T5 B5 Yates- Bill Fdr- 12-30-03 Powerpoint- Cis- Operation Design And Business Plan 173
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U.S. Citizenship and Immigration Services
Operation Design and Business Plan Office of Fraud Detection and National Security (FDNS)
Washington, DC December 30, 2003
Contract Number. GS-23F-9755H BPA Number: COW-2-A-0024 Order Number. Call #16 Deliverable 7.2.2 v2 This document is confidential and is intended solely for the use and information of the U.S. Citizenship and Immigration Services
U.S. Citizenship and Immigration Services
I
Table of Contents > Introduction > Organization Options > Organization Details > Process Details and Performance Measures > Technology Requirements > Staffing and Training Requirements > Facilities Requirements > Financial Requirements > Current Initiatives and Next Steps
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Development of The Office of Fraud Detection and National Security (FDNS)
> CIS has developed FDNS in recognition of the need to: - Enhance the integrity of the legal immigration system, and - Identify persons who pose a threat to national security and/or public safety
"While providing accurate and responsive service is of paramount importance, we must not do so at
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Response to General Accounting Office Findings
GAO Recommendation
CIS Response
"...Determine how INS should balance its dual responsibilities of processing applications in a timely manner and detecting fraudulent applications"
Establish an organization (FDNS) separate from Adjudications, dedicated to detecting and pursuing suspected fraud
"Develop guidance for INS...to use in deciding which benefit application fraud cases to pursue"
Develop joint CIS/ICE benefit fraud strategy and case referral criteria
"Use [a system], to track and manage benefit fraud investigations..."
Develop and engage a case tracking system to track all fraud cases from referral to completion
Source: Immigration Benefit Fraud. Focused Approach is Needed to Address Problems". General Accounting Office. January 2002. GAO-02-66
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
FDNS Mission and Objectives
FDNS Mission Enhance the integrity of the legal immigration system by: -
Identifying aliens who pose a threat to national security and/or public safety
-
Combating immigration benefit fraud
-
Identifying and removing systemic vulnerabilities of statutes, policies, procedures, forms, other documents, and guidelines that compromise the integrity of the legal immigration system
FDNS Objectives > Serve as CIS' lead and primary conduit on fraud detection and law enforcement (background) check-related efforts > Ensure benefits are not granted to individuals who pose a threat to national security and/or public safety > Ensure benefits are not granted as a result of fraud-based applications or petitions > Provide a new capability for proactive fraud detection and enhance current reactive operation
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Existing Weaknesses of the Immigration System
> Some individuals seeking benefits pose a threat to national security and public safety > Anti-fraud efforts remain inadequate, reactive, and uncoordinated > Passive enforcement invites fraud and abuse > Lack of commitment to combating fraud demoralizes staff and negatively impacts productivity > Communication with the law enforcement community remains inefficient > Law enforcement community support remains inadequate, particularly as it relates to information sharing and providing documents to informants and other cooperatives > No centralized group is responsible for identifying and correcting weaknesses and other vulnerabilities in policies, procedures, and other activities
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Organization Considerations
There Are Two Primary Functions Performed By FDNS:
Fraud Detection Organizational Options > Decentralized - Reactive (lead-based) fraud detection activities are performed in each Fraud Detection Unit (FDU) and Field Offices (Status Quo) > Centralized and Coordinated Fraud Detection:
1. Fraud Detection
Preferred Option
-
Proactive fraud detection activities are performed in a central location
-
Reactive (lead-based) fraud detection activities are coordinated by FDNS and performed in each FDU and Field Office
Background Check Organizational Options Limited Centralization - Background check resolution is performed in each Service Center FDU, selected form-type resolutions performed at the National Benefits Center (NBC) FDU, and all other resolutions performed at the DOs
2. Background Checks
Preferred Option
Centralization - Initial resolution (Tier 2) is performed in a central location for all offices. Serious hits (Tier 3) are resolved at each FDU and in DOs for forms not handled by the NBC Complete Centralization - All background check resolution (Tiers 2 and 3) is performed at one, single central location for all offices
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
FDNS Process Flow
Fraud Detection 1
CIS Fraud Detection and National Security
• Proactive fraud leads are generated through data mining • Taskings are sent to FDU
CIS
Adjudications (Districts and Service Centers)
FDNS Fraud Branch
External Agencies / Contacts
Fraud Leads
ir
Background Checks
/
ICE
FDNS Operations / ' Branch ^
1 1
i
• Accepts or rejects leads ; • Receives and / assigns fraud / cases
• Fraud leads are verified / * Verified leads are referred to
Proactive Fraud Leads
(FDU and DO Fraud Units)
1 Immigration and Customs Enforcement
Fraud and Background Check Referrals to ICE Feedback from ICE \ IBIS Tier 3 hits are resolved
/ Benefit rrauu Unit
w
L
Referred IBIS Hits
' • Cases needing enforcement actions are sent to ICE
/ / J
/
>^\t 1 \ for serious \ background \ check hits b;
SACs I I
CIS Adjudications (Districts and Service Centers)
.^_ IBIS Hits
w
FDNS Background Check Branch
IBIS Name Submission (Tier 1) performed in each office
Operation Design and Business Plan December 30, 2003
SACs \ IBIS Tier 2 beare handed proposed in atocentralized location • Majority of the staff are contractors
FOR FDNS USE ONLY
SACs I
|_J \ Performs field bAOs | \s — " and SACs enforcement for fraud cases
CAr
(Special Agents In-Charge)
FDNS Addresses Current and Long Standing Issues
Field Office Visit Observations
Issues
> Current processes and systems are inadequate to detect the amount of fraud that exists Fraud Detection
> Proactive fraud detection activities are only performed on an ad hoc basis > Fraud referral process within CIS and between CIS and ICE needs to be standardized > IBIS check mandate has created a backlog in the adjudication process and a strain on resources
Background Checks
> The IBIS process is not consistently applied > The CIA Name Trace process is in need of reengineering > Multiple chains of responsibility create a lack of accountability
Lack of Standardization
> Staff have received little formal training and have not received standard operating procedures > Demand for fraud detection and background check work exceeds the current staffing capacity
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
Benefits of FDNS
> CIS has a dedicated, specialized organization responsible for: -
Identifying aliens who pose a threat to national security and/or public safety
-
Combating immigration benefit fraud
-
Identifying and removing systemic vulnerabilities of statutes, policies, procedures, forms, other documents, and guidelines that compromise the integrity of the legal immigration system
> Processes associated with identifying fraud, criminal aliens, and aliens of national interest are enhanced > Productivity, quality, and efficiency are improved through a combination of centralization, standardization, and prioritization > Quality of background checks is enhanced as national security/public safety-related hits are resolved by specialized staff > Backlog reduction effort is supported by enabling adjudicators to concentrate on adjudication, instead of performing IBIS resolution and verifying fraud * ICE is able to use their limited resources more effectively and efficiently > Fraud-based applications are denied and violators are placed in removal proceedings > Communication between CIS and ICE is better coordinated
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
FDNS Organization Structure Director
Chief Operating Officer
Fraud Branch
Operation* Branch
Planning and Development Untt
Law Enforcement Liaison Untt
Proactive Fraud Detection Section
Planning and Development Untt
CIA Name Trace Untt
Intelligence Unit
Ij
Support Services Branch
Background Check (BC) Branch
Tier 3 Background Check •»— mntmMfat ovcHon fmfttlnn nevoiunon
TlerZ Background Check Resolution UnR
AMss/AscMants
Lead-Generated Fraud Section
FWd Office Anttfraud Units1
Supervisors
Contractors
Technology Support Untt
FDUI
PfOQfMii Anwyn S0cUon
Administration Unit
Training Section
Contract Support Section
D Denotes HQ Positions D Denotes Field Positions
'Not in FDNS chain of command, but follows FDNS established guidelines
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
10
Fraud Branch Branch Mission: Enhance the integrity of the legal immigration system by developing policies and procedures to detect, pursue, and deter benefit fraud.
