This is the accessible text file for GAO report number GAO-05-801 entitled 'Border Security: Actions Needed to Strengthen Management of Department of Homeland Security's Visa Security Program' which was released on July 29, 2005. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Report to Congressional Committees: July 2005: Border Security: Actions Needed to Strengthen Management of Department of Homeland Security's Visa Security Program: [Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-801]: GAO Highlights: Highlights of GAO-05-801, a report to congressional committees: Why GAO Did This Study: 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. What GAO Found: 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. DHS Participation in the Visa Process in Saudi Arabia: [See PDF for image] [End of figure] What GAO Recommends: GAO recommends that the Secretary of Homeland Security (1) develop a strategic plan to guide visa security operations and (2) develop and maintain performance data that demonstrate the impact of the Visa Security Program. In addition, Congress may wish to consider amending section 428(i) of the Homeland Security Act to allow DHS the flexibility to determine the extent to which the VSOs in Saudi Arabia will review applications, based upon the development of a risk-assessment tool. We received comments from DHS and State, both of which agreed with our report. DHS stated it was developing a strategic plan and a system to measure program impact, as we recommended. www.gao.gov/cgi-bin/getrpt?GAO-05-801. To view the full product, including the scope and methodology, click on the link above. For more information, contact Jess Ford at (202) 512- 4128 or fordj@gao.gov. [End of section] Contents: Letter: Results in Brief: Background: Several Factors Have Limited the Impact of Visa Security Operations in Saudi Arabia: DHS's Plans for Expansion of the Visa Security Program Delayed: Conclusions: Recommendations for Executive Action: Matter for Congressional Consideration: Agency Comments and Our Evaluation: Appendixes: Appendix I: Scope and Methodology: Appendix II: Comments from the Department of Homeland Security: GAO Comments: Appendix III: Comments from the Department of State: Appendix IV: GAO Contacts and Staff Acknowledgements: Table: Table 1: Visa Security Program Expansion: Figures: Figure 1: Establishment and Implementation of the Visa Security Program: Figure 2: Visa Process in Saudi Arabia: Abbreviations: CLASS: Consular Lookout and Support System: DHS: Department of Homeland Security: ICE: Immigration and Customs Enforcement: VSO: Visa Security Officer: Letter July 29, 2005: Congressional Committees: The September 11, 2001, terrorist attacks highlighted vulnerabilities that existed in the visa process, particularly the lack of emphasis placed on using interviews and application reviews as antiterrorism tools.[Footnote 1] In October 2002, we reported that the visa process should be strengthened and that increased priority should be given to national security.[Footnote 2] On November 25, 2002, Congress passed the Homeland Security Act of 2002. The act provides, among other things, for the assignment of Department of Homeland Security (DHS) employees to U.S. embassies and consulates to provide expert advice and training to consular officers regarding visa security, among other things.[Footnote 3] In particular, the act mandated that DHS personnel, referred to as Visa Security Officers (VSO), in Saudi Arabia review all visa applications prior to final adjudication by Department of State (State) consular officers. By September 2003, VSOs had assumed their responsibilities at U.S. posts in Riyadh and Jeddah, Saudi Arabia. DHS plans to expand the Visa Security Program[Footnote 4] to additional posts throughout fiscal years 2005 and 2006.[Footnote 5] Congress appropriated $10 million for the program in fiscal year 2005, and DHS requested $15 million for fiscal year 2006. Due to 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 the program to other consular posts overseas. To assess DHS operations in Saudi Arabia, we reviewed documentation on and observed visa operations at the U.S. Embassy in Riyadh and the U.S. Consulate in Jeddah. In Saudi Arabia and Washington, D.C., we interviewed DHS officials who manage the Visa Security Program, as well as State consular officials. To assess DHS's plans for expansion of the Visa Security Program, we visited two of the five posts to which DHS plans to expand the program and interviewed consular and embassy officials, including the chiefs and deputy chiefs of mission, at these locations to discuss the posts' plans for the VSOs. We also spoke with the consuls general from the other three posts initially chosen for expansion in fiscal year 2005. In addition to our review of the DHS Visa Security Program, we will report later this year on (State) changes to the visa process since our 2002 report. We conducted our evaluation from August 2004 to June 2005 in accordance with generally accepted government auditing standards. Results in Brief: VSOs assigned to consular posts in Riyadh and Jeddah, Saudi Arabia, are required to review all visa applications prior to final adjudication by consular officers and assist consular officers with interviews and fraud prevention. According to DHS, State's consular officials, and the deputy chief of mission in Saudi Arabia, the VSOs strengthen visa security at these posts. VSOs offer law enforcement and immigration experience and have access to and experience using information from law enforcement databases, which are not readily available to consular officers. The VSOs in Saudi Arabia provided anecdotal evidence of their contributions to the visa process; however, DHS does not maintain comprehensive data on the results of their activities, such as the number of cases for which VSOs recommended refusal, and thus is unable to fully demonstrate the program's overall impact on visa operations. Further, additional factors have limited the impact of the VSOs. Since the initial deployment of VSOs in August 2003 until June 2005, DHS assigned temporary officers to the posts in Saudi Arabia for tours that lasted between 2 and 15 months, which initially hindered continuity in operations. In June 2005, DHS hired and deployed permanent VSOs to Saudi Arabia. Additionally, the mandate requiring that VSOs review all visa applications in Saudi Arabia, including visas preliminarily refused by consular officers and low-risk applicants, limits their ability to perform other tasks that would further benefit consular officers, such as providing additional fraud prevention and detection training. Moreover, security concerns at consular posts in Saudi Arabia limit the number of personnel from DHS, as well as other agencies, that can be stationed at these posts. DHS planned to expand the Visa Security Program to five locations in fiscal year 2005 and intends further expansion in future years; however, chiefs of mission at the posts chosen for expansion in fiscal year 2005 delayed approval of DHS's National Security Decision Directive (NSDD) 38[Footnote 6] requests. Embassy and State officials attributed the delays to questions about the program's goals, objectives, and