Border Security: Actions Needed to Strengthen Management of	 
Department of Homeland Security's Visa Security Program 	 
(29-JUL-05, GAO-05-801).					 
                                                                 
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.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-801 					        
    ACCNO:   A31559						        
  TITLE:     Border Security: Actions Needed to Strengthen Management 
of Department of Homeland Security's Visa Security Program	 
     DATE:   07/29/2005 
  SUBJECT:   Americans employed abroad				 
	     Border security					 
	     Consulates 					 
	     Databases						 
	     Embassies						 
	     Homeland security					 
	     Law enforcement					 
	     Program evaluation 				 
	     Strategic planning 				 
	     Visas						 
	     Program implementation				 
	     DHS Visa Security Program				 
	     Saudi Arabia					 

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GAO-05-801

                 United States Government Accountability Office

                     GAO Report to Congressional Committees

July 2005

BORDER SECURITY

  Actions Needed to Strengthen Management of Department of Homeland Security's
                             Visa Security Program

                                       a

GAO-05-801

[IMG]

July 2005

BORDER SECURITY

Actions Needed to Strengthen Management of Department of Homeland Security's
Visa Security Program

                                 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

                      Applicant     Applicant                    
                      schedules      goes to                     
                      interview       post.                      
                      with post.         SAO not                 
                                          needed                 
                                    Applicant                            
                                    Consular                     
         Application                Consular       DHS reviews   Visa is
                                   interviewed                           
          reviewed,      DHS     officer reviews   and either     issued
                                     officer                     
        fingerprints             and name check    affirms or      or    
                                 decides to                      
                                  documentation                          
         taken, and                results and     refutes the   denied.
                                    issue or                     
                                 reviewed.                       
            name                 determines if      consular     
                                 deny visa                       
                                 DHS Security to officer's       
            check                       Advisory determination.  
         performed.                   applicant.                 

Opinion (SAO) is needed.

DHS

SAO SAUDI needed

ARABIA SAO Post submitted for receives interagency SAO check response

Sources: GAO; Nova Development (clip art), MapArt (map).

United States Government Accountability Office

Contents

  Letter

Results in Brief
Background
Several FactorsHaveLimited theImpactof 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

1 2 4

7 13 19 19 20 20

  Appendixes

Appendix I: Scope and Methodology 25

Appendix II:Comments from the Department of Homeland Security 26 GAO
Comments 37

Appendix III: Comments from the Department of State 39

Appendix IV: GAO Contacts and Staff Acknowledgements 42

Table Table 1: Visa Security Program Expansion

Figures Figure 1: Establishment and Implementation of the Visa Security
Program 6 Figure 2: Visa Process in Saudi Arabia 8

Contents

Abbreviations

CLASS Consular Lookout and Support System
DHS Department of Homeland Security
ICE Immigration and Customs Enforcement
VSO Visa Security Officer

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A

United States Government Accountability Office Washington, D.C. 20548

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.1 In
October 2002, we reported that the visa process should be strengthened and
that increased priority should be given to national security.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.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 Program4 to additional posts throughout
fiscal years 2005 and 2006.5 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

1A 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.

2We 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).

3P.L. 107-296.

4For 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.

5In this report, we do not name the exact locations DHS plans to expand to
because the department stated this is sensitive information.

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) 386
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.

6The 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.

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.7 In August 2003, DHS
created the Office of International Enforcement within the Border and
Transportation Security Directorate,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

o 	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;

7P.L. 107-296, Sec. 428(e) and Sec. 428(i).

8Border 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.

o 	review applications on their own initiative or at the request of
consular officers, and provide input on or recommend security advisory
opinion requests;9 and

o 	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.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.

9In 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.

10State'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.

Figure 1: Establishment and Implementation of the Visa Security Program

August 31, 2003 -VSOs assigned to Saudi Arabia.

September 26, 2003 -DHS submits NSDD-38 Memorandum of requests for 5
expansion

Understanding on posts. section 428 between DHS and State signed.

Source: GAO.

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.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.

11DHS 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).

Several Factors Have According to embassy officials in Saudi Arabia and
DHS officials, the VSOs

enhance homeland security through their review of visa applications
atLimited the Impact of posts in Saudi Arabia. However, several factors
have hindered the program, Visa Security including a lack of comprehensive
data on the VSOs' activities and results Operations in Saudi in Riyadh and
Jeddah to demonstrate the program's overall impact at these

  Arabia posts.

    VSOs Provide Additional Law Enforcement Capability to the Visa Process in
    Saudi Arabia

VSOs Provide Additional Review to Visa Adjudication Process

VSOs in Saudi Arabia provide an additional law enforcement capability to
the visa adjudication process. VSOs have access to and experience using
important law enforcement information not readily available to consular
officers. Moreover, VSOs' border security and immigration experience can
assist consular officers during the visa process.