Branch Functions Fraud Branch
• Develop fraud detection policies and procedures • Develop CIS fraud priorities Plannning and Development Unit
;
• Identify areas of vulnerability and propose solutions Monitor FDU intelligence reporting
Intelligence Unit
Identify fraud indicators for proactive and reactive data mining
Proactive Fraud Detection Section
V Perform proactive fraud detection and document significant findings in reports Use pattern recognition and data mining software in anti-fraud activities
Denotes HQ Positions I Denotes Field Positions
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
11
Operations Branch Branch Mission: Provide direction and oversight to FDNS field staff. Implement and perform activities to detect, pursue, and deter benefit fraud, and resolve national security and public safety related background check hits. Branch Functions
Operations Branch
Law Enforcement Liaison Unit
Service Center Fraud Detection Unit
Tier 3 Background Cheek Resolution Section
Assist LEAs and Intelligence agencies with operational requirements for CIS documents and subject information Liaise with DHS components/LEAs on issues impacting background checks Provide oversight and direction to fraud detection and background check staff Resolve background checks that are national security and public safety-related
Aides/Assistants
Lead-Generated Fraud Section
FfeW Office Anti-Fraud Units
Denotes HQ Positions I Denotes Field Positions Operation Design and Business Plan December 30,2003
> Review applications/petitions for fraud and identify fraud trends > Write intelligence reports and assist the Fraud Branch with proactive analysis > Support ICE in prosecuting cases FOR FDNS USE ONLY 12
Background Check Branch Branch Mission: Conduct law enforcement checks to identify derogatory information on persons seeking benefits who may pose a threat to national security or public safety. Branch Functions Background Check (BC) Branch
> Develop background check policies and procedures Planning and Development Unit
CIA Name Trace Unit
Tier 2 Background Check Resolution Untt
Provide system requirements for the Background Check System Coordinate background check process with other internal and external organizations (e.g., CIA, ICE, FBI) > Conduct background check activities Perform background check-related data analysis
Supervisors
Contractors
Denotes HQ Positions I Denotes Field Positions Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 13
Support Services Branch Branch Mission: Provide the coordination, communication, and operational support needed to facilitate the achievement of the FDNS mission.
Branch Functions
Support Services Branch
> Support FDNS specific Information Technology (IT) needs Technology Support Unit
> Develop functional requirements and training FDU Systems Support Section
> Incorporate and monitor training > Perform research on SOWs, facilities, and contracts
Program Analyst Section
> Conduct analytic reviews
«*.
**-
Administration Unit
> Perform human and capital resource related functions for FDNS including budget development and facilities/inventory management
Training Section
> Recruit and train staff Contract Support Section
> Oversee contract management, technology resources, and " communications
Denotes HQ Positions I Denotes Field Positions Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 14
FDNS Processes
Background Check Processes
Fraud Processes Proactive Fraud Detection using systems, data mining, and fraud indicators to actively identify fraud Reactive Fraud Detection responding to possible fraud leads Fraud Verification confirming a fraud lead is actual fraud Case Development packaging verified fraud leads for referral to ICE
> IBIS Tier 1 - entering applicant/petitioner data for submission to IBIS > IBIS Tier 2 - evaluating positive IBIS "hits" to confirm identity and resolving hits that are not national security/public safety (NS/PS) related
Integrity-Based Processes Integrity-Based Processinganalytically review CIS systems, regulations, policies, forms, and processes to minimize the opportunity for fraud or abuse of the legal immigration system
> IBIS Tier 3 - resolving NS/PS related hits and referring hits to ICE
Other Processes > Special/Undercover Documents - generating immigration benefit documents to be used by individuals assisting investigations > Intelligence Reporting coordinating, developing, and disseminating fraud and background check related information and intelligence
> CIA Name Trace - resolving CIA Name Trace results that have derogatory information
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 15
FDNS Processes Include Involvement from Adjudications and ICE
Process
FDNS ^D K Fraud Branch
c
FDNS
Operations Branch
FDNS
Background
Check Brgnch
Adjudications
ICE
Fraud Processes Proactive Fraud Detection Reactive Fraud Detection
•
•
•
•
• •
Fraud Verification
•
•
Case Development
•
•
Post Investigative/ Prosecution Analysis
•
• • • •
•
Background Check Processes
•
IBIS Tier 1
•
IBIS Tier 2
•
IBIS Tier 3
• •
CIA Name Trace
• •
•
integrity Process Integrity-Based Processing
•
•
Other Processes Intelligence Reporting Special/Undercover Documents • •
•
• •
• •
Denotes Primary Process Owner Denotes Supporting Role
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 16
Internal and External Info Sharing Processes
Law Enforcement Community
U.S. Citizenship and Immigration Services
FDNS recognizes that one of the best ways to prevent fraud and protect national security and public safety is through on-going info sharing
US. Immigrati and Customs Enforcement
Information From FDNS Intelligence reports CIS systems data mining reports Information on individuals of interest Liaison/cross training National security/public safety relationships Open accessibility and immediate responsiveness Information To FDNS Status of enforcement actions Intelligence
Other Government Agencies
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 17
Fraud Detection Processes
Fraud Priorities'
Fraud Evaluations
Proactive Fraud Detection
Enforcement Results Fraud Leads
Referrals
(FDNS HQ)
Enforcement Results
Fraud Verification (FDU/DO)
External Leads SuspiciousApplications/ Petitions
Reactive Fraud Detection (FDU/DO)
Enforcement
Cases With "Verified" Fraud
Case Development (FDU/DO)
Case With No Fraud Found Fraud Leads and Files
Operation Design and Business Plan December 30, 2003
Files With Fraud Documentation
Post Investigation/ Prosecution Analysis (FDNS HQ/FDU)
Fraud Evaluations
Adjudication Additional Files To Adjudicate
FOR FDNS USE ONLY 18
IBIS SC Triage Process
Applications/ Petitions
Documents In Files
IBIS Tier 1 Name Submission
Positive IBIS Results
IBIS Tier 2 Name Vetting and Non-NS/PS Resolution*
Adjudicative Decisions Resolved Hits
Adjudication
Confirmed NS/PS Hits, Unconfirmed Hits
Resolved Hits
IBIS Tier 3 NS/PS Resolution*
Cases Needing Enforcement Action
Investigations And Subsequent*
Enforcement
H
| Enforcement Results
* Initial resolution (Tier 2) and resolution of serious hits (Tier 3) is performed at each FDU and in DOs for forms not handled by the NBC. Each Service Center(SC) Triage (Tier 2) NS/PS hit resolved by FDU.
