allows certain parents to request access to the U.S.  Refugee Admissions Program (USRAP) for their children who are  nationals of one of these three countries and are outside of the United  States. Children who are found ineligible for admission as a refugee  under USRAP but still at risk of harm may be considered for parole—in  general a mechanism by which an individual not otherwise admitted to the  United States may be permitted entry into the country on a temporary  basis. CAM is jointly run by the Department of State’s (State) Bureau of  Population, Refugees, and Migration and the Department of Homeland  Security’s (DHS) U.S. Citizenship and Immigration Services (USCIS).
subsections: section_title: Requirements for Program Access
paragraphs: To participate in CAM, both parent and child must meet certain qualifying  criteria. Among other criteria, a qualifying parent must be 18 years of age  and lawfully present within the United States at the time of application and  at the time of admission or parole of the beneficiary (e.g., a qualifying  child) to the United States. The qualifying child must be a biological,  step, or legally adopted child of the qualifying parent; unmarried; under  the age of 21 at the time the qualifying parent initiates the process; and a  national of El Salvador, Guatemala, or Honduras. Other family members  of the child who meet certain criteria are also eligible to be part of the  qualifying child’s application. For example, an accompanying parent who  is the legal spouse of the U.S.-based qualifying parent may be eligible to  travel with the qualifying child. However, the accompanying parent cannot  derive his or her refugee status from the qualifying child and therefore  must independently establish that he or she qualifies as a refugee. In July  2016 State and DHS announced that CAM would expand to include  additional eligible family members, when accompanied by a qualifying  child—(1) the children, regardless of age or marital status, of a U.S.- based qualifying parent; (2) the biological parent of a qualifying child who  is not legally married to the U.S.-based lawfully present parent; and (3)  the caregiver of a qualifying child who is related to either the U.S.-based  lawfully present parent or the qualifying child. State began accepting  applications that included these additional family members in November  2016.

section_title: Application, Interview, and Screening Process
paragraphs: As shown in figure 8, a qualifying parent initiates the CAM application  process in the United States by completing a form (DS-7699, or “Affidavit  of Relationship” (AOR)) with the help of a resettlement agency—a State- funded entity that provides support services to refugees once they arrive  within the United States.

The qualifying parent files an AOR with the assistance of a designated  resettlement agency, which forwards the AOR to State. State is to  conduct a preliminary review of the AOR for completeness, including a  check that the qualifying parent has provided proof of his or her lawful  status, and then provide the case to Resettlement Support Center (RSC)  staff. RSC staff are to prescreen the qualifying children according to the  standard operating procedures for all USRAP applicants. Shortly after  prescreening, RSCs are to collect the child’s DNA to confirm biological  relationships between the parent and the qualifying child. State has  established policies and procedures specifically for the collection and  processing of DNA samples from the qualifying child. We observed RSC  staff taking 5 separate DNA samples at the RSC Latin America San  Salvador office, during which staff adhered to the established standard  operating procedures for DNA collection. Separately, within the United  States, State is to notify the parent in the United States to provide DNA  samples to a U.S.-based, accredited lab to confirm the biological  relationship with his or her claimed child or children. The parent must also  cover the costs associated with the DNA testing, but State is to reimburse  the costs of the tests if all the claimed biological relationships are  supported by the DNA evidence, even if the beneficiary is not ultimately  admitted as a refugee or paroled to the United States. The U.S.-based lab  reports the results of DNA testing for all cases to State, which then  uploads the results into the Worldwide Refugee Admissions Processing  System for viewing by USCIS. Although USCIS does not require DNA  testing for other eligible family members included on applications (e.g.,  the children of the qualifying child or the siblings of the qualifying child  who are not biologically related to the U.S.-based parent)—citing, among  other factors, concerns over the reliability of such testing between, for  example, siblings—USCIS officials stated that additional DNA testing will  occur for new CAM categories announced in July 2016.

