Border Security: Improvements Needed to Reduce Time Taken to	 
Adjudicate Visas for Science Students and Scholars (25-FEB-04,	 
GAO-04-443T).							 
                                                                 
Each year thousands of international science students and	 
scholars apply for visas to enter the United States to		 
participate in education and exchange programs. They offer our	 
country diversity and intellectual knowledge and are an economic 
resource. At the same time, the United States has important	 
national security interests in screening these individuals when  
they apply for a visa. At a House Committee on Science hearing in
March 2003, witnesses raised concern about the length of time it 
takes for science students and scholars to obtain a visa and	 
about losing top international students to other countries due to
visa delays. GAO reviewed 1) how long it takes a science student 
or scholar from another country to obtain a visa and the factors 
contributing to the length of time, and 2) what measures are	 
under way to improve the process and decrease the number of	 
pending cases.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-443T					        
    ACCNO:   A09361						        
  TITLE:     Border Security: Improvements Needed to Reduce Time Taken
to Adjudicate Visas for Science Students and Scholars		 
     DATE:   02/25/2004 
  SUBJECT:   Foreign students					 
	     Information systems				 
	     Systems conversions				 
	     National preparedness				 
	     Passports						 
	     Strategic planning 				 
	     Interagency relations				 
	     Visas						 
	     Scientists 					 
	     Timeliness 					 
	     Administrative procedures				 
	     Dept. of State Visas Mantis Program		 

******************************************************************
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GAO-04-443T

United States General Accounting Office

GAO Testimony

Before the Committee on Science, House

                               of Representatives

For Release on Delivery Expected at 9:30 a.m. EST

Wednesday, February 25, 2004 BORDER SECURITY

    Improvements Needed to Reduce Time Taken to Adjudicate Visas for Science
                             Students and Scholars

Statement of Jess T. Ford, Director International Affairs and Trade

GAO-04-443T

Highlights of GAO-04-443T, a testimony before the Committee on Science,
House of Representatives

Each year thousands of international science students and scholars apply
for visas to enter the United States to participate in education and
exchange programs. They offer our country diversity and intellectual
knowledge and are an economic resource. At the same time, the United
States has important national security interests in screening these
individuals when they apply for a visa. At a House Committee on Science
hearing in March 2003, witnesses raised concern about the length of time
it takes for science students and scholars to obtain a visa and about
losing top international students to other countries due to visa delays.
GAO reviewed 1) how long it takes a science student or scholar from
another country to obtain a visa and the factors contributing to the
length of time, and 2) what measures are under way to improve the process
and decrease the number of pending cases.

GAO is making a recommendation to the Secretary of State, in coordination
with the Director of the FBI and the Secretary of Homeland Security, to
develop and implement a plan to improve the security check process known
as Visas Mantis to avoid unnecessary delays in visa issuance. State
commented it had taken some action to improve the Visas Mantis process and
it would study our recommendation to make further improvements.

www.gao.gov/cgi-bin/getrpt?GAO-04-443T.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Jess T. Ford at (202)
512-4128 or [email protected].

February 2004

BORDER SECURITY

Improvements Needed to Reduce Time Taken to Adjudicate Visas for Science
Students and Scholars

State Department (State) cannot readily identify the time it takes for a
science student or scholar to obtain a visa. State has not set specific
criteria or time frames for how long the visa process should take, but its
goal is to adjudicate visas as quickly as possible, consistent with
immigration laws and homeland security objectives. GAO found that the time
it takes to adjudicate a visa depends largely on whether an applicant must
undergo an interagency security check known as Visas Mantis, which is
designed to protect against sensitive technology transfers. Based on a
random sample of Visas Mantis cases for science students and scholars sent
from posts between April and June 2003, GAO found it took an average of 67
days for the security check to be processed and for State to notify the
post. In addition, GAO's visits to posts in China, India, and Russia in
September 2003 showed that many Visas Mantis cases had been pending 60
days or more. GAO also found that the way in which Visas Mantis
information was disseminated at headquarters level made it difficult to
resolve some of these cases expeditiously. Furthermore, consular staff at
posts GAO visited said they were unsure whether they were contributing to
lengthy waits because they lacked clear guidance on when to apply Visas
Mantis checks and did not receive feedback on whether they were providing
enough information in their Visas Mantis requests. Another factor that may
affect the time taken to adjudicate visas for science students and
scholars is the wait for an interview.

