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 programs 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,

Similar Management
Challenges Continue

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

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

Statement of David Venturella, Former Acting Director of the Office of Detention and
Removal Operations, Department of Homeland Security, Before the Subcommittee on
Management, Integration, and Oversight, House Committee on Homeland Security
(Washington, D.C.: Mar. 9, 2005)

'GAO, Immigration Enforcement: Challenges to implementing the INS Interior
Enforcement Strategy, GAO-02 861T (Washington, D.C.. June 19, 2002); GAO, Immigration
Benefit Fraud: Focused Approach Is Needed to Address Problems, GAO-02-66
(Washington, D.C.: Jan. 31, 2002); GAO, INS's Southwest Border Strategy: Resource and
Impact Issues Remain after Seven Years, GAO-01-842 (Washington, D.C.. Aug 2, 2001),
GAO, Immigration Benefits Several Factors Impede Timeliness of Application
Processing, GAO-01-188 (Washington, D.C.: May 4, 2001).GAO, Alien Smuggling:
Management and Operational Improvements Needed to Address Growing Problem,
GADGGD-00-103 (Washington, D.C.: May 1, 2000); and Criminal Aliens INS's Efforts to
Identify and Remove Imprisoned Aliens Continue to Need Improvement,
GAO/T GGD-99-47 (Washington, D.C.: Feb., 25, 1999); and GAO, Criminal Abens: INS
Efforts to Identify and Remove Imprisoned Aliens Need to be Improved,
GAOFT GGD 37 174 (Washington, D C. July 15, 1997).

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 priorities, 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.

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 GPRArequired 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, outcomeoriented 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 success factors were derived from work we reported in GAO, Homeland Security: Management Challenges Faring Federal Leadership, GAC-03-260 (Waslungton, D.C.: Dec. 20, 2002) and GAO, Results-Oriented Cultures Implementation Steps to Assist Mergers and Organizational Transformations, GAO-454 669 (Washington, DC: July 2, 2003). Additional key practices for successful mergers and organizational transformations not discussed in this statement include focusing on a key set of principles and priorities at the outset of the transformation, setting implementation goals and a timeline to build momentum and show progress, dedicating an implementation team to manage the transformation process, establishing a communication strategy to create shared expectations and report related progress, and involving employees to obtain their ideas and gain their ownership for the transformation.

The Government Performance and Results Act of 1993 (GPRA) provides a strategic planning and management framework intended to improve federal agencies' performance and hold them accountable for achieving results. Our work on management structure and strategic planning is based largely on GPRA

• 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