State Has Worked  with UNHCR on  Various Measures  Designed to Ensure  the Integrity of the  Resettlement Referral  Process In July 2017, we found that State and UNHCR have worked together on  several measures designed to ensure integrity in the process through  which UNHCR refers refugees to USRAP for potential resettlement in the  United States (or, the resettlement referral process). Since 2000, State  and UNHCR have outlined their formal partnership using a Framework for  Cooperation. State and UNHCR signed the most recent framework  document in 2016, covering the period of March 14, 2016 to December  31, 2017. The organizations developed the framework to guide their  partnership, emphasizing measures such as oversight activities and risk  management. Among other things, the framework emphasizes improved  accountability at UNHCR through effective oversight measures, close  cooperation with State, and organization-wide risk management. In  addition, the framework notes that State will work to ensure that UNHCR  allocates sufficient resources to fully implement measures to provide  oversight and accountability. For instance, UNHCR has several offices  that are responsible for overseeing antifraud activities, in addition to  providing audit services, investigating instances of fraud, and conducting  broad reviews of country-level operations such as the United Nations  Office of Internal Oversight Services and the Board of Auditors. The  framework also describes regular coordination and communication  between State and UNHCR as an important principle in the relationship  between the two organizations. Specifically, at the headquarters level, the  U.S. Mission in Geneva, Switzerland, has a humanitarian affairs office  that, according to State officials, coordinates with UNHCR on a regular  basis. Additionally, UNHCR has developed standard operating procedures  (SOPs) and identity management systems to combat the risk of fraud and  worked with State to implement these activities in the resettlement  process. Despite the complexity and regional variations in its refugee  registration, refugee status determination, and resettlement referral  processes, UNHCR officials said that standardizing procedures ensures  that the organization has established basic antifraud practices worldwide.  These officials added that they believe that the SOPs are among the most  important tools with which they ensure the integrity of the resettlement  referral process. UNHCR officials also collect biometric information on  refugees, such as iris scans and fingerprints. State and UNHCR  developed a Memorandum of Understanding (MOU) regarding the  sharing of some biometric information. According to a Letter of  Understanding that accompanies the MOU, it provides a framework  whereby data from UNHCR is shared with State, which allows for  increased efficiency and accuracy in processing resettlement referrals to  the United States. See figure 2 for photographs of technology that  UNHCR uses to register and verify refugee identities. State and RSCs Have  Policies and  Procedures for  Processing Refugees,  but State Could  Improve Efforts to  Monitor RSC  Performance State and RSCs have policies and procedures for processing refugee  applications, but, as we found in July 2017, State has not established  outcome-based performance measures to assess whether RSCs are  meeting their objectives under USRAP. State’s USRAP Overseas  Processing Manual includes requirements for information RSCs should  collect when prescreening applicants and initiating national security  checks, among other things. RSCs communicate directly with USRAP  applicants and prepare their case files. For example, RSCs are to  conduct prescreening interviews to record key information, such as  applicants’ persecution stories and information about their extended  family, and submit certain security checks based on the information  collected during the interview to U.S. agencies. In addition, State  developed SOPs for processing and prescreening refugee applications at RSCs, which State officials indicated provide baseline standards for RSC  operations. Further, all four of the RSCs we visited provided us with their  own local SOPs that incorporated the topics covered in State’s SOPs.  Directors at the remaining five RSCs also told us that they had developed  local SOPs that covered the overarching USRAP requirements. We  observed how RSC staff implemented State’s case processing and  prescreening policies and procedures during our site visits to four RSCs  from June 2016 to September 2016. Specifically, we observed 27  prescreening interviews conducted by RSC caseworkers at the four RSCs  we visited and found that these caseworkers generally adhered to State  requirements during these interviews. In addition, we observed how RSC  staff in all four locations implemented additional required procedures  during our site visits, such as initiating required security checks and  compiling case file information for USCIS interviewing officers, and found  that these RSC staff were generally complying with SOPs. State has control activities in place to monitor how RSCs implement  policies and procedures for USRAP, but it does not have outcome-based  performance indicators to assess whether RSCs are meeting their  objectives under USRAP. Consistent with State’s January 2016 Federal  Assistance Policy Directive, and