Average Time Frames for Visas Mantis Adjudication Process, April to June
2003

While State and Federal Bureau of Investigation (FBI) officials
acknowledged there have been lengthy waits for visas, they report having
measures under way that they believe will improve the process and that
they are collaborating to identify and resolve outstanding Visas Mantis
cases. In addition, State officials told GAO they have invested about $1
million to upgrade the technology for sending Visas Mantis requests.
According to State officials, the new system will help to reduce the time
it takes to process Visas Mantis cases.

Mr. Chairman and Members of the Committee:

I am pleased to be here to discuss the report we are issuing today on the
need for improvements to the visa process to reduce the time it takes to
adjudicate visas for science students and scholars.1 Citizens of other
countries seeking to enter the United States temporarily for study,
exchanges, business, tourism, and other reasons generally must apply for
and obtain a U.S. travel document, called a nonimmigrant visa, at U.S.
embassies or consulates abroad before arriving at U.S. ports of entry.
Since September 11, 2001, visa operations have played an increasingly
important role in ensuring our country's national security. In deciding
who should and should not receive a visa, consular officers must balance
the need to facilitate legitimate travel with the need to protect the
United States against persons whose entry could be harmful to U.S.
national interests. For example, consular officers need to delicately
balance U.S. national security interests with other interests such as
promoting U.S. education and cultural exchanges, business, tourism, and
the overall health of our economy. As part of the visa application
process, many applicants with a science background, including students and
scholars, must undergo an interagency security check, known as Visas
Mantis, before being issued or denied a visa. A Visas Mantis check is
required by the State Department (State), the Federal Bureau of
Investigation (FBI), and other interested Washington agencies when there
are potential concerns that the visa applicant may engage in the illegal
transfer of sensitive technology, which could undermine U. S. national
security.

At a hearing held by the House Committee on Science on March 26, 2003,
witnesses raised concern about the length of time it takes for science
students and scholars to obtain a visa and about losing top international
students to other countries due to visa delays. You asked us to review 1)
how long it takes a science student or scholar from another country to
obtain a visa and the factors contributing to the length of time, and 2)
what measures are under way to improve the process and decrease the number
of pending cases.

1U.S. General Accounting Office, Border Security: Improvements Needed to
Reduce Time Taken to Adjudicate Visas for Science Students and Scholars,
GAO-04-371 (Washington, D.C.: Feb. 25, 2004).

Summary 	State cannot readily identify the time it takes for a science
student or scholar to obtain a visa.2 According to State officials, the
department has not set specific criteria or time frames for how long the
visa process should take, but its goal is to adjudicate visas as quickly
as possible, consistent with immigration laws and homeland security
objectives. We found that a key factor that can contribute to the length
of time for adjudicating visas is whether an applicant must undergo a
Visas Mantis security check. While State's systems do not allow it to keep
aggregate data on the number of Visas Mantis cases, State does have
information on individual cases,3 which we used to conduct our own
analysis. We conducted a random sample of Visas Mantis cases for science
students and scholars between April and June 2003 and found that it took
an average of 67 days for the security check to be processed and for State
to notify the post. Also, we visited posts in China, India, and Russia in
September 2003 and found that many Visas Mantis cases had been pending 60
days or more. We also found several factors that made it difficult to
expeditiously resolve some Visas Mantis cases. For example, in some
instances, Visas Mantis cases sent by posts did not get to the FBI for its
security check because of improperly formatted requests. Also,
interoperability problems among the systems that State and FBI use
contribute to the time taken to process a Visas Mantis case. In addition,
the consular staff at the posts we visited told us that they lacked clear
guidance on when to apply Visas Mantis checks and did not receive feedback
on whether they were providing enough information in their Visas Mantis
requests. Finally, we found that the wait for an interview also may affect
the time it takes to adjudicate visas for science students and scholars.

State and FBI officials acknowledge that there have been lengthy waits but
report having measures under way that they believe will improve the
process and resolve outstanding cases. For example, officials from State's
Bureau of Consular Affairs and the FBI told us they are working together

2State data are not available on the number of visas that were issued or
denied to science students and scholars or the length of time it takes to
issue visas to these people. Consular Affair officials told us that
State's systems can track aggregate student or scholar data by F
(students) and J (exchange visitors) visa categories, but they cannot
narrow their query search to specifically identify science students or
scholars.