staffing requirements, as well as DHS's plans to coordinate with existing law enforcement and border security staff and programs at post. According to DHS officials, the department provided sufficient responses throughout 2004 and 2005 to answer the concerns raised by chiefs of mission. However, DHS has not developed a strategic plan for visa security operations in Saudi Arabia or the future expansion posts in fiscal year 2005 and beyond. The development of a plan may address questions from chiefs of mission and prevent delays in approving the assignment of VSOs during future expansion of the Visa Security Program. In this report, we are recommending that DHS, in consultation with State, develop a strategic plan to guide the operations of the Visa Security Program in Saudi Arabia and the program's expansion to other embassies and consulates. This plan should define mission priorities and long-term goals and identify the outcomes expected at each post. In addition, the strategic plan and supporting documents should include the criteria used to select the locations for expansion, justification for the number of VSOs at each post, costs associated with assigning VSOs overseas, and the roles and responsibilities of the VSOs in relation to other agencies at post. We are also recommending that DHS develop and maintain comprehensive performance data that track the results of VSO activities to demonstrate the Visa Security Program's impact at each location. We are also including a matter for congressional consideration. Congress may wish to consider amending section 428(i) of the Homeland Security Act 2002, which requires the review of all visa applications in Saudi Arabia, to allow DHS the flexibility to determine which applications VSOs will review prior to final adjudication by consular officers. This would give VSOs greater discretion to prioritize their review of applicants to focus on those who may pose a risk to national security and would provide them time to perform other tasks that could benefit consular officers. We received written comments from DHS and State, which we have reprinted in appendixes II and III, respectively. DHS and State agreed with our report. DHS stated it was developing a strategic plan and a system to measure program impact, as we recommended. State agreed with the conclusions of the report. Both DHS and State agreed that amending the requirement for DHS to review all visa applications in Saudi Arabia would allow time for other high-priority activities. Background: 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.[Footnote 7] In August 2003, DHS created the Office of International Enforcement within the Border and Transportation Security Directorate,[Footnote 8] 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;[Footnote 9] 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.[Footnote 10] 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. Figure 1: Establishment and Implementation of the Visa Security Program: [See PDF for image] [End of figure] 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.[Footnote 11] (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. Several Factors Have Limited the Impact of Visa Security Operations in Saudi Arabia: 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 Provide Additional Law Enforcement Capability to the Visa Process in Saudi Arabia: 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. VSOs Provide Additional Review to Visa Adjudication 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. Figure 2: Visa Process in Saudi Arabia: [See PDF for image] [End of figure] 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 Law Enforcement Information Not Readily Available to Consular Officers: 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)[Footnote 12] 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.[Footnote 13] 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[Footnote 14]--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. VSOs Provide Law Enforcement and Fraud Detection Knowledge and Training: 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.[Footnote 15] 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. Impact of the Visa Security Program in Saudi Arabia Limited by Several Factors: 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.[Footnote 16] * 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's Plans for Expansion of the Visa Security Program Delayed: 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. DHS's Expansion of the Visa Security Program in Fiscal Year 2005: 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.[Footnote 17] 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 workload; * 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. Questions Raised by Embassy Officials Contributed to Delays of DHS Expansion: 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. Questions Raised about the Site Selection Criteria Used to Select Expansion Posts: 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. Table 1: Visa Security Program Expansion: Location: Post 1; Date of NSDD-38 request: June 2004; Date of approval: July 2004; VSO positions requested by DHS: 5; VSO positions approved by chiefs of mission: 4. Location: Post 2; Date of NSDD-38 request: June 2004; Date of approval: March 2005; VSO positions requested by DHS: 5; VSO positions approved by chiefs of mission: 3. Location: Post 3; Date of NSDD-38 request: June 2004; Date of approval: Not yet approved; VSO positions requested by DHS: 4; VSO positions approved by chiefs of mission: 0. Location: Post 4; Date of NSDD-38 request: June 2004; Date of approval: June 2005; VSO positions requested by DHS: 3; VSO positions approved by chiefs of mission: 3. Location: Post 5; Date of NSDD-38 request: June 2004; Date of approval: June 2005; VSO positions requested by DHS: 4; VSO positions approved by chiefs of mission: 3. Total; VSO positions requested by DHS: 21; VSO positions approved by chiefs of mission: 13. Source: Department of Homeland Security. Note: Table 1 shows VSO positions and administrative support positions approved as of June 2005. [End of table] 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. Office of Rightsizing the U.S. Overseas Presence Supports Questions of DHS's Expansion Plans: 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.[Footnote 18] In August 2004, State's Office of Rightsizing the U.S. Overseas Presence,[Footnote 19] 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 embassies or consulates; * 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. DHS Lacks a Strategic Plan to Guide Operations and Expansion of the Visa Security Program: 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[Footnote 20] 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.