according to State officials, State is  required to monitor the RSCs it funds, whether through cooperative  agreements or voluntary contributions. On the basis of our interviews  with State officials and as reflected in documentation from all nine RSCs,  including quarterly reports to State, all RSCs have generally undergone  the same monitoring regime regardless of funding mechanism. Further,  according to State officials, the department has dedicated Program  Officers located in Washington, D.C., and Refugee Coordinators based in  U.S. embassies worldwide, who are responsible for providing support to  RSCs and monitoring their activities—including conducting annual  monitoring visits. Further, State has established objectives for RSCs,  which include interviewing applicants to obtain relevant information for the  adjudication and ensuring the accuracy of information in State’s database  and the case files. State also establishes annual targets for the number of  refugees who depart for the United States from each RSC. Although State has established objectives and monitors several  quantitative goals for RSCs, it has not established outcome-based  performance indicators for key RSC activities such as prescreening  applicants or accurate case file preparation, or monitored RSC  performance consistently across such indicators. Specifically, neither the  quarterly reports nor other monitoring reports we examined have or use  consistent outcome-based performance indicators from which State could  evaluate whether RSCs were consistently and effectively prescreening  applicants and preparing case files—key RSC activities that have  important implications for timely and effective USCIS interviews and  security checks. Developing outcome-based performance indicators, as  required by State policy and performance management guidance, and  monitoring RSC performance against such indicators on a regular basis,  would better position State to determine whether all RSCs are processing  refugee applications in accordance with their responsibilities under  USRAP. USCIS Has Policies  and Procedures for  Adjudicating Refugee  Applications, but  Could Improve  Training and Quality  Assurance USCIS Has Policies and  Procedures to Adjudicate  Refugee Applications, but  Could Improve Training for  Temporary Officers USCIS has developed policies and procedures for adjudicating refugee  applications. In July 2017, we found that these policies and procedures  apply to all USCIS officers who adjudicate refugee applications—those  from USCIS’s Refugee Affairs Division (RAD), International Operations  Division (IO), and temporary officers from offices throughout USCIS—and  include those for how officers are to review the case file before the  interview and conduct the interview, as well as how supervisors are to  review applications to ensure they are legally sufficient. We observed 29  USCIS refugee interviews at the four RSCs that we visited from June  2016 to September 2016 and found that the interviewing officers  completed all parts of the assessment tool and followed other required  policies. We also observed that the USCIS officers documented the  questions they asked and the answers the applicants provided. We also  observed USCIS supervisors while they reviewed officers’ initial  decisions, interview transcripts, and case file documentation, consistent  with USCIS policy, at two of the sites we visited. Further, all six of the  officers that we met with stated that supervisors conducted the required  supervisory case file review during their circuit rides and the four  supervisory officers we met with were aware of the requirements and  stated that they conducted the supervisory reviews. USCIS also provides specialized training to all officers who adjudicate  applications abroad, but we found that USCIS could provide additional  training for officers who work on a temporary basis. According to USCIS  policy, all USCIS officers who adjudicate refugee applications must  complete specialized training, and the training varies based on the USCIS  division of the officer. However, temporary officers receive a condensed  (or shortened) version of the trainings received by full time refugee  officers and do not receive infield training. Although temporary officers  receive training prior to conducting in-person interviews with refugee  applicants, we found that they sometimes face challenges adjudicating  refugee applications. Specifically, we reviewed 44 summary trip reports  USCIS supervisors completed following officers’ trips overseas to  interview USRAP applicants from the fourth quarter of 2014 through the  third quarter of 2016 that included adjudications by temporary officers. In 15 of the 44 reports, the supervisors noted that temporary officers  faced challenges adjudicating refugee applications. Standards for Internal  Control in the Federal Government state that management should  demonstrate a commitment to recruit, develop, and retain competent  individuals. The standards also note that competence is the qualification  to carry out assigned responsibilities, and requires relevant knowledge,  skills, and abilities, which are gained largely from professional  experience, training, and certifications. To the extent that USCIS uses  temporary officers on future circuit rides, providing them with additional  training, such as in-field training, would help better