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 19
IBIS Background Check Processes Concept for Centralization
Applications/ Petitions
Documents In Files
IBIS Tier 1 Name Submission
Positive IBIS Results
IBIS Tier 2 Name Vetting and Non-NS/PS Resolution*
Adjudicative Decisions Resolved Hits
Adjudication
Confirmed NS/PS Hits, Unconfirmed Hits
Resolved Hits
IBIS Tier 3 NS/PS Resolution*
Investigations And Subsequent/
Cases Needing Enforcement Action Enforcement Results
' FDNS is evaluating the feasibility of centralizing aspects of the Background Check Resolution process. Under a Centralized concept: initial resolution (Tier 2) is performed in a central location for all offices and resolution of serious hits (Tier 3) fe performed at each FDU and in DOs for forms not handled by the NBC. In a decentralized model, each Service CenterfSC) Triage (Tier 2) NS/PS hit resolved by FDU.
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 20
CIA Name Check Process
Investigations And Subsequent Action
Information from Applications
Data Input
Names
CIA Vetts Names
Derog or No De,
Derog or No Derog
Adjudicative Decisions
Resolved Hits
FDNS Resolves Hit
Operation Design and Business Plan December 30,2003
Adjudications
FOR FDNS USE ONLY 21
Integrity-Based Processing Examples of Current FDNS Involvement > Refugee Fraud Working Group > 1-751 Revision Process and SOP > CIA Name Trace Policy and Process > Forms Revision Working Group > FDNS HQ identifies and removes systemic vulnerabilities of statutes, policies, procedures, forms, other documents, and guidelines that compromise the integrity of the legal immigration system > FDNS HQ interfaces with various internal and external components > FDNS HQ personnel actively participate in DHS and other working groups
> 1-140 Ability to Pay > 1-129 Business Pre-certification > SC Background Check Triage Process and SOP > IPS BAD Process > Patriot Act Section 403 A and B > Terrorist Screening Center Working Group > DHS Intelligence Working Group > DHS/ICE Enterprise Architecture (fraud-based) > Centralization of LEA special document requests
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 22
Technology FDNS Processes System
Proactive _ . Fraud Detection
Reactive _ . Fraud Detection
„ . Fraud verification c
Venficatlon
/•»„«.„ Case Develooment Development
Post .. .. lnvest'9ative .
Analysjs
Tierl
Tier 2
Tier 3
CIA Name Trace
•
•
•
•
•
•
•
CIS Owned Systems Background Check System (BCS) CIS National Systems (e.g. C3, C4)
•
•
•
•
Consolidated CIS Data System
•
•
•
•
FDNS Case Tracking System
•
•
•
•
Proactive Data Mining System
•
Other Info Systems
•
•
•
'
ChoicePoint
.-
•
•
•
•
•
Other Government Agency System
•
IBIS Intelink
• TBD
TBD
•
• TBD
= Denotes system used in this process
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 23
Short-Term Technology Initiatives
> FDNS Case Tracking System -
Deploy Case Tracking System developed by FDD - Texas
> Consolidated CIS Data System and Proactive Data Mining System: -
Continue to use Consolidated C3 LAN for data mining Consider adding additional data to system
-
Use existing data mining tools as a test bed for long term data mining solution Evaluate additional software to increase capability of data mining
> Background Check System: -
Continue to use systems in place until the Background Check System (currently being developed) is implemented
-
Consider use of commercial off-the-shelf identification software
> External Systems: -
Continue to identify and assess other systems that can be used for both fraud and background checks (e.g., Intelink)
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
24
Long-Term Technology Initiatives Fraud Case Tracking System
Background Check System Goal: Automate name submission and checks and enable centralized management of IBIS process
> Goal: Develop case tracking system for CIS/ICE > Implementation issues:
Implementation issues: -Centralized IBIS Tier 2 cannot be implemented without the Background Check System in place, with SQ11 capability
- Determine capacity and functionality for use CISwide and by ICE BFUs - Determine most efficient manner to track CIS fraud cases
Data Warehousing
Proactive Data Mining Goal: Use robust tools (rule based reasoning, statistical analysis, artificial intelligence) to identify patterns and generate fraud leads
Goals: Consolidate data into a single architecture, create partial replicas of data stored for each system Implementation issues:
Implementation issues: - Identifying applicable data fields and developing the capability to automatically detect patterns and trends likely to involve fraud
-A data warehouse may be developed as part of the Benefits Application Processing System, FDNS may need something sooner
- Data warehousing capability is required to realize system benefits
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 25
FDNS Staffing Plan Director (SES)
Chief Operating Officer (SES)
Fraud Branch 1 Chief (GS-14/15)
Background Check (BC) Branch 1 Chief (GS-14/15)
Operations Branch 1 Chief (GS-14/15)
Support Services Branch 1 Chief (GS-14/15)
Technology Support Unit 1 Officer (GS-13/14)
Planning and Development Unit 2 Officers (GS-13/14)
Law Enforcement Liaison Unit 2 Officers, 1 Officer (GS-13/14)
Planning and Development Unit 1 Officer (GS-13/14)
Intelligence Unit 2 Officers (GS-13/14)
Service Center Fraud Detection Unit 5 Chiefs (GS-13/14)
CIA Name Trace Unit TBD (GS-13/14)
FDU Systems Support Section 1 Specialist (GS-12/13)
Tier 2 Background Check Resolution Unit 4 Officers (GS-12/13)
