The Homeland Security Act of 2002 established the Department of Homeland Security (DHS) and gave it responsibility for visa policy. Section 428 of the act also authorized DHS to immediately assign personnel to Saudi Arabia to review all visa applications prior to final adjudication, as well as the future assignment of officers to other locations overseas to review visa applications. In August 2003, DHS created the Office of International Enforcement within the Border and Transportation Security Directorate, to implement these requirements. In the same month, four temporary DHS officers were deployed to Saudi Arabia to begin reviewing all visa applications. In September 2003, DHS and State signed a Memorandum of Understanding to govern the implementation of section 428. This agreement broadly defines the DHS officers' responsibilities in reviewing visa applications, indicating, in particular, that they will provide expert advice to consular officers regarding specific security threats relating to visa adjudication, specifically by gathering and reviewing intelligence relevant to visa adjudication and providing training to consular officers on terrorist threats and detecting applicant fraud; review applications on their own initiative or at the request of consular officers, and provide input on or recommend security advisory opinion requests; and conduct investigations on consular matters under the jurisdiction of the Secretary of Homeland Security. Several other agencies stationed overseas have roles in the visa adjudication process. For example, the State Department Diplomatic Security Bureau's regional security officers assist the consular section by investigating passport and visa fraud detected through the consular officers' reviews of visa applications and supporting documents. In addition, officials from the Federal Bureau of Investigation overseas can assist consular officers when questions about an applicant's potential criminal history arise during adjudication. DHS's Bureaus of Citizenship and Immigration Services and Customs and Border Protection have responsibility for some immigration and border security programs overseas. For example, consular officers may seek advice from these officials on issues such as DHS procedures at U.S. ports of entry. In October 2003, DHS designated its Bureau of Immigration and Customs Enforcement (ICE) to handle the operational and policy-making responsibilities outlined in section 428 (e) and (i). Subsequently, ICE created an office to oversee the Visa Security Program. Since the assignment of VSOs to Saudi Arabia in 2003 until May 2005, DHS has spent about $4 million for Visa Security Program operations at headquarters and overseas, of which approximately $2 million was spent on operations in Saudi Arabia. Figure 1 provides a timeline for the establishment and implementation of the visa security program. In August 2004, the DHS Office of Inspector General reported on the planning and implementation of the VSOs' activities in Saudi Arabia. The report was based on observations beginning in July 2003, at which time DHS was in the early stages of designing the Visa Security Program. (DHS officers did not arrive in Saudi Arabia until August 31, 2003.) According to the Inspector General, DHS operations at the time of the review were not as efficient or effective as they could be due to the use of temporary officers in Saudi Arabia, a lack of specialized training and foreign language proficiency, and the lack of a clear plan for the VSOs. The Inspector General recommended that DHS hire permanent officers, develop a visa security training program, and establish criteria for selecting VSOs. According to the Inspector General's office, DHS has taken steps to implement these recommendations, but as of July 8, 2005, six remain open. According to embassy officials in Saudi Arabia and DHS officials, the VSOs enhance homeland security through their review of visa applications at posts in Saudi Arabia. However, several factors have hindered the program, including a lack of comprehensive data on the VSOs' activities and results in Riyadh and Jeddah to demonstrate the program's overall impact at these posts. VSOs in Saudi Arabia provide an additional law enforcement capability to the visa adjudication process. VSOs have access to and experience using important law enforcement information not readily available to consular officers. Moreover, VSOs' border security and immigration experience can assist consular officers during the visa process. According to State Department consular officers, the deputy chief of mission, and DHS officials, VSOs in Saudi Arabia enhance the security of the visa adjudication process at these consular posts. In particular, the consular sections in Riyadh and Jeddah have incorporated the VSOs' review of all visa applications into the adjudication process (see fig. 2). After consular officers interview an applicant and review the relevant supporting documentation, they make a preliminary determination about whether to issue or refuse the visa or refer the case to Washington for additional security clearances. Consular officers may consult with VSOs during this initial determination. According to the VSOs, within 24 hours of this initial determination by consular