[Footnote 21] 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. Conclusions: 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. Recommendations for Executive Action: 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. Matter for Congressional Consideration: 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. Agency Comments and Our Evaluation: 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 [Hyperlink, http://www.gao.gov]. If you have any questions about this report, please contact me at (202) 512-4128 or [Hyperlink, 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. Signed by: Jess T. Ford: Director, International Affairs and Trade: List of Committees: The Honorable Susan M. Collins: Chairman: The Honorable Joseph I. Lieberman: Ranking Minority Member: Committee on Homeland Security and Governmental Affairs: United States Senate: The Honorable Jon Kyl: Chairman: The Honorable Dianne Feinstein: Ranking Minority Member: Subcommittee on Terrorism, Technology, and Homeland Security: Committee on the Judiciary: United States Senate: The Honorable Tom Davis: Chairman: Committee on Government Reform: House of Representatives: The Honorable Christopher Shays: Chairman: The Honorable Dennis J. Kucinich: Ranking Minority Member: Subcommittee on National Security, Emerging Threats, and International Relations: Committee on Government Reform: House of Representatives: The Honorable Christopher Cox: Chairman: The Honorable Bennie G. Thompson: Ranking Minority Member: Committee on Homeland Security: House of Representatives: The Honorable F. James Sensenbrenner, Jr.: Chairman: The Honorable John Conyers, Jr.: Ranking Minority Member: Committee on the Judiciary: House of Representatives: The Honorable John N. Hostettler: Chairman: The Honorable Sheila Jackson Lee: Ranking Minority Member: Subcommittee on Immigration, Border Security, and Claims: Committee on the Judiciary: House of Representatives: [End of section] Appendixes: Appendix I: Scope and Methodology: 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. [End of section] Appendix II: Comments from the Department of Homeland Security: U.S. Department of Homeland Security: Office of the Assistant Secretary: U.S. Immigration and Customs Enforcement: 425 I Street, NW Washington, DC 20536: July 15, 2005: Jess T. Ford, Director: International Affairs and Trade: United States Government Accountability Office: 441 G Street, NW: Washington, DC 20548: Re: GAO Report - Job Code 320352, DHS Visa Security Program: On behalf of the Secretary of Homeland Security; I would like to thank you for your report entitled Actions Needed to Strengthen Management of Department of Homeland Security's Visa Security Program." Given the Secretary's authority over visa issuance under Section 428 of the Homeland Security Act, the security of the visa process is one of the Department's highest priorities. We are pleased that e GAO has recognized the benefits to national security provided b DHS' Visa Security Program (VSP). In particular, the GAO has recognized the unique and complementary expertise; that a DHS law enforcement officer provides in the visa process. The observations cited in your report -the real-time interaction between Visa Security Officers (VSOs) and consular officers throughout the adjudication process, the advice provided by VSOs to consular officers, and the investigative expertise demonstrated by VSOs in resolving complex cases - speak to the powerful partnership of DHS and State in visa issuance. We are confident that the positive impact of this partnership will increase as DHS expands this program to additional locations. Most critically, the Visa Security Program increases the security of the United States by identifying the not yet known threats to national security who attempt to exploit the visa process. The traditional screening systems, which include "name checks" of applicants against various watch lists and law enforcement databases, have provided an essential security foundation. However, by integrating DHS law enforcement through the VSP, we add a powerful and necessary human investigative capability that allows the United States to move well beyond "name checks" to focus on identifying new threats long before they reach U.S. borders. This capability, when combined with DHS' security mandate and unique statutory authority, makes the VSP an essential component of DHS' strategy of layered, risk-based defenses. The integration and expansion of databases and automated screening systems is necessary for homeland security, but not sufficient to identify threats that are not yet known. We support the expanded sharing of information between all appropriate U.S. personnel involved in screening activities. We caution, however, that no amount of automation can replace the skill, judgment, and expertise of a seasoned, professional law enforcement officer with a focused mission and the unique authority to ensure the security of visa issuance from ever-changing threats. Effective performance measurement is the cornerstone of strong program management, Our systems and mechanisms for recording and reporting performance-related data are continually improving and will further demonstrate that visa issuance is more secure because of DHS' unique enforcement capability and national security role. We are expanding the tracking and measurement of performance outcomes to reflect the full set of the VSP's functional responsibilities: investigations, vetting of visa applicants, advising and training of consular officers, and other important law enforcement activities. Accordingly, the VSP's performance metrics will not, based on a single factor, overturn a consular officer's recommendation. Given our collaborative operational approach, we seek to achieve consensus and minimize the number of times DES "overrules" the Department of State. Success must be measured through DHS' ability to generate additional enforcement value from the visa process, rising such indicators as: generation of new lookouts; denial of visas to ineligible applicants; identification of terrorist and criminal threats, trends, and tactics; initiation of criminal investigations; delivery of training; and other enforcement-related activities. As described in the ICE Strategic Plan, the Visa Security Program is an important tool in ICE's efforts to "prevent exploitation of our customs and immigration systems" (Goal 2). Specifically, the VSP focuses on preventing "terrorists and other criminals from obtaining visas" to enter the United States. The additional strategic elements we have worked to develop include our vision for the program's expansion, specific strategic objectives, performance measures, and other important factors. ICE is integrating these elements into a more detailed, initiative-specific strategic plan, which will be a valuable management tool to be shared with our stakeholders. Though useful for communications purposes, it is unlikely such a plan would have aided the approval of our NSDD-38s, considering ICE has consulted with the State Department on this program during the past two years. ICE has the highest standards for personnel selection, and those selected as Visa Security Officers are among the best the U.S. government has to offer for this mission. We are proud of our officers' exemplary performance and the strong, collaborative relationships they have developed at their posts, as noted by GAO throughout this report. In this context, foreign language capability is one qualification for DHS officers assigned overseas, but it is not the only one. Our staffing decisions reflect careful consideration of the full law enforcement