ICE Deportation
Operations

April 13, 2017
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DHS OIG HIGHLIGHTS

ICE Deportation Operations
April 13, 2017

Why We
Did This
Inspection
This is the second
inspection related to U.S.
Immigration and Customs
Enforcement’s (ICE)
management of aliens
released from detention and
under ICE supervision. We
sought to determine
whether there are systemic
factors hampering ICE’s
ability to deport these
aliens.

What We
Recommend
We made five
recommendations to
improve ICE’s management
of its deportation
operations.
For Further Information:
Contact our Office of Public Affairs at
(202) 254-4100, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov

www.oig.dhs.gov

What We Found
ICE does not effectively manage the deportation of
aliens who are no longer detained, but are under
its supervision. Effective management requires
preparing and deploying the right number of
employees to achieve program and policy
objectives. In contrast, although many ICE
Deportation Officers supervising aliens reported
overwhelming caseloads and difficulty fulfilling
their responsibilities, ICE does not collect and
analyze data about employee workloads to allocate
staff judiciously and determine achievable
caseloads. Effective management also requires
providing well-defined policies and procedures to
employees. ICE has not clearly and widely
communicated Department of Homeland Security
deportation priorities to Deportation Officers; not
issued up-to-date, comprehensive, and accessible
procedures; and not provided sufficient training.
ICE’s failure to effectively balance and adequately
prepare its workforce also makes it harder to
address other obstacles to deportation, which may
require significant time and resources. These
management deficiencies and unresolved obstacles
make it difficult for ICE to deport aliens
expeditiously. ICE is almost certainly not deporting
all the aliens who could be deported and will likely
not be able to keep up with growing numbers of
deportable aliens.

ICE Response
ICE concurred with all five recommendations and
has initiated corrective actions that should
improve its management of deportation of aliens
under its supervision. We consider all five
recommendations resolved and open.

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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Washington, DC 20528 / www.oig.dhs.gov
April 13, 2017
MEMORANDUM FOR:

The Honorable Thomas Homan
Acting Director
U.S . Immigration and Customs Enforcement

FROM:

John Roth
Inspector General

SUBJECT:

ICE Deportation Operations

~~'\(.oh

Attached for your information is our final report, ICE Deportation
Operations. We have incorporated ICE's formal comments as appropriate in
the final report.
The report contains five recommendations to improve ICE's management of
its deportation operations. Your office concurred with all five
recommendations. Based on information provided in your response to the
draft report, we consider all five recommendations resolved and open. Once
your office has implemented the recommendations, please submit a formal
closeout letter to us within 30 days so that we may close the
recommendations. The memorandum should be accompanied by evidence of
completion of agreed upon corrective actions. Please send your response or
closure request to OIGinspectionsFollowup@oig.dhs.gov.
Consistent with our responsibility under the Inspector General Act, we will
provide copies of our report to congressional committees with oversight and
appropriation responsibility over the Department of Homeland Security. We
will post the report on our website for public dissemination.
Please call me with any questions, or your staff may contact Laurel Loomis
Rimon, Acting Assistant Inspector General for Inspections and Evaluations,
at (202) 254-4100 .
Attachment

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Table of Contents
Background .................................................................................................... 1 

Results of Inspection ....................................................................................... 3 

ICE Does Not Ensure Deportation Officer Workloads Are Balanced and 

Achievable ............................................................................................. 3 

ICE Does Not Provide Clear Policies and Procedures 

Or Sufficient Training ............................................................................ 7 

ICE Does Not Effectively Prepare Its Workforce to Handle Complicated 

Deportations.......................................................................................... 8 

Conclusion ............................................................................................ 9 

Recommendations......................................................................................... 10 


Appendixes
Appendix
Appendix
Appendix
Appendix

A: Objective, Scope, and Methodology ................................. 14 

B: ICE Comments to the Draft Report................................... 15 

C: Office of Inspections Major Contributors to This Report.... 18 

D: Report Distribution .......................................................... 19 


Abbreviations
BIETP
CBP
CMT
DO
ERO
ICE
OIG

www.oig.dhs.gov

Basic Immigration Enforcement Training Program
U.S. Customs and Border Protection
Case Management Training
Deportation Officer
Enforcement and Removal Operations
U.S. Immigration and Customs Enforcement
Office of Inspector General