officers, they review the application and inspect the applicant's documentation for evidence of fraud or misrepresentation, indicators of potential national security risks, criminal activity, and potential illegal immigration risks. VSOs may also query the applicant's information against a number of law enforcement, immigration, and other databases, which may contain more detail than the consular officers' name check results. Based on these reviews, the VSOs will either affirm or oppose the consular officer's original decision, and the consular officer then decides to issue or deny the visa. If the consular section chief and the VSOs disagree on a case, it is sent to DHS, where the Secretary of Homeland Security, in consultation with State officials, will render a final determination. According to a consular official in Saudi Arabia at the time of our visit in February 2005, no case has ever been sent back to Washington for such a decision. In addition to reviewing applications, the VSOs may conduct secondary interviews with some visa applicants based either on findings from their application reviews or a consular officer's request. For example, DHS officials in Riyadh reported that the VSOs, in cooperation with intelligence officials at post, interviewed an applicant who had ties to an organization of national security concern to the U.S. government. This individual was denied a visa after the interview based upon the VSO's determination of the potential threat the individual posed to the United States. We also observed the VSOs conduct a secondary interview with an applicant they had identified as a concern through their physical review of the visa application. VSOs have access to and experience using immigration and law enforcement databases not readily available to consular officers, who are not classified as criminal justice, or law enforcement, personnel. Consular officers rely on information contained in the Consular Lookout and Support System (CLASS) to adjudicate a visa. As law enforcement agents, the VSOs can access detailed criminal history records and immigration information not included in CLASS. For example, the VSOs have access to criminal history records contained in the National Crime Information Center's Interstate Identification Index, which cannot be directly accessed by consular officers. The VSOs also use databases containing information on employers and businesses, hotel reservation information, and sponsors of applicants seeking temporary work visas. They can use these databases to verify, for instance, an applicant's claim to be working for a particular business. Consular officials at headquarters and in the field believe this data would be useful to them in the adjudication process, particularly at the other posts worldwide that do not have VSOs. Indeed, consular officials in Washington indicated that they are working with DHS to gain access to these databases. In Riyadh, we observed a VSO assist a consular officer review a potential "hit" in CLASS for an applicant in Riyadh. The applicant claimed that, during a trip to the United States, border inspectors refused him entry to the country even though he had a valid visa. At the consular officer's request, we observed the VSO search a database and inform the consular officer that the applicant at the window had been placed on the "No-Fly" list--information that was not specified in CLASS--since the issuance of the initial visa and was therefore ineligible for another visa. In addition, the VSOs in Riyadh conduct searches on applicants' names prior to their interviews with consular officers and provide more detailed information on potential matches obtained from these searches of law enforcement databases. Consular officers indicated that this practice helps them tailor their questioning of applicants. Furthermore, the VSOs in Saudi Arabia interact with consular officers on a real-time basis. We observed consular officers ask the VSOs for assistance during interviews, for example, to clarify questions pertaining to potential criminal hits in CLASS. By contrast, in other embassies, consular officers must request additional information from other DHS overseas offices or from Washington. According to DHS, the VSOs' law enforcement experience and training and knowledge of immigration law enables them to more effectively identify applicants who are potential threats to U.S. national security, as well as identify potentially fraudulent documents submitted by applicants. Since the Inspector General's report in 2004, DHS has developed criteria for selecting VSOs, which includes certain levels of law enforcement and counterterrorism experience, as well as knowledge of immigration law and experience working overseas. In addition, VSOs have experience and training in detecting fraudulent documents. The Memorandum of Understanding between State and DHS states that VSOs at consular posts will provide antifraud training to consular officers, among other things. This training is particularly useful given that State does not have full-time fraud prevention officers at all of its consular posts overseas, with antifraud duties often performed by junior officers on a part-time basis. Indeed, at all but one of the posts that have or plan to have