needs at each location. We are confident that the considerable benefit of DHS' presence to law enforcement, in terms of national security an investigative expertise, outweighs any perceived constraint related to language ability's effect on conducting enforcement activity. We also note that our selection criteria are consistent with those of other law enforcement and government entities operating overseas. Like all federal agencies. ICE will continue to increase its number of foreign language-capable personnel overseas, but we will not compromise the high standards Visa Security Officers must meet to succeed in this mission. There also is a need for streamlined communication and coordination channels for the NSDD-38 recess. DHS has coordinated closely with State on this initiative since March 2003, starting with a comprehensive Memorandum of Understanding that established guidelines for assignment of DHS personnel overseas, their duties once assigned, and the interactions and authorities they have with respect to consular officers and the visa process. Subsequently, DHS consulted State and other agencies' officials, both domestically and abroad, in the selection of posts for further deployment. Only after that extensive consultation process did DHS formally submit NSDD-38 requests for deployment to additional locations, which then were followed by extensive communication throughout 2004 and 2005, as noted by GAO. Despite these efforts, we have observed that the NSDD-38 process often leads to a lack of communication between U.S. agencies and chiefs of tnission, thus delaying the progress of important security initiatives. We believe the most appropriate and effective NSDD-38 process is that which facilitates open, direct, and expeditions dialogue between Departments and provides the Chief of Mission with sufficient information to evaluate agencies' carefully considered NSDD-38s. We will continue to work with all stakeholders to encourage two-way communication as we expand this important program. Finally, your report highlights for Congressional consideration the potential amendment of Section 428(i) of the Homeland Security Act. GAO's stated rationale for this change is to allow DHS officers to expand their capacity to perform all Section 428 functions, including investigations and additional training for consular officers. We agree these. important activities should be expanded. It is the position of DHS that any legislative amendment to Section 428(i) should emphasize the importance of each of these functions, and clearly maintains DHS' authority and discretion in determining this scope of its operational activities. We look forward to working with the Congress this issue. We appreciate the dedication of you and your staff in compiling this important report. Enclosed are comments specific to the GAO's findings and recommendations, including general and technical comments regarding statements that need to be clarified prior to finalization of this report. If we can offer any further assistance, please contact Stephanie Jones-Hampton, ICE OI GAO Coordinator, at (202) 305-0513. Sincerely, Signed by: Michael J. Garcia: Assistant Secretary: DHS General and Technical Comments to Draft GAO Report - 320352 General Comments: Incomplete/"Anecdotal" Performance Data: p. 1, first sentence under "What GAO Found" "however, no data exists to demonstrate the VSOs' impact." This should read "however, incomplete data exists to demonstrate the VSOs' impact." Otherwise, this statement is inconsistent with GAO's findings throughout the report that "..DHS does not maintain comprehensive data on the results of their activities, and thus is unable to fully demonstrate the program's overall impact." [emphasis added] p. 4, under "Results in Brief: "The VSOs in Saudi Arabia provided anecdotal evidence of their contributions to the visa process.." We do not support GAO's use of the term "anecdotal." DHS maintains official, formalized documentation of its visa applicant review, training. and investigative activities through several official systems of record, including weekly operational reports, reports of investigation in TECS, and a workload tracking database. Some of this information, such as examples of the operational reports, was provided to GAO. Other evidence, such as that relating to ongoing investigations, was described but not provided due to its law enforcement sensitivity. DHS is currently expanding other efforts, such as with our workload tracking database, to enable more comprehensive performance measurement of the full range of VSP program activities and outcomes. Regardless, there is clear evidence that significantly more documentation of the program's impact exists than has been given credit here. p. 4, under "Results in Brief" "..however DHS does not maintain comprehensive data on the results of their activities such as the number of cases for which they recommended fusal, and thus is unable to fully demonstrate the VSOs' impact." p. 16, first bullet: "VSOs .. had recommended that visas be refused in about 15 cases between October 2004 and February 2005." This statistic refers to the number of times VSOs have formally "overruled" consular officers, not the number of times VSOs have recommended denial. Recommended denials occur on a daily basis. However, sine recommended denials can happen at any point during the visa process, they are more difficult to track and measure. We have unproved our approach for measuring these recommendations and will be collecting much more accurate data in this area. p. 9, first paragraph, "..several factors have hindered the program, including a lack of comprehensive data.." This appears to be an error in syntax. A lack of comprehensive data does not hinder the program, but may hinder the ability to fully measure performance. We suggest a clarification in this language to reflect that performance measurement is hindered. DHS Role/Agencies' Roles: p. 6, under Background, first sentence, "The Homeland Security Act-gave it a role in the visa process." p.7, first paragraph, "Several other agencies stationed overseas have roles in the visa adjudication process." More precisely, the Act made DHS responsible for visa policy and related guidance and regulations. Specifically, Section 428(b)(1) states that the Secretary "shall be vested exclusively with all authorities to issue regulations with respect to, administer, and enforce the provisions of such Act, and of all other immigration and nationality laws, relating to the functions of consular officers of the United States in connection with the granting and refusal of visas...". It also assigned DHS a specific operational role, implemented through U.S. Immigration and Customs Enforcement's (ICE) Visa Security Program. VSP's operational role is unique in the visa process worldwide, providing law enforcement resources dedicated entirely to the single mission of visa security, as achieved through the vetting of visa applicants, investigations, and the delivery of advice and training to consular officers. VSOs' Capability: p. 9, second paragraph, "VSOs in Saudi Arabia provide an additional law enforcement capability to the visa adjudication process." p. 9, second