Program Analyst Section 2 Analysts or Contractors (GS-12/13 equivalent)
Tier 3 Background Check Resolution Section 15 Officers, 135 Contractors (GS-7/9/11/12.GS-7/9/11/12 equivalent)
Proactive Fraud Detection Section 3 Analysts (GS-11/12)
Aides/Assistants 10 Aides/Assistants (GS-5/7 equivalent)
Supervisors 5 Supervisors (GS-9/11/12 equivalent)
Lead-Generated Fraud Section 3 Officers, 31 Officers (GS-5/7/9/11/12,13)
Legend: 2004 Staff
Contractors 73 Contractors (GS-5/7 equivalent)
Administration Unit 1 Officer (GS-13/14)
Training Section 1 Officer (GS-12/13/14)
Contract Support Section 2 Contractors (GS-5 equivalent)
Field Office Anti-Fraud Units 33 Officers (GS-13)
• New Staff • Existing Staff
D Denotes HQ Positions
• Contractors
D Denotes Field Positions
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 26
Position Descriptions Position
Locations
Headquarters
Overview of Duties
Branch Chief (GS-14/15)
Oversee the operations of an FDNS branch Conduct and approve personnel actions within the branch
Immigration Officer (IO) (GS-13/14) Intelligence Research Specialist (IRS) (GS-13/14)
Perform planning and development, intelligence activities, liaise with law enforcement, perform the CIA Name Trace process and oversee the Support Services Technology Support and Administration Units
Program Analyst (GS-12/13)
Assist in developing and assessing systems used by FDNS
HQ, Computer Contractor (GS-12/13 equivalents) Support Section
FDU
FDU Chief (GS-13/14)
Serve as FDU Chief overseeing FDU operations Coordinate Immigration Officers in the Field Office Anti-Fraud Units
IRS(GS-5/7/9/11/12) Senior IRS (GS-13)
Perform fraud-related work verifying fraud leads for referral to ICE Perform IBIS Tier 3 activities such as contacting law enforcement agencies to obtain hit information and resolving IBIS hits
Program Analyst (GS-12/13)
Assist in developing and assessing systems used by FDNS
Assistants (GS-5/7) District Offices
Background Check Identity Resolution Unit (Tier 2)
Assist in developing and assessing systems used by FDNS
• •
Perform IBIS checks and resolutions Enter cases into the FDNS Tracking System and assist with case development
IO(GS-13)
Perform fraud-related work verifying fraud leads for referral to FDUs Perform case development for cases not pursued by ICE
IRS (GS-12/13)
Oversee and support the operations of the unit Develop operating procedures, improve processes
Supervisors (GS-9/11/12)
Supervise contractors performing Tier 2 IBIS activities
Contractor (GS-5/7 equivalents)
Perform IBIS Tier 2 activities such as name vetting and resolution of hits that are not national security or public safety related
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 27
Training
Training Requirements
IRS (GS-5/7)
IRS (GS-9/11)
IRS (GS 11/12/13)
10 (GS-13)
Immigration Process
S
S
S
Systems Training /Systems Refresher
S
S
S
S
Effective Communications (Written and Oral)
S
S
S
S
^
^
L
Immigration Law Intel Analysis School - FLETC Investigative Analysis Forensic Documents - Document Analysis Advanced Leadership and Management
^
^
^ ^
^
^*
^
* For supervisory GS-13s
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 28
Facility Requirements
Current Facilities
Potential Short-Term Needs
Headquarters staff located in Washington, DC
> Potential need for additional file space at FDUs and/or SCs
Five FDUs located in California, Missouri, Nebraska, Texas, and Vermont
t Development of the Secure Compartmented Information Facility (SCIF)
Potential Long-Term Needs If Service Centers need to recover space in existing Centers for its own staff/work, the FDUs may need to find alternative space1 If the CIS background check centralization plan is approved, a single location will have to be identified for the centralized facility
Current facilities satisfy current staffing levels
1 The co-location of FDUs and SCs is not an absolute requirement. Should it become viable financially, we may want to consider co-locating the FDUs with Regional CIS offices, as they are also responsible for supporting centers and field offices within their respective geographic areas. This would also be consistent with ICE's Benefit Fraud Unit structure, albeit their legacy INS Regional Investigations Offices are now referred to as "areas".
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 29
SCIF Development
SCIF Description
FDNS SCIF Status
SCIFs are the only areas authorized for processing, storing, transmitting, and discussing Sensitive Compartmented Information (SCI) All personnel working in SCIFs must possess SCI access
Source: FBI SCI Program Brochure
Operation Design and Business Plan December 30,2003
> Justification for SCIF - Required for secure communications > Current Status of FDNS SCIF - A room to be used as a SCIF has been identified in the ULLICO building, but must undergo significant modifications to meet security requirements - CIS Facilities has advised that costs will be covered as a part of FDNS relocation
FOR FDNS USE ONLY 30
FY04 Budget Note on Staff Cost Categories Costs include the following: Salary Overtime and Awards Benefits Travel Change of Station Communications Registration, Training, And Supplies Assets (furniture, computer, etc.) Temporary Duty Budget
Note on Additional Training Costs include training provided to District Office Fraud Detection Staff and additional training/conference costs for FDNS staff.
Note on Capital Investments These asset costs only represent the cost associated with building a SCIF and specialized software. Additional facilities costs will be calculated when FDNS is provided with the appropriate information.