prepare them to  interview refugees and adjudicate their applications, increase the quality  and efficiency of their work, and potentially reduce the supervisory burden  on those who oversee temporary officers. USCIS Has Resources to  Help Officers Identify  Applicants with National  Security Concerns, but  Has Not Documented  Plans for Deploying  Officers with National  Security Expertise  Overseas In addition to training, USCIS has developed guidance documents and  tools to help officers identify USRAP applicants with potential national  security concerns. However, we found that USCIS could strengthen its  efforts by developing and implementing a plan for deploying officers with  national security expertise on selected circuit rides. USCIS provides a  number of resources to officers to help them identify and address  potential national security-related concerns in USRAP applications. In  addition, USCIS’s national security policies and operating procedures  require that cases with national security concerns be placed on hold by  interviewing officers. These cases are then reviewed by USCIS  headquarters staff who have additional specialized training and expertise  in vetting national security issues. While USCIS has training and  guidance to adjudicate cases with national security-related concerns,  USCIS trip reports we analyzed and officers we interviewed indicated that  it can be challenging to adjudicate such applications. USCIS officials  identified several reasons why it is challenging to provide training and  guidance on how to adjudicate cases with potential national security  concerns. For example, according to RAD and IO headquarters officials,  indicators of national security concerns and the country conditions that  give rise to them evolve and change; as a result, USCIS guidance on how  to address those concerns also changes over time. To further help interviewing officers adjudicate cases with national  security concerns, in 2016, USCIS completed a pilot program that  included sending officers with national security expertise overseas to  support interviewing officers in some locations. USCIS determined the  pilot was successful and has taken steps to formalize it; however, USCIS  has not developed and implemented a plan for deploying these additional  officers, whose expertise could help improve the efficiency and  effectiveness of the adjudication process. In light of the evolving and  significant nature of national security concerns, developing and  implementing a plan to deploy additional USCIS officers with national  security expertise on circuit rides—including timeframes for deployment  and how USCIS will select circuit rides for deployment—would better  ensure that USCIS provides interviewing officers with the resources  needed to efficiently and effectively adjudicate cases with national  security concerns. USCIS Does Not Conduct  Regular Quality Assurance  Assessments of Refugee  Adjudications We also found that USCIS has not regularly assessed the quality of  refugee adjudications, which help ensure that case files are completed  accurately and that decisions by USCIS officers are well-documented and  legally sufficient. USCIS conducted a quality assurance review of  refugee adjudications in fiscal year 2015, which included a sample of  applications adjudicated by RAD and IO during one quarter of the fiscal  year. The 2015 quality assurance review found that most cases in the  sample were legally sufficient. However, the review indicated that there  were differences between RAD and IO adjudications. Specifically, the  review rated 69 of 80 RAD case files (86 percent) as good or excellent,  and rated 36 of 73 IO case files (49 percent) as good or excellent. Two of  80 RAD case files (less than 3 percent) in the review and 17 of 73 IO  case files (23 percent) were rated as not legally sufficient. USCIS  developed action items to address identified deficiencies and has taken  steps to implement them. Among cases rated not legally sufficient, the  most common deficiency identified was that interviewing officers did not  fully develop the interview record with respect to possible  inadmissibilities. Other deficiencies reported included interview records  not being fully developed with respect to well-founded fear of persecution,  improper documentation and analysis of terrorism-related inadmissibility  concerns, incorrect hold determination, and required sections of the  assessment leading to the adjudication decision that were incomplete. Although there have been major changes in the refugee caseload in the  past 2 years (such as an increase in Syrian refugees), an increased use  of temporary staff to conduct refugee adjudications in fiscal year 2016,  and the difference in quality between RAD and IO adjudications noted in  the 2015 quality assurance review, USCIS did not conduct quality reviews  in 2016 and had no plans to conduct them in 2017. Standards for Internal  Control in the Federal Government states that management should  establish and operate monitoring activities to monitor the internal control  system and evaluate the results. In addition, standard practices for  program management state that program quality should be monitored on  a regular basis to provide confidence that the program will comply with  the relevant quality policies and standards. USCIS officials stated that  supervisors continue to review