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    Subject Term: "Immigration services"

    4 publications with a total of 17 open recommendations
    Director: Seto Bagdoyan
    Phone: (202) 512-6722

    1 open recommendations
    Recommendation: To strengthen USCIS's EB-5 Program fraud risk management, the Director of USCIS should develop a fraud risk profile that aligns with leading practices identified in GAO's Fraud Risk Framework.

    Agency: Department of Homeland Security: United States Citizenship and Immigration Services
    Status: Open

    Comments: In November 2016, Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS)stated that the program would implement GAO's recommendation to develop a fraud risk profile and anticipated completion by September 30, 2017. In April 2017, USCIS provided an update including supporting documentation which reported that USCIS had contracted with an outside consultant to, among other things, develop a fraud risk profile that aligns with leading practices identified in GAO's Fraud Risk Framework. According to its response, USCIS expected to complete development of the profile by September 30, 2017.
    Director: Andrew Von Ah
    Phone: (213) 830-1011

    4 open recommendations
    Recommendation: To ensure effective management and oversight of DHS programs receiving fees and other collections, and to ensure that component management take the following actions for each fee and other collections program that they administer, the Secretary of Homeland Security should direct the DHS Chief Financial Officer to use some means, such as the DHS Fee Governance Council, to document the processes and analyses for assessing and, as appropriate, for managing the difference between program costs and collections and document resulting decisions.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS's Fee Governance Council, led by the Deputy CFO plans to draft and publish a revised section of the Financial Management Policy Manual devoted to documenting the processes and analyses for assessing and managing the difference between program costs and collections and document resulting decisions. The Council is currently working to establish interim milestones associated with this objective.
    Recommendation: To ensure effective management and oversight of DHS programs receiving fees and other collections, and to ensure that component management take the following actions for each fee and other collections program that they administer, the Secretary of Homeland Security should direct the DHS Chief Financial Officer to use some means, such as the DHS Fee Governance Council, to establish processes for managing unobligated carryover balances, to include targets for minimum and maximum balances for programs that lack such processes and targets.

    Agency: Department of Homeland Security
    Status: Open

    Comments: The Fee Governance Council will draft and publish a revised section of the Financial Management Policy Manual devoted to managing unobligated carryover balances. The Council is currently working to develop specific milestones associated with this objective.
    Recommendation: To ensure effective management and oversight of DHS programs receiving fees and other collections, and to ensure that component management take the following actions for each fee and other collections program that they administer, the Secretary of Homeland Security should direct the DHS Chief Financial Officer to use some means, such as the DHS Fee Governance Council, to conduct reviews to identify any management and operational deficiencies.

    Agency: Department of Homeland Security
    Status: Open

    Comments: The DHS Fee Governance Council plans to publish a revised section of the Financial Management Policy Manual devoted to how components conduct studies of fee programs to identify any management or operational deficiencies. The Council is currently working to establish specific milestones associated with this objective.
    Recommendation: To ensure effective management and oversight of DHS programs receiving fees and other collections, and to ensure that component management take the following actions for each fee and other collections program that they administer, the Secretary of Homeland Security should direct the DHS Chief Financial Officer to use some means, such as the DHS Fee Governance Council, to take action to track and report on management and operational deficiencies--including reasons supporting any decisions to not pursue recommended actions--identified in fee reviews or through other means.

    Agency: Department of Homeland Security
    Status: Open

    Comments: The DHS Fee Governance Council will publish a revised section of the Financial Management Policy Manual devoted to how regular biennial reviews are conducted at DHS and how any findings and recommendations on management and operational deficiencies identified in these fee studies are tracked and reported.
    Director: Carol C. Harris
    Phone: (202) 512-4456