Management
Headquarters
FDU Sites
Contractors
Additional Training Capital Investments
Budget ($,OOOs) Sub Totals 543
Sub Totals
Budget ($,OOOs) 5,349
Sub Totals
Budget ($,OOOs) 10,457
Consulting IT BPA Sub Totals
Budget ($,OOOs) 1,050 308 21,136 22,493
Sub Tola Is
Budget ($,OOOs) 198
Budget ($,OOOs) Sub Totals 635
Total
Budget ($, OOOs) 39,674
Total Cost of New Staff Members ($ ,000s) Total Training Budget ($ ,000s) Total Contractor Cost ($ ,000s)
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 31
FY05 Budget Considerations
> Increased costs due to the potential addition of new staff * Cost reduction due to 45 new staff hired in 2004 being fully on-board > Development of proactive fraud capability could result in highly variable IT development costs > Decision regarding IBIS Check centralization could result in the hiring of a sizable contract staff > Decision regarding ICE's ownership stake in the background check process could greatly reduce FDNS financial requirements
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
32
Key FDNS Priorities
> Develop FDNS organizational structure, mission, and functions > Develop joint CIS/ICE Anti-Fraud Strategy, case referral criteria, process, and MOU > Develop MOU containing respective CIS and ICE guidelines regarding referral of NS/PS cases > Enhance current reactive (leads-based) data mining and pattern analysis efforts > Develop proactive anti-fraud processes > Develop case management tracking system that will track referrals and case progress > Review the integrity of CIS policies, procedures, operations, and other activities to identify and remove systemic vulnerabilities > Develop standardized IBIS triage process at each SC and field office > Evaluate the feasibility of centralizing the IBIS Process > Develop training modules for fraud detection and background check resolution activities > Serve as primary conduit to/from ICE and other LEAs emphasizing the importance of info sharing between agencies > Develop centralized/controlled policy and process to provide immigration documents and other benefits to informants and other LEA cooperatives > Participate in DHS intelligence, LEA information sharing, and Terrorist Support Center working groups
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
33
Short-Term Initiatives (less than 4 months)
Develop and implement human resource recruiting strategy Hire, train, and place 45 new staff Finalize positions and position descriptions within FDNS Standardize PWPs and identify performance standards Derformance work measures that correspond to Implement Service Center Triage and FDU process Obtain approval on referral criteria for IBIS and fraud with ICE Approve MQU with ICE Approve case referral criteria with ICE Develop process for moving cases/files between CIS and ICE Implement short term ICE Fraud Referral Plan Set and communicate fraud priorities and formalize referral process in a written SOP Establish initial set of fraud indicators for short-term proactive data mining Standardize critical processes and collect PAS data Develop and implement Phase 1 of the CIA Name Trace Re-engineering process Establish regular communication vehicles to outside organizations and within FDNS Develop proactive data mining capability (auto check of new receipts to fraud indicators) Develop MOUs with all organizations owning systems/data needed for proactive data mining (RAPS, SEVIS, etc.) Ensure Background Check System includes FDNS functional requirements Finalize requirements for Case Tracking System Obtain server for FDNS Incorporate FDNS training needs into overall CIS training initiative Communicate new Case Tracking Systems Procedures
•^^^•BBBBl^BBBBi
Finalize and deliver the Organizational Overview Document Finalize FY05 budget Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 34
Mid-Term Initiatives (greater than 4 months)
Implement To-Be processes from Operational Design & Business Plan document Finalize CIA name trace process Determine information warehousing strategy Develop proactive data mining capability (pattern recognition over all data and relational display of information) Develop a case tracking program within confines of to-be developed DHS System Establish plan for Oracle implementation svstem redundancies Establish recovery/back up system strat Develop training course content Develop training for each standardized process Begin FY'06 budget development
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 35
FDNS Communications Strategy
Grass Roots Communication
Stakeholder Education
> Standardize FDNS Correspondence: -Referrals from Adjudications -Referrals to ICE -Memoranda of Investigation -Fraud Findings
Inform Adjudications, ICE, CBP, DHS, etc.: -Develop communications to service center personnel -Provide training module to Adjudications -Develop guidelines for fraud indicators and FDU contact information -Communicate importance of fraud at the highest level of adjudications management
> Consider FDNS name branding > Involve field in developmental activities > Increase routine communications: -Management conferences and teleconference calls -All hands meetings -Town Hall Meetings (in-person/telephonic) -Field Office Visits -Work with OPA and Intercom on a communications strategy and plan (initial roll-out of anti-fraud initiative and ongoing national security and other accomplishments)
Operation Design and Business Plan December 30,2003
Liaise with Law Enforcement Community: -Share fraud analyses -Info sharing -Issuance of special request documents -Response to other needs
FOR FDNS USE ONLY 36
Operation Design and Business Plan Office of Fraud Detection and National Security (FDNS)
Washington, DC December 30, 2003
Contract Number. GS-23F-9755H BPA Number: COW-2-A-0024 Order Number. Call #16 Deliverable 7.2.2 v2 This document is confidential and is intended solely for the use and information of the U.S. Citizenship and Immigration Services
U.S. Citizenship and Immigration Services
I
Table of Contents > Introduction > Organization Options > Organization Details > Process Details and Performance Measures > Technology Requirements > Staffing and Training Requirements > Facilities Requirements > Financial Requirements > Current Initiatives and Next Steps
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Development of The Office of Fraud Detection and National Security (FDNS)
> CIS has developed FDNS in recognition of the need to: - Enhance the integrity of the legal immigration system, and - Identify persons who pose a threat to national security and/or public safety
"While providing accurate and responsive service is of paramount importance, we must not do so at
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Response to General Accounting Office Findings
GAO Recommendation
CIS Response
"...Determine how INS should balance its dual responsibilities of processing applications in a timely manner and detecting fraudulent applications"
Establish an organization (FDNS) separate from Adjudications, dedicated to detecting and pursuing suspected fraud
"Develop guidance for INS...to use in deciding which benefit application fraud cases to pursue"
Develop joint CIS/ICE benefit fraud strategy and case referral criteria
"Use [a system], to track and manage benefit fraud investigations..."