each refugee case file for legal sufficiency  and completeness at the time of the interview. While supervisory review is  an important quality control step, it does not position USCIS to identify  systematic quality concerns, such as those identified in the fiscal year  2015 quality assessment results. Conducting such reviews would help  ensure that case files are completed accurately and that decisions by  USCIS officers are well-documented and legally sufficient. State, USCIS, and  Their Partners Have  Implemented  Antifraud Measures  but Could Further  Assess Staff and  Applicant Fraud Risks To Address Fraud Risks,  State and RSCs Have  Taken Steps to Follow  Many Leading Antifraud  Practices but Could  Improve Implementation of  Controls and Assessment  of Risk According to State officials we interviewed for our July 2017 report, staff  fraud at RSCs occurs infrequently, but instances of staff fraud have taken  place in recent years, such as RSC staff soliciting bribes from applicants  in exchange for promises of expediting applicants through RSC  processing. State and RSCs reported instituting a number of activities to  combat the risk of fraud committed by RSC staff. Many of these activities  correspond with leading practices identified in GAO’s Fraud Risk  Framework which identifies leading antifraud practices to aid program  managers in managing fraud risks that affect their program. For  instance, State and RSCs reported that they have taken steps to commit  to an organizational culture and structure to help manage staff fraud risks  and established collaborative relationships with both internal and external  partners to share information. Officials from all nine RSCs stated that they  assign staff fraud risk management responsibilities to designated  individuals. In addition, State and RSCs reported that RSCs have  designed control activities to address staff fraud risk. State officials  identified two key guidance documents containing control activities: RSC  SOPs and the Program Integrity Guidelines. The Program Integrity  Guidelines are a list of 87 measures designed to prevent and mitigate  staff fraud at RSCs. The measures were developed by State and  provided to RSCs in response to a staff fraud incident in 2013 that  resulted in the termination of two RSC staff. These measures include  control activities addressing issues such as background checks,  interpreter assignment, antifraud training, office layout, case file reviews,  electronic data management, and reporting and responding to instances  of suspected fraud. State required RSCs to comply with the original Program Integrity  Guidelines by October 2014; however, our review of RSC documents  found that RSCs reported complying with most, but not all, of the required  measures applicable to their operations. Reported compliance with  required, applicable measures at individual RSCs ranged from 86 percent  to 100 percent. For 53 of the 72 measures, compliance was reported by  all RSCs for which the measure was applicable. Some RSCs have  reported that they face challenges in fully implementing certain controls.  State officials told us that they work to ensure that each RSC complies  with all required controls in the Program Integrity Guidelines. If an RSC  reports that it does not yet fully comply with a measure listed in the  Program Integrity Guidelines, State expects the RSC to report its  progress toward compliance to State. While this reporting assists State in  its implementation efforts, we found that gaps remain. Full compliance  with these measures could help RSCs ensure the integrity of their  operations and guard against staff fraud. In addition, State has taken some steps to assess the risks posed by staff  fraud to RSC operations; however, we found that not all RSCs have  conducted staff fraud risk assessments that follow leading practices  identified in the Fraud Risk Framework, including (1) conducting  assessments at regular intervals or when the program experiences  changes, (2) tailoring assessments to the program and its operations, and  (3) examining the suitability of existing fraud controls. State officials told  us that not all RSCs had conducted staff fraud risk assessments because  State’s Program Integrity Guidelines recommend but do not require these  assessments. Without State requiring RSCs to conduct regular staff fraud  risk assessments tailored to their specific operations, staff fraud risk  assessments conducted by individual RSCs have varied. Further, we  found that State and most RSCs have not examined the suitability of  existing fraud controls. For example, while one RSC has regularly  assessed the suitability of its existing staff fraud controls by conducting  regular staff fraud risk assessments that examine the likelihood and  impact of potential fraudulent activity and related fraud controls, the  remaining eight RSCs have not done so. State officials told us that  because State does not require RSCs to conduct risk assessments,  information needed to assess the suitability of existing controls is not  available from all RSCs. As the number of refugees accepted varies each  year by RSC, internal control systems may need to be changed to  respond to the potential increased fraud risk. Without requiring RSCs to  conduct regular staff fraud risk assessments that are tailored to their  specific operating environments and reviewing these assessments to  examine the suitability of existing fraud controls, State may lack  necessary information about staff fraud risks and therefore not have  reasonable assurance that existing controls effectively reduce these risks.  