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Background
This is the second inspection related to U.S. Immigration and Customs
Enforcement’s (ICE) management of aliens who have been released from
detention. In our first inspection,1 undertaken in response to a congressional
request, we reviewed the circumstances surrounding the case of an alien from
Haiti, Jean Jacques, who committed murder after receiving final deportation
orders.2 Our initial review revealed potentially broader issues affecting ICE’s
efforts to deport aliens. We conducted this second inspection to determine
whether there are systemic factors hindering ICE’s ability to deport aliens who
are not in ICE detention, but are under its supervision.
ICE shares responsibility for enforcing the nation’s civil immigration laws with
U.S. Customs and Border Protection (CBP) and U.S. Citizenship and
Immigration Services. ICE's two primary missions are to (1) identify and
apprehend criminal aliens and other deportable individuals in the United
States and (2) detain and deport those individuals apprehended in the interior
of the United States. ICE Enforcement and Removal Operations (ERO) is
responsible for carrying out this two-fold mission.
ICE detains aliens, both criminal and non-criminal, who are apprehended and
determined to need custodial supervision. While in detention, ICE attempts to
deport aliens with final deportation orders. ICE refers to aliens in its detention
facilities as cases in a “detained docket.”
A 2001 Supreme Court decision3 limits the length of time under the
Immigration and Nationality Act [8 U.S.C. § 1231(a)(1)(A)] that ICE can detain
aliens who are subject to a deportation order but cannot be deported in the
near future.4 When aliens are released from detention because deportation is
no longer reasonably foreseeable, ICE continues its efforts to deport those with
final deportation orders.
ICE also monitors aliens released from detention who are waiting for a hearing
in immigration court. Some aliens released from detention do not have final
Release of Jean Jacques from ICE Custody, June 16, 2016
When an immigration judge orders an alien to be deported the judge issues an order of
removal. In this report, we refer to orders of removal as deportation orders and to removal as
deportation.
3 Zadvydas v. Davis, 533 U.S. 678, 697 (2001)
4 There are several reasons why ICE may have difficulty deporting an alien with final
deportation orders. For example, some countries refuse to repatriate their citizens and other
countries restrict the number of aliens they will accept for repatriation. For more information
on the Supreme Court decision and ICE’s policies and procedures in one release from
detention, see Release of Jean Jacques from ICE Custody, June 16, 2016.
1
2

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deportation orders, but instead are waiting to appear in immigration court for a
ruling on their deportation. For example, aliens who claim they are fearful of
returning to their home countries or who are seeking asylum in the United
States must wait to appear in immigration court for a judge to render a
decision. It may take months or years for an appearance before an immigration
judge.
Aliens released from detention with final deportation orders, as well aliens who
have been released and are waiting for an immigration court hearing, compose
ICE’s “non-detained docket.”
Among other duties, ICE DOs may work on either a detained or a non-detained
docket. We focused this review on DOs primarily responsible for the nondetained docket. In this report, we refer to an ICE DO’s responsibilities for nondetained aliens as “supervision.” Supervision of non-detained aliens with final
deportation orders entails facilitating their deportation and repatriation by
working with embassies and consulates to obtain travel identification
documents, which officially permit ICE to deport aliens. Supervision of nondetained aliens awaiting final court decisions on their immigration status
entails ensuring the aliens check in at regular intervals to report any changes
in their status, such as a change of address or updates on their immigration
court proceedings. These DOs also interview the aliens and run criminal
background checks.
In fiscal year 2014, the United States experienced a surge in illegal immigration
along the southwest border. That year, the Border Patrol apprehended nearly
500,000 individuals entering the United States illegally. This represented a
nearly 16 percent increase from FY 2013 and about a 34 percent increase from
FY 2012. An increase in Border Patrol apprehensions potentially translates to
more aliens that ICE must detain, deport, and supervise.
On November 20, 2014, the then Secretary of Homeland Security issued a
memorandum, Policies for the Apprehension, Detention and Removal of
Undocumented Immigrants, with revised department-wide immigration
enforcement priorities to “inform enforcement and removal activity, detention
decisions, budget requests and execution, and strategic planning.” The
memorandum directed the Department, including ICE, to focus resources and
deportation efforts on, among others, criminals convicted of felonies, multiple
misdemeanors, and “significant” misdemeanors (e.g., domestic violence and
sexual abuse and exploitation), as well as aliens who unlawfully enter or re-