Develop and engage a case tracking system to track all fraud cases from referral to completion
Source: Immigration Benefit Fraud. Focused Approach is Needed to Address Problems". General Accounting Office. January 2002. GAO-02-66
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
FDNS Mission and Objectives
FDNS Mission Enhance the integrity of the legal immigration system by: -
Identifying aliens who pose a threat to national security and/or public safety
-
Combating immigration benefit fraud
-
Identifying and removing systemic vulnerabilities of statutes, policies, procedures, forms, other documents, and guidelines that compromise the integrity of the legal immigration system
FDNS Objectives > Serve as CIS' lead and primary conduit on fraud detection and law enforcement (background) check-related efforts > Ensure benefits are not granted to individuals who pose a threat to national security and/or public safety > Ensure benefits are not granted as a result of fraud-based applications or petitions > Provide a new capability for proactive fraud detection and enhance current reactive operation
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Existing Weaknesses of the Immigration System
> Some individuals seeking benefits pose a threat to national security and public safety > Anti-fraud efforts remain inadequate, reactive, and uncoordinated > Passive enforcement invites fraud and abuse > Lack of commitment to combating fraud demoralizes staff and negatively impacts productivity > Communication with the law enforcement community remains inefficient > Law enforcement community support remains inadequate, particularly as it relates to information sharing and providing documents to informants and other cooperatives > No centralized group is responsible for identifying and correcting weaknesses and other vulnerabilities in policies, procedures, and other activities
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
Organization Considerations
There Are Two Primary Functions Performed By FDNS:
Fraud Detection Organizational Options > Decentralized - Reactive (lead-based) fraud detection activities are performed in each Fraud Detection Unit (FDU) and Field Offices (Status Quo) > Centralized and Coordinated Fraud Detection:
1. Fraud Detection
Preferred Option
-
Proactive fraud detection activities are performed in a central location
-
Reactive (lead-based) fraud detection activities are coordinated by FDNS and performed in each FDU and Field Office
Background Check Organizational Options Limited Centralization - Background check resolution is performed in each Service Center FDU, selected form-type resolutions performed at the National Benefits Center (NBC) FDU, and all other resolutions performed at the DOs
2. Background Checks
Preferred Option
Centralization - Initial resolution (Tier 2) is performed in a central location for all offices. Serious hits (Tier 3) are resolved at each FDU and in DOs for forms not handled by the NBC Complete Centralization - All background check resolution (Tiers 2 and 3) is performed at one, single central location for all offices
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
FDNS Process Flow
Fraud Detection 1
CIS Fraud Detection and National Security
• Proactive fraud leads are generated through data mining • Taskings are sent to FDU
CIS
Adjudications (Districts and Service Centers)
FDNS Fraud Branch
External Agencies / Contacts
Fraud Leads
ir
Background Checks
/
ICE
FDNS Operations / ' Branch ^
1 1
i
• Accepts or rejects leads ; • Receives and / assigns fraud / cases
• Fraud leads are verified / * Verified leads are referred to
Proactive Fraud Leads
(FDU and DO Fraud Units)
1 Immigration and Customs Enforcement
Fraud and Background Check Referrals to ICE Feedback from ICE \ IBIS Tier 3 hits are resolved
/ Benefit rrauu Unit
w
L
Referred IBIS Hits
' • Cases needing enforcement actions are sent to ICE
/ / J
/
>^\t 1 \ for serious \ background \ check hits b;
SACs I I
CIS Adjudications (Districts and Service Centers)
.^_ IBIS Hits
w
FDNS Background Check Branch
IBIS Name Submission (Tier 1) performed in each office
Operation Design and Business Plan December 30, 2003
SACs \ IBIS Tier 2 beare handed proposed in atocentralized location • Majority of the staff are contractors
FOR FDNS USE ONLY
SACs I
|_J \ Performs field bAOs | \s — " and SACs enforcement for fraud cases
CAr
(Special Agents In-Charge)
FDNS Addresses Current and Long Standing Issues
Field Office Visit Observations
Issues
> Current processes and systems are inadequate to detect the amount of fraud that exists Fraud Detection
> Proactive fraud detection activities are only performed on an ad hoc basis > Fraud referral process within CIS and between CIS and ICE needs to be standardized > IBIS check mandate has created a backlog in the adjudication process and a strain on resources
Background Checks
> The IBIS process is not consistently applied > The CIA Name Trace process is in need of reengineering > Multiple chains of responsibility create a lack of accountability
Lack of Standardization
> Staff have received little formal training and have not received standard operating procedures > Demand for fraud detection and background check work exceeds the current staffing capacity
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
Benefits of FDNS
> CIS has a dedicated, specialized organization responsible for: -
Identifying aliens who pose a threat to national security and/or public safety
-
Combating immigration benefit fraud
-
Identifying and removing systemic vulnerabilities of statutes, policies, procedures, forms, other documents, and guidelines that compromise the integrity of the legal immigration system
> Processes associated with identifying fraud, criminal aliens, and aliens of national interest are enhanced > Productivity, quality, and efficiency are improved through a combination of centralization, standardization, and prioritization > Quality of background checks is enhanced as national security/public safety-related hits are resolved by specialized staff > Backlog reduction effort is supported by enabling adjudicators to concentrate on adjudication, instead of performing IBIS resolution and verifying fraud * ICE is able to use their limited resources more effectively and efficiently > Fraud-based applications are denied and violators are placed in removal proceedings > Communication between CIS and ICE is better coordinated
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
FDNS Organization Structure Director
Chief Operating Officer
Fraud Branch
Operation* Branch
Planning and Development Untt
Law Enforcement Liaison Untt
Proactive Fraud Detection Section
Planning and Development Untt
CIA Name Trace Untt
Intelligence Unit
Ij
Support Services Branch
Background Check (BC) Branch
Tier 3 Background Check •»— mntmMfat ovcHon fmfttlnn nevoiunon
TlerZ Background Check Resolution UnR
AMss/AscMants
Lead-Generated Fraud Section
FWd Office Anttfraud Units1
Supervisors
Contractors
Technology Support Untt
FDUI
PfOQfMii Anwyn S0cUon
Administration Unit
Training Section
Contract Support Section
D Denotes HQ Positions D Denotes Field Positions
'Not in FDNS chain of command, but follows FDNS established guidelines
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
10
Fraud Branch Branch Mission: Enhance the integrity of the legal immigration system by developing policies and procedures to detect, pursue, and deter benefit fraud.