paragraph, "Moreover, VSOs' border security and immigration experience can assist consular officers during the visa process." VSOs provide a unique and dedicated law enforcement capability focused entirely on visa security as the front line of homeland security. Such capability does not otherwise exist in Saudi Arabia or at any other posts globally. The VSOs' law enforcement expertise, sophisticated understanding of immigration law, and experience with the spectrum of border security functions qualifies them for the breadth of their operational duties-the vetting of visa applicants, investigations, and providing advice and training to consular officers. In addition to enhancing security, these dedicated resources yield other benefits: for example, according to Department of State statistics, the average processing time for the visa adjudication at the Saudi posts has improved dramatically, in part because VSOs have been able to resolve outstanding questions about individual visa applicants, enabling swift resolution on cases that would have lagged for weeks or months. Number of VSOs in Saudi/Security Concerns: p. 5, top paragraph, last sentence: "Moreover, physical security concerns ... limit the number of personnel..." p. 15, last sentence, "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." p. 15, near the top, "...the 3 VSOs in Riyadh and 1 VSO in Jeddah were each working 7 days per week at the time of our visit." In Spring 2004, because of security concerns, State issued an ordered departure, which reduced the staff levels of all agencies; it reduced VSP's staff level from six to four. Since that time, according to data from the Consular Consolidated Database (CCD), consular visa activity now is up over 50% year-over-year for the recent two-month period. State has filled several of its vacated consular positions since the ordered departure. DHS has requested that we be allowed to fill the two vacant VSO positions so that DHS may reasonably accomplish its critical security mandate given the substantial workload increase. Use of Temporary Detail (TDY) Officers: * p. 4, under "Results in Brief": "Since the initial deployment... DHS assigned temporary officers to the posts in Saudi Arabia for tours that tasted between 2 and 15 months, which initially hindered continuity in operations." The cited observation that temporary deployments led to "constant turnover" that hindered continuity in operations reflects the program's initial start-up phase in late 2003. It must be noted that over the last 18 months, officer assignments have been long-term and stable. Since January 2004, ICE has minimized turnover by deploying officers on long- term assignments of approximately 6 to 12 months. Our permanent officers are now assigned for 12-month tours, consistent with DOS policy that applies to all U.S. government personnel assigned to Saudi Arabia. NSDD-38 Delays/DOS Questions: p. 5, middle paragraph, "DHS planned to expand the Visa Security Program to five locations in fiscal year 2005 ... however, chiefs of mission at the posts chosen for expansion in fiscal year 2005 told us that they delayed approval ... questions about the program's goals, objectives, and staffing requirements, as well as DRS' plans to coordinate with existing law enforcement... " p. 16, second paragraph, "The State Department and chiefs of mission attributed the delays to various questions about the program, including the criteria used by DHS to select expansion..." p. 5, middle paragraph, "According to DHS officials, the department provided sufficient responses throughout 2004 and 2005 to answer the concerns raised by chiefs of mission." p. 17, bottom, "Embassy officials raised questions and concerns.... State's Office of Rightsizing supported the posts' questions of DHS' plans for expansion..." p. 18, top, "Embassy officials at the expansion posts expressed concerns with the site selection process and criteria used to select the posts..." p. 18, second paragraph, "Embassy officials also questioned the reasoning behind the number of VSOs that DHS requested for assignment to the selected expansion posts... p. 20, bottom, and p. 21 top, "In 2004 and 2005, DHS provided responses, through State's Bureau of Consular Affairs, to the questions raised by the chiefs of mission... According to DHS, the responses were sufficient...." Since the Department's inception in March 2003 through the present, DHS has worked extremely closely with State to develop and implement all of the responsibilities of Section 428 of the Homeland Security Act. This effort began with the development of a comprehensive Memorandum of Understanding (MOU) between DHS and State that was intended to establish the detailed blueprint for implementation of each Department's roles, responsibilities, and authorities. The development process for this MOU took approximately six months and involved very close coordination between DHS and State, culminating in a detailed, 19- page MOU that was signed by Secretaries Ridge and Powell in September 2003. Included in this MOU are the roles of VSOs and Consular Officers, the processes and mechanisms for expanding VSO deployment, qualifications for visa security officers, and other considerations. In joint DHS-DOS testimony before Congress on September 30, 2003, Assistant Secretary Harty of the Bureau of Consular Affairs stated that "the MOU establishes guidelines for assignment of DHS personnel at our missions abroad, their duties once assigned, and the interactions and authorities they will have with consular officers and the visa process once they arrive overseas." In this testimony, she also attributes the length of time taken to develop this detailed MOU to the desire to "get it right the first time." Pursuant to the MOU, DHS began an in-depth quantitative and qualitative evaluation process to determine locations for future expansion. As GAO notes, this process began with a matrix of quantitative data, which helped DHS narrow the field of locations to further evaluate. DHS then considered qualitative data, including intelligence, additional risk factors, existing DHS overseas staffing, other agency perspectives, and practical and logistical considerations. DHS and State jointly conducted site assessments, where the DHS-DOS assessment teams consulted with Chiefs of Mission, consular officials, administrative officials, and other agencies at post. The purpose of these visits was to collect additional qualitative information relevant to final deployment determinations, provide additional information to embassy officials regarding program objectives, and respond to any questions or concerns. After that process was complete, DHS, in consultation with State, selected the "top five" locations for deployment. These are the five locations referenced in this report. DHS made its official homeland security determination under Section 428, and DHS sent the NSDD-38s in June 2004. All told, this in-depth, consultative selection process lasted approximately seven months. Over the next year, DHS again worked closely with DOS officials to provide as much information as possible in response to additional inquiries surrounding our NSDD-38s. In response to these issues, State requested DHS and DOS