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United States Government Accountability Office: 
GAO: 

Report to the Committee on Homeland Security and Government Affairs, 
U.S. Senate: 

March 2011: 

Border Security: 

DHS's Visa Security Program Needs to Improve Performance Evaluation 
and Better Address Visa Risk Worldwide: 

GAO-11-315: 

GAO Highlights: 

Highlights of GAO-11-315, a report to the Committee on Homeland 
Security and Government Affairs, U.S. Senate. 

Why GAO Did This Study: 

Since 2003, the Department of Homeland Security’s (DHS) Visa Security 
Program (VSP) has participated in the visa process by reviewing 
applications at some embassies and consulates, with the intention of 
preventing individuals who pose a threat from entering the United 
States. The attempted bombing of an airline on December 25, 2009, 
renewed concerns about the security of the visa process and the 
effectiveness of the VSP. For this report GAO assessed (1) the ability 
of DHS’s Immigration and Customs Enforcement (ICE) to measure the 
program’s objectives and performance, (2) challenges to VSP 
operations, and (3) ICE efforts to expand the VSP program. To evaluate 
the VSP, we reviewed VSP data, guidance, and the ICE’s 5-year 
expansion plan. We also interviewed ICE officials, and observed VSP 
operations at 6 posts overseas. 

What GAO Found: 

ICE cannot accurately assess progress toward its VSP objectives. ICE 
outlined three primary objectives of the VSP-—identifying and 
counteracting potential terrorist threats from entering the United 
States, identifying not-yet-known threats, and maximizing law 
enforcement and counterterrorism value of the visa process-—and 
established performance measures intended to assess VSP performance, 
including situations where VSP agents provide information that results 
in a consular officer’s decision to deny a visa. ICE’s VSP tracking 
system, used to collect data on VSP activities, does not gather 
comprehensive data on all the performance measures needed to evaluate 
VSP mission objectives. In addition, data collected by ICE on VSP 
activities were limited by inconsistencies. ICE upgraded its VSP 
tracking system in April 2010 to collect additional performance data, 
but the system still does not collect data on all the performance 
measures. Therefore, ICE’s ability to comprehensively evaluate the 
performance of the VSP remains limited. While ICE can provide some 
examples demonstrating the success of VSP operations, ICE has not 
reported on the progress made toward achieving all VSP objectives. 

Several challenges to the implementation of the VSP affected 
operations overseas. DHS and the Department of State (State) have 
issued some guidance, including several memorandums of understanding, 
to govern VSP operations. However, some posts experienced difficulties 
because of the limited guidance regarding interactions between State 
officials and VSP agents, which has led to tensions between the VSP 
agents and State officials at some posts. In addition, most VSP posts 
have not developed standard operating procedures for VSP operations, 
leading to inconsistency among posts. Additionally, the mandated 
advising and training of consular officers by VSP agents varies from 
post to post, and at some posts consular officers received no 
training. Finally, VSP agents perform a variety of investigative and 
administrative functions beyond their visa security responsibilities 
that sometimes slow or limit visa security activities, and ICE does 
not track this information in the VSP tracking system, making it 
unable to identify the time spent on these activities. 

In 2007, ICE developed a 5-year expansion plan for the VSP, but ICE 
has not fully followed or updated the plan. For instance, ICE did not 
establish 9 posts identified for expansion in 2009 and 2010. 
Furthermore, the expansion plan states that risk analysis is the 
primary input to VSP site selection, and ICE, with input from State, 
ranked visa-issuing posts by visa risk, which includes factors such as 
the terrorist threat and vulnerabilities present at each post. 
However, 11 of the top 20 high-risk posts identified in the expansion 
plan are not covered by the VSP. Furthermore, ICE has not taken steps 
to address visa risk in high-risk posts that do not have a VSP 
presence. Although the expansion of the VSP is limited by a number of 
factors, such as budgetary limitations or limited embassy space, ICE 
has not identified possible alternatives that would provide the 
additional security of VSP review at those posts that do not have a 
VSP presence. 

What GAO Recommends: 

GAO made several recommendations designed to address weaknesses we 
identified in the VSP. DHS concurred with the recommendations that the 
VSP provide consular officer training and develop a plan to provide 
more VSP coverage at high-risk posts. DHS did not concur with the 
recommendations that the VSP collect comprehensive data on all 
performance measures and track the time spent on visa security 
activities. GAO continues to maintain that these recommendations are 
necessary to accurately assess VSP performance. 

View [hyperlink, http://www.gao.gov/products/GAO-11-315] or key 
components. For more information, contact Jess Ford at (202) 512-4268 
or fordj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

ICE Remains Unable to Accurately Measure the Performance of the Visa 
Security Program: 

Several Challenges Affect Visa Security Operations Overseas: 

ICE Has Not Fully Adhered to the VSP Expansion Plan: 

Conclusion: 

Recommendations for Executive Action: 

Agency Comments and our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of Homeland Security: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Objectives and Performance Measures of the Visa Security 
Program: 

Figures: 

Figure 1: Organizational Chart of DHS and the VSP: 

Figure 2: Timeline for the Establishment and Expansion of the VSP: 

Abbreviations: 

DHS: Department of Homeland Security: 

DS: Bureau of Diplomatic Security: 

ICE: Immigration and Customs Enforcement: 

MOU: memorandum of understanding: 

SAO: security advisory opinion: 

TECS: Treasury Enforcement and Communications System: 

VSP: Visa Security Program: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 31, 2011: 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Since its establishment in 2002, following the September 2001 
terrorist attacks on the United States, the Department of Homeland 
Security (DHS) has been responsible for the issuance of visa policy. 
[Footnote 1] In 2003, DHS implemented the Visa Security Program (VSP), 
and has since deployed DHS officials to certain U.S. embassies and 
consulates to strengthen the visa process by working with Department 
of State (State) officials in reviewing visa applications.[Footnote 2] 
However, the attempted bombing of Northwest Airlines flight 253 on 
December 25, 2009, by a Nigerian citizen in possession of a valid U.S. 
visa renewed concerns about the security of the visa process. 

In 2005, we reported on VSP activities in Saudi Arabia--at that time, 
the only country where DHS had implemented the program--and on the 
department's plans to expand the program to other countries.[Footnote 
3] To help ensure effective management of the VSP and its expansion, 
we recommended that the Secretary of Homeland Security develop a 
strategic plan that includes, among other things, information on 
criteria for selecting locations for expansion. We also recommended 
that the Secretary maintain performance data that could be used to 
assess the program's impact at each post.[Footnote 4] In response to 
our recommendations, DHS's Immigration and Customs Enforcement (ICE), 
which oversees the program, developed a 5-year expansion plan and 
deployed a tracking system to capture performance data. As of December 
2010, ICE had established VSP units at 19 posts in 15 countries. 

In response to your request, this report (1) assesses the ability of 
DHS to measure the program's objectives and performance, (2) 
identifies potential challenges to VSP operations overseas, and (3) 
examines DHS efforts to expand the VSP program. 

To conduct our evaluation, we reviewed relevant legislation, such as 
the Homeland Security Act of 2002, and documentation including 
internal guidance and interagency memorandums. To assess ICE's ability 
to measure the objectives and performance of the VSP, we reviewed the 
VSP mission objectives and performance measures identified by ICE. We 
also reviewed data from VSP's tracking system, and compared the data 
collected with the performance measures to identify the ability of ICE 
to assess its performance and progress toward the identified 
objectives. To evaluate the challenges to VSP operations, we reviewed 
the issued guidance governing the implementation of the VSP. We met 
with ICE and State officials in Washington, D.C., and interviewed VSP 
agents and consular officials, via telephone and e-mail, at 13 VSP 
posts that were operational as of April 2010 to identify some VSP 
operational challenges. We also visited six U.S. embassies and 
consulates with VSP operations to observe VSP operations. To assess 
ICE's efforts to expand the VSP, we reviewed the VSP 5-year expansion 
plan and compared the expansion with the plan. We also reviewed the 
criteria for the selection of posts identified for expansion. We also 
interviewed ICE and State officials regarding the expansion plan and 
the challenges of expanding the VSP. 

We conducted this performance audit from March 2010 through March 2011 
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. 

Background: 

Legislative Authority for the Visa Security Program: 

The Homeland Security Act of 2002 established DHS and gave the agency 
responsibility for visa policy. Specifically, the act granted DHS the 
authority to issue regulations on, administer, and enforce the 
Immigration and Nationality Act and other immigration and nationality 
laws relating to the functions of U.S. consular officers in connection 
with the granting and denial of visas. Section 428 of the act also 
authorized DHS to immediately assign personnel to Saudi Arabia to 
review all visa applications prior to final adjudication, and 
authorized DHS to assign officers to other locations overseas to 
review visa applications. Section 428 designated the following 
functions for DHS officers assigned overseas: 

1. provide expert advice and training to consular officers regarding 
specific security threats relating to the adjudication of individual 
visa applications or classes of applications, 

2. review visa applications either on the initiative of the employee 
of the department or at the request of a consular officer, or other 
persons charged with adjudicating such applications, and: 

3. conduct investigations with respect to consular matters under the 
jurisdiction of the Secretary of Homeland Security. 

