INS's Response to the Draft Report

U.S. Department of Justice Immigration and Naturalization Service

HQOIA 110/8.2-C

MEMORANDUM FOR:	Mary W. Demory Assistant Inspector General for Evaluations and Inspections Department of Justice
FROM:	Kevin D. Rooney Acting Commissioner Immigration and Naturalization Service
SUBJECT:	Travel Card Delinquencies - Immigration and Naturalization Service A-O1-003-SA

I appreciate the opportunity to comment on the subject report and solicited input from the senior management official who is most significantly impacted, the Executive Associate Commissioner for Management. I reviewed the response and concur with the conclusions and observations.

The Immigration and Naturalization Service is aggressively improving the management and oversight of the Travel Card Program. Many of your recommendations have been implemented and we anticipate that the travel card delinquency rate will soon drop.

If you have any questions, please contact Kathleen Stanley, Audit Liaison, at (202) 514-8800.

Attachment

cc: Vickie L. Sloan, DOJ Audit Liaison

U.S. Department of Justice Immigration and Naturalization Service

HQFIN 80/6.11.2

MEMORANDUM FOR:	Kevin D. Rooney Acting Commissioner
FROM:	George H. Bohlinger, III Executive Associate Commissioner Office of Management
SUBJECT:	Travel Card Delinquencies - Immigration and Naturalization Service A-O1-003-SA

This memorandum serves as the Immigration and Naturalization Service's (INS) official response to the findings and recommendations in the Office of the Inspector General's (GIG) Draft Travel Card Delinquency Report, dated June 15. The INS agrees with the overall conclusion of the report that administration of the travel card program could be improved, and had already begun many improvements to the program prior to the GIG review.

RECOMMENDATION 1: Stress to INS management the importance of reducing travel card delinquencies and misuse.

INS RESPONSE: Concur. During the past two years, the INS has taken several steps to keep employees informed about the importance of complying with the terms and conditions associated with using their Government travel cards. For example, since FY 1999 the INS has issued numerous frequently asked question and answer memoranda to all employees that covered a wide range of travel issues, including delinquencies and misuse. The INS also issued an Employees Travel Card Program Guide in January 2000 that contained pertinent information on employee responsibility with respect to the Government travel cards. In addition, the INS issued a comprehensive travel policy guide in November 2000 and an updated version in March 2001. In December 2000, the INS began initiating wage garnishment procedures against employees whose accounts had been charged-off by Bank One and has issued Notices of Intent to Garnish Wages to over 80 employees. The INS senior management attended the GIG exit conference to emphasize the fact that the INS is extremely interested in resolving bankcard delinquencies. The INS provided informational sessions addressing the travel card delinquency and misuse problem at various management conferences, including the Commissioner's priority reviews and regional and district conferences. The INS has begun to revise its travel card program guide to reflect program improvements and other information with an expected completion date of December 31. In addition, the INS has developed a summary report, by office, to track delinquent and charged-off accounts. The summary reports are provided to managers, in a timely manner, to ensure that they are made aware of problem accounts.

RECOMMENDATION 2: Require local travel card coordinators to refer cardholder accounts (1) to supervisors when the account becomes 30-days delinquent and (2) to location managers when the account becomes 60-days delinquent.

INS RESPONSE: Concur. The INS' current policy requires the Agency Program Coordinators (APCs) to review monthly reports from Bank One and to contact employees whose accounts are delinquent. In practice, the APCs have been referring delinquencies to supervisors and managers when the accounts become 60 days delinquent. However, during recent monthly phone conferences, the National Travel Card Coordinator (NTCC) advised the APCs that they should refer all delinquencies to management-including ones under 60 days delinquent. A broadcast electronic message was sent to all INS employees reflecting this procedural change. The NTCC is also working with regional managers to ensure that hierarchies are correct and travel card responsibilities are implemented correctly at field locations. The revised travel card program guide (to be issued by December 31) will require APCs to review all delinquencies and report to the appropriate managers.

RECOMMENDATION 3: Require local travel card coordinators to refer instances of travel card misuse (1) to supervisors immediately for follow up and (2) to location managers if misuse is serious, frequent, or unresolved.

INS RESPONSE: Concur. The current INS written policy requires the APCs to review monthly reports received from Bank One and contact employees whose accounts show misuse. The APCs also refer misuse to supervisors or managers. If the manager determines that misuse has occurred, the case should be referred to the INS' Office of Internal Audit (OIA) for investigation. Due to the fact that managers did not always refer cases of misuse to the OIA in the past, the Office of Financial Management will ensure Bank One provides OLA with all monthly reports. In addition, the NTCC will develop reports to assist in the identification of possible misuse and will continue to work with local APCs to ensure that the Bank One reporting hierarchies are correct. The new policy will be clarified in the revised travel card program guide to be issued by December 31.

RECOMMENDATION 4: Develop and implement a standard form to be used by supervisors to document the reasons for the travel card delinquency or misuse and the actions taken by the supervisor to resolve the delinquency or misuse. Require the supervisors to submit these forms in a timely manner to the local travel coordinators.