According to State Department consular officers, the deputy chief of
mission, and DHS officials, VSOs in Saudi Arabia enhance the security of
the visa adjudication process at these consular posts. In particular, the
consular sections in Riyadh and Jeddah have incorporated the VSOs' review
of all visa applications into the adjudication process (see fig. 2). After
consular officers interview an applicant and review the relevant
supporting documentation, they make a preliminary determination about
whether to issue or refuse the visa or refer the case to Washington for
additional security clearances. Consular officers may consult with VSOs
during this initial determination. According to the VSOs, within 24 hours
of this initial determination by consular officers, they review the
application and inspect the applicant's documentation for evidence of
fraud or misrepresentation, indicators of potential national security
risks, criminal activity, and potential illegal immigration risks. VSOs
may also query the applicant's information against a number of law
enforcement, immigration, and other databases, which may contain more
detail than the consular officers' name check results. Based on these
reviews, the VSOs will either affirm or oppose the consular officer's
original decision, and the consular officer then decides to issue or deny
the visa. If the consular section chief and the VSOs disagree on a case,
it is sent to DHS, where the Secretary of Homeland Security, in
consultation with State officials, will render a final determination.
According to a consular official in Saudi Arabia at the time of our visit
in February 2005, no case has ever been sent back to Washington for such a
decision.

Figure 2: Visa Process in Saudi Arabia

Applicant schedules interview with post.

SAUDI ARABIA

SAO not needed

Applicant Application    Applicant    Consular   Consular   DHS reviews     Visa 
                                      officer                                 is 
 goes to   reviewed,    interviewed   reviews    officer     and either   issued 
  post.                     and         name                              
          fingerprints documentation   check    decides to   affirms or       or 
             taken,                   results                             
            and name     reviewed.      and      issue or   refutes the   denied 
             check                   determines    deny                   
           performed.                    if      visa to      consular    
                                      Security                            
                   DHS           DHS  Advisory  applicant.   officer's    
                                      Opinion              determination. 
                                       (SAO)                              
                                     is needed.                           

SAO needed DHS

DHS officers in consular posts in Saudi Arabia participate in the visa
process at three points:

1. VSOs in Riyadh conduct some name checks and investigative research in
criminal and SAO Post immigration databases to assist consular submitted
receives officers' interviews of applicants. for SAO

2. VSOs may conduct secondary interviews. interagency response

3. VSOs assist consular officers during interviews. check

Source: GAO; Nova Development (clip art), MapArt (map).

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 VSOs have access to and experience using
immigration and law

Enforcement Information Not enforcement databases not readily available to
consular officers, who are

Readily Available to Consular not classified as criminal justice, or law
enforcement, personnel. Consular

Officers 	officers rely on information contained in the Consular Lookout
and Support System (CLASS)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.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.

12CLASS 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.

13Section 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.

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"
list14-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 According to DHS, the VSOs' law enforcement
experience and training and

and Fraud Detection Knowledge knowledge of immigration law enables them to
more effectively identify

and Training 	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

14The 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.

antifraud duties often performed by junior officers on a part-time
basis.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.

o 	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.

o 	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,

15Consular 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.

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.

o 	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.16

o 	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.

16Pursuant to DHS's NSDD-38 request for Saudi Arabia, the department is
authorized to have up to 6 personnel in Saudi Arabia.

    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.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:

o 	risk of terrorism in a country based on State's threat assessments and
intelligence of terrorist activity;

o  visa workload;

o  visa denial rates; and

o  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.

17The 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.

    Questions Raised by Embassy Officials Contributed to Delays of DHS Expansion

Questions Raised about the Site Selection Criteria Used to Select
Expansion Posts

Embassy officials raised questions and concerns regarding the plans to
expand the Visa Security Program, which contributed to the delays in the
approval of the NSDD-38 requests. State's Office of Rightsizing the U.S.
Overseas Presence supported the posts' questions of DHS's plans for
expansion of the Visa Security Program.

Embassy officials at the expansion posts expressed concerns with the site
selection process and the criteria DHS used to select the posts, which
contributed to the delays in approving DHS's requests for VSOs. Based on
DHS's quantitative evaluation criteria used to select expansion posts,
visa issuing posts were ranked to identify priority posts for the
deployment of VSOs. However, of the 5 posts selected for expansion of the
Visa Security Program, 2 of the posts ranked outside of the top 10 posts
identified by DHS's evaluation. Moreover, embassy officials at one of
these expansion posts that did not rank in the initial top 10 believe that
DHS's selection criteria does not justify the assignment of VSOs to their
post. In particular the consular chief stated that the post had a
relatively low application volume and a low refusal rate-two criteria that
DHS used to select the fiscal year 2005 expansion posts. DHS stated that
this particular post was chosen based on other qualitative data,
consultation with law enforcement and intelligence officials, and
practical considerations for expansion of the program. These additional
factors were not included in the methodology DHS developed to identify
priority posts for expansion of the Visa Security Program. Embassy
officials at 2 posts chosen for expansion were unaware of the criteria
used to select the expansion posts; however, DHS stated that they had
explained their criteria.