VSOs, consular officers served as part-time fraud prevention officers in addition to their other duties in the consular section. Therefore, the VSOs' experience in this area can be valuable to consular sections. The deputy chief of mission, consular officers, and VSOs in Saudi Arabia indicated that the VSOs have positively impacted visa operations; however, several issues raise concerns about the role and impact of these officers. These include (1) the use of temporary duty employees, which can limit the impact of the VSOs in Saudi Arabia; (2) the lack of Arabic language proficient officers; (3) the requirement that the officers review all visa applications, which limits their time to perform other valuable tasks; and (4) the lack of measurable data on the VSOs' activities, which would demonstrate their impact on the visa process. From August 31, 2003, through June 2005, DHS assigned temporary duty VSOs to Saudi Arabia for tours that varied in length between about 2 and 15 months, for an average assignment of about 7 months. According to the deputy chief of mission in Saudi Arabia, the use of temporary VSOs led to a lack of continuity in visa security operations, and, as a result, the VSOs initially were not able to significantly impact the visa process at post. The constant turnover of officers can hinder the development of institutional knowledge and overall visa security efforts. However, the deputy chief of mission indicated that each subsequent temporary officer improved operations in Saudi Arabia and enhanced security of the visa adjudication process. DHS acknowledged that the reliance on temporary detailed staff is not ideal for the continuity of operations and the ongoing development of the Visa Security Program. DHS officials believe that they have addressed the situation as DHS has hired and trained four permanent employees who were deployed to Saudi Arabia in June 2005, and will be assigned for a 12-month tour. Most of the VSOs stationed in Saudi Arabia since 2003 have not been proficient Arabic speakers and, according to DHS, two of the four new permanent staff assigned to Saudi Arabia speak Arabic. Additionally, consuls general at three of the locations chosen for expansion told us language proficiency would be beneficial at their posts, particularly for interviewing applicants and reviewing applications and documents. The ability to speak the host country language is a qualification for VSOs, as agreed to in the Memorandum of Understanding with State. DHS acknowledged the utility of language capability, but noted that law enforcement skills and expertise outweigh the limitations of a lack of language proficiency. According to DHS, if language training is deemed necessary, such courses would be offered in addition to the standard VSO training, which includes courses on interviewing, detection of deception, and national security law, as well as regional and country briefings. The Memorandum of Understanding between State and DHS states that VSOs would provide training to consular officers on detecting applicants who pose a threat to homeland security and fraudulent documents; however, the requirement that VSOs review all visa applications in Saudi Arabia limits the amount of time that they can spend on training and other valuable services. We observed that VSOs in Riyadh and Jeddah must spend a significant amount of time reviewing all visa applications, including those of low-risk applicants or individuals who do not pose a threat to national security, as well as those that have preliminarily been refused by consular officers. For example, according to DHS officials, lower priority applications may include those from elderly applicants and very young children. Furthermore, the requirement has resulted in extremely long work hours for the VSOs. For example, to return applications to consular officers within 24 hours of the initial decision, the three VSOs in Riyadh and one VSO in Jeddah were each working 7 days per week at the time of our visit. Moreover, the VSOs spend considerable time--as much as 2 hours each day, according to one officer in Jeddah--reviewing applications that are preliminarily refused by consular officers or from low-risk applicants. A Visa Security Program official noted that this mandate is only for visa security operations in Saudi Arabia and not other posts to which DHS plans to assign VSOs. At posts outside of Saudi Arabia, DHS proposed the use of site-specific criteria to focus the review of applications based on several factors, including the number of applications at the post and post-specific threat assessments. VSOs, DHS and State officials, and the deputy chief of mission all agreed that the mandate to review all applications was forcing the VSOs to spend time on lower priority tasks, limiting their ability to perform other activities, such as providing training or conducting additional secondary interviews of applicants. Consular officers also agreed that they would benefit from additional training and other interaction with the VSOs. According to DHS, if its VSOs were granted more flexibility to determine the extent of their review and were not required to review all applications, they could prioritize visa application reviews--a process which they plan to implement at