Establishment of the Visa Security Program: 

DHS designated ICE to handle the operational and policy-making 
responsibilities outlined in section 428 in January 2004. 
Subsequently, ICE established the Office of International Affairs and 
gave it responsibility for overseeing the Visa Security Program. 
Figure 1 shows the organization of the Visa Security Program within 
DHS. 

Figure 1: Organizational Chart of DHS and the VSP: 

[Refer to PDF for image: organizational chart] 

Top level: 
Department of Homeland Security. 

Second level: 
Immigration and Customs Enforcement. 

Third level: 
Homeland Security Investigations. 

Fourth level: 
Office of International Affairs. 

Fifth level: 
Visa Security Program: 
* Visa Security Program Section; 
* Security Advisory Opinion Unit. 

Source: GAO analysis of DHS documents. 

[End of figure] 

Primary Guidance Governing Visa Security Program Operations: 

Since the establishment of the Visa Security Program, ICE and State 
have issued four primary forms of guidance governing VSP operations 
overseas: (1) a 2003 memorandum of understanding (MOU) concerning 
implementation of the Homeland Security Act; (2) a 2004 MOU on 
administrative aspects of assigning personnel overseas; (3) a 2008 
cable directing State Bureau of Diplomatic Security (DS) officers, 
[Footnote 5] VSP agents, and the senior consular officer at each post 
to develop standard operating procedures; and (4) a 2011 MOU 
delineating the roles and responsibilities of VSP agents, consular 
officers, and diplomatic security officers in daily operations of VSP 
at posts overseas. 

2003 MOU. In 2003, DHS and State issued a memorandum of understanding 
to govern the implementation of section 428. In accordance with the 
legislation, the memorandum outlined the following responsibilities of 
DHS officers assigned to posts overseas to perform visa duties: 

* Advising and training consular officers. DHS employees are to 
provide expert advice to consular officers regarding specific security 
threats relating to visa adjudication and provide training to consular 
officers on terrorist threats and detecting applicant fraud. 

* Reviewing visa applications. DHS employees have the authority to 
review visa applications on their own initiative or at the request of 
consular officers, and provide input on or recommend security advisory 
opinion requests. 

* Conducting investigations. DHS employees are authorized to conduct 
investigations on consular matters under the jurisdiction of the 
Secretary of Homeland Security, as well as conduct and support 
investigations under other DHS authorities. 

2004 MOU. In 2004, ICE and State signed a MOU on administrative 
aspects of assigning personnel overseas. Among other things, this MOU 
described administrative support, security, facilities, security 
awareness training, and information systems for VSP personnel. 

2008 cable. In 2008, State issued a cable in which ICE and State 
directed VSP posts to develop standard operating procedures. The cable 
stated that these standard operating procedures should include, but 
not be limited to: 

* chain of command; 

* clearance procedures for cables and other correspondence; 

* dispute resolution practices; 

* specific coordination procedures among the fraud prevention unit, 
VSP agents, and the regional security officer; 

* procedures for determining case selection; 

* specific hours of operation and other coordination issues; 

* stating how electronic reviews will be conducted and documented; 

* stating how physical reviews will be conducted and documented; 

* coordination of procedures for handling expedited or exceptional 
visa cases; 

* procedures for sharing and documenting applicant information 
constituting grounds for ineligibility; and: 

* procedures for VSP applicant interviews and re-interviews. 

2011 MOU. On January 11, 2011, ICE and State issued a MOU that 
explains the roles, responsibilities, and collaboration of VSP agents, 
consular officers, and diplomatic security officers in daily 
operations of VSP at posts overseas. The MOU outlines the following, 
among other things: 

* general collaboration between ICE and State for VSP operations; 

* roles and responsibilities of VSP agents and consular officers and 
routine interaction between the officers and agents; 

* development of formal, targeted training and briefings by VSP agents 
for consular officers and other U.S. government officials at post; 

* clarification of the dispute resolution process; and: 

* collaboration between diplomatic security officers and VSP agents on 
visa and passport fraud investigations. 

Visa Adjudication Process: 

The review of visa applications by VSP agents is incorporated into the 
visa process at overseas posts where the VSP is located. 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.[Footnote 6] The VSP agents screen 
the applicant information against DHS's Treasury Enforcement and 
Communications System (TECS) database to identify applicants that 
potentially match records of individuals who are known threats to the 
United States.[Footnote 7] The VSP agents then perform a vetting 
process on a smaller number of applications, based upon a threat-based 
targeting plan. During vetting, the VSP agents perform checks against 
additional law enforcement and other databases, and review the 
applications and supporting documentation for evidence of fraud or 
misrepresentation, indicators of potential national security risks, 
criminal activity, and potential illegal immigration risks. During the 
review, the VSP agents may also consult consular officers and other 
law enforcement officials as needed. On the basis of these reviews, 
the VSP agents will either agree with the consular officer's original 
decision or recommend refusal of the visa. The consular officer 
decides to issue or deny the visa.[Footnote 8] If the consular section 
chief and the VSP agents disagree on a case, a dispute resolution 
process is started to render a final determination of the application. 

Several other agencies stationed overseas have roles in the visa 
process. For example, State 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. 

Expansion Plan for the Visa Security Program: 

ICE's 5-year plan for expanding the VSP, which ICE released in 
consultation with State in 2007, states that global visa risk is 
substantial and that the VSP must be expanded in order to mitigate 
threats identified through the visa process and to address visa risk. 
The plan also includes the following principles to guide the program's 
expansion: 

* concentrate expansion on risk by deploying personnel sooner to the 
highest-risk visa-issuing locations; 

* develop a global capacity by expanding to select high-risk posts in 
diverse regions; and: 

* cover the highest-risk visa activity while incorporating dynamic 
conditions such as funding, personnel, and logistical issues such as 
the availability of space. 

* The 5-year plan also includes the following site selection 
methodology to inform the expansion process: 

* Initial quantitative risk analysis. ICE and State developed a list 
of 216 visa-issuing locations that are ranked according to risk. The 
underlying analysis incorporates information on terrorist activity, 
DHS enforcement and removals, host government circumstances, 
corruption, visa activity, and several other factors. 

* Interagency and interdepartmental consultation. Throughout the site 
selection process, ICE coordinates with State, law enforcement and 
intelligence communities, and other components of DHS. This 
coordination helps to establish mutual understanding among interested 
parties and to inform and refine the decision-making process. 

* Site assessments. ICE selects a smaller number of locations for on- 
site assessments to further improve communication and gather 
information about local conditions at post. 

* Final evaluation and selection. Using all of the information 
gathered, ICE makes a final evaluation and selection for new VSP unit 
locations. 

Figure 2 shows a timeline for the establishment of the VSP and the 
expansion of the program. As of December 2010, ICE had established VSP 
units at 19 posts in 15 countries. 

Figure 2: Timeline for the Establishment and Expansion of the VSP: 

[Refer to PDF for image: timeline] 

November 2002: 
Homeland Security Act of 2002 passed. 

August 2003: 
VSP operations start in Riyadh, Saudi Arabia.[A] 

September 2003: 
MOU on section 428 between DHS and State signed. 

October 2005: 
VSP operations start at four posts. 

January 2007: 
VSP operations start at one post. 

March 2007: 
VSP operations start at one post. 

May 2007: 
VSP operations start at one post. 

September 2007: 
VSP operations start at one post. 

November 2007: 
VSP operations start at one post. 

September 2008: 
VSP operations start at one post. 

January 2009: 
VSP operations start at one post. 

May 2009: 
VSP operations start at one post. 

2010: 
VSP expands to four new posts. 

Source: GAO analysis of DHS documents. 

Note: Locations are not specified for security reasons. 

[A] VSP operations start at other posts in Saudi Arabia in October 
2003. 

[End of figure] 

Visa Security Program Funding: 

For fiscal years 2007 through 2010, ICE reported that approximately 
$94 million in appropriated funds was allotted for the Visa Security 
Program. Of these amounts, in fiscal years 2009 and 2010, Congress 
specified that $6.8 million and $7.3 million, respectively, would 
remain available for 1 additional year. In fiscal year 2010, the Visa 
Security Program received $30.7 million in appropriated funds, and the 
agency requested $30.7 million in the fiscal year 2011 budget request. 