3During our review, State data were not available on the overall number of
Visas Mantis cases or on the Visas Mantis cases by visa category. State's
systems can track the visa process for individual Visas Mantis cases but
do not allow for aggregate queries of Visas Mantis cases.

to identify and resolve outstanding Visas Mantis cases. These officials
also told us that State has invested about $1 million to upgrade its
technology for transmitting Visas Mantis requests, and the system is
expected to be functional later this year. According to State officials,
the new system will help to reduce the time it takes to process Visas
Mantis checks.

State claims that the time taken to adjudicate visas for science students
and scholars has decreased from last year. While this may be true, the
data presented by State in support of its claim continues to show that
some applicants still face lengthy waits. We acknowledge that there may be
valid reasons for taking long periods of time on some visa applications,
given the national security concerns that may be involved. However, we
believe it is important that State and the FBI continue to make
improvements to avoid unnecessary delays. Therefore, our report recommends
that the Secretary of State, in coordination with the Director of the FBI
and the Secretary of Homeland Security, develop and implement a plan to
improve the Visas Mantis process in order to avoid unnecessary delays in
visa issuance. In developing this plan, State should consider actions to
establish milestones to reduce the current number of pending Visas Mantis
cases; develop performance goals and measurements for processing Visas
Mantis checks; provide additional information to consular posts that
clarifies guidance on the Visas Mantis program; and work to achieve
interoperable systems and expedite the transmittal of data between
agencies.

Mr. Chairman, my statement today will elaborate further on the waits that
may occur when Visas Mantis security checks are conducted and on the
measures State and the FBI are implementing to improve the process.

Background 	Visa applicants, including science students and scholars,
generally begin the visa process by scheduling an interview at a consular
post. On the day of the appointment, a consular officer reviews the
application, interviews the applicant, and checks the applicant's name in
the Consular Lookout and Support System (CLASS).4 The consular officer
then decides if the applicant will need a Security Advisory Opinion, which
provides an opinion or clearance from Washington on whether to issue a
visa to the

4CLASS 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, and security concerns.

applicant and may include a Visas Mantis check. In deciding if a Visas
Mantis check is needed, the consular officer determines whether the
applicant's background or proposed activity in the United States could
involve exposure to technologies on the Technology Alert List, which lists
science and technology-related fields where, if knowledge gained from work
in these fields were used against the United States, it could be
potentially harmful.5

After a consular officer decides that a Visas Mantis security check is
necessary for an applicant, several steps are taken to resolve the
process. The consular officer prepares a Visas Mantis cable, which
contains information on the applicant, and then transmits the information
to Washington for an interagency security check. The State Department's
Bureau of Nonproliferation, the FBI, and other agencies review the
information contained in the cable and then provide a response on the
applicant to the Consular Affairs section of State headquarters.6 The
Bureau of Nonproliferation and other agencies are given 15 working days to
respond to State with any objections. However, State has agreed to wait
for a response from the FBI before proceeding with each Visas Mantis case.

Once State headquarters receives all the information pertaining to an
applicant, Consular Affairs summarizes the information and transmits a
response to the consular post. A consular official at post reviews the
response and decides, based on the information from Washington, whether to
issue the visa to the applicant.

5Under Section 212(a)(3)(A)(i)(II) of the Immigration and Nationality Act,
an applicant is rendered inadmissible if there is reason to believe that
the applicant is seeking to enter the United States to violate U.S. laws
prohibiting the export of goods, technology, or sensitive information from
the United States. 8 U.S.C. S: 1182(a)(3)(A)(i)(II).

6The Visas Mantis program allows all participating agencies to provide
information and raise any particular concerns that they may have regarding
an applicant and/or the applicant's proposed activity in the United
States. According to State, the key role of the Visas Mantis process is to
protect U.S. national security, particularly in combating the
proliferation of weapons of mass destruction, their delivery systems, and
conventional weapons.

  Security Check Is Major Contributing Factor to Length of Time It Takes to
  Adjudicate Visas

State cannot readily identify the total length of time it takes for a
science student or scholar to obtain a visa. However, in discussions with
State officials, we learned that a key factor that contributes to the
length of time is whether an applicant must undergo a Visas Mantis.