other posts. DHS acknowledged that adding additional officers to the posts in Saudi Arabia could allow VSOs time to perform other tasks, but DHS would still need to prioritize these resources to address training and other activities in Saudi Arabia. However, security concerns at the U.S. embassy and consulate have limited the number of personnel DHS, as well as other U.S. agencies, can assign to these posts. DHS has not maintained measurable data to fully demonstrate the impact of VSOs on the visa process. The VSOs that were stationed in Riyadh during our visit estimated that, based on their review of visa applications, they had recommended that visas be refused after the preliminary decision to issue a visa by consular officers in about 15 cases between October 2004 and February 2005. In addition, the DHS officials in Saudi Arabia and in Washington, D.C., were able to provide anecdotal examples of assistance provided to the consular officers. However, DHS has not developed a system to fully track the results of visa security activities in Saudi Arabia. For example, DHS could not provide data to demonstrate the number of cases for which they have recommended refusal. DHS plans to expand the Visa Security Program to five additional posts in fiscal year 2005; however, the assignments of VSOs were delayed at four of the five selected expansion posts. DHS attributed the delay to resistance by State, as well as funding problems. State and chiefs of mission attributed the delays to various questions about the program, including the criteria used by DHS to select expansion posts and the reasoning for the number of VSOs requested for the posts. A strategic plan to guide operations and expansion of the Visa Security Program could have answered some of these questions and potentially prevented some delays in expanding the program to additional posts, but DHS has not prepared such a plan. The Homeland Security Act of 2002 authorized the assignment of DHS officers to each diplomatic post where visas are issued to provide expert advice and training to consular officers and review visa applications. In 2003, a DHS working group established criteria for ranking potential posts for the program's expansion. The site selection criteria considered the following primary factors: risk of terrorism in a country based on State's threat assessments and intelligence of terrorist activity; visa denial rates; and issuance of visas to multiple nationalities at a post. In addition, a Visa Security Program official indicated that DHS also considered intelligence reports and the host nation circumstances, including government cooperation, corruption, immigration controls, and identification document controls, when selecting potential expansion posts. DHS conducted site assessments, in coordination with State, at six consular posts in October and November 2003 and April 2004 to further evaluate the potential for establishing the Visa Security Program at these posts. According to DHS, delays in expanding the program were due, in part, to the fact that funding was not reprogrammed for visa security operations until December 2004. DHS selected five posts to expand the Visa Security Program and in June 2004 submitted requests for the assignment of 21 VSO positions to five posts. One post approved the NSDD-38 request in July 2004. Another post approved the assignment of VSOs in March of 2005, and two posts approved the requests in June 2005. As of June 2005, one post has still not approved the NSDD-38 request. Four posts have approved the assignment of VSOs at their respective posts, but DHS had not yet assigned VSOs to any of the expansion posts. Embassy officials raised questions and concerns regarding the plans to expand the Visa Security Program, which contributed to the delays in the approval of the NSDD-38 requests. State's Office of Rightsizing the U.S. Overseas Presence supported the posts' questions of DHS's plans for expansion of the Visa Security Program. Embassy officials at the expansion posts expressed concerns with the site selection process and the criteria DHS used to select the posts, which contributed to the delays in approving DHS's requests for VSOs. Based on DHS's quantitative evaluation criteria used to select expansion posts, visa issuing posts were ranked to identify priority posts for the deployment of VSOs. However, of the 5 posts selected for expansion of the Visa Security Program, 2 of the posts ranked outside of the top 10 posts identified by DHS's evaluation. Moreover, embassy officials at one of these expansion posts that did not rank in the initial top 10 believe that DHS's selection criteria does not justify the assignment of VSOs to their post. In particular the consular chief stated that the post had a relatively low application volume and a low refusal rate--two criteria that DHS used to select the fiscal year 2005 expansion posts. DHS stated that this particular post was chosen based on other qualitative data, consultation with law enforcement and intelligence officials, and practical considerations for expansion of the program. These additional factors were not included in the methodology DHS developed to identify priority posts for expansion of the Visa Security Program. Embassy officials at 2 posts chosen