develop a second Memorandum of Understanding regarding implementation of Section 428. DHS complied and jointly drafted another MOU with State, which was finalized in November 2004. As a result, the DOS Office of Rightsizing followed its original August 2004 cable, which had advised Chiefs of Mission to delay approval of our NSDD-38's, with a November 2004 worldwide cable advising that posts should now "respond expeditiously to these pending NSDD-38 requests." As noted by GAO, we were approved for additional locations in March and June of 2005. We have provided GAO with a detailed record of our documented interactions and communication efforts during these 12 months. As stated in our official response, we believe that the process for evaluating NSDD-38s needs to be significantly streamlined in order to promote direct dialogue and minimize the need for agencies to respond to multiple requests for similar information. Such a streamlined process would clarify State's needs and concerns upfront, provide appropriate opportunities for agencies to respond, and allow swift resolution. We will continue to exercise every effort to keep all parties as informed as possible regarding the Visa Security Program. Determination of Number of VSOs: p. 18, second paragraph, "Embassy officials also questioned the reasoning behind the number of VSOs that DHS requested for assignment to the selected expansion posts... p. 19, first paragraph, "...will not have enough staff at each post to effectively impact the visa adjudication process at these locations." p. 19, second paragraph, "DHS negotiated the final number of positions... p. 19, second paragraph, "The deputy chief of mission and consul general at another embassy noted that DHS' 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 ..." [consider technical edit - they actually approved three.] DHS bases its determinations of the size of each location footprint based on a case-by-case assessment of the magnitude and nature of the work to be performed at each post. Considering that VSP's functional responsibilities involve vetting of visa applicants, providing training and advice, and initiating investigations, the size and nature of visa workload is one of several factors. Furthermore, the nature of VSP operations involves taking an active, day-to-day role in the visa adjudication process, partnering with Consular Officers to add an additional enforcement dimension. This generally warrants a contingent of at least three officers at a given location (or more if deemed necessary) to ensure an appropriate skill mix and ensure continuity of operations. (We note that GAO's observation of the high workload demands on our diminished staff of four officers in Saudi Arabia supports our original threat and workload assessment in requesting a total of six officers at those two posts.) We recognize that there may be instances in which DHS' determination of the threat at a particular location is different from that of other officials. However, we believe strongly that these determinations, which are strictly guided by a homeland security perspective, reflect the intent of DHS' statutory authority under Section 428. We have welcomed each opportunity to share our rationale in making these determinations, and we are confident that as our operational presence expands, so too will the understanding of this unique mission. Legislative Change: * p. 6, second paragraph, "We are also including a matter for congressional consideration..." * p. 23, under "Matter for Congressional Consideration..." * p. 23, last sentence, "This flexibility will allow them to engage in other activities that will provide additional benefit to consular officers and the visa process." As indicated in our official response, DHS agrees with GAO's observation that it would be beneficial for VSOs in Saudi Arabia to have more flexibility to prioritize their activities, which is currently constrained due to the requirement to review all visa applications. It is the position of DHS that any legislative amendment to Section 428(i) must emphasize the importance of each of these functions and must maintain DHS' authority and discretion in determining the scope of its operational activities. IG Report: p. 8, last sentence, "According to the Inspector General's office, DHS has taken steps to implement these recommendations, but as of July 8, 2005, six remain open." Though some recommendations from this initial report remain open, the IG designated all of them "resolved" at the time of publication in August 2004 (meaning the IG validated the approach and progress made in those areas), and we expect the remaining six recommendations to be formally closed shortly. Name Checks/Systems Access: p. 9, last paragraph, "VSOs may also query the applicant's information against a number of law enforcement ... databases, which may contain more detail than the consular officers' name check results." p. 11, "VSOs Have Access to Law Enforcement Information Not Readily Available to Consular Officers" p. 12, second paragraph, "In addition, the VS Os 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." It is important to note that the VSOs' work in this regard is of an investigative nature and is more sophisticated than a simple name check. Name checks, through such automated screening systems as CLASS, are intended to identify known threats based on specific biographic information and predefined rules. Above and beyond this, VSOs conduct investigative research on the applicant and his/her businesses, associates, sponsors, and addresses, and any other relevant information to assemble a complete picture in order to determine whether the applicant presents a potential threat to the United States. Critically, this activity often yields new information that is not yet a part of government databases and watch lists. In this light, simply citing "access to information not readily available to consular officers" mischaracterizes the professional skill involved in researching and evaluating this type of information, and perpetuates a mistaken premise that "access to additional systems" without requisite professional expertise can sufficiently address vulnerabilities in visa security. In order to fully address these homeland security vulnerabilities, we must be able to identify all threats beyond basic screening and pursue all appropriate enforcement beyond a visa denial. Saudi Process: * p. 10, Figure 2. For the reasons stated above with respect to the nature of VSO vetting, we suggest modifying the box in the lower left-hand corner, "VSOs in Riyadh conduct some name checks..." to "VSOs in Riyadh conduct applicant vetting." Site Selection: Program, two of the posts ranked outside of the top 10 posts identified by DHS' evaluation." The characterization of DHS' evaluation process is inaccurate. DHS' methodology involved two stages: quantitative analysis followed by qualitative analysis. The initial quantitative analysis examined a series of standard workload and enforcement data related to a number of evaluation criteria and was intended to develop a "short list" of posts for further evaluation. GAO's statement on page 18 of the report implies that quantitative analysis was the conclusion