After prescreening, but before USCIS interviews the child, USCIS’s  Refugee Access Verification Unit (RAVU) is to, among other things, take  steps to confirm the parent’s lawful status and to review the results of  DNA testing, if available. According to USCIS procedures, if RAVU  cannot confirm the parent’s status or DNA testing results do not confirm  the relationship, USCIS will generally reject the application. According to  State data, USCIS rejected or disqualified about 600 (5 percent) of the  approximate 12,000 CAM AORs submitted from December 2014 through  March 2017. USCIS generally adjudicates CAM applicants as they do all  other USRAP applicants. However, according to USCIS policy, and  consistent with characteristics of the targeted populations and stated  objectives of the program, USCIS officials stated that CAM applicants  undergo additional vetting for potential gang affiliations in cases with such indicators. If USCIS concludes that such an applicant is not eligible for  admission as a refugee, the applicant may be considered for parole.

Vetting CAM applicants for potential gang affiliation. USCIS policy  requires that officers place CAM applications on hold if gang affiliation  indicators exist. As with all USRAP applicants, CAM program applicants  are inadmissible to the United States as refugees if USCIS officers find  them to be persecutors of others, have committed certain crimes, or be a  threat to the security of the United States, among other things. Consistent  with USCIS policy, USCIS officers may place a case on hold to do  additional research or investigation if the officer determines that the  applicant or other case members may be inadmissible due to information  provided during the interview (e.g., the applicant has a known or  suspected gang affiliation). For example, to further review CAM  applications from Salvadoran applicants identified by USCIS interviewers  as having indicators of possible gang affiliation during the USCIS  interview, USCIS staff are to contact the Federal Bureau of Investigation  (FBI). For CAM applicants in El Salvador, FBI agents stationed in San  Salvador are to coordinate with the government of El Salvador in sharing  investigative information on gangs. According to FBI officials, if the FBI  has any information on the CAM program applicant and potential gang  affiliations, they are to forward the information to USCIS officials, who  determine whether the information renders the applicant ineligible for the  program. FBI officials in San Salvador said that they receive 6 to 10  requests per month from USCIS for any available information related to  CAM program applicants. From December 2014 through March 2017,  USCIS officers had placed about 14 percent of CAM applicants they  interviewed on hold, and in most cases, according to State data, the hold  was for USCIS’s headquarters’ review of possible gang affiliations.

Parole. CAM program applicants found by USCIS to be ineligible for  refugee status in the United States are to be considered on a case-by- case basis for parole, which is a mechanism to allow someone who is  otherwise inadmissible to enter the United States on a temporary basis  for urgent humanitarian reasons or significant public benefit. USCIS  procedures require that, to support an authorization of parole, the  qualifying child must assert to the USCIS officer during the interview that  he or she has a fear of being harmed, and the objective evidence must  demonstrate that the child would face a reasonable possibility of harm if  he or she remains in their home country. The interviewing officer has  discretion to conditionally approve parole, after consideration of the entire  record, and several factors—such as the outcome of the security checks  or derogatory information (which may include involvement in gangs or  other criminal activity)—could lead to a denial of parole. The final decision  regarding parole is made by a USCIS officer after review of medical exam  results and an additional review of security checks. Once in the United  States a parolee, unlike a refugee, is not considered to have been  admitted into the country, has not been conferred a lawful immigration  status, and does not have the benefit of a pathway to U.S. citizenship.  Parole under CAM may be authorized for a period of up to 2 years and  parolees are to file their request for re-parole no later than 90 days before  the expiration of their authorized parole. Parolees may also apply for  employment authorization but the extent to which they may be eligible for  other public benefits is determined in accordance with U.S. law.