for expansion were unaware of the criteria used to select the expansion posts; however, DHS stated that they had explained their criteria. Embassy officials also questioned the reasoning behind the number of VSOs that DHS requested for assignment to the selected expansion posts. In June 2004, DHS originally requested the assignment of 21 VSO positions to 5 posts. According to DHS, the request for the number of VSOs at each post was based on the assessment of several factors including the workload at post. However, chiefs of mission and consular officials also told us that they were unclear about the number of VSOs required for visa security operations and requested for assignment. DHS officials stated that they had explained their rationale fully. As of June 2005, four posts had approved the assignment of 13 VSO positions. Table 1 shows the number of VSO positions requested compared to the number of VSO positions approved by chiefs of mission. DHS received approval for 8 fewer VSO positions than it requested, and received the full complement of staff requested at one expansion post. This gap in approving the assignment of VSOs indicates that DHS either overestimated the staff it needed to conduct activities at each post or will not have enough staff at each post to effectively impact the visa adjudication process at these locations. DHS negotiated the final number of positions with chiefs of mission at several posts to help expedite the NSDD-38 requests. For example, DHS and embassy officials at one post agreed to reduce the number of positions requested from 5 to 3; subsequently, the NSDD-38 request was approved in March 2005. The deputy chief of mission and consul general at another embassy noted that DHS's request for four VSOs appeared excessive, considering the low volume of visas that are processed at that post, which conducts about 30 to 40 applicant interviews daily, and that there are only four consular officers stationed at the post. Therefore, the embassy approved two VSOs in June 2005. The post that has not approved DHS's request as of June 2005 proposed that DHS assign not four but one VSO for a 6-month assignment. According to the chief of mission, during this time, the VSO could demonstrate how the program would benefit the post, as well as the need for the additional positions DHS requested. DHS officials, however, believe that one officer would not be sufficient to meet the threat to visa security at the post. As we have previously reported, questions related to (1) security of facilities and employees, (2) mission priorities and requirements, and (3) cost of operations should be addressed when determining the appropriate number of staff that should be assigned to a U.S. embassy. In August 2004, State's Office of Rightsizing the U.S. Overseas Presence, which manages the NSDD-38 process for the U.S. government, issued interim guidance to chiefs of mission regarding factors to consider when approving DHS's requests for VSOs. A Rightsizing Office official stated that this guidance is consistent with guidance that is applicable to all agencies that submit NSDD-38 requests. Specifically, the cable advised the five chiefs of mission at posts selected for VSO expansion to delay approving the DHS positions until State or the post had received sufficient responses to several outstanding issues, including criteria for selecting the expansion posts; agreement on administrative support services, such as building maintenance, utilities, supplies, and equipment, among others; the extent to which the VSOs will have regional responsibilities at other the roles and responsibilities of the VSOs in relation to State's consular fraud investigators and regional security officers at post, as well as any other agencies at post; and the criteria that will be used to measure the effectiveness of the visa security operations. In 2004 and 2005, DHS provided responses, through State's Bureau of Consular Affairs, to the questions raised by the chiefs of mission at four of the expansion posts. According to DHS, the responses were sufficient to answer the concerns raised by the chiefs of mission. We reviewed the responses to the posts, and identified a number of issues that had not been fully addressed. For example, the documentation did not specify the criteria that DHS will use to demonstrate the effectiveness of its officers. Nevertheless, the chiefs of mission at three posts approved NSDD-38 requests in March and June 2005. In 2003, DHS and State agreed in a Memorandum of Understanding that DHS would identify those diplomatic and consular posts where DHS considered the presence of its personnel necessary to perform visa security functions and would subsequently assign VSOs to those posts. DHS plans to expand the Visa Security Program to five additional consular posts throughout fiscal year 2005. Furthermore, DHS plans to expand the Visa Security Program beyond the posts initially selected for expansion, conducted a site assessment in May 2005 for a sixth expansion location, and plans to continue deployment of VSOs to attain worldwide coverage of the program. According to DHS, the Secretary of Homeland Security has suggested a pace of five new posts per year. Although DHS plans to expand the Visa Security Program in