ICE Remains Unable to Accurately Measure the Performance of the Visa 
Security Program: 

ICE does not maintain comprehensive performance data to accurately 
evaluate progress toward all VSP mission objectives. In 2007, ICE 
outlined three primary objectives of the Visa Security Program in its 
5-year expansion plan and identified and established performance 
measures intended to assess performance toward the stated objectives. 
However, the initial VSP tracking system did not gather data on all 
the performance measures and mission objectives identified in the VSP 
expansion plan. Although ICE upgraded the VSP tracking system in April 
2010 to collect additional performance data, the system still does not 
collect data on all the performance measures, hampering ICE's efforts 
to comprehensively evaluate the performance of the VSP. While ICE can 
provide some examples demonstrating the success of VSP operations, ICE 
has not produced reports identifying the progress made toward 
achieving VSP objectives. In addition, data collected by ICE on VSP 
activities prior to 2010 were limited by inconsistencies. 

ICE Unable to Accurately Assess the Value of the VSP: 

From 2003 to 2010, ICE did not maintain comprehensive data on its 
identified performance measures to fully assess progress toward VSP 
objectives. As we reported in 2005, ICE did not maintain data on VSP 
activities in order to assess the program's performance since its 
establishment in 2003.[Footnote 9] In the fall of 2005, in response to 
GAO recommendations, ICE developed a database to track VSP workload 
and to serve as a performance management tool. The initial VSP 
tracking system, which was operational until 2010, collected 
information on the results of the review of visa applications by VSP 
agents, including tracking the number of visas screened, the number of 
visas vetted, and the number of visas recommended for denial by VSP 
agents. 

While the initial tracking system allowed ICE to track VSP workload 
and assist with performance assessment, the VSP did not establish 
program objectives until 2007. The Government Performance and Results 
Act of 1993 requires agencies to develop objective performance goals 
and report on their progress.[Footnote 10] In addition, GAO's 
Standards for Internal Control in the Federal Government state that 
U.S. agencies should monitor and evaluate the quality of performance 
over time.[Footnote 11] ICE's 5-year expansion plan for the VSP, 
issued in 2007, identified three primary mission objectives to enhance 
national security and public safety: 

1. identify and counteract threats before they reach the United States, 

2. identify not-yet-known threats to homeland security, and: 

3. maximize the law enforcement and counterterrorism value of the visa 
process. 

Furthermore, the expansion plan indicates that the program must 
measure its performance and demonstrate the value it contributes to 
homeland security, with mechanisms in place to adequately and 
accurately measure its performance. ICE identified six categories of 
performance measures to assess the progress toward the objectives of 
the program (see table 1): 

Table 1: Objectives and Performance Measures of the Visa Security 
Program: 

VSP objective: Identify and counteract threats before they reach the 
United States; 
VSP activities: Review of visa applications; 
Performance measures: 
1. Recommendations for refusal; 
Description: Any instance in which a VSP agent provides input, advice, 
or information that results in a consular officer's decision to deny a 
visa to an ineligible applicant. 
2. Additional enforcement outputs; 
Description: Represents the generation of additional law enforcement 
value, including terrorist watchlist entries, intelligence reports, 
investigative leads, and identification of terrorist trends and 
tactics. 
3. Derogatory information removal; 
Description: This measure reflects the removal of derogatory 
information by VSP agents that assists the travel of legitimate, 
eligible applicants. 

VSP objective: Identify not-yet-known threats; 
VSP activities: Initiate investigations; 
Performance measures: 
4. Open/closed investigations; 
Description: Captures the number of investigations opened and closed 
and the hours spent supporting domestic and foreign investigations. 

VSP objective: Maximizing law enforcement and counterterrorism value; 
VSP activities: Advice and training; 
Performance measures: 
5. Consular and other training; 
Description: Tracks the expert advice and training provided to 
consular officers. 

VSP objective: Maximizing law enforcement and counterterrorism value; 
VSP activities: Information sharing and liaison; 
Performance measures: 6. Assistance and liaison provided; 
Description: Measure the ways in which VSP agents liaise with other 
law enforcement, intelligence, and host country officials. 

Source: DHS 5-year expansion plan. 

[End of table] 

The VSP tracks and reports on activities through reports submitted 
regularly by VSP agents at overseas posts, through the activities 
recorded in the TECS database, and through the VSP tracking system. 
The VSP tracking system is used by ICE to monitor and report on 
performance of its VSP agents overseas. 

While ICE developed a VSP tracking system before the expansion plan 
identified the VSP objectives in 2007, ICE did not modify the system 
to collect data related to the performance measures and objectives in 
the expansion plan. The initial VSP tracking system tracked the 
results of one of the six identified performance measures--the number 
of recommendations for refusal--and the system did not track the other 
five performance measures (see table 1). Furthermore, the initial VSP 
tracking system did not collect performance data to evaluate progress 
toward two of its overall objectives, identifying not-yet-known 
threats and maximizing law enforcement and counterterrorism value. 

According to VSP officials, in April 2010, ICE implemented a new data 
tracking system intended, among other things, to better track 
performance, to better reflect the work performed by the VSP agents 
overseas, and to provide management with improved reports to better 
evaluate the VSP activities performed overseas. However, the new 
system does not collect performance data on three of the measures 
identified in the plan: (1) investigations opened or closed and hours 
spent supporting investigative activity, (2) consular and other 
training provided, and (3) assistance and liaison provided by VSP 
agents. Furthermore, while ICE has some information regarding the 
hours charged to VSP activities at posts, it cannot accurately 
determine the time VSP agents spend on non-VSP activities. An ICE 
official indicated that some activities are recorded outside of the 
VSP tracking system. For example, training for consular officers 
performed by VSP agents are often included in the weekly reports 
submitted to ICE. In addition, some of the liaison activities and 
assistance VSP agents provide to local law enforcement is captured in 
TECS and other DHS reports, such as search, arrest, and seizure 
reports. However, ICE does not track these activities systematically 
and cannot evaluate the comprehensive effort of these activities. ICE 
has requested upgrades to the VSP tracking system to capture 
additional data on training and liaison activities, but according to 
an ICE official, because of development delays, the system upgrades 
are not complete. 

ICE Does Not Produce Reports Evaluating VSP Performance: 

ICE has reported on the results of some VSP activities, but these 
reports do not address all of the VSP performance measures and 
therefore do not show progress toward each of the VSP mission 
objectives. For example, ICE annual reports and DHS's performance 
report for fiscal years 2008 to 2010 address only one of the six VSP 
performance measures--the number of visa applications denied because 
of recommendations from VSP agents. For example, ICE reported that the 
VSP recommended refusal of more than 900 visa applications in fiscal 
year 2008. ICE has presented some anecdotal examples of VSP 
participation in the visa process. For example, in testimony in 2009, 
the Assistant Secretary of ICE stated that the review of a specific 
visa applicant revealed information that resulted in the denial of the 
applicant's visa on the basis of national security. However, because 
these reports do not address all VSP performance measures, they do not 
comprehensively show progress toward all of the VSP objectives 
identified in the expansion plan. 

According to ICE officials, the VSP reviews monthly statistical 
reports on the activities performed by the VSP agents at each post, 
which allows management to identify discrepancies in the VSP 
activities and eliminate potential errors in the system. According to 
ICE, reports and information from the VSP tracking system are 
routinely used to inform budget decisions as well as other resource 
decisions including permanent and temporary duty staffing of VSP posts. 

VSP Data Collected at Posts Have Not Been Reliable: 

VSP data collected through the initial tracking system are 
significantly limited by inconsistencies. As we reported in 2005, ICE 
had not maintained measurable data to fully demonstrate the impact of 
VSP agents on the visa process. 

We have reported that for agencies to be able to assess progress 
toward performance goals, the performance measures, and the quality of 
the data supporting those measures, must be reliable and valid. 
[Footnote 12] Our analysis of VSP data collected at posts in fiscal 
years 2007 to 2010 identified significant limitations to the data's 
reliability. For example, at one post the data recorded for the 
category "sum of post-adjudication: vetted" rose from 1,630 
applications in fiscal year 2007 to 28,856 in fiscal year 2008, and 
then decreased to 2,754 in fiscal year 2009. In addition, another post 
recorded in fiscal year 2007 that VSP agents screened and vetted over 
13,000 applicants that received security advisory opinions, but 
recorded zero applicants in the security advisory opinion categories 
in any subsequent year. ICE officials indicated that ICE did not 
provide guidance to the VSP agents on the proper use of the tracking 
system, which likely resulted in inconsistent use of the system. 
Furthermore, according to an ICE official, the accuracy of the data in 
the tracking system is contingent upon VSP agents at post entering the 
data and using the system consistently across all posts. ICE officials 
acknowledged that turnover of VSP agents at many posts likely resulted 
in inconsistent use of the tracking system. 

