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that, prior to the transition, largely worked side by side in many land ports of entry around the country and that shared similar missions. In contrast, ICE is a patchwork of agencies and programs that includes INS's investigations and intelligence programs, Customs' investigations and intelligence programs, the Federal Protective Service, and the Federal Air Marshals. In combining the investigations programs, ICE has been tasked with merging former INS investigators who specialized in immigration enforcement (e.g., criminal aliens) with former Customs investigators who specialized in customs enforcement (e.g, drug smuggling).

The integration of INS and Customs investigators into a single investigative program has involved the blending of two vastly different workforces, each with its own culture, policies, procedures, and mission priorities. Both pmgrams were in agencies with dual missions that prior to the merger had differences in investigative priorities. For example, INS primarily looked for illegal aliens and Customs primarily looked for illegal drugs. In addition, INS investigators typically pursued administrative violations, while Customs investigators typically pursued criminal violations

Whether further structural changes are warranted is one of the topics that this hearing is to address. Some observers have proposed merging ICE and CBP. For example, the Heritage Foundation and the Center for Strategic and International Studies (CSIS), in a report on DHS management, suggested a possible merger of ICE and CBP to address some of these management problems. A Senior Research Fellow at The Heritage Foundation stated in a March 2005 congressional testimony, “DHS needs to be organized not to accommodate the present, but to build toward the ideal organization of the future. Therefore, the department needs to articulate how it envisions conducting its missions five to ten years from now and let this vision drive the organizational design, particularly the structure of border security operations." Another witness stated, "Whether the decision is ultimately made to merge ICE and CBP or not,

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the real issues will remain unless the underlying mission, vision, and planning occur in a unified manner."

Similar Management
Challenges Continue

Over the years, we have issued numerous reports that identified
management challenges INS experienced in its efforts to achieve both
effective immigration law enforcement and service delivery. For example,
in 1997 we reported that INS lacked clearly defined priorities and goals
and that its organizational structure was fragmented both
programmatically and geographically. Additionally, after reorganization in
1994, field managers still had difficulty determining whom to coordinate
with, when to coordinate, and how to communicate with one another
because they were unclear about headquarters offices' responsibilities and
authority. We also reported that INS had not adequately defined the roles
of its two key enforcement programs-Border Patrol and investigations-
which resulted in overlapping responsibilities, inconsistent program
implementation, and ineffective use of resources. INS's poor
communication led to weaknesses in policies and procedures. In later
reports, we showed that broader management challenges affected INS's
efforts to implement programs to control the border, deter alien
smuggling, reduce immigration benefit fraud, reduce unauthorized alien
employment, remove criminal aliens, and manage the immigration benefit
application workload and reduce the backlog.'

In 1999 and 2001, we testified on these management challenges before this subcommittee. Our 2001 testimony was delivered at the time when

Statsmurnt of David Venturella, l'orner Acting Diretor of the offer of Druntion and
Renewal Operations, Department of Hound Security. Before the Subcrinulle on
Management Integration, and Oversight, llous: Committer on Homeland Sexurity
(Washington, DC: Mar 9, 2005).
YAO. Immigration Enforcement: (hallenges to implementing the IXS Interior
Enforceaunul Strulegy. GARL) Mai T (Washington, D.C.: June 19, 2002); GAO, Immigrulion
Benen I'mud, housed Appmach Is Varded to Address I'mblemas, +1012.16
(Washington, DC: Jan 31, 2002), GAO, INS's Southursi Baruer Sintegy Resoure und
Impact Issues Remain after Seren Years, GAC-01*12 (Washington, DC: Aug 2, 2001),
GAO. Immigration Benefits. Serveral factors Impede Timeliness of Application
Processing. CAO 01-18 (Washington, D.C. May 4, 2001).GAO, Alien Smuggling
Management and Openitional imprurements Vooded in Address (miny Pmhlom,
GADT 00103 (Waslungion, DC May 1, 2000), and Criminal Aliens INS - Ecorts to
Identity and Remotr imprisonni Alions comtinue to Need Impruiment,
GVTC17 (Washington, DC: Feb, 23, 1942)and GAO, Criminal Alms. INS
Egorts to Identify and Renture imprisoned Aliens Need to be Improved,
GROVE GODY 101 (Washington, DC July 1.3, 17)

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Congress, the Administration, and others had offered various options for restructuring the INS to deal with its management challenges. We testified that while restructuring may help address certain management challenges, we saw an organization (INS) that faced significant challenges in assembling the basic building blocks that any organization needs: clearly delineated roles and responsibilities, policies and procedures that effectively balance competing prionties, effective internal and external communications and coordination, and automation systems that provide accurate and timely information. We noted that unless these elements were established, enforcing our immigration laws, providing services to eligible aliens, and effectively participating in the government-wide efforts to combat terrorism would be problematic regardless of how INS was organized.