INS RESPONSE: Concur. The INS will develop and include a standard form with instructions in its revised travel card program guide (to be issued by December 31). The INS expects that its new form will be patterned after the worksheet developed by the El Paso District Office.

RECOMMENDATION 5: Require location managers to comply with INS procedures and refer all unresolved delinquencies and instances of serious or frequent misuse to the INS Office of Internal Audit for investigation.

INS RESPONSE: Concur. Although current INS policy requires managers to comply with the subject procedures and to refer unresolved delinquencies and serious or frequent misuse to the OIA, the travel card program guide will be revised to emphasize this issue. The guide (to be issued by December 31) will be very specific on the roles and responsibilities of supervisors and managers.

RECOMMENDATION 6: Establish procedures requiring the INS national coordinator to provide management information pertaining to unresolved travel card delinquencies and instances of serious or frequent misuse to a senior INS official for review and follow-up.

INS RESPONSE: Concur. The INS NTCC currently receives a list of all accounts charged-off by Bank One. Monthly, the NTCC provides this report to OIA and quarterly provides the information to the Office of Security to determine if the charged-off account affects an employee's ability to maintain a proper security clearance. The NTCC also developed summary reporting to track charged-off dollars as well as delinquent amounts by office. Additional delinquency reports have been developed for the Executive Associate Commissioners to inform them of very serious cardholder delinquencies and misuse by employees in their chain of command. Although the volume of travel card transactions makes it extremely difficult for the NTCC to detect all cases of card misuse, the Office of Financial Management is developing reports to identify potential cardholder misuse. The above reports and procedures for use of the reports will be completed by September 30. In addition, information on the reports will be included in the revised travel card program guide (to be issued by December 31).

RECOMMENDATION 7: Deny cash advances to those employees who have had their travel cards canceled due to delinquency or misuse.

INS RESPONSE: Concur. The INS drafted a policy memorandum that denies cash advances to employees who have had their travel cards canceled due to delinquency or misuse. The Border Patrol Union has requested that the INS management bargain on this issue. The INS is attempting to schedule bargaining dates so as to resolve the matter by September 30. If an agreement is reached by that time, the new policy will be included in the revised travel card program guide (to be issued by December 31).

RECOMMENDATION 8: Consider automating the process by which Bank One is notified of cardholder name and hierarchy address changes.

INS RESPONSE: Concur in part. The INS agrees that an automated system, such as the one used by the Federal Bureau of Investigation, would be effective in maintaining correct hierarchies because it would permit the INS to monitor the travel charge card program closer. However, INS' legacy financial systems do not support automating the current process and attempting to do so would not be cost effective. Nonetheless, the INS is completing a manual review of old data and canceling inactive cards. The manual review will be completed by the end of FY 2001. The INS will continue to take all steps possible to ensure that Bank One is notified in a timely manner of cardholder name and hierarchy address changes. The INS will certainly consider automating the process at a later date as it migrates toward a fully integrated modem financial management system.

RECOMMENDATION 9: Assess the travel requirements of INS employees and consider restricting access to travel cards.

INS RESPONSE: Concur in part. Although the INS agrees that improvements are needed in the travel card program, it does not believe that physical access to travel cards should be restricted. The liability for payment of travel card charges rests with the employee and not the government. Instead of physically restricting cards, the INS will require managers and APCs to review the open account report provided by Bank One and cancel cards that do not meet the INS definition of frequent travel (travels more than two times a year). In addition, local managers will be advised that they can request that travel cards be placed in an inactive status when employees are not in travel status. This guidance will be included in the revised travel card program guide (to be issued by December 31). The INS believes that its planned actions fully address the OIG's recommendation.

RECOMMENDATION 10: Require that all coordinators receive formal training.

INS RESPONSE: Concur. The INS NTCC, in coordination with Bank One, hosted four APC training courses over the past two years. The NTCC will plan additional training sessions for all APCs when the revised travel card program guide is issued and will work with senior INS officials to ensure that APCs who have not received training attend the next training session. Training will be made available to all APCs by the end of March 31, 2002 and will be offered annually thereafter.

RECOMMENDATION 11: Inform all managers and supervisors of their role in the travel card monitoring process.

INS RESPONSE: Concur. The current INS Government Travel Card Program Guide provides written guidance for managers and supervisors on their roles and responsibilities for the travel card program. Supervisors' roles will be more clearly defined in the revised travel card program guide (to be issued by December 31). In addition, the INS plans to include a session on travel charge card roles and responsibilities in its supervisory training courses.

RECOMMENDATION 12: Provide employees with regular briefings on their responsibilities related to the travel card.

INS RESPONSE: The INS will include a session on travel card responsibilities in its standard orientation training of new employees. In addition, the NTCC will work with the INS Ethics Office to expand travel card responsibility training in the employee ethics course. The first round of the training will be completed by the end of the second quarter FY 2002. Also, the NTCC will continue to issue question and answer type broadcast messages to all employees on travel card responsibilities.

If you have any further questions or concerns relative to the subject response, please do not hesitate to contact Judy R. Harrison, Assistant Commissioner, Office of Financial Management, at (202) 305-1200 or Mary Ann Atkinson of her staff, at (202) 305-0064.