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enter the United States and “cannot establish … that they have been physically
present … continuously since January 1, 2014.”5
According to ICE, as directed by the Secretary, in FY 2015 it focused its
resources on apprehending, arresting, and deporting the most serious threats
to national security, border security, and public safety. ICE also reported that
its deportation statistics for the last three quarters of FY 2015 aligned with the
Secretary’s revised immigration enforcement priorities. As of August 2016, ICE
was supervising about 2.2 million aliens (on the non-detained docket); of these,
about 368,574 are convicted criminals. In FY 2015, ICE removed or returned
235,413 individuals of which 139,368 were convicted criminals.

Results of Inspection
ICE does not effectively manage the supervision and deportation of nondetained aliens. Effective management requires preparing and deploying the
right number of employees to achieve program and policy objectives. In
contrast, although many ICE DOs supervising aliens reported overwhelming
caseloads and difficulty fulfilling their responsibilities, ICE does not collect and
analyze data about employee workloads to allocate staff judiciously and
determine achievable caseloads. Effective management also requires providing
well-defined policies and procedures to employees. ICE has not clearly and
widely communicated Department priorities for deportation to DOs; not issued
up-to-date, comprehensive, and accessible procedures for supervising aliens;
and not provided sufficient training. ICE’s failure to effectively balance and
adequately prepare its workforce also makes it harder to address obstacles to
deportation, which may require significant time and resources. These
management deficiencies and unresolved obstacles make it difficult for ICE to
deport aliens expeditiously. ICE is almost certainly not deporting all the aliens
who could be deported and will likely not be able to keep up with growing
numbers of deportable aliens.

ICE Does Not Ensure Deportation Officer Workloads Are
Balanced and Achievable
DO workloads appear to be uneven — DOs working on non-detained dockets
have many more aliens they must supervise than DOs working with detained
aliens. While the tasks associated with overseeing detained and non-detained
On February 20, 2017, the Secretary of Homeland Security issued a memo, Enforcement of
the Immigration Laws to Serve the National Interest, which rescinded “all existing conflicting
directives, memoranda, or field guidance regarding the enforcement of our immigration laws
and priorities for removal,” including the November 20, 2014 memo.
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aliens differ, ICE could not adequately explain the reasons for the workload
differences at the locations we visited. Many of those working with nondetained aliens reported they had difficulty fulfilling all their responsibilities,
such as working with embassies and consulates to obtain travel documents
necessary for deportation, interviewing aliens under their supervision, and
running criminal checks on aliens in their docket. Yet, ICE has not collected or
analyzed workload data to determine the time and effort DOs need to
adequately supervise and facilitate the deportation of non-detained aliens.
Without workload data, ICE cannot ensure its caseload distribution is balanced
and that non-detained workloads are achievable. ICE also cannot measure
performance and apply lessons learned to ensure effective and efficient
supervision and deportation of aliens.
Caseload Distribution Is Uneven
At all four ICE field offices we visited, the caseloads of DOs supervising nondetained aliens were much larger than those of DOs working with detained
aliens. As shown in Figure 1, on average, DOs working on non-detained
dockets were responsible for about 1,700 to about 10,000 non-detained aliens,
compared to averages ranging from 65 to 110 for DOs working on detained
dockets.
Figure 1: Average Number of Cases per Deportation Officer For Nondetained and Detained Aliens in Four ICE Field Offices, 2016
10,156
10,000
Non-detained Caseload
Detained Caseload