To obtain visa data on science students and scholars, and to determine how
long the visa process takes, we reviewed all Visas Mantis cables received
from posts between April and June 2003, which totaled approximately 5,000.
Of these cases, 2,888 pertained to science students and scholars, of which
approximately 58 percent were sent from China, about 20 percent from
Russia, and less than 2 percent from India.

We drew a random sample of 71 cases from the 2,888 science student and
scholar visa applications to measure the length of time taken at various
points in the visa process. The sample of 71 cases is a probability
sample, and results from the data in this sample project to the universe
of the 2,888 science visa applications. We found that visas for science
students and scholars took on average 67 days7 from the date the Visas
Mantis cable was submitted from post to the date State sent a response to
the post.8 This is slightly longer than 2 months per application, on
average. In the sample, 67 of the visa applications completed processing
and approval by December 3, 2003. In addition, 3 of the 67 completed
applications had processing times in excess of 180 days. Four of the cases
in our sample of 71 remained pending as of December 3, 2003. Of the 4
cases pending, 3 had been pending for more than 150 days and 1 for more
than 240 days.9

In addition to our sample of 71 cases, State provided us with data on two
samples it had taken of Visas Mantis case processing times. Data on the
first sample included 40 visa cases taken from August to October 2003;
data on the second sample included 50 Visas Mantis cases taken from
November and December 2003. State indicated that both samples show

7The 95 percent confidence interval for the average number of days to
process a science visa application is between 50 and 84 days.

8According to State, factors that contribute to the length of time it
takes to process a Visas Mantis check include investigations by clearing
agencies or requests for additional applicant information. Once State
sends a response regarding a Visas Mantis check, the post has to contact
the applicant to issue or deny the visa. However, we did not attempt to
determine how long this process takes.

9We assessed the reliability of the sample data provided by State by
tracing a statistically random sample of data to source documents. We
determined that the data were sufficiently reliable for the purposes of
this report.

improvements in processing times compared with earlier periods in 2003.
However, based on the documentation of how these cases were selected, we
were unable to determine whether these were scientifically valid samples
and therefore we could not validate that processing times have improved.
For the first sample, the data show that 58 percent of the cases were
completed within 30 days; for the second sample, the data show that 52
percent were completed within this time frame. In addition, the data for
both samples show that lengthy waits remain in some cases. For example, 9
of the 40 cases had been outstanding for more than 60 days as of December
3, 2003, including 3 cases that had been pending for more than 120 days.
Also, 9 of the 50 cases were still pending as of February 13, 2004,
including 6 that had been outstanding for more than 60 days. State
officials commented that most of the outstanding cases from both samples
were still being reviewed by the agencies.

During our fieldwork at posts in China, India, and Russia in September
2003, we also obtained data indicating that 410 Visas Mantis cases
submitted in fiscal year 2003 were still outstanding more than 60 days at
the end of the fiscal year.10 In addition, we found numerous cases-
involving 27 students and scholars from Shanghai-that were pending more
than 120 days as of October 16, 2003.

Several Factors Contribute to the Length of Time It Takes to Resolve Visas
Mantis Cases

We found that several factors, including interoperability problems among
the systems that State and FBI use, contribute to the time it takes to
process a Visas Mantis case. Because many different agencies, bureaus,
posts, and field offices are involved in processing Visas Mantis security
checks, and each has different databases and systems, we found that Visas
Mantis cases can get delayed or lost at different points in the process.11
We found that in fiscal year 2003, some Visas Mantis cases did not always
reach their intended recipient and as a result, some of the security
checks

10Outstanding cases include those where the posts had not heard back from
State headquarters and those where State had responded to the posts by
indicating that additional information or review time was needed. The
number of outstanding Visas Mantis cases is based only on F and J Visas
Mantis cases for the posts in China but includes other visa categories for
the remaining posts we visited.