Several Challenges Affect Visa Security Operations Overseas: 

The Visa Security Program faces several key challenges in implementing 
operations at overseas posts. First, limited guidance from 
headquarters regarding VSP operations has led to confusion and 
inconsistency among posts. Both VSP and consular officials indicated 
that ICE and State have issued limited official guidance about how VSP 
agents, consular officers, and DS officials should interact with one 
another at post or resolve disputes concerning specific visa 
applications. Second, VSP agents' advising and training of consular 
officers, as mandated by section 428 of the Homeland Security Act, 
varies from post to post, and some posts provided no training to 
consular officers. Third, VSP agents perform a variety of 
investigative and administrative functions beyond their visa security 
responsibilities, including criminal investigations, attaché 
functions, and regional responsibilities. Fourth, ICE's use of 30-day 
temporary duty assignments has created challenges and affected 
continuity of operations at some posts. Last, ICE does not provide 
language or country-specific training for its agents serving overseas, 
thereby limiting agents' ability to conduct interviews and coordinate 
with host country officials. 

VSP and Consular Interaction Has Been Difficult at Some Posts, and ICE 
Has Provided Limited Guidance for Such Interaction: 

Some VSP posts reported difficulties in the interactions between VSP 
agents and consular officers at post, and ICE and State had provided 
limited guidance in this regard. During our visits to several posts in 
2010, both VSP agents and consular officers at several posts we 
visited indicated that difficulties arose from confusion surrounding 
the VSP-consular relationship. For example, a consular official at one 
post stated that he does not know how to interact with the VSP agents 
or what to do with the information VSP agents provide on visa 
applicants, particularly when that information is insufficient to 
render an applicant ineligible for a visa. This official suggested 
State's Visa Office provide yearly guidance on the VSP-consular 
relationship and instructions on how to use information from the VSP 
tracking system reports. At another post, disagreement over how the 
consular section should share information with law enforcement 
agencies at post led to significant tension between VSP agents and DS 
officials. One consular official at this post stated that tension 
between VSP agents and DS officials at post sometimes prevents the 
consular section from receiving information in a timely manner. At a 
third post, the Consular Chief stated that VSP agents and consular 
officials rarely interacted with one another and that visa 
applications sometimes "disappeared" in the VSP unit. Consular 
officers at this post stated they did not understand the VSP's mission. 

ICE had issued limited guidance for VSP-consular interaction. ICE 
guidance, including the 2003 joint DHS-State MOU and the 2008 cable, 
does not explicitly address VSP-consular interaction at posts. The 
2003 MOU states that DHS, in consultation with State, will develop 
policies and procedures for DHS employees' overseas functions, but 
does not detail such policies. The 2008 cable directs VSP posts to 
develop standard operating procedures for a number of operational 
areas requiring interaction among VSP, consular officers, and DS 
officials, such as chain of command, dispute resolution practices, 
specific coordination procedures between VSP agents and State 
officials at post, and case selection procedures. However, the cable 
does not include guidelines for such procedures. The most recent ICE-
State MOU, issued in January 2011, addresses roles, responsibilities, 
and collaboration at VSP posts abroad. Specifically, the new MOU 
provides additional information on routine interaction between VSP 
agents and consular officers at post. For example, it indicates that 
interviewing officers can request VSP screening prior to an interview, 
VSP can request cases to be put on hold for additional investigation, 
and the consular chief may ask VSP to expedite cases. 

Most VSP Posts Have Not Developed Standard Operating Procedures: 

Most of the VSP posts had not developed written standard operating 
procedures as recommended by the 2008 ICE-State cable. Two of the 13 
posts had developed written standard operating procedures, but those 
procedures did not include all of the components identified in the 
2008 cable. Nine of the 13 consular sections and 13 of 13 VSP units 
reported having developed informal standard operating procedures, but 
the scope and content of these procedures varied widely. VSP agents at 
1 post told us that they were waiting for the issuance of the 2011 MOU 
before developing standard operating procedures and hoped that the MOU 
would provide additional operational guidance. At 1 post, VSP agents 
said that they had declined to develop standard operating procedures 
with the consular section and told consular officials that 
headquarters did not want them to develop "post-specific" standard 
operating procedures. 

The 2008 cable issued by ICE and State--intended to address consular 
concerns about the VSP, according to VSP officials--recommends that 
VSP posts develop standard operating procedures. The 2008 cable also 
directs regional security officers and VSP agents to work with 
consular officers to establish post-specific procedures to manage 
fraud investigations that comply with the 2003 MOU. However, VSP 
officials told us that they later instructed VSP agents to postpone 
development of post-specific standard operating procedures pending 
completion of the new MOU with State. The 2011 MOU states that ICE and 
State may develop post-specific standard operating procedures or other 
agreements regarding VSP operations, adding that these procedures may 
further refine, but must remain consistent with, the roles, 
responsibilities, and collaboration described in previous guidance. 

At posts that had developed standard operating procedures, consular 
officers stated that these procedures had improved the VSP-consular 
relationship. For example, a VSP agent at 1 post developed standard 
operating procedures with both the consular section and DS officials. 
The standard operating procedures at this post address the timing of 
VSP screening and vetting activities, how much time those activities 
will take, and points of contact in each agency. One VSP agent at this 
post described the process of developing these standard operating 
procedures as "painless," and the Consular Chief at post indicated 
that the VSP agents' reviews of visa applications were helpful because 
they provided a second review of visa applicants. In addition, a State 
official at another post that had developed standard operating 
procedures stated that having written guidance is crucial to a good 
relationship and valuable for new consular officers. 

Advising and Training Performed by VSP Agents Varies among Posts: 

Although the Homeland Security Act requires DHS to advise and train 
consular officers, VSP agents' training and advising of consular 
officers varies among posts. Section 428 of the Homeland Security Act 
directs VSP agents to provide "expert advice and training to consular 
officers regarding specific security threats relating to the 
adjudication of individual visa applications or classes of 
applications." In addition, the 2003 and 2011 MOUs also state that VSP 
agents will provide training to consular officers. 

Five of the 13 consular sections we interviewed stated that they had 
received no training from the VSP agents in the last year, and none of 
the VSP agents we interviewed reported providing training on specific 
security threats. At posts where VSP agents provided formal training 
for consular officers, topics covered included fraudulent documents, 
immigration law, human smuggling, and interviewing techniques. 
[Footnote 13] In addition, 6 of the 13 VSP agents interviewed provided 
introductory briefings to new consular officers during the past year, 
but the VSP agents at the other 7 posts did not provide these 
briefings. VSP agents at 3 posts stated that they do not have time to 
deliver advice and training to consular officers. At 1 post, VSP 
agents refused to allow consular officers to observe VSP screening and 
vetting activities on the ground that they did not have a law 
enforcement "need to know." At the embassy in Riyadh, consular 
officers generally agreed that the VSP agents do not provide advice 
and training and are not proactive in developing such programs. 
Additionally, Riyadh consular officers stated that the VSP agents do 
not advise them on the security situation, current trends, or types of 
information to collect to assist the agents. 

During our site visits and interviews, consular officers at several 
posts stated that they do not understand either the VSP's mission, or 
what the VSP agents do, or what types of information they collect. 
Officers at 6 of 13 consular sections interviewed requested additional 
training on the VSP's procedures and activities. For example, in 
Riyadh, consular officers generally agreed that greater knowledge of 
VSP activities would inform their interviews of visa applicants. At 1 
post the VSP agents provided lunchtime briefings on patterns or trends 
with implications for visa issuance, as well as an orientation for all 
new consular officers and allow consular officers to observe screening 
and vetting activities. The Consular Chief at this post stated that 
the training was very useful to consular officers and provided a 
better appreciation for how the VSP operates. 

Guidance for Visa Dispute Resolution Mechanism Has Not Helped Resolve 
Some VSP-Consular Disagreements: 

Although ICE and State have developed formal and informal procedures 
for resolving disputes about specific visas, both VSP and consular 
officials stated that these procedures are sometimes insufficient for 
resolving such disputes. Disagreement between VSP and consular 
officials about specific visa applications is generally infrequent, 
and posts usually resolve these disputes through informal discussions 
between VSP and consular officials. However, 4 of 6 posts we visited 
reported disagreements about specific visa cases that could not be 
resolved informally at the post, and that in some cases, unresolved 
disputes have led to tension at post. 

ICE and State officials told us that the two agencies sometimes have 
different interpretations of visa law, such as criteria for 
ineligibility based on "fraud or misrepresentation" or "crimes of 
moral turpitude." VSP officials also told us that they sometimes 
disagree with consular officials as to what degree of "association" 
with a terrorist is sufficient to render an applicant ineligible for a 
visa. Further, according to State officials, ICE and State have 
differing understandings of the VSP's jurisdiction under the Homeland 
Security Act. 