fiscal year 2005 and beyond, it does not a have a strategic plan that defines mission priorities and long-term goals and identifies the outcomes expected at each post to guide operations of the program. We have identified the development of a strategic plan as an essential component of measuring progress and holding agencies accountable for achieving results. The development of an overall strategic plan for the Visa Security Program prior to the expansion of the program may have addressed the questions initially raised by State and embassy officials that led to the delay of the assignment of VSOs. Moreover, a strategic plan would provide a framework for DHS to address broader questions regarding the selection criteria for expansion, the roles and responsibilities of VSOs, and the cost of establishing the program at posts. In addition, a strategic plan would guide rightsizing analyses to determine the appropriate number of VSOs at each post. Officials from DHS and State, as well as consular officials we contacted overseas, all agreed that the development of such a plan would be useful to guide visa security operations in Saudi Arabia and other posts. It would also be useful to inform the Congress, as well as State and other agencies who participate in the visa process at consular posts overseas. Furthermore, as a key stakeholder in the Visa Security Program, State should be consulted in the strategic planning process and, therefore, the concerns and questions raised by State's Office of Rightsizing the U.S. Overseas Presence and chiefs of mission should be addressed by DHS. Moreover, without a strategic plan that serves as a roadmap for expansion, DHS may continue to experience delays in the approval of NSDD-38 requests at future expansion posts. The placement of VSOs overseas has the potential to improve the security of the visa process at U.S. embassies and consulates. However, the congressional mandate requiring the VSOs in Saudi Arabia to review all applications prior to adjudication limits them from engaging in other counterterrorism activities, such as providing additional training to consular officers on fraud prevention and interview techniques. Moreover, DHS has not incorporated key features of strong program management essential to measuring program results and holding staff accountable for achieving results into its oversight of the Visa Security Program. Before DHS expands this program to other consular posts, it needs a plan outlining its goals and objectives to allow the department to measure program performance and determine the overall value of its visa security operations worldwide. Such a plan needs to address questions from the chiefs of mission who must approve the assignment of VSOs to U.S. embassies or consulates. Addressing these questions would help facilitate negotiations of the expansion of the Visa Security Program. To help ensure that the Visa Security Program, and its expansion to other locations worldwide, is managed effectively, we recommend that the Secretary of Homeland Security: develop a strategic plan, in consultation with the Secretary of State, to guide visa security operations in Saudi Arabia and in other embassies and consulates overseas. This plan should incorporate the key elements of strategic planning, including a mission statement, program goals and objectives, approaches to achieving those goals, a connection between the long-term and short-term goals, and a description of how the effectiveness of the program will be evaluated. In addition, DHS should include or develop supporting documents that provide more specific information on the criteria used to select the locations for expansion, justification for the number of VSOs at each post, the roles and responsibilities of the VSOs in relation to other agencies located at post, and the resources needed to establish the Visa Security Program overseas. develop performance data that can be used to assess the results of the Visa Security Program at each post. Congress may wish to consider amending current legislation, which requires that VSOs in Saudi Arabia review all visa applications prior to adjudication, to provide DHS the flexibility to determine the extent to which VSOs review applications, based upon the development of a risk- assessment tool. This flexibility will allow them to engage in other activities that will provide additional benefit to consular officers and the visa process. DHS and State provided written comments on a draft of this report (see apps. II and III). DHS stated it was taking actions to implement performance measurements and a strategic plan for the Visa Security Program, as described in our recommendations. DHS indicated that it is expanding the tracking and measurement of performance data to better reflect program results. In addition, DHS stated it is developing a strategic plan that will integrate the key elements described in our recommendation; however, DHS stated that it was unlikely that such a plan would have aided in the approval of the NSDD-38 requests at the five expansion posts. We believe that a strategic plan would allow DHS to better address questions about the program and would be useful in guiding visa security operations in Saudi Arabia and other consular posts. Regarding