    9 open recommendations
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of the Department of Homeland Security (DHS) should direct the Director of USCIS to direct the USCIS Chief Information Officer (CIO), in coordination with the DHS CIO and the Chief of the Office of Transformation Coordination (OTC), to review and update, as needed, existing policies and guidance and consider additional controls to complete planning for software releases prior to initiating development and ensure software meets business expectations prior to deployment.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, the U.S. Citizenship and Immigration Services (USCIS) within the Department of Homeland Security (DHS) had taken steps to address this recommendation. In particular, in June 2017, USCIS provided an updated policy, dated April 2017, governing planning and deploying software releases. USCIS also demonstrated partial compliance with that policy. For example, it provided some release planning review documentation for recent releases that are required by the updated policy, including readiness review memos for releases 7.2 and 8.1. However, USCIS did not demonstrate that the program responsible for developing the USCIS Electronic Immigration System (USCIS ELIS) was consistently following its updated policy. For example, USCIS did not demonstrate that the program was completing all planning activities prior to initiating development, as called for in its updated policy. Moreover, the agency did not demonstrate compliance with its previous policy for all software releases planned and deployed since our July 2016 report. We will continue to work with USCIS to monitor actions the agency is taking to address this recommendation.
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update, as needed, existing policies and guidance and consider additional controls to consistently implement the principles of the framework adopted for Agile software development.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, USCIS had taken steps to address this recommendation. For example, in May 2017, USCIS provided updated policy governing the development of software releases, dated April 2017, along with release planning artifacts specific to USCIS ELIS. The updated policy included an appendix devoted to generally accepted agency practices and applying Agile principles in the agency. However, USCIS had not clearly indicated if USCIS ELIS was to implement the practices described in the policy. For example, the updated policy did not require program compliance with the generally accepted agency practices. Moreover, supporting artifacts from the release planning process did not always define a commitment to a particular development methodology or set of development practices. For example, the team process agreements, which describe how members of individual teams will work with each other, did not indicate if developers were to adhere to the practices described in updated USCIS policy. We will continue to work with USCIS to obtain additional documentation about actions it is taking to address this recommendation.
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update, as needed, existing policies and guidance and consider additional controls to define and consistently execute appropriate roles and responsibilities for individuals responsible for development activities consistent with its selected development framework.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, USCIS had taken steps to address this recommendation. For example, in June 2017, USCIS provided updated policy, dated April 2017, governing the development of software releases and release planning artifacts. The updated policy and release documentation defined some roles and responsibilities that were previously only described by USCIS in its informal November 2014 management model, such as the authority and responsibility of a product owner. However, program documentation and policy did not define all of the roles and responsibilities. For example, program documentation and policy did not define the roles and responsibilities of a facilitator, or Scrum Master, which is a position identified in leading practices for software development using Scrum, the development methodology previously identified by the program. In addition, USCIS did not demonstrate that it had defined and committed to an updated development methodology for software releases. Such a defined methodology will impact expectations for the roles and responsibilities in software development. Without such a defined methodology or approach to Agile software development, it is not clear if roles and responsibilities defined by previously documented approach to Agile software development are still applicable for the current development approach. Moreover, documentation associated with program releases and updated policy did not define all of the roles and responsibilities for positions described by USCIS in its May 2017 written response to GAO. We will continue to work with USCIS to obtain additional documentation about actions it is taking to address this recommendation.
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update, as needed, existing policies and guidance and consider additional controls to identify all system users and involve them in release planning activities.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, DHS and USCIS had not provided information demonstrating that the department has addressed this recommendation. In October 2016, DHS provided a written response stating that the USCIS Office of Information Technology and Office of Transformation Coordination were working closely with the various USCIS directorates to obtain and integrate feedback through regular review sessions with the end users and through additional end user testing. However, as of July 2017, DHS and USCIS have not provided new information about the status of this recommendation.
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update, as needed, existing policies and guidance and consider additional controls to write user stories that identify user roles, include estimates of complexity, take no longer than one sprint to complete, and describe business value.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, USCIS had provided GAO with documentation intended to demonstrate that the agency had taken steps to address this recommendation. For example, in May 2017, USCIS provided updated policy governing the development of software releases along with release planning artifacts specific to USCIS ELIS and an Independent Verification and Validation assessment. The agency also provided a series of backlogs that captured user stories for some software releases. In addition, the Independent Verification and Validation assessment indicated that the program was tracking user story quality as part of assessing whether value was continuously discovered and aligned to the mission. However, the assessment report provided to GAO indicated a negative trend for this outcome. Moreover, USCIS policy no longer set expectations regarding user story development. In addition, supporting artifacts from the release planning process did not always define a commitment to a particular development methodology, which is turn impacts the expectations for writing user stories. Finally, backlogs provided by USCIS did not cover all releases in development since our July 2016 report and did not include enough detail to assess all aspects of the user story process (e.g., story size and user involvement). We will continue to work with USCIS to obtain additional documentation about actions it is taking to address this recommendation.
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update, as needed, existing policies and guidance and consider additional controls to establish outcomes for Agile software development.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, USCIS had taken steps to address this recommendation. For example, in April 2017, USCIS issued updated policy governing software development at the agency. The updated policy included an appendix devoted to generally accepted agency practices and applying Agile principles in the agency. This appendix also included a set of ten outcomes associated with using Agile practices at USCIS. For example, outcomes included that value is continuously discovered and aligned to the mission. However, the updated policy did not require program compliance with the practices and principles described in the appendix. Moreover, the agency did not demonstrate that USCIS ELIS had committed to achieving a specific set of outcomes for Agile software development, such as the outcomes described in the USCIS policy. We will continue to work with USCIS to obtain additional documentation about actions it is taking to address this recommendation.
    Recommendation: To provide reasonable assurance that the program executes Agile software development for USCIS ELIS consistent with its own policies and guidance and follows applicable leading practices, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update, as needed, existing policies and guidance and consider additional controls to monitor program performance and report to appropriate entities through the collection of reliable metrics.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, USCIS had taken steps to address this recommendation. For example, in May 2017, USCIS provided updated policy governing the development of software that called for teams to prepare an Operations Monitoring Plan or dashboard showing the practices, tools, and measures that will monitor applications in production. The agency also provided a series of documents from internal systems and processes intended to monitor performance, such as a product dashboard for analyzing code quality (i.e., SonarQube) and a report from its Independent Verification and Validation team. However, the program was undergoing a re-baseline and had yet to document updated cost, schedule, and performance expectations against which to monitor. Moreover, the agency did not demonstrate that other metrics, such as customer satisfaction and team velocity, were being reliably collected. We will continue to work with USCIS to obtain additional documentation about actions it is taking to address this recommendation.
    Recommendation: To help manage the USCIS ELIS system, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update existing policies and guidance and consider additional controls to conduct unit and integration, and functional acceptance tests, and code inspection consistent with stated program goals.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, USCIS had taken steps to address this recommendation. For example, in May 2017, USCIS provided artifacts from internal systems in place to monitor software development performance. These metrics monitored aspects of testing, such as code quality and code coverage. However, the program did not provide an updated Test and Evaluation Master Plan, which is a document it will produce as part of its ongoing effort to re-baseline. A Test and Evaluation Master Plan sets the testing expectations for the program as agreed upon with its stakeholders in DHS and USCIS. The updated plan will provide a basis for further evaluation of the steps DHS and USCIS have taken to address this recommendation. Moreover, the agency did not demonstrate that functional acceptance tests were being conducted in accordance with stated program goals. For example, the agency did not provide acceptance criteria or the associated tests demonstrating that user stories passed the defined acceptance criteria. We will continue to work with USCIS to obtain additional documentation about actions it is taking to address this recommendation.
    Recommendation: To help manage the USCIS ELIS system, the Secretary of DHS should direct the Director of USCIS to direct the USCIS CIO, in coordination with the DHS CIO and the Chief of OTC, to review and update existing policies and guidance and consider additional controls to develop complete test plans and cases for interoperability and end user testing, as defined in the USCIS Transformation Program Test and Evaluation Master Plan, and document the results.