Although the 2003 MOU outlines a dispute resolution mechanism, both 
ICE and State officials told us in May 2010 that this mechanism is not 
sufficient. The 2003 MOU states, "If the chief of section or 
supervisory consular officer does not agree that the visa should be 
refused or revoked, the post will initiate a request for a security or 
other advisory opinion and the DHS employee will be consulted in its 
preparation." The MOU goes on to state that no advisory opinion will 
be issued thereafter without the full consultation of State and DHS. 
However, both VSP and consular officials told us that this process has 
not always worked well in practice and that security advisory opinions 
sometimes do not result in the resolution of the dispute. According to 
ICE and State officials, because the Secretary of Homeland Security 
has not delegated authority to refuse visas under section 428 of the 
Homeland Security Act, any irreconcilable dispute about a visa 
application ultimately must be elevated to the Secretary level for 
final resolution. ICE and State officials stated that to supplement 
this process, ICE and Consular Affairs officials at headquarters have 
sometimes used other informal methods to reach agreement on the 
adjudication of a visa. For example, ICE and State tried to resolve 
disagreements at the unit chief level when possible. 

The 2011 MOU addresses some of these issues by specifying that posts 
can raise disputes to the Managing Director of the Visa Office and the 
Assistant Director of ICE Homeland Security Investigations- 
International Affairs and, subsequently, to the State Assistant 
Secretary for Consular Affairs and the Director of ICE. 

VSP Agents' Performance of Nonconsular Activities Sometimes Constrains 
Visa Security Operations: 

In some cases, VSP agents' performance of activities unrelated to visa 
security has limited their ability to carry out visa security 
activities. VSP agents perform a variety of investigative and 
administrative functions in addition to their visa security workload, 
such as conducting nonconsular investigations, serving as ICE's 
official presence in the region, and performing the duties of DHS 
attachés. According to ICE officials, VSP agents perform non-VSP 
functions only after completing their visa security screening and 
vetting workload. However, both VSP agents and State officials at some 
posts told us that these other investigative and administrative 
functions sometimes slow or limit VSP agents' visa security-related 
activities. 

Existing guidance for VSP agents' performance of other non-VSP 
functions is limited. Section 428 of the Homeland Security Act states 
that one of the functions of VSP employees assigned to overseas posts 
is to conduct investigations with respect to consular matters under 
the jurisdiction of the Secretary of Homeland Security. For example, 
VSP agents may uncover and follow up on leads as a result of their 
screening and vetting activities. While the 2003 MOU between DHS and 
State states that DHS employees may conduct investigations with regard 
to consular matters under the jurisdiction of the Secretary of 
Homeland Security, those officials shall not conduct investigations 
that are within the jurisdiction of the Bureau of Diplomatic Security 
or the State Inspector General. Furthermore, VSP agents have the same 
position description as other ICE agents and have the authority to 
perform a wide range of tasks unrelated to visa security, including 
the ability to investigate a wide range of cases within ICE's 
jurisdiction. For example, VSP agents pursue cases related to bulk 
cash smuggling or human rights violations. According to ICE officials, 
ICE has not issued formal guidance that dictates how VSP agents should 
spend their time. ICE officials told us that, in some cases, requests 
to VSP agents come directly from other agencies, not from ICE itself. 
The 2011 MOU states that the primary responsibility of VSP agents is 
visa security. However, the 2011 MOU acknowledges that ICE personnel 
perform functions of regional or worldwide scope related to the post 
where they are assigned and that VSP agents may be called upon to 
perform other functions in support of the consulate. 

ICE officials told us that, at most Visa Security Program posts, the 
VSP units represent the only ICE presence at post, and that some VSP 
agents have ICE responsibilities for other countries in the region. 
ICE officials told us that VSP agents are frequently tasked with 
collateral requests to assist other ICE offices with investigations. 
For example, as part of an ongoing investigation into a U.S.-hosted 
Web site, one VSP agent assisted in the arrest of two individuals who 
were producing and distributing child pornography. VSP agents are also 
tasked with a variety of attaché functions, including serving as the 
liaison between ICE and other U.S. government agencies. For example, 
as the only DHS representative in Saudi Arabia, the VSP in Riyadh is 
also responsible for supporting the Coast Guard, Transportation 
Security Administration, official visitors, and detention and removal 
operations. In addition, the regional responsibilities of the VSP 
agent may require the agent to work on other investigations or respond 
to collateral requests in other countries in the region. At one post, 
VSP agents told us that these responsibilities were essentially 
nominal and involved very little additional work. In Riyadh, these 
regional responsibilities involved frequent travel throughout the 
region to perform other investigations. 

ICE officials told us that agents pursue these other investigations 
only after completing Visa Security Program responsibilities. However, 
consular officers at some posts told us that these additional 
investigations interfered with completion of visa security work and 
made ICE agents less available to consular officers. For example, at 
one post, the VSP agent told us he was sometimes unable to complete 
his screening and vetting activities because of other ICE 
responsibilities. At another post, VSP agents worked alongside other 
ICE agents, and the VSP agent at this post told us he focused 
primarily on visa security work. In our interviews, VSP agents' 
estimates of the amount of time spent on nonvisa requests and 
investigations ranged from 5 percent to 40 percent. ICE does not track 
the time VSP agents spend on both its visa security activities and its 
nonvisa requests and investigations. While the VSP expansion plan 
identifies the hours spent performing investigations as a performance 
measure, ICE can not accurately determine the amount of time that VSP 
agents spend on investigative and visa security activities, as its 
systems do not distinguish between the time VSP agents and other ICE 
officials spend on investigations at post. Furthermore, the VSP 
tracking system does not collect data on the time VSP agents spend on 
visa security activities. ICE cannot identify the time VSP agents 
spend on visa security operations or on the other investigation and 
attaché functions performed by VSP agents stationed overseas. 

VSP agents' additional investigations also overlap with consular and 
DS investigations at some posts, leading to confusion in the consular 
section. According to the 2008 joint ICE-State cable to VSP posts, VSP 
agents' responsibility to identify the potential exploitation of the 
visa process by terrorists frequently overlaps the responsibilities of 
consular units investigating fraud and criminal investigations. 
According to one State official, all three units have a general 
understanding of their respective jurisdictions but sometimes 
interpret these jurisdictions differently. Generally, consular fraud 
investigations begin with consular officers, who check for fraudulent 
documentation and application information. When consular officers 
notice organized fraud activity, they refer the case to the post's 
Fraud Prevention Unit. When this organized activity is criminal, the 
post's DS office launches an investigation. When the activity is 
terrorism-related, the post's VSP agents investigate. However, some 
posts we visited had experienced tension between VSP agents and other 
law enforcement agency officials at post. For example, at one post, 
the VSP agents and DS officials disagreed about whether the VSP agent 
had authority and responsibility to conduct investigations locally. 
Consular officials at another post wanted a DS officer to serve as a 
liaison between VSP and the consular section. The 2011 MOU describes 
the types of cases that fall under the jurisdiction of diplomatic 
security investigators and VSP agents, and states that cases that fall 
under the responsibility of both parties will require the officials to 
notify each other. 

Staffing Shortages and Use of Temporary Duty Agents Have Caused 
Difficulties at Some Posts: 

Staffing shortages, and a reliance on temporary duty VSP agents to 
fill such shortages, have led to difficulties at some posts. Consular 
officers at 3 of 13 posts we interviewed discussed challenges caused 
by this use of temporary duty agents. For example, the VSP unit in 
Riyadh used two temporary duty agents per month in fiscal year 2009 
and one temporary duty agent per month in fiscal year 2010. Although 
ICE officials indicated that the VSP filled its positions in Riyadh as 
of December 2010, both VSP and consular officials stated that this 
reliance on temporary duty agents affected continuity of operations. 
One consular official pointed to a "severe lack of coverage" for 
consular operations in Riyadh, because the unit was not fully staffed 
and relied on temporary duty agents. Consular officers stated that 
agents in Riyadh are rarely available to answer questions and that the 
value of these temporary duty agents was limited, because it took them 
several weeks of their 30-day tour to learn VSP policies and 
procedures. Additionally, consular officers stated that temporary duty 
agents' grounds for recommending refusal of visa applications were 
sometimes inconsistent or insufficient. Lack of staff at VSPs in 
Jeddah and Dhahran also created delays and forced consular officers to 
re-adjudicate cases because VSP agents delayed an application beyond 
the point where consular "name checks" of applicants expire. According 
to one VSP official, reliance on temporary duty agents limits 
continuity of operations at post. 