8,000

5,337

6,000
4,000
2,000

1,872

1,720
104

100

84

65

0
Seattle, WA

Washington, DC

St. Paul, MN

Atlanta, GA

Source: ICE-reported data from July through October 2016

Deportation Officers Report Overwhelming Workloads
ICE personnel at all four field offices agreed that the workloads of DOs
supervising non-detained aliens are unmanageable, yet ICE has not tried to
determine what is achievable and what would alleviate the burden.
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In general, DOs working on non-detained dockets are supposed to obtain travel
documents for aliens with final deportation orders as well as supervise aliens
awaiting final decisions on their immigration status. To deport aliens, ICE DOs
must work with embassies and consulates to obtain travel identification
documents, such as birth certificates and passports, which officially permit ICE
to deport the aliens. Each country that accepts its citizens has its own rules
and proof of citizenship requirements that must be satisfied before it will issue
travel documents and accept its citizens. All these tasks can be time
consuming.
Supervision of non-detained aliens entails ensuring they check in at regular
intervals to report any changes in their status, such as a change of address or
updates on their immigration court proceedings. During and prior to an alien’s
check-in appointment, DOs respond to aliens’ attorneys’ inquiries and
requests, interview non-detained aliens, run criminal background checks, and
are supposed to record any changes in status in the ICE electronic case
management system. The system is also used to alert DOs about upcoming
scheduled check-ins. The large backlog of aliens awaiting final decisions on
their immigration status drives increasing workloads for DOs supervising nondetained aliens.
Among the field offices we visited, however, DO responsibilities vary widely and
shift, sometimes unexpectedly. For example, DOs working on the non-detained
docket are sometimes asked to help with aliens in detention. DOs are also
taken from assignments supervising non-detained aliens to work in specialized
units that target criminals and fugitive aliens. Further, to assist with the
increase in aliens crossing the southwest border, ICE has required some field
offices to temporarily assign staff to the border field offices for 45-day rotations.
One field office reported regular staffing shortages in supervising aliens
because of these assignments. Also, other DOs must pick up the workload of
those temporarily working elsewhere.
In addition, DOs may be asked to help with other “collateral” duties including:
x
x
x

transporting and escorting departing aliens on commercial and chartered
flights, which can take several days;
rotating on “window duty” to check in aliens arriving for interviews; and
transporting aliens to and from detention centers for immigration court
proceedings.

At the four offices we visited, DOs supervising non-detained aliens reported
they do not have enough time to obtain necessary travel documents to deport
aliens. According to the DOs, their collateral duties leave them time only to
deal with daily scheduled check-in appointments and unscheduled visits by
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aliens, answer phone calls from aliens, and input new cases into the electronic
system. One DO also reported that because of competing work responsibilities
criminal background checks are not conducted every time a non-detained alien
checks in with the field office.
In a particularly troubling example of overworked staff, a DO at one field office
we visited reported that a heavy workload limited oversight of non-detained
aliens in that geographic area that ICE had flagged as risks to national
security. In addition to oversight of these aliens, the DO supervised about
6,000 juvenile aliens, 150 of whom were detained; the DO said managing the
detained juveniles took up most of the workday, including many hours of
overtime. Without adequate oversight, this ICE DO may be unaware of missed
check-in appointments and missed court dates and may have inaccurate
information on the whereabouts of the non-detained aliens deemed to be a risk.
In addition to reported staffing shortages because of temporary DO
assignments to the southwest border, ICE’s non-detained unit also has unfilled
vacancies for positions that are relatively hard to fill. According to ICE officials
at one field office we visited, 6 of 19 DO positions assigned to the non-detained
case management unit were vacant, and the number of personnel who provide
administrative and clerical support has also dwindled, so DOs have had to take
on administrative duties.
Because of the overwhelming workload, DOs at these four offices reported they
need to work overtime to try to keep up with their caseloads. Nevertheless, as
one DO said, “you might work 18 hours a day, but you still won’t get caught
up.”
ICE Does Not Distribute Caseloads Systematically
Although the non-detained and detained caseloads appear unequal and DOs
working on the non-detained docket seem overwhelmed, ICE could not provide
any data on how it determines the staff needed to handle non-detained
dockets.
In February 2009, ICE developed a draft staffing model to reorganize DO
assignments to manage field offices. The model included suggested DO staffing
levels for the detained and non-detained dockets, as well as mission support.
However, ICE has not used the 2009 staffing model to allocate human
resources at field offices.
Rather than determine how to distribute staff based on caseload requirements,
supervisory personnel reported they arbitrarily assign the aliens in their
geographic area of responsibility to staff working on the detained and nondetained dockets. This means cases are distributed without regard to the work
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they entail or whether DOs will be able to handle the number of cases they are
assigned. An ICE official said that field office case management is complicated
and both detained and non-detained caseloads vary based on enforcement
priorities and other factors. These complications likely mean the two dockets
will never be equal, but gathering and analyzing workload data could help ICE
ensure a more balanced workload distribution.