Embassy officials also questioned the reasoning behind the number of VSOs
that DHS requested for assignment to the selected expansion posts. In June
2004, DHS originally requested the assignment of 21 VSO positions to 5
posts. According to DHS, the request for the number of VSOs at each post
was based on the assessment of several factors including the workload at
post. However, chiefs of mission and consular officials also told us that
they were unclear about the number of VSOs required for visa security
operations and requested for assignment. DHS officials stated that they
had explained their rationale fully. As of June 2005, four posts had
approved the assignment of 13 VSO positions. Table 1 shows the number of
VSO positions requested compared to the number of VSO positions approved
by chiefs of mission.

                    Table 1: Visa Security Program Expansion

                                                                VSO positions 
                                                 VSO positions    approved by 
                     Date of NSDD-      Date of   requested by      chiefs of 
          Location   38 request        approval            DHS        mission 
            Post 1    June 2004       July 2004              5 
            Post 2    June 2004      March 2005              5 
            Post 3    June 2004         Not yet              4 
                                       approved                
            Post 4    June 2004       June 2005              3 
            Post 5    June 2004       June 2005              4 
             Total                                          21 

Source: Department of Homeland Security.

Note: Table 1 shows VSO positions and administrative support positions
approved as of June 2005.

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.18 In August
2004, State's Office of Rightsizing the U.S. Overseas Presence,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

o  criteria for selecting the expansion posts;

o 	agreement on administrative support services, such as building
maintenance, utilities, supplies, and equipment, among others;

o 	the extent to which the VSOs will have regional responsibilities at
other embassies or consulates;

o 	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

o 	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

18See GAO, Overseas Presence: Framework for Assessing Embassy Staff Levels
Can Support Rightsizing Initiatives, GAO-02-780 (Washington, D.C.: July
26, 2002).

19State'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.

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 plan20 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.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

20The 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.

21See GAO, Executive Guide: Effectively Implementing the Government
Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).

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 	To help ensure that the Visa Security Program, and
its expansion to other locations worldwide, is managed effectively, we
recommend that the

Executive Action Secretary of Homeland Security:

o 	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.

o 	develop performance data that can be used to assess the results of the
Visa Security Program at each post.

Matter for Congress may wish to consider amending current legislation,
which

requires that VSOs in Saudi Arabia review all visa applications prior
toCongressional adjudication, to provide DHS the flexibility to determine
the extent to Consideration 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 http://www.gao.gov.

If you have any questions about this report, please contact me at (202)
512
4128 or [email protected]. 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.

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

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.

Appendix II

Comments from the Department of Homeland Security

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

Appendix II Comments from the Department of Homeland Security Appendix II
Comments from the Department of Homeland Security Appendix II Comments
from the Department of Homeland Security

Now on Highlights Page. See comment 1.

Now on page 2. See comment 2.

Now on page 2.

Now on page 13. See comment 3.

Now on page 11. See comment 4.

Appendix II Comments from the Department of Homeland Security

Now on page 4. Now on page 5.

Now on page 7. Now on page 7.

Now on page 2. Now on page 13.

Now on page 12.

Appendix II Comments from the Department of Homeland Security

                                 Now on page 2.

                                 See comment 5.

                                 Now on page 3.

                                Now on page 13.

 Now on page 3. Now on page 15. Now on page 15. Now on page 15. Now on page 17.

Appendix II Comments from the Department of Homeland Security Appendix II
Comments from the Department of Homeland Security

Now on page 15.

Now on page 16.

Now on page 16. Now on page 16.

Now on page 3. Now on page 20. Now on page 20.

Appendix II Comments from the Department of Homeland Security

Now on page 6.

Now on page 7.

Now on page 9. Now on page 10.

See comment 6.

Now on page 8. See comment 6.

Appendix II Comments from the Department of Homeland Security

                         Now on page 15. See comment 7.

                                Now on page 15.

                        Now on page 18. Now on page 18.

                                Now on page 19.

                                Now on page 19.

                                 See comment 8.

Appendix II Comments from the Department of Homeland Security

         Appendix II Comments from the Department of Homeland Security

The following are GAO's comments on the Department of Homeland Security's
letter dated July 15, 2005.

  GAO Comments 1.

2.

3.

4.

5.

We revised the highlights page to reflect that no comprehensive data
exists to demonstrate the impact of the VSOs in Saudi Arabia.

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.

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.

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.

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

Appendix II Comments from the Department of Homeland Security

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.

                                  Appendix III

                     Comments from the Department of State

Appendix III
Comments from the Department of State

Appendix III
Comments from the Department of State

Appendix IV

                     GAO Contact and Staff Acknowledgments

                      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.

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