The Visa Security Program's 5-year plan identified recruitment of 
qualified personnel as a challenge and recommended incentives for VSP 
agents as critical to the program's mission, stating, "These 
assignments present significant attendant lifestyle difficulties. If 
the mission is to be accomplished, ICE, like State, needs a way to 
provide incentives for qualified personnel to accept these hardship 
assignments." However, according to ICE officials, ICE has not has not 
provided incentives to facilitate recruitment for hardship posts. 
[Footnote 14] ICE officials stated that they have had difficulty 
attracting agents to Saudi Arabia, and ICE agents at post told us they 
have little incentive to volunteer for Visa Security Program 
assignments. ICE officials in headquarters stated that opportunities 
to gain international experience and earn danger pay are the primary 
recruitment incentives for VSP service. Additionally, according to ICE 
officials, some hardship posts, such as Riyadh, now allow spouses to 
accompany agents during their tour. However, according to an ICE 
official, ICE does not offer career and financial incentives for 
personnel at hardship posts, such as Washington, D.C.-based locality 
pay or priority consideration for onward assignments, which State 
Foreign Service Officers receive when posted at the same locations. 
[Footnote 15] 

VSP Agents Do Not Receive Language Training, and Additional Training 
May Be Helpful: 

VSP agents generally do not receive foreign language training before 
deployment overseas. Section 428 of the Homeland Security Act allows 
that, to the extent possible, VSP agents shall be provided the 
necessary training to enable them to perform their designated 
functions--reviewing visa applications, and conducting investigations 
on consular matters--including training in foreign languages, 
interview techniques, and fraud detection techniques, in conditions in 
the particular country where each employee is assigned, and in other 
appropriate areas of study. The 2003 MOU states that DHS training and 
assignment policies will emphasize identification or development of 
personnel with the ability to speak the host country language and 
"experience in or knowledge of the host country and extensive 
understanding of terrorism or other homeland security concerns in the 
host country." The 2011 MOU states that whenever practical, VSP staff 
should receive interagency training and, prior to deployment, should 
undergo orientation including, if possible, appropriate specialized 
consultations and briefings with Consular Affairs and Diplomatic 
Security officers. 

ICE provides some training for VSP agents. ICE trains agents for Visa 
Security Program duties in a 3-week training course, sponsored by ICE 
and two other DHS divisions and conducted three times per year at the 
Federal Law Enforcement Training Center in Glynco, Georgia. This 
training includes, among other things, interview techniques, VSP 
systems, document examination, and terrorist trends. 

However, ICE does not have a program for language training and has not 
established language training as a requirement for VSP agents. To 
date, VSP agents at one post have received language training. This was 
because, at one post, the Chief of Mission required language training 
as a condition for approving the VSP's request to send personnel to 
post. According to a VSP agent who received this training at the start 
of his deployment, language skills were "critical" because he was able 
to interact with host country law enforcement and conduct interviews. 
Both the VSP agent and Consul General at this post recommended that 
all VSP agents receive language training. According to ICE officials, 
ICE's ability to provide language training for VSP agents is limited 
by budgetary constraints. Because some VSP agents serve 1-or 2-year 
tours, language training can be an expensive investment given the 
amount of time an agent would actually use this training. ICE 
officials told us that, when possible, they deploy ICE agents with 
existing language skills. ICE also indicated that self-study language 
training is available for VSP agents. 

According to some consular officers and VSP agents, VSP agents who 
have prior experience with immigration law may be better able to 
advise consular officers than officers whose training on the subject 
is limited to the VSP training course. For example, a consular 
official at one post stated that she found VSP agents with backgrounds 
in the former Immigration and Naturalization Service to be 
particularly helpful because they have extensive expertise on 
immigration law. All ICE agents receive basic instruction on 
immigration law, and ICE provides additional instruction to its agents 
during VSP training. One VSP agent stated he was unsure whether this 
training would provide sufficient expertise in immigration law for 
less experienced agents. VSP agents do not attend State's Consular 
General training at the Foreign Service Institute, although VSP agents 
and consular officials at some posts stated that attending such 
training would be beneficial. VSP agents at several posts also 
expressed a desire for more frequent opportunities to share problems, 
techniques, and best practices with headquarters and other VSP units. 

ICE Has Not Fully Adhered to the VSP Expansion Plan: 

Although ICE developed a plan to expand the VSP to additional high-
risk visa-issuing posts, ICE has not fully adhered to the plan or kept 
it up to date. The VSP 5-year expansion plan, developed in 2007, 
identifies 14 posts for expansion between 2009 and 2010, but 9 of 
these locations have not been established, and ICE has not updated the 
plan to reflect the current situation. Furthermore, ICE has not fully 
addressed remaining visa risk in high-risk posts that do not have a 
VSP presence. ICE, with input from State, developed a list of 
worldwide visa-issuing posts that are ranked according to visa risk. 
Although the expansion plan states that risk analysis is the primary 
input to VSP site selection and that the expansion plan represents an 
effort to address visa risk, ICE has not expanded the VSP to some high-
risk posts. For example, 11 of the top 20 high-risk posts identified 
by ICE and State are not covered by VSP. The expansion of the VSP may 
be limited by a number of factors--including budget limitations and 
objections from State officials at some posts--and ICE has not 
identified possible alternatives that would provide the additional 
security of VSP review at those posts that do not have a VSP presence. 

VSP Expansion Plan Has Not Been Fully Followed or Updated: 

Although ICE has expanded the VSP to a total of 19 posts in 15 
countries, the agency has not fully followed the 5-year expansion 
plan. ICE's plan identified 14 posts for expansion in 2009 and 2010, 
but ICE did not establish VSP units at 9 of these 14 posts. Further, 
ICE officials stated that 3 locations planned for 2011 may not be 
opened because of budget constraints. Moreover, the expansion plan has 
not been updated since its release in 2007, although ICE officials 
said that the expansion plan will be revised in 2011. In the expansion 
plan, ICE notes that the locations it identifies for expansion reflect 
its best current assessment of the factors relevant to decision makers 
and that evolving variables, including changes in risk and the results 
of site assessments to determine the feasibility and timing of 
deployment, may affect, among other things, the ultimate selection of 
locations for VSP expansion. The plan states that ICE will continue to 
update its assessment of conditions based on the most current 
information and intelligence. 

A number of factors have limited the VSP's expansion and consequently 
its coverage of global visa risk. According to ICE officials, 
expansion of the VSP has been constrained by budget limitations, 
difficulties in obtaining visas to certain countries, State's mandate 
to reduce personnel overseas, and objections from State officials at 
some posts for reasons such as limited embassy space and security 
concerns. For example, space limitations and security concerns are 
currently hindering VSP's expansion to a high-risk post of interest to 
ICE officials. The inability to obtain visas to another country is 
preventing ICE officials from conducting a preliminary site assessment 
at a possible expansion post in that country. 

ICE Has Not Taken Steps to Address Remaining Visa Risk: 

ICE has not consistently located VSP units at the posts identified as 
highest risk and has not ensured VSP coverage for the posts without a 
VSP unit, leaving significant gaps in the program's capacity to 
address global visa risk. The VSP expansion plan states that global 
visa risk is substantial and that the VSP addresses threats that could 
exploit the visa process. ICE, in consultation with State, ranked 216 
overseas posts based upon the visa security risk posed at each 
location. However, 5 of the 19 established VSP units are located at 
posts other than the 50 posts in the top tier, or critical quartile, 
of the agencies' rankings of high-risk posts. One established location 
ranks 70th on the list, while another ranks 86th. ICE officials 
explained that certain posts were opened to achieve regional coverage 
for other ICE activities. Moreover, of the 20 posts identified by ICE 
and State as highest risk, 11 do not have a VSP unit. 

ICE officials stated that visa risk at posts without a VSP presence is 
addressed through the security advisory opinion (SAO) process, which 
provides in-depth screening and vetting of certain visa applicants at 
posts worldwide, regardless of whether the post has a VSP unit. 
[Footnote 16] SAOs are initiated when an applicant meets certain 
predefined criteria or when a consular officer requests an SAO for a 
specific visa application. Officials from several agencies, including 
ICE and State, participate in certain categories of SAO reviews in 
Washington, D.C. However, while the SAO process can mitigate some visa 
risk at those locations without a VSP unit, it does not ensure the 
breadth of coverage provided by VSP agents through the routine 
screening and vetting of applicants who are not subjected to the SAO 
process. 

ICE's expansion plan does not identify ways in which to address this 
lack of VSP coverage at the remaining high-risk posts it identified. 
However, ICE officials in headquarters indicated that they have used 
TECS, the primary database used by VSP agents to screen and vet visa 
applicants, to conduct screening and vetting domestically when a VSP 
unit at a post experienced computer problems or temporary personnel 
shortages. TECS interfaces with other law enforcement databases can be 
accessed by ICE officials. Similarly, one VSP agent stated that agents 
can perform screening and vetting for other posts in the event of a 
computer systems outage. In addition, ICE officials stated that they 
are currently developing a system that will make the screening and 
vetting process more automated and will provide information to 
consular officers in advance of the visa applicant's interview and 
adjudication decision. Further, several ICE and State officials at 
post indicated that the screening and vetting of visa applicants could 
be performed domestically on a permanent basis. 