section_title: Outcomes for CAM Program Applications Submitted from December 2014 through March 2017
paragraphs: Parole has been the most common outcome of CAM program  applications, but a lower percentage of parolees have arrived in the  United States than those granted refugee status through the program.  From December 2014, when the program began accepting AORs,  through March 2017, USCIS received AORs for about 12,100 individuals.  Most of the AORs submitted were for applicants from El Salvador (86  percent). USCIS had made final decisions on half (6,300) of these  applicants, approving 70 percent for parole and granting 29 percent  refugee status. According to USCIS officials, more CAM cases receive  parole because the generalized violence that applicants experience does  not rise to the level of persecution or is not on account of a protected  characteristic required to support a refugee determination. However, the  officials noted that the conditions in El Salvador, Guatemala, and  Honduras, and the fact that the children are living without at least one  parent in their country of origin are generally sufficient to demonstrate the  fear of harm required to support a parole determination. USCIS officers  determined that the remaining 1 percent of applicants did not qualify for  refugee status or parole and denied the associated cases. However, a  higher percentage of CAM applicants who had received refugee status  had arrived in the United States, as of March 2017. Program data on  applications submitted from December 2014 through March 2017 show  that 63 percent (about 1,100) of all CAM-approved refugees and 33  percent (about 1,500) of CAM approved parolees had traveled to the  United States. Parolees must finance their travel to the United States and  do not receive benefits upon arrival, circumstances that, according to  State officials, most likely account for the difference in CAM refugee and  parolee arrivals. Refugees have access to travel loans, and must sign a  promissory note to assume responsibility for repaying the cost of travel to  the United States. Parolees are also responsible for paying for the costs  of medical exams.

section_title: Appendix II: Summary of United States Refugee Admissions Program Priority Categories
paragraphs: The U.S. Refugee Admissions Program (USRAP) provides refugees who  are of special humanitarian concern from around the world with  opportunities for resettlement in the United States. The Departments of  State (State) and Homeland Security (DHS) have joint responsibility for  the admission of refugees to the United States. Specifically, State’s  Bureau of Population, Refugees, and Migration coordinates and manages  USRAP and makes decisions, along with DHS’s U.S. Citizenship and  Immigration Services (USCIS), on which individuals around the world are  eligible to apply for refugee status in the United States. Nine State-funded  Resettlement Support Centers (RSCs) with distinct geographic areas of  responsibility communicate directly with applicants to process their  applications, collect their information, conduct a prescreening interview,  and prepare applications for adjudication by USCIS. State and its  partners—including USCIS—make initial determinations about whether  an individual will be accepted into or excluded from USRAP (referred to  as program “access”) for subsequent screening and interview by USCIS  officers. State has identified three categories of individuals who are of  special humanitarian concern and, therefore, can qualify for access to  USRAP—Priority 1, Priority 2, and Priority 3. Table 2 describes these  priority categories—including the multiple programs that comprise the  Priority 2 category—and how State applicants within these priorities gain  access to USRAP.

section_title: Appendix III: Comments from the Department of State

section_title: Appendix IV: Comments from the Department of Homeland Security

section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Kathryn Bernet (Assistant  Director), David Alexander, Mona Nichols Blake, Eric Erdman, Cynthia  Grant, Brian Hackney, Paul Hobart, Eric Hauswirth, Susan Hsu, Thomas  Lombardi, Mike McKemey, Erin McLaughlin, Thomas Melito, Clair  Peachey, Mary Pitts, Elizabeth Repko, Judith Williams, and Su Jin Yon  made significant contributions to this report.


Question-summary annotations: questions: question: What refugees were admitted to the US from FY2011-2016?
answer: From fiscal year 2011 through June 2016, the U.S. Refugee Admission Program (USRAP) received about 655,000 applications and referrals—with most referrals coming from the United Nations High Commissioner for Refugees—and approximately 227,000 applicants were admitted to the United States (see figure).
child_questions: question: What countries were the majority of refugees fleeing from?
answer: More than 75 percent of the applications and referrals were from refugees fleeing six countries—Iraq, Burma, Syria, Somalia, the Democratic Republic of Congo, and Bhutan.