ICE Does Not Provide Clear Policies and Procedures or
Sufficient Training
ICE does not adequately communicate overall policies or give overstretched
DOs comprehensive, up-to-date, and accessible procedures to guide them in
supervising and deporting aliens. In addition, ICE has not routinely reviewed,
updated, and organized its procedures to give DOs access to up-to-date
manuals. Guidance is often communicated to field office personnel orally or by
email, rather than through formal, documented policies and procedures. These
deficiencies hinder proper supervision of non-detained aliens, including those
who may be fugitives or who commit crimes. Field office staff confirmed that
ICE’s available policies and procedures did not help them properly manage
their non-detained cases.
ICE often communicates changes in enforcement priorities for deportation
through memoranda, directives, and broadcast messages to field offices.
Because they are not reviewed by the ICE Enforcement Removal Operations
Policy Office these communications are not official policies. According to ICE
staff we interviewed, the official policy review and issuance process can be
lengthy, so ICE opts to issue more immediate guidance through unofficial
chains, but does not formalize these policies after the fact. Further, the
communications are usually posted on websites where they are poorly
organized and difficult for field office staff to find. Many of the documents on
these websites had not undergone a periodic review every 4 years as required
by ICE’s Policy Development Handbook.
ICE has not issued comprehensive procedures for monitoring aliens
throughout immigration court proceedings and taking aliens into ICE custody
if deportation orders are issued. ICE also does not have an official policy
requiring DOs to periodically review aliens’ case files to verify and record
contact information, the status of immigration proceedings, and criminal
history. As a result, according to staff we interviewed, ICE’s records on the
number and status of aliens are likely inaccurate, which can cause
repercussions. For example, the cases of aliens who have relocated may not be
referred to the appropriate field office for supervision. Unless they verify the
status of immigration proceedings, ICE DOs may not know about aliens who
fail to report for court appearances and, thus, whose names should be
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forwarded to the fugitive operations unit. Without checking on criminal history,
DOs may be unaware of aliens who have committed crimes and should be
detained.
Deportation policies and procedures are outdated and unclear. Officials we
interviewed said ICE considers the 2003 Detention and Removal Operations
Policy and Procedure Manual (manual) “the official guide” to operations, but ICE
has not periodically reviewed the manual or revised it since 2008. For a time,
ICE would affix a memo to the front of the appropriate chapter to indicate
changes, rather than incorporate changes and issue a revised manual.
Eventually, many chapters were individually archived or left pending with
unfinished revisions. To date the manual has not been extensively revised.
Staff in the field offices confirmed the neglected state of ICE’s guidance.
Probably as a result of ICE’s failure to issue clear guidance, procedures at the
ICE field offices we visited vary widely. Some field offices have created their own
policies and procedures. Also, DOs are often allowed to act autonomously in
determining alien reporting intervals, documenting alien check-ins, and even
deciding which aliens to recommend for scheduled deportation charters.
According to ICE staff, DOs do not get enough training to help them supervise
and deport non-detained aliens. Staff at all four field offices said that training
was primarily on-the-job and informal. To compound this issue, since
September 2015, ICE has transitioned about 2,900 Immigration Enforcement
Agents to DO positions without, in our opinion, adequately training the fresh
DOs on their new responsibilities.
From July to September 2016, ICE headquarters scheduled non-detained
training for all 24 field offices, but did not plan for recurring training nor
document training attendance to ensure all required staff attended. In our
opinion, the training did not fully cover all necessary information. The training
slides we reviewed did not sufficiently cover managing cases electronically, for
example, by updating and sorting cases of deceased and self-deported aliens,
which would help reduce the number of aliens in the non-detained docket.
Overall, this combination of training did not give field office staff enough
information to carry out their non-detained responsibilities. ICE headquarters
personnel acknowledged they could improve training and communication with
field offices.