Conclusion: 

The Visa Security Program is intended to build additional security 
into the visa process by incorporating a law enforcement function at 
posts with the highest risk. However, the program is hampered in its 
efforts to strengthen visa security globally. A lack of comprehensive 
performance data collected since the establishment of the VSP in 2003 
hinders ICE's ability to evaluate and report on the extent to which 
the VSP enhances the security of the visa process. Although ICE 
officials state that they have made improvements to their data 
tracking systems, the agency cannot demonstrate the progress of the 
VSP prior to 2010 toward its stated objectives of enhancing public 
safety and national security. Furthermore, the responsibility of VSP 
agents to perform investigations unrelated to visa security may limit 
their ability to carry out visa security activities, their primary 
responsibility, further affecting the relationship with consular 
officials, and may limit the VSP's performance and its ability to 
enhance national security and public safety. In addition, the VSP is 
not contributing to the visa process at many high-risk posts. As a 
result, there is a significant gap in the additional scrutiny that VSP 
provides in the visa process among many posts considered to be of high 
risk. ICE has not considered other options to strengthen security at 
those posts where VSP does not have a physical presence. The VSP will 
be limited in its goal to minimize global visa risk until DHS 
addresses the challenges of guidance, staffing, and data collection, 
and provides coverage and support to those high-risk posts without VSP 
agents at post. 

Recommendations for Executive Action: 

To ensure that the Visa Security Program enhances the security of the 
visa process at posts overseas, we recommend that the Secretary of 
Homeland Security take the following four actions: 

1. ensure that the VSP tracking system collects reliable data on all 
performance measures, to allow ICE to accurately evaluate VSP 
performance and report to Congress on progress toward the VSP mission 
objectives; 

2. issue guidance requiring VSP agents to provide training for 
consular officers as mandated by section 428 of the Homeland Security 
Act; 

3. develop a mechanism to track the amount of time spent by VSP agents 
on visa security activities and other investigations, in order to 
determine appropriate staffing levels and resource needs for VSP 
operations at posts overseas to ensure visa security operations are 
not limited; and: 

4. develop a plan to provide VSP coverage at high-risk posts where the 
possibility of deploying agents may be limited. 

Agency Comments and our Evaluation: 

We provided a draft of our report to DHS and State. DHS provided 
written comments about the draft, which are reproduced in appendix II. 
State did not provide official comments on the draft. In addition, DHS 
and State provided technical comments, which we incorporated as 
appropriate. 

DHS agreed with our recommendation that the department issue guidance 
instructing VSP agents to provide training to consular officers as 
mandated by section 428 of the Homeland Security Act. In addition, DHS 
concurred with our recommendation that it develop a plan to provide 
coverage for posts that lack a VSP presence and indicated that it is 
taking steps to address this recommendation. 

DHS did not agree with our recommendation that it ensure that the VSP 
tracking system collected reliable data on all performance measures. 
In its written comments, DHS stated that the VSP currently captures 
all the required performance metrics identified in its 5-year 
expansion plan through the VSP tracking system and TECS. Although we 
acknowledge that ICE is collecting some data on the performance 
measures identified in the VSP expansion plan, our analysis showed 
that the data were not sufficient to accurately demonstrate the 
progress made toward the stated objectives. As we report, the 5-year 
expansion plan identifies six performance measures to assess VSP 
performance. The documents that ICE provided us indicate that ICE has 
collected comprehensive data on three of the performance measures, but 
not on the three remaining performance measures. Specifically, ICE did 
not provide us evidence that it collected data on the assistance and 
liaison activities performed by VSP. Furthermore, although ICE 
collects some information on the hours that VSP agents spend on 
investigations and the training they provided to consular officials, 
the VSP tracking system and TECS do not collect comprehensive data on 
the activities performed by all of its VSP agents abroad. Without 
collecting comprehensive data on the performance measures identified 
by ICE, DHS cannot accurately demonstrate progress toward its stated 
objectives of enhancing national security. Therefore we have retained 
our recommendation. 

DHS did not agree with our draft recommendation to issue operational 
guidance for VSP posts. DHS stated that the 2011 MOU provides general 
guidance for the visa process and the development of standard 
operating procedures. We acknowledge that the MOU between ICE and 
State, signed on January 11, 2011, clarifies the respective roles and 
responsibilities of VSP agents and consular officers at post and 
states that posts may develop standard operating procedures that were 
identified in the 2008 cable. Therefore, we are removing our draft 
recommendation from the report. However, although the 2011 MOU and the 
2008 cable provide a basis for developing effective standard operating 
procedures, we remain concerned that, during our review, most posts 
had not developed these procedures. Only 2 of 13 posts we contacted 
had developed standard operating procedures as recommended in the 2008 
cable. At the 2 posts that developed standard operating procedures, 
consular officers stated that procedures had improved the consular-VSP 
relationship. It is critical for DHS to encourage posts to develop 
standard operating procedures to improve the VSP-consular relationship 
and strengthen VSP operations at posts. 

DHS also did not agree with our recommendation to develop a mechanism 
to track the amount of time that VSP agents spend on visa security 
activities and other investigations. DHS states that ICE currently 
tracks case investigation hours through TECS, and that adding the 
metric to the VSP tracking system would be redundant. DHS's response 
does not address our finding that ICE does not have a mechanism that 
allows the agency to track the amount of time VSP agents spend on both 
investigation hours and hours spent on visa security activities. 
Although ICE states that its system tracks case hours of its agents, 
we found, based on ICE documentation, that ICE cannot accurately 
determine the amount of time that VSP agents spend on investigative 
and visa security activities. First, the reports that ICE provided us 
show the hours ICE officials spent on investigative and 
noninvestigative activities, but do not distinguish between the hours 
logged by VSP agents and hours logged by other ICE officials at posts 
abroad. During our structured interviews, VSP agents indicated that 
the time they spent on activities other than visa security reviews 
ranged from 5 to 40 percent. Second, our analysis of the VSP tracking 
system, which is intended to track visa-related activities of VSP 
agents, identified significant limitations to the reliability of the 
data. Thus, ICE does not maintain accurate data on the time VSP agents 
spend on visa security activities at posts. The VSP is intended to add 
additional security to the visa process through the screening and 
vetting of visa applications by experienced law enforcement officers. 
Without accurate data to determine the amount of time VSP agents spend 
on the visa security activities, ICE will not be able to determine 
whether the current allocations of staffing and resources at posts are 
adequate to carry out the visa security reviews and thereby fulfill 
the VSP objective of enhancing national security and public safety. 
Therefore, we have not changed our recommendation. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
Secretaries of Homeland Security and State, as well as other 
interested Members of Congress. In addition, this report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions, 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 contribution to this 
report are listed in appendix III. 

Signed by: 

Jess T. Ford: 
Director, International Affairs and Trade: 

[End of section] 

Appendix I: Scope and Methodology: 

To assess the ability of the Department of Homeland Security (DHS) to 
measure the objectives and performance of the Visa Security Program 
(VSP), we reviewed VSP mission objectives and performance measures 
identified in Bureau of Immigration and Custom Enforcement's (ICE) 5- 
year expansion plan. We reviewed data from the VSP tracking system, 
used to collect information on daily VSP activities, and compared the 
data collected from the system with the measures and mission 
objectives identified in the expansion plan. On the basis of 
inconsistencies of the data from the reporting systems prior to 2010 
that we identified through our analysis of the reports and confirmed 
with ICE officials, we determined that the data that we received were 
not sufficiently reliable for the purposes of this report. We also 
reviewed performance reports from DHS and ICE that included references 
to the VSP. In addition, we met with ICE officials in Washington, 
D.C., who manage the VSP. We also observed VSP agents at six U.S. 
embassies and consulates conducting their daily screening and vetting 
activities and using the VSP Tracking System. 

To identify challenges to the VSP's capacity to accomplish its goals, 
we reviewed the Homeland Security Act of 2002, which authorized DHS to 
assign DHS employees to posts overseas to support the visa process 
through various functions. We also reviewed documentation including 
the 2003 memorandum of understanding (MOU) between DHS and the 
Department of State (State) governing the implementation of section 
428 of the Homeland Security Act; the 2004 administrative MOU; the 
2008 cable directing VSP units to develop standard operating 
procedures; the 2011 MOU explaining the roles, responsibilities, and 
collaboration of VSP agents and other officials at posts overseas; 
VSP's training curriculum; and the VSP expansion plan. We met with ICE 
officials in Washington, D.C., who manage the VSP and State officials 
from the Bureaus of Consular Affairs and Diplomatic Security. We also 
visited six U.S. embassies and consulates with established VSP units 
where we interviewed and observed VSP agents, State officials from the 
Bureaus of Consular Affairs and Diplomatic Security, and chiefs of 
mission or deputy chiefs of mission. In order to allow for post-by-
post comparison, we administered a set of structured interview 
questions to both the VSP units and consular sections in person at the 
six previously mentioned posts and by phone at an additional seven VSP 
locations. The five most recently established VSP posts, as well as 
one unit that underwent recent personnel turnover, were not included 
in our review. 