Information from such risk assessments could help State and RSCs  revise existing controls or develop new controls to mitigate the staff fraud  risks faced by the program, if necessary. State and USCIS Have  Mechanisms to Help  Detect and Prevent  Applicant Fraud, but Could  Jointly Assess Applicant  Fraud Risks Fraud can occur in the refugee process in a number of ways, and State,  RSCs, and USCIS have implemented certain mechanisms to help detect  and prevent fraud by USRAP applicants. USCIS officers can encounter  indicators of fraud while adjudicating refugee applications, and State has  suspended USRAP programs in the past because of fraud. To detect and  prevent applicant fraud in USRAP, State, RSCs, and USCIS have put  mechanisms in place such as DNA testing for certain applicants; training  on applicant fraud trends for USCIS officers; and procedures at RSCs to  require, where possible, that different interpreters be involved in different  stages of the USRAP application process to decrease the likelihood that  applicants collude with interpreters. However, State and USCIS have not  jointly assessed applicant fraud risks program-wide. The Fraud Risk  Framework calls for program managers to plan and conduct regular fraud  risk assessments. In addition, Standards for Internal Control in the  Federal Government states that management should consider the  potential for fraud when identifying, analyzing, and responding to risks,  and analyze and respond to identified fraud risks, through a risk analysis  process, so that they are effectively mitigated. Although State and USCIS perform a number of fraud risk management  activities and have responded to individual instances of applicant fraud,  we found that these efforts do not position the agencies to assess fraud  risks program-wide for USRAP or know if their controls are appropriately  targeted to the areas of highest risk in the program. State and USCIS  officials told us that each agency has discrete areas of responsibility in  the refugee admissions process, and each agency’s antifraud activities  are largely directed at their portions of the process. Because the  management of USRAP involves several agencies, without jointly and  regularly assessing applicant fraud risks and determining the fraud risk  tolerance of the entirety of USRAP, in accordance with leading practices,  State and USCIS do not have comprehensive information on the inherent  fraud risks that may affect the integrity of the refugee application process  and therefore do not have reasonable assurance that State, USCIS, and  other program partners have implemented controls to mitigate those risks.  Moreover, regularly assessing applicant fraud risks program-wide could  help State and USCIS ensure that fraud prevention and detection efforts  across USRAP are targeted to those areas that are of highest risk, in  accordance with the program’s fraud risk tolerance. Our  Recommendations  and Agencies’  Responses In our July reports, we made several recommendations to State and DHS.  Specifically, we recommended that State take the following actions in  GAO-17-706: develop outcome-based indicators for RSC, as required by State monitor RSC performance against such indicators on a regular basis;  And we recommended that State take the following actions in  GAO-17-737: actively pursue efforts to ensure that RSCs comply with required,  applicable measures in the Program Integrity Guidelines; update guidance, such as the Program Integrity Guidelines, to require  each RSC to conduct regular staff fraud risk assessments that are  tailored to each RSC’s specific operations; and  regularly review RSC staff fraud risk assessments and use them to  examine the suitability of existing staff fraud controls and revise  controls as appropriate. We recommended that USCIS take the following actions in GAO-17-706: provide additional training for any temporary officers who adjudicate develop and implement a plan to deploy officers with national security  conduct regular quality assurance assessments of refugee application  adjudications across RAD and IO. We also recommended that State and USCIS conduct regular joint risk  assessments of applicant fraud risk across USRAP. State and USCIS concurred with all of our recommendations and have  actions underway to address them. For example, State noted that it has  developed new guidance to enhance the monitoring of RSCs, which  outlines roles, responsibilities, and tools for program officers and refugee  coordinators. In addition, USCIS provided documentation that USCIS  officials conducted a quality assurance assessment of refugee  adjudications in July 2017. Moreover, in July 2017, USCIS provided  documentation indicating that it instituted additional headquarters and  overseas training for temporary officers consistent with our  recommendation. Therefore, we closed this recommendation as  implemented. Chairman Labrador, Ranking Member Lofgren, and Members of the  Subcommittee, this completes my prepared statement. I would be  pleased to respond to any questions that you may have. GAO Contacts and  Staff  Acknowledgments For further information regarding this testimony, please contact Rebecca  Gambler, Director, Homeland Security and Justice at (202) 512-8777 or  gamblerr@gao.gov, or Thomas Melito, Director, International Affairs and  Trade at (202) 512-9601 or melitot@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement. GAO staff who made key contributions to  this testimony are David Alexander, Ashley Alley, Kathryn Bernet,  Anthony Costulas, Martin De Alteriis, Brian Hackney, Paul Hobart,  Thomas Lombardi, and Elizabeth Repko. This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.