    Agency: Department of Homeland Security
    Status: Open

    Comments: As of July 2017, DHS and USCIS had not provided information demonstrating that they had addressed this recommendation. In October 2016, DHS provided a written response indicating that an internal process for revisiting the USCIS ELIS Test and Evaluation Master Plan had been initiated, with participation from all relevant stakeholder groups. A Test and Evaluation Master Plan sets the testing expectations for the program as agreed upon with its stakeholders in DHS and USCIS. The updated plan will provide a basis for further evaluation of the steps DHS and USCIS have taken to address this recommendation. The letter also stated that USCIS had begun to work on a policy for new interoperability test procedures. Moreover, the letter added that end user testing is a continuing activity, including providing feedback of observed issues into the development queue, with the slow launch of the naturalization capabilities in USCIS ELIS being a model. However, as of July 2017, DHS and USCIS had not provided new information about the status of this recommendation. We will continue to work with DHS and USCIS to obtain additional documentation about actions they are taking to address this recommendation.
    Director: Gambler, Rebecca S
    Phone: (202) 512-8777

    3 open recommendations
    Recommendation: To strengthen USCIS's EB-5 Program fraud prevention, detection, and mitigation capabilities, and to more accurately and comprehensively assess and report program outcomes and the overall economic benefits of the program, the Director of USCIS should plan and conduct regular future fraud risk assessments of the EB-5 Program.

    Agency: Department of Homeland Security: United States Citizenship and Immigration Services
    Status: Open

    Comments: The Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS) is responsible for administering the Employment-Based Fifth Preference Immigrant Investor Program (EB-5 Program). In 2015, we reviewed the EB-5 program to determine if USCIS assesses fraud and other related risks facing the program. We found that USCIS had collaborated with its interagency partners to assess fraud and national security risks in the program in fiscal years 2012 and 2015 but that these assessments were onetime efforts that did not have documented plans to conduct regular future risk assessments, in accordance with fraud prevention practices, which could help inform efforts to identify and address evolving program risks. To strengthen the program's fraud prevention, detection, and mitigation capabilities, we recommended that USCIS plan and conduct regular future fraud risk assessments. USCIS concurred with the recommendation, stating that it will continue to conduct at least one fraud, national security, or intelligence assessment on an aspect of the program annually. In September 2015, USCIS stated that the Fraud Detection and National Security Directorate unit of its Immigrant Investor Program (IPO) will conduct its next fraud, national security, and intelligence assessment in FY 2016 and one assessment annually thereafter. In an August 2016 update, USCIS stated that it had conducted a national security assessment, the draft of which was under review by management, to be finalized by September 30, 2016. We will continue to monitor USCIS's efforts to ensure that the agency finalizes this assessment and documents plans to conduct future fraud assessments on a regular basis.
    Recommendation: To strengthen USCIS's EB-5 Program fraud prevention, detection, and mitigation capabilities, and to more accurately and comprehensively assess and report program outcomes and the overall economic benefits of the program, the Director of USCIS should develop a strategy to expand information collection, including considering the increased use of interviews at the I-829 phase as well as requiring the additional reporting of information in applicant and petitioner forms.