To examine DHS's efforts to expand the Visa Security Program, we 
reviewed relevant documents such as the VSP 5-year expansion plan, 
which includes the mission and contributions of the program, criteria 
for selecting new expansion posts, cost estimates for establishing and 
maintaining VSP posts, and projected budget information. In addition, 
we reviewed the ranked list of visa-issuing posts identified by ICE, 
in consultation with State. We then compared the expansion plan and 
the ranked list of posts with the VSP's actual expansion between 2005 
and 2010. In addition, we reviewed the requests submitted by ICE to 
overseas posts for expansion of the program. Our interviews with ICE 
and State officials at 13 VSP locations worldwide and in Washington, 
D.C., also informed this analysis. 

[End of section] 

Appendix II: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528 

March 21, 2011: 

Jess Ford: 
Director, International Affairs and Trade: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re;	Draft Report GAO-11-315: "Border Security: The Department of 
Homeland Security's Visa Security Program Needs to Improve Performance 
Evaluation and Better Address Visa Risk Worldwide. 

Dear Mr. Ford: 

The Department of Homeland Security (DHS) and U.S. Immigration and 
Customs Enforcement (ICE) appreciate the opportunity to comment on the 
draft report. We have addressed each recommendation separately below: 

Recommendation 1: Ensure that the VSP tracking system collects 
reliable data on all performance measures, to allow ICE to accurately 
evaluate VSP performance and report to Congress on progress toward the 
VSP mission objectives. 

Response: DHS does not concur. The Visa Security Program (VSP) 
captures all required metrics associated with its five-year plan 
through the VSPTS and Treasury Enforcement Communications System 
(TECS). The VSPTS and TECS are the two systems of record for VSP. 
Currently, the VSPTS records: recommendations for refusal, additional 
enforcement outcomes, derogatory information removal, opened 
investigations (with supplementary information such as case hours 
regarding investigations recorded into TECS), and assistance and 
liaison activities. Consular and other training is reported to the ICE 
Homeland Security Investigations, Office of International Affairs (HSI 
OIA) directly from ICE Attaché offices in a weekly metrics report. 
This formalized procedure for reporting training would make reporting 
in the VSPTS redundant. 

Recommendation 2: Issue additional operational guidance for VSP posts, 
including standard operating procedures for the visa process and the 
dispute resolution process. 

Response: DHS does not concur. The 2011 "Memorandum of Understanding 
among U.S. Immigration and Customs Enforcement of the Department of 
Homeland Security and the Bureaus of Consular Affairs and Diplomatic 
Security of the Department of State on Roles, Responsibilities and 
Collaboration at Visa Security Units Abroad" (MOU) recognizes that the 
circumstances at each post are unique. The MOU provides general 
guidance and recommends that management at each post negotiate a local 
standard operating procedure (SOP) to fit their needs. ICE 
headquarters' program managers assist posts in developing these SOPs 
according to post specific needs. Standard procedures across all posts 
would prove overly restrictive, given the dynamic environment of 
overseas operations. Each VSP post currently has an individualized 
plan that is specific to their location. 

Recommendation 3: Issue guidance requiring VSP agents to provide 
training for consular officers as mandated by section 428 of the 
Homeland Security Act. 

Response: DHS concurs. While VSP headquarters can provide general 
training guidance for all posts, it is incumbent upon each ICE Attaché 
and corresponding Department of State (DOS) manager to identify post-
specific training needs relative to their respective environments. 

Recommendation 4: Develop a mechanism to track the amount of time 
spend by VSP agents on visa security activities and other 
investigations, in order to determine appropriate staffing levels and 
resource needs for VSP operations at posts overseas to ensure visa 
security operations are not limited. 

Response: DHS does not concur. ICE currently tracks case hours through 
existing ICE systems which are standardized throughout the agency. 
TECS is the system of record that tracks case investigation hours of 
all ICE agents worldwide. Adding this function to the VSPTS would be 
redundant. 

Recommendation 5: Develop a plan to provide VSP coverage at high-risk 
posts where the possibility of deploying agents may be limited. 

Response: DHS concurs. ICE is actively addressing this recommendation. 

ICE identified alternatives for VSP review at high risk posts that 
currently do not have a physical VSP presence. ICE currently 
participates in the interagency Security Advisory Opinion (SAO) 
process, which reviews the highest risk visa applicants, covering all 
worldwide posts. ICE is currently enhancing its IT systems, in 
coordination with U.S. Customs & Border Protection (CBP) and DOS. 
These changes will allow the screening and reviewing of all applicants 
at all posts worldwide. Use of TECS and CBP's Automated Targeting 
System (ATS), in addition to improved transfer of information with 
DOS's Consular Consolidated Database (CCD) and Visa Opinion 
Information System (VOIS) will enhance communication within DHS
(ICE/CBP) and DOS, thereby strengthening the layered defense strategy. 

Both the physical presence of ICE special agents abroad and worldwide 
coverage via IT enhancements are integral parts of VSP. IT 
enhancements will enable ICE to conduct visa security investigations 
at all existing ICE Attaché offices thereby providing coverage to an 
additional 34 high risk posts in furtherance of the VSP expansion plan. 

DHS generally concurs with Government Accountability Office (GAO) 
recommendations three and five; however, DHS does not concur with 
recommendations one, two and four. DHS is taking corrective actions to 
address the overall recommendations. Thank you for the opportunity to 
comment on this Draft Report. We look forward to working with you on 
future Department of Homeland Security issues. 

Sincerely, 

Signed by: 

Jim	H. Crumpacker: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Jess T. Ford, (202) 512-4128 or fordj@gao.gov. 

Staff Acknowledgments: 

In addition to the contact names above, Anthony Moran (Assistant 
Director) and Jeff Miller, Ashley Vaughan, Dave Bieler, Katie Bernet, 
Amanda Miller, Mary Moutsos, Sushmita Srikanth, and Brian Egger made 
key contributions to this report. 

[End of section] 

Footnotes: 

[1] The Homeland Security Act of 2002 (P.L. 107-296) established DHS 
and gave the Secretary of Homeland Security authority to issue 
regulations with respect to the issuance and refusal of visas. 

[2] Section 428 of the Homeland Security Act authorizes the Secretary 
of Homeland Security to assign DHS employees to consular posts 
overseas to support the visa process through various functions. 

[3] GAO, Border Security: Actions Needed to Strengthen Management of 
Department of Homeland Security's Visa Security Program, [hyperlink, 
http://www.gao.gov/products/GAO-05-801] (Washington, D.C.: July 2005). 

[4] In this report, we use the word "post" to identify U.S. embassies 
and consulates. 

[5] The State Department Bureau of Diplomatic Security is responsible 
for personal protection, protection of facilities, investigations, 
threat analysis, and training. Overseas, Diplomatic Security personnel 
include regional security officers, who are responsible for the 
security of facilities, personnel, and information at U.S. overseas 
facilities, and assistant regional security officer-investigators, who 
focus on investigations into passport and visa fraud at posts with 
high levels of fraud. 

[6] The security advisory opinion process is a multi-agency review 
process that collects additional information on applicants to provide 
a recommendation to posts to issue or refuse a visa. 

[7] TECS is an updated and modified version of the former Treasury 
Enforcement Communications System, which is principally owned and 
managed by U.S. Customs and Border Protection. TECS is an automated 
enforcement and antiterrorism database that provides information for 
law enforcement and border security purposes, and can exchange 
information automatically with other U.S. government systems. 

[8] Prior to adjudication, every visa application undergoes biometric 
and biographic clearances against several databases, including Facial 
Recognition, Consular Lookout and Support System, and Terrorist 
Screening databases. 

[9] [hyperlink, http://www.gao.gov/products/GAO-05-801]. 

[10] P.L. 103-62. 

[11] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[12] [hyperlink, http://www.gao.gov/products/GAO/GGD-10.1.20], The 
Results Act: An Evaluator's Guide to Assessing Agency Annual 
Performance Plans (Washington, D.C.: April 1998). 

[13] In our structured interview, we provided several examples of 
training, including "briefings, brown bags, hands-on exercises, 
reports or other written products" We asked both the VSP agents and 
the consular section to determine whether these sessions were "formal" 
or "informal." 

[14] State has designated roughly two-thirds of its 268 overseas posts 
as hardship posts. Staff working in such locations often encounter 
harsh environmental and living conditions that can include inadequate 
medical facilities, limited opportunities for spousal employment, poor 
schools, high levels of crime, and severe climate. 

[15] Locality pay is a salary comparability benefit, typically 
available to domestic federal employees only to attract workers in the 
continental United States to the federal government versus the private 
sector. 

[16] SAOs provide an opinion or clearance from Washington on whether 
to issue a visa to an applicant. These clearances are required for a 
number of reasons, including whether an applicant's name appears as a 
"hit" in the name-check system, or if the applicant's country of 
origin is a state sponsor of terrorism. 

[End of section] 

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