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ICE Does Not Effectively Prepare Its Workforce to Handle
Complicated Deportations
According to ICE officials, deporting aliens to some countries is nearly
impossible, but in other instances, if ICE managed its operations better and
provided DOs with clear guidance and sufficient training, there would be a
greater chance of overcoming obstacles to deportation. Some countries refuse
to repatriate any of their citizens, and ICE generally cannot deport aliens to
these countries without intervention by the Department of State. Other
countries restrict the number of individuals they will repatriate, and some
accept their citizens, but ICE has difficulty obtaining the travel documents
needed for deportation. ICE officials explained they would likely be more
successful in deporting aliens to these countries if they could better coordinate
with the Department of State and work more effectively with embassies and
consulates representing these countries.
For ICE to deport an alien to his or her home country, the country must agree
to repatriation. As of August 2016, ICE had identified 23 “uncooperative”
countries to which it generally cannot deport aliens. To help deport aliens to
these countries ICE may request diplomatic intervention by the Department of
State, which determines whether and what action to take against the country.
ICE officials also said that some countries, such as China, Bangladesh, and
India, restrict the number of aliens for whom they will issue travel documents
and accept for repatriation. Finally, ICE has identified 62 countries that are
cooperative, but with which it has experienced delays in obtaining required
travel documents. Deporting aliens to these 62 countries also requires more
time and effort working with embassies and consulates to obtain travel
documents and approval for alien repatriation.
ICE management at the field offices we visited noted that staff need to “stay on
top” of the embassies and consulates because ICE has more success deporting
aliens when DOs can be persistent in obtaining travel documents. DOs cited
the large number of cases they are assigned and their collateral duties as
hindrances to pursuing complicated deportations. If workloads were more
reasonable and ICE provided better guidance and training, DOs would likely
have more success with these deportations.

Conclusion
Our inspection and site visits of four ICE field offices revealed weaknesses in
ICE’s management of its deportation operations. These weaknesses are
hampering ICE’s ability to adequately supervise aliens awaiting immigration
hearings, as well as efforts to deport those who should be deported, including
some convicted criminals. Factors beyond ICE’s control may virtually prohibit
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deportation to some countries. In general, however, a more organized, diligent,
and complete approach to management would help ICE deport aliens
expeditiously and keep up with growing numbers of aliens who should be
deported.