11Posts have no way to ensure that State receives the Visas Mantis
request, State has no systematic check to know if the FBI receives the
cases, and the FBI has no way to ensure that its results are forwarded to
the posts. Information regarding a case may potentially be sent back and
forth between different agencies and offices several times before a
decision can be made on whether to issue a visa.

were delayed. For example, we followed up with the FBI on 14 outstanding
cases from some of the posts we visited in China in September 2003 to see
if it had received and processed the cases. FBI officials provided
information indicating that they had no record of receiving three of the
cases, they had responded to State on eight cases, and they were still
reviewing three cases. FBI officials stated that the most likely reason
why they did not have a record of the three cases from State were due to
cable formatting errors. State did not comment on the status of the 14
cases we provided to the FBI for review. However, a Consular Affairs
official told us that in fall 2003, there were about 700 Visas Mantis
cases sent from Beijing that did not reach the FBI for the security check.
The official did not know how the cases got lost but told us that it took
Consular Affairs about a month to identify this problem and provide the
FBI with the cases. As a result, several hundred visa applications were
delayed for another month.

Figure 1 illustrates some of the time-consuming factors in the Visas
Mantis process for our sample of 71 cases. While the FBI received most of
the cases from State within a day, seven cases took a month or more, most
likely because they had been improperly formatted and thus were rejected
by the FBI's system. In more than half of the cases, the FBI was able to
complete the clearance process the same day, but some cases took more than
100 days. These cases may have taken longer because (1) the FBI had to
investigate the case or request additional information from State; (2) the
FBI had to locate files in field offices, because not all of its files are
an electronic format; or (3) the case was a duplicate, which the FBI's
name check system also rejects. In most of the cases, the FBI was able to
send a response-which it generally does in batches of name checks, not by
individual case-to State within a week. The FBI provides the results of
name checks for Visas Mantis cases to State on computer compact disks
(CDs), a step that could cause delays. In December 2003, a FBI official
told us that these CDs were provided to State twice a week. However, in
the past, the CDs were provided to State on a less frequent basis. In
addition, it takes time for data to be entered in State's systems once
State receives the information. In the majority of our sample cases, it
took State 2 weeks or longer to inform a post that it could issue a visa.
State officials were unable to explain why it took State this long to
respond to post. Officials told us that the time frame could be due to a
lack of resources at headquarters or because State was waiting for a
response from agencies other than the FBI. However, the data show that
only 5 of the 71 cases were pending information from agencies other than
the FBI.

    Figure 1: Average Time Frames for Visas Mantis Cases, April to June 2003

Post Officials Seek Clearer Guidance and More Feedback

During our visits to posts in September 2003, officials told us they were
unsure whether they were adding to the wait time because they did not have
clear guidance on when to apply the Visas Mantis process and were not
receiving feedback on the amount of information they provided in their
Visas Mantis requests. According to the officials, additional information
and feedback from Washington agencies regarding these issues could help
expedite Visas Mantis cases. Consular officers told us that they would
like the guidance to be simplified-for example, by expressing some
scientific terms in more easily understood language. Several consular
officers also told us they had only a limited understanding of the Visas
Mantis process, including how long the process takes. They told us they
would like to have better information on how long a Visas Mantis check is
taking so that they can more accurately inform the applicant of the
expected wait.

Consular officers at most of the posts we visited told us they would like
more feedback from State on whether the Visas Mantis cases they are
sending to Washington are appropriate, particularly whether they are
sending too many or too few Visas Mantis requests. They said they would
like to know if including more information in the security check request
would reduce the time to process an application in Washington. Moreover,
consular officers indicated they would like additional information on some

of the outstanding Visas Mantis cases, such as where the case is in the
process. State confirmed that it has not always responded to posts'
requests for feedback or information on outstanding cases.

Wait for an Interview Can Also Add Significant Time

  Agency Officials Cite Improvements

Aside from the time it takes to process Visas Mantis checks, an applicant
also has to wait for an interview. State does not have data or criteria
for the length of time applicants at its overseas posts wait for an
interview, but at the posts we visited in September 2003, we found that it
generally took 2 to 3 weeks. Furthermore, post officials in Chennai,
India, told us that the interview wait time was as long as 12 weeks during
the summer of 2003 when the demand for visas was greater than the
resources available at post to adjudicate a visa. Officials at some of the
posts we visited indicated they did not have enough space and staffing
resources to handle interview demands and the new visa requirement that
went into effect on August 1, 2003. That requirement states that, with a
few exceptions, all foreign individuals seeking to visit the United States
need to be interviewed prior to receiving a visa. Factors such as the time
of year an applicant applies for a visa, the appointment requirements, and
the staffing situation at posts generally affect how long an applicant
will have to wait for an interview.