the matter for congressional consideration to provide DHS with the flexibility to determine the review of visa applications in Saudi Arabia, DHS agreed that it needed to expand some of the VSOs' activities in Saudi Arabia, such as providing additional training, which we found were not being provided because of the volume of work that resulted from fulfilling the legislative requirement. DHS noted that a legislative change should maintain DHS's authority and discretion in determining the scope of the VSOs' review. DHS also provided additional details on the Visa Security Program, its plans to improve operations, and its interaction with State regarding program expansion. These comments are reprinted in appendix II, along with our analysis. DHS also provided technical comments, which we incorporated into the report, as appropriate. State agreed with our conclusions, stating that the report is an accurate description of the implementation of the Visa Security Program. In addition, State agreed with our matter for congressional consideration. State noted that the ability of the VSOs in Saudi Arabia to access law enforcement and other databases not available to consular officers highlights the importance of shared, interoperable databases worldwide. With regard to the program's expansion outside Saudi Arabia, State also noted that chiefs of mission and its Rightsizing Office are obligated to ensure that staffing overseas for all agencies is at the proper level and consistent with available space and resources. State's comments are reprinted in appendix III. We are sending copies of this report to the Secretaries of State and Homeland Security, and to other interested Members of Congress. We will also make copies available to others upon request. In addition, this report will be available at no charge on the GAO Web site at http://www.gao.gov. If you have any questions about this report, please contact me at (202) 512- 4128 or fordj@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix IV. To assess the Visa Security Officers' activities in Saudi Arabia, we reviewed the Homeland Security Act of 2002, which authorized DHS to create the Visa Security Program. In addition, we reviewed the subsequent September 2003 Memorandum of Understanding between State and DHS regarding the implementation of the requirements set forth in section 428 of the Homeland Security Act. We also reviewed a prior report from August 2004 on DHS's implementation of section 428 requirements, conducted by the DHS Office of Inspector General, and spoke with the Inspector General officials who conducted that review. We interviewed officials from DHS who manage the Visa Security Program in Washington, D.C., as well as officials from State's Bureau of Consular Affairs and the Office of Rightsizing the U.S. Overseas Presence. Moreover, we observed the VSOs' activities in Riyadh and Jeddah, Saudi Arabia, and interviewed the VSOs, as well as consular officials and the chief of mission, regarding the impact of the Visa Security Program at these posts. To assess DHS's plans to expand the Visa Security Program to consular posts outside Saudi Arabia, we reviewed documentation on the department's requests to establish new positions at 5 additional posts and spoke with DHS officials regarding the planned expansion. In addition, we reviewed DHS's criteria for selecting VSOs and the criteria and methodology for selecting expansion posts. We also compared DHS's management strategy for the Visa Security Program and its expansion with criteria from the Government Performance and Results Act and associated GAO reports on performance-based, strategic planning. In addition, we visited two of the five posts to which DHS plans to expand the Visa Security Program and interviewed consular and embassy officials, including the chiefs and deputy chiefs of mission, at these locations to discuss these posts' plans for the VSOs. We also spoke with officials from other law enforcement agencies at post who work with the consular section. Further, we spoke with the consuls general from the other three posts initially chosen for expansion in fiscal year 2005 to discuss the status of DHS plans to expand to these locations. We conducted our evaluation from August 2004 to June 2005 in accordance with generally accepted government auditing standards. The following are GAO's comments on the Department of Homeland Security's letter dated July 15, 2005. 1. We revised the highlights page to reflect that no comprehensive data exists to demonstrate the impact of the VSOs in Saudi Arabia. 2. We requested documentation from DHS on the visa application reviews conducted by VSOs in Saudi Arabia. DHS provided weekly operational reports that contained descriptive examples of the reviews of visa applications and the outcomes of those reviews. DHS did not provide systematic data on the operations of the VSOs, and VSOs in Saudi Arabia stated that they did not have a system in place to track the activities of the program. The steps DHS describes appear to be positive steps to incorporate performance measurement into the Visa Security Program, and to implement a workload tracking database. We believe these actions should allow DHS to better demonstrate program results and are consistent with our recommendation. 