Branch Functions Fraud Branch
• Develop fraud detection policies and procedures • Develop CIS fraud priorities Plannning and Development Unit
;
• Identify areas of vulnerability and propose solutions Monitor FDU intelligence reporting
Intelligence Unit
Identify fraud indicators for proactive and reactive data mining
Proactive Fraud Detection Section
V Perform proactive fraud detection and document significant findings in reports Use pattern recognition and data mining software in anti-fraud activities
Denotes HQ Positions I Denotes Field Positions
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
11
Operations Branch Branch Mission: Provide direction and oversight to FDNS field staff. Implement and perform activities to detect, pursue, and deter benefit fraud, and resolve national security and public safety related background check hits. Branch Functions
Operations Branch
Law Enforcement Liaison Unit
Service Center Fraud Detection Unit
Tier 3 Background Cheek Resolution Section
Assist LEAs and Intelligence agencies with operational requirements for CIS documents and subject information Liaise with DHS components/LEAs on issues impacting background checks Provide oversight and direction to fraud detection and background check staff Resolve background checks that are national security and public safety-related
Aides/Assistants
Lead-Generated Fraud Section
FfeW Office Anti-Fraud Units
Denotes HQ Positions I Denotes Field Positions Operation Design and Business Plan December 30,2003
> Review applications/petitions for fraud and identify fraud trends > Write intelligence reports and assist the Fraud Branch with proactive analysis > Support ICE in prosecuting cases FOR FDNS USE ONLY 12
Background Check Branch Branch Mission: Conduct law enforcement checks to identify derogatory information on persons seeking benefits who may pose a threat to national security or public safety. Branch Functions Background Check (BC) Branch
> Develop background check policies and procedures Planning and Development Unit
CIA Name Trace Unit
Tier 2 Background Check Resolution Untt
Provide system requirements for the Background Check System Coordinate background check process with other internal and external organizations (e.g., CIA, ICE, FBI) > Conduct background check activities Perform background check-related data analysis
Supervisors
Contractors
Denotes HQ Positions I Denotes Field Positions Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 13
Support Services Branch Branch Mission: Provide the coordination, communication, and operational support needed to facilitate the achievement of the FDNS mission.
Branch Functions
Support Services Branch
> Support FDNS specific Information Technology (IT) needs Technology Support Unit
> Develop functional requirements and training FDU Systems Support Section
> Incorporate and monitor training > Perform research on SOWs, facilities, and contracts
Program Analyst Section
> Conduct analytic reviews
«*.
**-
Administration Unit
> Perform human and capital resource related functions for FDNS including budget development and facilities/inventory management
Training Section
> Recruit and train staff Contract Support Section
> Oversee contract management, technology resources, and " communications
Denotes HQ Positions I Denotes Field Positions Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 14
FDNS Processes
Background Check Processes
Fraud Processes Proactive Fraud Detection using systems, data mining, and fraud indicators to actively identify fraud Reactive Fraud Detection responding to possible fraud leads Fraud Verification confirming a fraud lead is actual fraud Case Development packaging verified fraud leads for referral to ICE
> IBIS Tier 1 - entering applicant/petitioner data for submission to IBIS > IBIS Tier 2 - evaluating positive IBIS "hits" to confirm identity and resolving hits that are not national security/public safety (NS/PS) related
Integrity-Based Processes Integrity-Based Processinganalytically review CIS systems, regulations, policies, forms, and processes to minimize the opportunity for fraud or abuse of the legal immigration system
> IBIS Tier 3 - resolving NS/PS related hits and referring hits to ICE
Other Processes > Special/Undercover Documents - generating immigration benefit documents to be used by individuals assisting investigations > Intelligence Reporting coordinating, developing, and disseminating fraud and background check related information and intelligence
> CIA Name Trace - resolving CIA Name Trace results that have derogatory information
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 15
FDNS Processes Include Involvement from Adjudications and ICE
Process
FDNS ^D K Fraud Branch
c
FDNS
Operations Branch
FDNS
Background
Check Brgnch
Adjudications
ICE
Fraud Processes Proactive Fraud Detection Reactive Fraud Detection
•
•
•
•
• •
Fraud Verification
•
•
Case Development
•
•
Post Investigative/ Prosecution Analysis
•
• • • •
•
Background Check Processes
•
IBIS Tier 1
•
IBIS Tier 2
•
IBIS Tier 3
• •
CIA Name Trace
• •
•
integrity Process Integrity-Based Processing
•
•
Other Processes Intelligence Reporting Special/Undercover Documents • •
•
• •
• •
Denotes Primary Process Owner Denotes Supporting Role
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 16
Internal and External Info Sharing Processes
Law Enforcement Community
U.S. Citizenship and Immigration Services
FDNS recognizes that one of the best ways to prevent fraud and protect national security and public safety is through on-going info sharing
US. Immigrati and Customs Enforcement
Information From FDNS Intelligence reports CIS systems data mining reports Information on individuals of interest Liaison/cross training National security/public safety relationships Open accessibility and immediate responsiveness Information To FDNS Status of enforcement actions Intelligence
Other Government Agencies
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 17
Fraud Detection Processes
Fraud Priorities'
Fraud Evaluations
Proactive Fraud Detection
Enforcement Results Fraud Leads
Referrals
(FDNS HQ)
Enforcement Results
Fraud Verification (FDU/DO)
External Leads SuspiciousApplications/ Petitions
Reactive Fraud Detection (FDU/DO)
Enforcement
Cases With "Verified" Fraud
Case Development (FDU/DO)
Case With No Fraud Found Fraud Leads and Files
Operation Design and Business Plan December 30, 2003
Files With Fraud Documentation
Post Investigation/ Prosecution Analysis (FDNS HQ/FDU)
Fraud Evaluations
Adjudication Additional Files To Adjudicate
FOR FDNS USE ONLY 18
IBIS SC Triage Process
Applications/ Petitions
Documents In Files
IBIS Tier 1 Name Submission
Positive IBIS Results
IBIS Tier 2 Name Vetting and Non-NS/PS Resolution*
Adjudicative Decisions Resolved Hits
Adjudication
Confirmed NS/PS Hits, Unconfirmed Hits
Resolved Hits
IBIS Tier 3 NS/PS Resolution*
Cases Needing Enforcement Action
Investigations And Subsequent*
Enforcement
H
| Enforcement Results
* Initial resolution (Tier 2) and resolution of serious hits (Tier 3) is performed at each FDU and in DOs for forms not handled by the NBC. Each Service Center(SC) Triage (Tier 2) NS/PS hit resolved by FDU.