According to UNHCR, as of June 2017, more than 21 million people were refugees worldwide. State manages the U.S. Refugee Admissions Program (USRAP) and coordinates with UNHCR, which refers the most applicants to USRAP, and USCIS, which adjudicates refugee applications. Deterring and detecting fraud is essential to ensuring the integrity of USRAP and an increase in the number of applicants approved for resettlement in the United States from countries where terrorists operate has raised questions about the adequacy of applicant screening. This statement addresses (1) how State works with UNHCR to ensure program integrity in the UNHCR resettlement referral process; (2) the extent to which State and RSCs have policies and procedures on refugee case processing and State has overseen RSC activities; (3) the extent to which USCIS has policies and procedures for adjudicating refugee applications; and (4) the extent to which State, USCIS, and their partners follow leading practices to reduce the risk of staff and applicant fraud in USRAP. This statement is based on GAO's July 2017 reports regarding USRAP. To conduct that work, GAO analyzed State, USCIS, and UNHCR policies; interviewed relevant officials; conducted fieldwork in 2016 at selected UNHCR offices, as well as at RSCs in Austria, Jordan, Kenya, and El Salvador, where GAO observed a nongeneralizable sample of refugee screening interviews (selected based on application data and other factors). The Department of State (State) and the United Nations High Commissioner for Refugees (UNHCR) have worked together on measures designed to ensure integrity in the refugee resettlement referral process and have established a framework to guide their partnership. Working with State, UNHCR has implemented standard operating procedures and other guidance that, according to UNHCR officials, provides baseline requirements throughout the referral process. UNHCR also uses databases to help verify the identities of, and manage information about, refugees. State and the nine worldwide Resettlement Support Centers (RSC) have policies and procedures for processing refugee applications. Overseen by State, the organizations that operate RSCs hire staff to process and prescreen applicants who have been referred for resettlement consideration. GAO observed 27 prescreening interviews conducted by RSC caseworkers in four countries and found that, for example, RSCs generally recorded key information and submitted any required security checks. However, State has not established outcome-based performance indicators to evaluate whether RSCs were consistently and effectively prescreening applicants and preparing case files—key RSC activities that have important implications for timely and effective adjudication and security checks. Developing outcome-based performance indicators would better position State to determine whether RSCs are meeting their responsibilities. The Department of Homeland Security's U.S. Citizenship and Immigration Services (USCIS) has policies and procedures for adjudicating refugee applications for resettlement in the United States, including how officers are to conduct interviews and adjudicate applications. GAO observed 29 USCIS interviews and found that officers completed all parts of the required assessment. USCIS also provides guidance to help officers identify national security concerns in applications, which can be challenging to identify as country conditions evolve. In 2016, USCIS determined that its pilot to send officers with national security expertise overseas to support interviewing officers was successful. USCIS has taken steps to fill these positions, but it has not yet developed a plan for deploying these additional officers, whose expertise could help improve the effectiveness of the adjudication process. State, USCIS, and their partners have implemented antifraud measures to reduce the risk of staff and applicant fraud—both of which have occurred—but could further assess fraud risks. Officials from all nine RSCs stated that they assign staff fraud risk management responsibilities to designated individuals. However, not all RSCs reported complying with all required program integrity measures—reported compliance at individual RSCs ranged from 86 to 100 percent. State has also not required RSCs to conduct regular staff fraud risk assessments tailored to each RSC or examined the suitability of related controls. Without taking additional steps to address these issues, State and RSCs may face challenges in identifying new staff fraud risks or gaps in the program's internal control system and implementing new control activities to mitigate them. Further, State and USCIS have not jointly assessed applicant fraud risk program-wide. Doing so could help them ensure that fraud detection and prevention efforts across USRAP are targeted to those areas that are of highest risk.