On March 27, 2001, the Evaluation and Inspections Division sent copies of the draft report to the Commissioner, Immigration and Naturalization Service (INS) with a request for written comments. The Commissioner responded by memorandum dated May 14, 2001 (APPENDIX III). Our analysis of the INS's response to each of our eight recommendations follows.

Recommendation 1 - Closed. The INS has complied with the OIG recommendation to direct the districts to ensure that all Group 3 aliens are properly escorted. The INS response included a memorandum dated May 13, 2001, from the Executive Associate Commissioner, Office of Field Operations, addressed to all Regional Directors, that directs them to conduct quarterly reviews to ensure compliance with the INS escort standards and to implement corrective action in instances of non-compliance.

Recommendation 2 - Resolved - Open. The OIG agrees with the INS proposal to develop a training curriculum for field managers and supervisors and to train them at the scheduled October 2001 conference in the use of INS escort policies and the practical application of the policies. The OIG also concurs with the INS plan for the Headquarters Office of Detention and Removal to provide oversight, feedback, and necessary changes related to training. Furthermore, the OIG agrees with the INS proposal to include such training for journeyman Deportation Officers and Detention Enforcement Officers. Please provide documentation that verifies the development of the curriculum, completion of conference training, and implementation of the journeyman training.

Recommendation 3 - Resolved - Open. The OIG agrees with the INS proposal for Regional Offices to conduct self-audits of their respective Districts to help ensure compliance with the INS escort policy. Additionally, the OIG concurs with the INS proposal to use the Office of Detention and Removals to audit and improve field compliance by sampling criminal cases contained in the Deportable Alien Control System. Please provide documentation that verifies implementation of the proposals.

Recommendation 4 - Resolved - Open. The OIG agrees with the INS plan to have the Office of Internal Audit check compliance with the INS escort policy during its normal INSpect visits. Please provide documentation that verifies implementation of this plan.

Recommendation 5 - Resolved - Open. The INS's response to our recommendation indicates that its review of the existing escort standards confirms that the policy is adequate for use in identifying violent and disruptive aliens. The response does not indicate whether the INS considered adding a requirement to escort known members of violent gangs or terrorist groups in its review. The current INS escort policy requires an escort for those individuals that have been charged, or are chargeable, with a crime. The OIG's concern is that while members of violent gangs or terrorist groups may not have been charged with a crime, their known affiliation with these violent organizations may pose a risk to the traveling public and an escort may be warranted. The OIG requests that the INS review its escort policy in view of this particular element of our recommendation and provide us with the results of that review.

Recommendation 6 - Resolved - Open. The OIG agrees with the INS's proposal to issue a memorandum to the INS field offices that contains guidance concerning alien removals that are the responsibility of commercial air carriers. The OIG understands that this guidance will state field office responsibility for providing a carrier with any information possessed by the INS on an alien's criminal history, violent behavior, and the reason entry was denied. Please provide a copy of the memorandum.

Recommendation 7 - Resolved - Open. The OIG agrees with the INS plan to modify language in the Intergovernmental Services Agreements with organizations that house INS detainees so that all instances of violent or disruptive behavior are reported to the INS. The INS response indicated that this will be completed by July 15, 2001. Please provide documentation that verifies completion of this plan.

Recommendation 8 - Resolved - Open. The OIG agrees with the INS plan to improve the notification and coordination of its escort travel plans with the Department of State. Based on the INS response the OIG understands that a prototype for an improved notice will be deployed in the field with appropriate training by May 30, 2001. The OIG also understands that the proposal for a consolidated process for the notice and airline ticketing will be initiated by September 30, 2001. The OIG further understands that INS will request a position in their FY 2003 budget submission that will be located at the Department of State to work as a removal liaison officer. Please provide documentation that verifies completion of each action.