State and FBI officials acknowledged that visa waits have been a problem
but said they are implementing improvements to the process and working to
decrease the number of pending Visas Mantis cases. For example,

o  	State and FBI officials told us that the validity of Visas Mantis
checks for students and scholars has been extended to 12 months for
applicants who are returning to a program or activity and will perform the
same functions at the same facility or organization that was the basis for
the original Visas Mantis check.

o  	FBI officials said that to address delays stemming from problems with
lost case files or systems that are not interoperable, the FBI is working
on automating its files and setting up a common database between the field
offices and headquarters. They also told us they have set up a tracking
system within the FBI for all Security Advisory Opinions, including Visas
Mantis cases.

o  	Consular Affairs officials told us that State has invested about $1
million on a new information management system that it said would reduce
the time it takes to process Visas Mantis cases. They described the new

system as a mechanism that would help strengthen the accountability of
Visas Mantis clearance requests and responses, establish consistency in
data collection, and improve data exchange between State and other
agencies involved in the clearance process. In addition, officials said
the system would allow them to improve overall visa statistical reporting
capabilities and data integrity for Mantis cases. The new system will be
paperless, which means that the current system of requesting Visas Mantis
clearances by cable will be eliminated. State officials told us that the
system is on schedule for release early this year and that the portion
relating to Security Advisory Opinions will be operational sometime later
this year. However, challenges remain. FBI officials told us that the name
check component of the FBI's system would not immediately be interoperable
with State's new system but that they are actively working with State to
seek solutions to this problem. Nonetheless, FBI and State have not
determined how the information will be transmitted in the meantime. We
were not able to assess the new system since it was not yet functioning at
the time of our review.

o  	Officials from Consular Affairs and the FBI told us they are
coordinating efforts to identify and resolve outstanding Visas Mantis
cases. For example, they have been working together on a case-by-case
basis to make sure that cases outstanding for several months to a year are
completed. However, State officials said they do not have a target date
for completion of all the outstanding cases, which they estimated at 1,000
in November 2003.

o  	In addition to improvements to the Visas Mantis process, State
officials told us that they are monitoring post resource needs and adding
staff as needed. These officials also told us that State added 66 new
officers in 2003 and plans to add an additional 80 in 2004.

In conclusion, Mr. Chairman, agency officials recognize that the process
for issuing a visa to a science student or scholar can be an important
tool to control the transfer of sensitive technology that could put the
United States at risk. They also acknowledge that if the process is
lengthy, students and scholars with science backgrounds might decide not
to come to the United States, and technological advancements that serve
U.S. and global interests could be jeopardized. Our analysis of a sample
of Visas Mantis cases from April to June 2003 show that some applicants
faced lengthy waits. While the State Department and the FBI report
improvements in Visas Mantis processing times, our analysis of data from
the posts we visited in September 2003 and our contact with post officials
in January 2004 show that there are still some instances of lengthy waits.
State's and FBI's implementation of the Visas Mantis process still has
gaps

that are causing wait times for visas. State's new information management
system could improve the Visas Mantis process. Nevertheless, it is unclear
whether the new system will address all the current issues with the
process.

To help improve the process and reduce the length of time it takes for a
science student or scholar to obtain a visa, we are recommending that the
Secretary of State, in coordination with the Director of the FBI and the
Secretary of Homeland Security, develop and implement a plan to improve
the Visas Mantis process. In developing this plan, the Secretary should
consider actions to

o  	establish milestones to reduce the current number of pending Visas
Mantis cases;

o  	develop performance goals and measurements for processing Visas Mantis
checks;

o  	provide additional information through training or other means to
consular posts that clarifies guidance on the overall operation of the
Visas Mantis program, when Mantis clearances are required, what
information consular posts should submit to enable the clearance process
to proceed as efficiently as possible, and how long the process takes; and

o  	work to achieve interoperable systems and expedite transmittal of data
between agencies.

In commenting on our draft report, State said it had taken some actions to
improve the Visas Mantis process and it would study our recommendation to
make further improvements.

Mr. Chairman, this concludes my prepared statement. I would be happy to
answer any questions you or other members of the committee may have.

Contact and For future contacts regarding this testimony, please call Jess
Ford or John Brummet at (202) 512-4128. Individuals making key
contributions to this Acknowledgments testimony included Jeanette
Espinola, Heather Barker, Janey Cohen, and Andrea Miller.

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