Recommendations
We recommend that the Director of ICE or a designee:
Recommendation 1: Comprehensively review, revise, update, and maintain
ICE Enforcement and Removal Operations policies, procedures, and guidance
to address gaps and outdated information.
Recommendation 2: Comprehensively review Deportation Officer functions at
field offices to determine staffing allocations for non-detained units and identify
appropriately sized caseloads for Deportation Officers working with nondetained aliens.
Recommendation 3: Based on a completed comprehensive review, develop a
plan to identify and implement appropriate staffing of Deportation Officers.
Recommendation 4: Develop a standardized training curriculum for all
current and future Deportation Officers, including recurrent refresher training
courses for docket review and detained and non-detained case management.
Recommendation 5: Collaborate with the Department of State to identify
potential mechanisms to address issues that hinder deportation efforts.
Management Comments and OIG Analysis
In its response to our draft report, ICE concurred with all five
recommendations and has initiated corrective actions that should improve the
effectiveness of managing the deportation of aliens under its supervision. We
consider all five recommendations resolved and open.
Recommendation 1: We recommend that the Director of ICE or a designee
comprehensively review, revise, update, and maintain ICE Enforcement and
Removal Operations policies, procedures, and guidance to address gaps and
outdated information.
ICE Response: ICE concurred with the recommendation. ICE agrees that ERO
policies, procedures, and guidance should be reviewed, revised, updated, and
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maintained to address gaps and outdated information. ICE is currently working
with the Department's Office of Policy and others to examine current ICE
policies and guidance to ensure that they align with the President’s recent
Executive Orders and the Secretary of Homeland Security's vision and plans for
implementing those orders. This will be an iterative process that will also
address gaps in current policies, procedures, and guidance. The estimated
completion date is January 31, 2018.
OIG Analysis: ICE’s response addresses the intent of the recommendation.
This recommendation is resolved and will remain open until ICE provides
evidence that ERO policies, procedures, and guidance have been reviewed,
revised, updated, and maintained to address gaps and outdated information
and that such policies, procedures, and guidance align with the Executive
Orders and the Secretary’s plans to implement them.
Recommendation 2: We recommend that the Director of ICE or a designee
comprehensively review Deportation Officer functions at field offices to
determine staffing allocations for non-detained units and identify appropriately
sized caseloads for Deportation Officers working with non-detained aliens.
ICE Response: ICE concurred with the recommendation. ICE ERO is currently
examining staffing structures throughout the organization to inform future
hiring that will implement the President's Executive Order 13768, Enhancing
Public Safety in the Interior of the United States. This effort, along with ERO's
evolving enforcement posture, will determine the future operational footprint
for ERO's 24 field offices. This initiative is also aligned with ICE's project to
complete a workforce staffing model that uses subject matter expertise and
operational data to determine appropriate workforce staffing in positions and
geographical areas. Such analyses will include a review of DO functions,
including management of the non-detained docket and an appropriate case-toofficer ratio. The estimated completion date is January 31, 2018.
OIG Analysis: ICE’s response provides an initial corrective action plan that
addresses the intent of the recommendation. This recommendation is resolved,
but will remain open until ICE provides specific information about its planned
staffing structure initiative, especially as it affects DO staffing, as well as
evidence of the completed workforce staffing model, including a comprehensive
review of DO functions, all of which will help determine appropriate staffing
allocations for non-detained units and caseload sizes for DOs assigned to nondetained dockets.

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Recommendation 3: We recommend that the Director of ICE or a designee,
based on a completed comprehensive review, develop a plan to identify and
implement appropriate staffing of Deportation Officers.
ICE Response: ICE concurred with the recommendation. As stated above, ICE
ERO is currently examining staffing structure determine the future operational
footprint for ERO's 24 field offices and a multi-year hiring plan. The estimated
completion date is January 31, 2018.
OIG Analysis: ICE’s response addresses the intent of the recommendation.
This recommendation is resolved and will remain open until ICE provides
evidence of the completed examination of its staffing structure to determine the
future operational footprint for ERO's 24 field offices and a multi-year hiring
plan, in conjunction with recent hiring surges proposed by the new
Administration and DHS leadership.
Recommendation 4: We recommend that the Director of ICE or a designee
develop a standardized training curriculum for all current and future
Deportation Officers, including recurrent refresher training courses for docket
review and detained and non-detained case management.
ICE Response: ICE concurred with the recommendation. Standardized training
curriculum for future DOs is operated through ICE’s basic program, the Basic
Immigration Enforcement Training Program (BIETP), instructed by the ICE
Office of Training and Tactical Programs. Immigration Enforcement Agents,
who have been recently upgraded to the DO position, and new DOs who have
attended a substantially equivalent course of instruction to the BIETP, must
complete ICE ERO Case Management Training (CMT), which provides
instruction that includes docket-related duties (docket review and detained and
non-detained case management). CMT classes began in the latter part of 2016.
ERO intends to have 70 percent of the upgraded Immigration Enforcement
Agents complete the program by December 2017 and 100 percent by March
2018. ICE ERO is also currently working with the ICE Office of Principal Legal
Advisor to begin the process of negotiating an ICE ERO on-the-job training
program with the national union, which will also be used as a recurrent
refresher for several ERO specific skill sets, including those related to docket
review, detained casework, and non-detained casework. The estimated
completion date is March 30, 2018.
OIG Analysis: ICE’s response addresses the intent of the recommendation.
This recommendation is resolved and will remain open until ICE provides
evidence that 100 percent of Immigration Enforcement Agents converted to
DOs have completed CMT, and that it has fully implemented an ICE ERO onwww.oig.dhs.gov