of the DHS' analysis, when in fact it was the initiation of DHS' analysis. Since a simple numerical formula based on available data cannot accurately capture the full risk picture, a more sophisticated qualitative analysis followed. This stage involved collecting and evaluating additional information sources, interagency consultation, the review of intelligence reports, consideration of existing DHS overseas staffing, and practical and logistical considerations. Based on this additional information, DHS, in consultation with State, made its final selections. This is consistent with DHS' authority in Section 428 and the MOU with State. State officials were consulted throughout this process, and DHS was not made aware of any objections until after DHS submitted the NSDD-38s. * p. 18, first paragraph, "In particular the consular chief stated that the post had a relatively low application volume and a low refusal rate..." In DHS' assessment, low application volume and low refusal rate do not necessarily translate into low threat. We stand by our determination. Strategic Plan: p. 21, bottom paragraph, "Although DHS plans to expand the Visa Security Program in fiscal year 2005 and beyond, it does not a have a strategic plan..." p. 21, bottom paragraph, p. 22, top, "The development of an overall strategic plan ... may have addressed the questions initially raised by State and embassy officials that led to the delay of the assignment of VSOs." p. 22, second paragraph, "Furthermore... 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. Further, 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." p. 22, bottom paragraph, "Before DHS expands this program to other consular posts, it needs a plan outlining its goals and objectives ... 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, and would help facilitate negotiations of the expansion of the Visa Security Program." DHS has already developed many if not most of the components of a strategic plan for the Visa Security Program, including our mission, strategic objectives, approach to risk management, planning and budgeting estimates, optimal performance measures, and other key elements. We strongly agree with GAO that these pieces need to be integrated into a strategic plan and are working toward that end. We do not, however, share GAO's belief that a strategic plan will minimize future delays to VSP implementation. The mission, goals, and objectives of the VSP have been clear to State since the signing of the September 2003 MOU. We believe that the process for NSDD-38 review has been unnecessarily delayed. These delays have prevented the VSP from the timely expansion that is needed to mitigate urgent threats. Unless addressed, we expect such delays to continue. The following are GAO's comments on the Department of Homeland Security's letter dated July 15, 2005. GAO Comments: 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. [End of section] Appendix III: Comments from the Department of State: United States Department of State: Assistant Secretary and Chief Financial Officer: Washington, D.C. 20520: JUL 22 2005: Ms. Jacquelyn Williams-Bridgers: Managing Director: International Affairs and Trade: Government Accountability Office: 441 G Street, N.W. Washington, D.C. 20548-0001: Dear Ms. Williams-Bridgers: We appreciate the opportunity to review your draft report, "BORDER SECURITY: Actions Needed to Strengthen Management of Homeland Security's Visa Security Program," GAO Job Code 320352. The enclosed Department of State comments are provided for incorporation with this letter as an appendix to the final report. If you have any questions concerning this response, please contact Susan Jacobs, Senior Advisor, Bureau of Consular Affairs, at (202) 736- 4985. Sincerely, Signed by: Sid Kaplan (Acting): cc: GAO - Katie Hartsburg; CA - Maura Harty; State/OIG - Mark Duda: Department of State Comments on GAO Draft Report "BORDER SECURITY: Actions Needed to Strengthen Management of Homeland Security's Visa Security Program" (GAO-05-639 GAO Code 320352): Thank you for the opportunity to respond to the report on Actions Needed to Strengthen Management of Homeland Security's Visa Security Program. On the whole, we believe the report is a fair and accurate depiction of the implementation of Section 428 to date. The report notes, "VSOs in Saudi Arabia aim to provide an additional security layer to the visa adjudication process. Additionally, VSOs have access to important law enforcement information not readily available to consular officers." The "added value" of the Section 428 officers posted in Riyadh and Jeddah - their ability to access databases unavailable to consular officers - highlights the importance of shared interoperable databases and of providing consular officers access to all law enforcement and other databases that contain information relevant to making visa determinations. The lack of direct access by consular officers to these systems has important consequences for our goal to "push out the borders" to the maximum extent possible in order to enhance U.S. border security. Since only two posts have a DHS Section 428 presence, consular officers at all other 209 posts are screening applicants and issuing visas without the ability to access all available information that may be relevant or necessary to adjudicate any given visa application. Providing consular officers worldwide with access to law enforcement and other databases not currently available to them would be a cost effective and efficient way of improving the visa adjudication process. With further regard to the visa adjudication process, the Secretary of Homeland Security has the authority to deny a visa in accordance with law. However, the State Department's expectation is that these denials will be based primarily on national security, counter-terrorism, or fraud grounds. As their name suggests, the function of VSOs is not to adjudicate visas, but to provide security related consultative services to consular officers in their adjudications. As mentioned above, only two posts have Section 428 officers, and NSDD- 38 agreements have been reached to place VSOs at four others. While the law authorizes DHS to have Section 428 officers at every post, DHS is not required to place a Section 428 officer at each post, and - consistent with Section 428 - the MOU makes explicit that each placement is subject to the NSDD-38 process. In evaluating DHS NSDD-38 proposals, Chiefs of Mission and the State Department's Office of Right- Sizing have an obligation to ensure that staffing overseas is at the proper level and consistent with available space and resources for all agencies at each Mission. In DHS site visits to various posts, there was some lack of clarity in articulating its selection criteria, e.g., how many officers would be assigned and what functions each would perform. Chiefs of Mission had both policy and process questions for DHS before agreeing to the assignment of officers. In general, we concur with GAO's assessment that increased consultation with the Department of State on selection criteria would facilitate the NSDD-38 process. While VSOs have done a fine job in Saudi Arabia under difficult conditions, we do not