3. We revise the report to clarify that VSOs may recommend a refusal after a preliminary determination to issue the visa by a consular officer. We agree that there might be additional cases where VSOs may influence the decision of consular officers. We believe it is important to measure other outcomes that demonstrate the impact of the Visa Security Program. Furthermore, we believe that it is not difficult to track additional data, and such performance measures should be incorporated into the tracking system for VSO activities. 4. We do not agree that the statement was an error in syntax. We believe that performance measurement is an integral part of effective program management, and the lack of comprehensive data on program impact has hindered the Visa Security Program. Performance data could be used to demonstrate the effectiveness of operations in Saudi Arabia, as well as to illustrate the benefits of the program when presenting the benefits of the program to interested parties, including chiefs of mission at future expansion posts and the Congress. 5. In August 2004, the DHS Office of Inspector General found that the continued use of temporary officers to fill VSO positions was not conducive to developing an effective or efficient long-term visa security operation. In addition, in February 2005, the deputy chief of mission in Saudi Arabia told us that the use of temporary VSOs led to a lack of continuity in operations, and that the VSOs initially were not able to significantly impact the visa process at post. Our report recognized that DHS assigned permanent officers to Saudi Arabia in June 2005. 6. We revised the figure to reflect that VSOs also conduct investigative research on visa applicants in addition to conducting name checks. 7. Our report noted that, in addition to the quantitative data used as preliminary selection criteria, DHS stated it used qualitative data and other practical considerations in choosing the posts. DHS did not provide this qualitative data nor the additional considerations used to select expansion posts to GAO, and thus we were unable to assess the additional criteria. We made an assessment based on the information and data provided by DHS. 8. We believe that the development of a strategic plan would assist DHS by providing stakeholders, such as State and chiefs of mission, with information regarding the mission, goals and operations of the Visa Security Program. A strategic plan may have helped to address the questions raised by State and embassy officials that led to the delays in the approvals of the NSDD-38 requests. In addition, we believe that a strategic plan would expedite the approval of future NSDD-38 requests for assignment of VSOs to consular posts. State officials support this view. DHS is taking positive steps by working towards the development of a strategic plan as we recommend. In addition, John Brummet, Daniel Chen, Katie Hartsburg, Jeff Miller, Mary Moutsos, Joseph Carney, and Etana Finkler made key contributions to this report.

Summary:
The Homeland Security Act of 2002 required that the Department of Homeland Security's on-site personnel in Saudi Arabia review all visa applications. The act also authorized the expansion of the Visa Security Program to other embassies and consulates to provide expert advice and training to consular officers, among other things. Given the congressional interest in effective implementation of the Visa Security Program, we assessed (1) the Visa Security Officers' activities in Saudi Arabia, and (2) DHS's plans to expand its Visa Security Program to other consular posts overseas. Visa Security Officers (VSO) assigned to Saudi Arabia review all visa applications prior to final adjudication by consular officers, and assist consular officers with interviews and fraud prevention; however, no comprehensive data exists to demonstrate the VSOs' impact. According to State Department consular officers, the deputy chief of mission, and Department of Homeland Security (DHS) officials in Saudi Arabia, the VSOs in Riyadh and Jeddah strengthen visa security because of their law enforcement and immigration experience, as well as their ability to access and use information from law enforcement databases not immediately available, by law, to consular officers. Furthermore, the requirement to review all visa applications in Saudi Arabia limits the VSOs' ability to provide additional training and other services to consular officers, such as assisting with interviews. Moreover, security concerns in Saudi Arabia limit staffing levels at these posts. DHS has not developed a strategic plan outlining the Visa Security Program's mission, activities, program goals, and intended results for operations in Saudi Arabia or the planned expansion posts. Chiefs of mission at the five posts chosen for expansion in fiscal year 2005 delayed approving DHS's requests for the assignment of VSOs until DHS answered specific questions regarding the program's goals and objectives, staffing requirements, and plans to coordinate with existing staff and law enforcement and border security programs at post. DHS's development of a strategic plan may address outstanding questions from chiefs of mission and other embassy officials and help DHS expand the program.