question: What were the Resettlement Support Centers (RSC) funded for?
answer: Nine Department of State- (State) funded Resettlement Support Centers (RSC) located abroad process applications by conducting prescreening interviews and initiating security checks, among other activities.
child_questions: question: What is this information used for?
answer: Such information is subsequently used by the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS), which conducts in-person interviews with applicants and assesses eligibility for refugee status to determine whether to approve or deny them for resettlement.

questions: question: What measures exist for processing refugees?
answer: State and RSCs have policies and procedures for processing refugee applications, but State has not established outcome based-performance measures.

question: What requirements does the State's USRAP Overseas Processing Manual include?
answer: For example, State's USRAP Overseas Processing Manual includes requirements for information RSCs should collect when prescreening applicants and initiating national security checks, among other things.
child_questions: question: How does the RSC adhere to these requirements?
answer: GAO observed 27 prescreening interviews conducted by RSC caseworkers in four countries and found that they generally adhered to State requirements.

question: How does State monitor RSCs?
answer: Further, State has control activities in place to monitor how RSCs implement policies and procedures.
child_questions: question: What does State's monitoring lack?
answer: However, State has not established outcome-based performance indicators for key activities—such as prescreening applicants and accurate case file preparation—or monitored RSC performance consistently across such indicators.

question: Why would better performance indicators be better?
answer: Developing outcome-based performance indicators, and monitoring RSC performance against such indicators on a regular basis, would better position State to determine whether RSCs are processing refugee applications in accordance with their responsibilities.

questions: question: What USCIS policies and procedures for adjudicating applications exist?
answer: USCIS has policies and procedures for adjudicating applications—including how its officers are to conduct interviews, review case files, and make decisions on refugee applications—but could improve training, the process for adjudicating applicants with national security concerns, and quality assurance assessments.
child_questions: question: What did USCIS provide for their process?
answer: For example, USCIS has developed an assessment tool that officers are to use when interviewing applicants.

question: How did officers perform their interviews by GAO review?
answer: GAO observed 29 USCIS interviews and found that officers completed all parts of the assessment.

question: How could the USCIS improve their officer training?
answer: USCIS also provides specialized training to all officers who adjudicate applications abroad, but could provide additional training for officers who work on a temporary basis, which would better prepare them to adjudicate applications.

question: How does USCIS assist officers with nation security concerns?
answer: In addition, USCIS provides guidance to help officers identify national security concerns in applications and has taken steps to address challenges with adjudicating such cases.
child_questions: question: What pilot was performed to assist this?
answer: For example, in 2016, USCIS completed a pilot that included sending officers with national security expertise overseas to support interviewing officers in some locations.
child_questions: question: How did the USCIS rate their performance?
answer: USCIS determined the pilot was successful and has taken steps to formalize it.

question: How should the USCIS advance this pilot?
answer: However, USCIS has not developed and implemented a plan for deploying these additional officers, whose expertise could help improve the efficiency and effectiveness of the adjudication process.

question: What federal internal control standards does the USCIS violate?
answer: Further, USCIS does not conduct regular quality assurance assessments of refugee adjudications, consistent with federal internal control standards.
child_questions: question: How would meeting these standards assist the USCIS?
answer: Conducting regular assessments of refugee adjudications would allow USCIS to target training or guidance to areas of most need.

questions: question: How do the State and USCIS prevent fraud?
answer: State and USCIS have mechanisms in place to detect and prevent applicant fraud in USRAP, such as requiring DNA testing for certain applicants, but have not jointly assessed applicant fraud risks program-wide.
child_questions: question: What is included as fraud?
answer: Applicant fraud may include document and identity fraud, among other things.

question: When is fraud encountered?
answer: USCIS officers can encounter indicators of fraud while adjudicating refugee applications, and fraud has occurred in USRAP programs in the past.

question: How could assessment of applicant fraud risks program-wide be useful?
answer: Because the management of USRAP involves several agencies, jointly and regularly assessing fraud risks program-wide, consistent with leading fraud risk management practices and federal internal control standards, could help State and USCIS ensure that fraud detection and prevention efforts across USRAP are targeted to those areas that are of highest risk.