believe that Saudi Arabia should be the model for future deployments. If VSOs are to evaluate intelligence and provide expert advice and training to consular officers on terrorist travel and trends, VSOs will not be able to review 100% of all applications. We encourage DHS to institute a policy that gives VSOs flexibility to focus their resources on terrorism concerns as it takes up its responsibilities in other posts. Finally, we concur in the GAO recommendation that Congress consider revising the law to eliminate the need for 100% review in Saudi Arabia. [End of section] Appendix IV: GAO Contacts and Staff Acknowledgements: GAO Contact: Jess Ford (202) 512-4128: Acknowledgments: In addition, John Brummet, Daniel Chen, Katie Hartsburg, Jeff Miller, Mary Moutsos, Joseph Carney, and Etana Finkler made key contributions to this report. (320352): FOOTNOTES [1] A visa is a U.S. travel document that most foreign citizens must obtain before arriving at U.S. ports of entry to enter the United States temporarily for business, tourism, or other reasons. The United States also grants visas to people who intend to immigrate to the United States. In this report, we use the term "visa" to refer to nonimmigrant visas only. [2] We reported that the visa process prior to September 11 focused primarily on screening applicants to determine if they intended to work or reside illegally in the United States. See GAO, Border Security: Visa Process Should Be Strengthened as an Antiterrorism Tool, GAO-03- 132NI (Washington, D.C.: Oct. 21, 2002). [3] P.L. 107-296. [4] For the purpose of this report, we will refer to DHS's program that oversees the implementation of the requirements in sect. 428 (e) and sect. 428 (i) of the Homeland Security Act of 2002 as the Visa Security Program. [5] In this report, we do not name the exact locations DHS plans to expand to because the department stated this is sensitive information. [6] The National Security Decision Directive-38 process requires non- State agencies to seek approval of chiefs of missions on any proposed changes in the size, composition, or mandate of their staff. [7] P.L. 107-296, Sec. 428(e) and Sec. 428(i). [8] Border and Transportation Security is responsible for, among other things, (1) preventing the entry of terrorists and the instruments of terrorism to the United States, while ensuring the efficient flow of lawful traffic and commerce; (2) securing U.S. transportation systems; and (3) enforcing U.S. immigration laws. [9] In some cases, the consular officer is required to submit an application for a Security Advisory Opinion, or decides that one is needed. A Security Advisory Opinion provides 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 when 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. [10] State's Bureau of Diplomatic Security is mainly responsible for providing a safe and secure environment for the conduct of U.S. foreign policy. Overseas, bureau personnel develop and implement security programs to safeguard all personnel who work in every U.S. diplomatic mission around the world. [11] DHS Office of Inspector General, An Evaluation of DHS Activities to Implement Section 428 of the Homeland Security Act of 2002, OIG-04- 33 (Washington, D.C.: Aug. 2004). [12] CLASS is a State Department name check database that posts use to access critical information for visa adjudication. The system contains records provided by numerous agencies and includes information on persons with visa refusals, immigration violations, criminal histories, and terrorism concerns. [13] Section 403 of the USA PATRIOT Act (P.L. 107-56) directs the Federal Bureau of Investigation to provide State with access to criminal history records contained in the National Crime Information Center's Interstate Identification Index (NCIC - III) files for the purpose of determining whether or not a visa applicant has a criminal history record. In accordance with this mandate, the Federal Bureau of Investigation provides extracts that contain biographical information such as the date of birth and height of the person with the criminal record. However, the extracts in CLASS do not contain details such as the charge or disposition of the case, which are necessary to determine if the applicant might be ineligible for a visa. To see this degree of detail from the records, the National Crime Prevention and Privacy Compact Act of 1998 (42 U.S.C. 14611 et seq.) (Compact Act) requires that consular officers first submit fingerprints of the visa applicant for positive identification before the record can be released. [14] The Transportation and Security Administration maintains the "No- Fly" list, which identifies individuals known or reasonably suspected to be a threat to national security and allows airlines to pre-screen passengers' names before a flight. [15] Consular officers who serve as fraud prevention managers are in charge of investigating cases of fraud, conducting fraud training for the consular section, and providing information on fraud relevant to the consular section at post. [16] Pursuant to DHS's NSDD-38 request for Saudi Arabia, the department is authorized to have up to 6 personnel in Saudi Arabia. [17] The Secretary of Homeland Security is authorized to assign DHS officers to consular posts overseas unless he determines that such an assignment at a particular post would not promote homeland security. [18] See GAO, Overseas Presence: Framework for Assessing Embassy Staff Levels Can Support Rightsizing Initiatives, GAO-02-780 (Washington, D.C.: July 26, 2002). [19] State's Office of Rightsizing the U.S. Overseas Presence is charged with aligning the number and location of staff assigned overseas with foreign policy priorities and security and other constraints. The office leads State's efforts to coordinate and manage deployment of personnel of all U.S. government agencies overseas. [20] The Government Performance and Results Act of 1993, as amended, P.L. 103-62, provides a strategic planning and management framework intended to improve federal programs' performance. The act outlines key elements of a strategic plan including the development of a mission statement, general goals and objectives that explains expected results, operational processes and resources needed to accomplish the program goals, daily performance and activities linked to program goals, external factors that affect the program, and performance assessments to establish and revise program goals. [21] See GAO, Executive Guide: Effectively Implementing the Government Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996) GAO's Mission: The Government Accountability Office, the investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. GAO examines the use of public funds; evaluates federal programs and policies; and provides analyses, recommendations, and other assistance to help Congress make informed oversight, policy, and funding decisions. GAO's commitment to good government is reflected in its core values of accountability, integrity, and reliability. Obtaining Copies of GAO Reports and Testimony: The fastest and easiest way to obtain copies of GAO documents at no cost is through the Internet. 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