In 2004, we reported DHS experienced management challenges similar to those we had found at INS. For example, some officials noted that in some areas related to investigative techniques and other operations, unresolved issues regarding the roles and responsibilities of CBP and ICE give rise to disagreements and confusion, with the potential for serious consequences. As in 1999 and 2001, we reported in 2004 that selected operations had reportedly been hampered by the absence of communication and coordination between CBP and ICE. Further, we reported in 2004 that CBP and ICE lacked formal guidance for addressing some overlapping responsibilities.

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alignment, performance measures, and leadership focus and accountability,

Clarity of Mission: We have previously reported on the importance of

establishing a coherent mission that defines an organization's culture
and serves as a vehicle for employees to unite and rally around. As
such, a comprehensive agency mission statement is the first GPRA-
required element of a successful strategic plan. In successful
transformation efforts, developing, communicating, and constantly
reinforcing the mission gives employees a sense of what the
organization intends to accomplish, as well as helps employees figure
out how their positions fit in with the new organization and what they
need to do differently to help the new organization achieve success.
However, as noted above, while CBP was created from programs that
generally shared similar missions, ICE blended agencies with distinct
mission priorities and cultures, and thus faces a greater challenge in
creating a unified bureau.

Strategic Planning: Closely related to establishing a clear mission is

strategic planning-a continuous, dynamic, and inclusive process that
provides the foundation for the fundamental results that an
organization seeks to achieve. The starting point for this process is the
strategic plan that describes an organization's mission, outcome-
oriented strategic goals, strategies to achieve these goals, and key
factors beyond the agency's control that could impact the goals'
achievement, among other things. As with the mission, strategic goals
for a transforming organization must be clear to employees, customers,

These sikre factors CT derved from work we reported in GMO, Lomrland Security: Marugement Challenges Faring Fodes Leadership, G.30-08-30 (Wisslungion, DC: Dex. 20, 2002) and GAO, Results-Oriented Cultuns Implomunulion Supa lo Assasi Meryers and Organizational Transformats 0,101.36'(Washington, DC: July 2, 2013). Addition key prislices for wessful nergers and ornalon runsformations pol dis used in this statement include sortising on a key set of principles and prioriles and the outset of the transfomuition, setting implementation goals and a time me to build Totentum and show progress, dedicating an implementation tean lo nanage the transfomation process, (stabhshing a conmunication strategy to create shared expectations and report related progresy, and involving employees to obtain their ideas and gain their ownership for the transformation. The Gewernient Perfomance and Results Act of 1993 (GIRA) provides a strategic planning and management franrwork intended to improve federal agencies' performance and hold the contable for actueving results. Our work on newgentni structure and strategie planning is has d largely on GPRA

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Leadership Focus and Accountability: To be successful,

transformation efforts must have leaders, managers, and employees who have the individual competencies to integrate and create synergy among the multiple organizations involved in the transformation effort. Leaders need to be held accountable for ensuring results, recognizing when management attention is required and taking corrective action. High-performing organizations create this clear linkage between individual performance and organizational success and thus transform their cultures to be more results-oriented, customer-focused, and collaborative in nature. As we have reported, a Chief Operating Officer (COO)/Chief Management Officer (CMO) may effectively provide the continuing, focused attention essential to successfully completing these multi-year transformations in agencies like DHS.” At DHS, we have reported that the COO/CMO concept would provide the department with a single organizational focus for the key management

On September 9, 2002, GAO convened a roundtable of govem tient leaders and managenmnt (Xrts to discuss the (XX) coneopt and how it might apply within shted federal departments and agenutos. SocGAO), Highlights of a GAO Rindtable: The Chief Operuling Officer Conopi: A Polontiul Strulogy to Address Foderul Guverace Challenges, CACIBIDSP (Washington, D.C. (1 1, 2012).

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