    Agency: Department of Homeland Security: United States Citizenship and Immigration Services
    Status: Open

    Comments: In 2015, we evaluated the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS) Employment-Based Fifth Preference Immigrant Investor Program (EB-5 Program) to determine the extent to which the agency had addressed any identified fraud risks in the program. We found that USCIS had identified unique fraud risks in the program and had taken certain steps to address and enhance its fraud risk management efforts, including establishing a dedicated entity to oversee these efforts. However, we found that USCIS's information systems and processes limited its ability to collect and use data on EB-5 Program participants to comprehensively address fraud risks in the program. To strengthen the program's fraud mitigation capabilities, we recommended that USCIS develop a strategy to expand information collection, including considering the increased use of interviews at the application for permanent residency (form I-829) phase as well as requiring the additional reporting of information in applicant and petitioner forms. USCIS concurred with the recommendation, stating that IPO will develop a strategy to enhance and expand information collection, including publishing revised EB-5 application and petition forms, and considering the use of interviews. In a September 2015 update to this recommendation, USCIS stated that it had begun internal discussions for developing a comprehensive strategy to incorporate interviews into various stages of the EB-5 process, including the I-829 phase. In addition, USCIS was implementing a comprehensive approach for revising all EB-5 specific forms (I-526, I-924, and I-924A) to improve program integrity and data collection. USCIS expects the revised forms to be available after December 31, 2015. In an August 2016 update, USCIS stated that it has revised Forms I-924, I-924A, and I-526, and anticipated revising Forms I-924 and I-924A by November 2016 and Form I-829 by March 2017. USCIS also stated that IPO had initiated a new process to allow interview of Form I-829 petitioners by video conference, and planned to develop a comprehensive interview strategy based on the results of initial and future interviews as well as other relevant information. We will continue to monitor USCIS's efforts to develop and implement this more comprehensive EB-5 data collection strategy.
    Recommendation: To strengthen USCIS's EB-5 Program fraud prevention, detection, and mitigation capabilities, and to more accurately and comprehensively assess and report program outcomes and the overall economic benefits of the program, the Director of USCIS should track and report data that immigrant investors report, and the agency verifies on its program forms for total investments and jobs created through the EB-5 Program.

    Agency: Department of Homeland Security: United States Citizenship and Immigration Services
    Status: Open

    Comments: In 2015, we evaluated the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS)'s capacity to verify job creation and to use a valid and reliable methodology to report the economic benefits of its Employment-Based Fifth Preference Immigrant Investor Program (EB-5 Program). We found that over time USCIS had increased its capacity to verify job creation by increasing the size and expertise of its workforce and by providing clarifying guidance and training, among other actions. However, we found that USCIS's methodology for reporting program outcomes and overall economic benefits of the EB-5 Program was not valid and reliable because it may understate or overstate program benefits in certain instances as it was based on the minimum program requirements of 10 jobs and a $500,000 investment per investor, instead of the number of jobs and investment amounts collected by USCIS on individual EB-5 Program forms. To more accurately and comprehensively assess and report the overall economic benefits of the program, we recommended that USCIS track and report data that immigrant investors report, and the agency verifies on its program forms for total investments and jobs created. USCIS concurred with this recommendation, stating that IPO will develop a plan to collect and aggregate additional data regarding EB-5 investment amounts and job creation, including revising USCIS data systems and processes, as appropriate. In a September 2015 update, USCIS further stated that IPO officials had already met with officials from the USCIS Office of information Technology (OIT) on August 25, 2015, to discuss EB-5 data requirements, and that IPO is reviewing the fields in the Intranet Computer Linked Application Information Management System (iCLAIMS) database used for maintaining EB-5 and other immigration program data, to define data entry requirements. Once that is completed, USCIS stated that IPO will work with OIT to discuss any system changes needed to reliably aggregate data regarding EB-5 program investment amounts and job creation. In an August 2016 update, USCIS stated that through regular meetings with OIT, IPO has identified the assets needed to develop a case management system to meet the complex data needs of the EB-5 program. This system, which will be compatible with USCIS's electronic immigration system, is tentatively projected to be completed in FY 2017. We will continue to monitor USCIS's efforts to develop a system that will enable it to accurately and comprehensively assess and report the overall economic benefits of the program.