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the-job (or similar) recurrent refresher training program for docket review and
detained and non-detained case management.
Recommendation 5: We recommend that the Director of ICE or a designee
collaborate with the Department of State to identify potential mechanisms to
address issues that hinder deportation efforts.
ICE Response: ICE concurred with this recommendation. Since 2011, there
has been a standing Memorandum of Understanding between the Department
of State and ICE ERO that specifically identifies and uses available
mechanisms to address issues that hinder removal efforts. Additionally, ICE
ERO currently uses a Removal Cooperation Initiative tool to better assess a
country's level of cooperation with the removal process and is thereby able to
develop a plan of action to specifically address the issue(s) at hand, with the
assistance of the Department of State. ICE ERO and the Department of State
will continue to work together to ensure that countries accept the return of
their nationals who have been ordered removed from the United States, in
accordance with international law. ICE requested that DHS OIG consider this
recommendation resolved and closed.
OIG Analysis: In its response, ICE identified the Memorandum of
Understanding with the Department of State, current mechanisms, and the
Removal Cooperation Initiative tool as addressing the intent of the
recommendation. We acknowledge these ongoing efforts, but ICE continues to
have problems ensuring deportation of aliens to uncooperative countries and
countries with which it has problems obtaining travel documents. Therefore,
this recommendation is resolved, but will remain open until ICE provides
evidence of enhancements to current mechanisms and improvements to
cooperation with the Department of State to remove hindrances to deportation.
In particular, ICE needs to provide details on how it uses assessments from the
Removal Cooperation Initiative tool to address issues and work with the
Department of State to deport aliens to these countries. ICE also needs to
provide any new plans and strategies it is developing with the Department of
State to improve cooperation with these countries.

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Appendix A
Objective, Scope, and Methodology
DHS OIG was established by the Homeland Security Act of 2002 (Public
Law 107–269) by amendment to the Inspector General Act of 1978.
We conducted this inspection from June 2016 to October 2016 under the
authority of the Inspector General Act 1978, as amended, and according to the
Quality Standards for Inspection and Evaluation issued by the Council of the
Inspectors General on Integrity and Efficiency. The objective of our review was to
determine whether ICE has systemic factors that may hamper deportations of
aliens not in detention facilities.
We analyzed ICE’s available supervision and deportation metrics as well
as its field office case workload data, organizational charts, and staffing
models. We also examined ICE’s supervision and deportation priorities,
policies, procedures, and information on uncooperative countries;
agreements with the Department of State; and email communication
and training provided to ICE field offices. Further, we reviewed
congressional hearings and testimony, as well as media articles
relevant to the objective of this review, which focused on the failure to
deport criminal aliens who allegedly endangered the public. During this
review, we also met with congressional staff to understand concerns
related to their requests for inspection.
We interviewed ICE headquarters staff and traveled to ICE field offices
in Atlanta, GA; Washington, DC; St. Paul, MN; and Seattle, WA to
discuss the above subject areas, local policies and procedures, and
issues beyond ICE’s control. During these site visits, we interviewed
Field Office Directors and their senior staff as well as DOs working on
non-detained dockets and supervisors. We also observed DOs
interviewing and gathering information from non-detained aliens and
accessing the electronic case management system, ENFORCE Alien
Removal Module. As needed, we followed up with ICE headquarters and
field office personnel by phone and email. We interviewed ICE
headquarters and field office staff members during site visits.
After October 2016, we contacted subject matter experts in ICE to clarify
issues in our report and to confirm that the conditions we identified had
not changed. In December 2016, we briefed these subject matter experts
on our report’s findings and conclusions.

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Appendix B
ICE Comments to the Draft Report

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Appendix C
Office of Inspections Major Contributors to This Report
John Shiffer, Chief Inspector
Wayne Ekblad, Lead Inspector
Stephanie Christian, Lead Inspector
Marybeth Dellibovi, Senior Inspector
Ryan Nelson, Senior Inspector
Jason Wahl, Senior Inspector
Anna Leslie, Senior Inspector
Kimberley Crabbe, Inspector
Kelly Herberger, Communications Analyst
Tatyana Martell, Independent Referencer

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Appendix D
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Policy
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees

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ADDITIONAL INFORMATION AND COPIES
To view this and any of our other reports, please visit our website at: www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General Public Affairs
at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on Twitter at: @dhsoig.

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