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 19
IBIS Background Check Processes Concept for Centralization
Applications/ Petitions
Documents In Files
IBIS Tier 1 Name Submission
Positive IBIS Results
IBIS Tier 2 Name Vetting and Non-NS/PS Resolution*
Adjudicative Decisions Resolved Hits
Adjudication
Confirmed NS/PS Hits, Unconfirmed Hits
Resolved Hits
IBIS Tier 3 NS/PS Resolution*
Investigations And Subsequent/
Cases Needing Enforcement Action Enforcement Results
' FDNS is evaluating the feasibility of centralizing aspects of the Background Check Resolution process. Under a Centralized concept: initial resolution (Tier 2) is performed in a central location for all offices and resolution of serious hits (Tier 3) fe performed at each FDU and in DOs for forms not handled by the NBC. In a decentralized model, each Service CenterfSC) Triage (Tier 2) NS/PS hit resolved by FDU.
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 20
CIA Name Check Process
Investigations And Subsequent Action
Information from Applications
Data Input
Names
CIA Vetts Names
Derog or No De,
Derog or No Derog
Adjudicative Decisions
Resolved Hits
FDNS Resolves Hit
Operation Design and Business Plan December 30,2003
Adjudications
FOR FDNS USE ONLY 21
Integrity-Based Processing Examples of Current FDNS Involvement > Refugee Fraud Working Group > 1-751 Revision Process and SOP > CIA Name Trace Policy and Process > Forms Revision Working Group > FDNS HQ identifies and removes systemic vulnerabilities of statutes, policies, procedures, forms, other documents, and guidelines that compromise the integrity of the legal immigration system > FDNS HQ interfaces with various internal and external components > FDNS HQ personnel actively participate in DHS and other working groups
> 1-140 Ability to Pay > 1-129 Business Pre-certification > SC Background Check Triage Process and SOP > IPS BAD Process > Patriot Act Section 403 A and B > Terrorist Screening Center Working Group > DHS Intelligence Working Group > DHS/ICE Enterprise Architecture (fraud-based) > Centralization of LEA special document requests
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 22
Technology FDNS Processes System
Proactive _ . Fraud Detection
Reactive _ . Fraud Detection
„ . Fraud verification c
Venficatlon
/•»„«.„ Case Develooment Development
Post .. .. lnvest'9ative .
Analysjs
Tierl
Tier 2
Tier 3
CIA Name Trace
•
•
•
•
•
•
•
CIS Owned Systems Background Check System (BCS) CIS National Systems (e.g. C3, C4)
•
•
•
•
Consolidated CIS Data System
•
•
•
•
FDNS Case Tracking System
•
•
•
•
Proactive Data Mining System
•
Other Info Systems
•
•
•
'
ChoicePoint
.-
•
•
•
•
•
Other Government Agency System
•
IBIS Intelink
• TBD
TBD
•
• TBD
= Denotes system used in this process
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 23
Short-Term Technology Initiatives
> FDNS Case Tracking System -
Deploy Case Tracking System developed by FDD - Texas
> Consolidated CIS Data System and Proactive Data Mining System: -
Continue to use Consolidated C3 LAN for data mining Consider adding additional data to system
-
Use existing data mining tools as a test bed for long term data mining solution Evaluate additional software to increase capability of data mining
> Background Check System: -
Continue to use systems in place until the Background Check System (currently being developed) is implemented
-
Consider use of commercial off-the-shelf identification software
> External Systems: -
Continue to identify and assess other systems that can be used for both fraud and background checks (e.g., Intelink)
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
24
Long-Term Technology Initiatives Fraud Case Tracking System
Background Check System Goal: Automate name submission and checks and enable centralized management of IBIS process
> Goal: Develop case tracking system for CIS/ICE > Implementation issues:
Implementation issues: -Centralized IBIS Tier 2 cannot be implemented without the Background Check System in place, with SQ11 capability
- Determine capacity and functionality for use CISwide and by ICE BFUs - Determine most efficient manner to track CIS fraud cases
Data Warehousing
Proactive Data Mining Goal: Use robust tools (rule based reasoning, statistical analysis, artificial intelligence) to identify patterns and generate fraud leads
Goals: Consolidate data into a single architecture, create partial replicas of data stored for each system Implementation issues:
Implementation issues: - Identifying applicable data fields and developing the capability to automatically detect patterns and trends likely to involve fraud
-A data warehouse may be developed as part of the Benefits Application Processing System, FDNS may need something sooner
- Data warehousing capability is required to realize system benefits
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 25
FDNS Staffing Plan Director (SES)
Chief Operating Officer (SES)
Fraud Branch 1 Chief (GS-14/15)
Background Check (BC) Branch 1 Chief (GS-14/15)
Operations Branch 1 Chief (GS-14/15)
Support Services Branch 1 Chief (GS-14/15)
Technology Support Unit 1 Officer (GS-13/14)
Planning and Development Unit 2 Officers (GS-13/14)
Law Enforcement Liaison Unit 2 Officers, 1 Officer (GS-13/14)
Planning and Development Unit 1 Officer (GS-13/14)
Intelligence Unit 2 Officers (GS-13/14)
Service Center Fraud Detection Unit 5 Chiefs (GS-13/14)
CIA Name Trace Unit TBD (GS-13/14)
FDU Systems Support Section 1 Specialist (GS-12/13)
Tier 2 Background Check Resolution Unit 4 Officers (GS-12/13)
Program Analyst Section 2 Analysts or Contractors (GS-12/13 equivalent)
Tier 3 Background Check Resolution Section 15 Officers, 135 Contractors (GS-7/9/11/12.GS-7/9/11/12 equivalent)
Proactive Fraud Detection Section 3 Analysts (GS-11/12)
Aides/Assistants 10 Aides/Assistants (GS-5/7 equivalent)
Supervisors 5 Supervisors (GS-9/11/12 equivalent)
Lead-Generated Fraud Section 3 Officers, 31 Officers (GS-5/7/9/11/12,13)
Legend: 2004 Staff
Contractors 73 Contractors (GS-5/7 equivalent)
Administration Unit 1 Officer (GS-13/14)
Training Section 1 Officer (GS-12/13/14)
Contract Support Section 2 Contractors (GS-5 equivalent)
Field Office Anti-Fraud Units 33 Officers (GS-13)
• New Staff • Existing Staff
D Denotes HQ Positions
• Contractors
D Denotes Field Positions
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 26
Position Descriptions Position
Locations
Headquarters
Overview of Duties
Branch Chief (GS-14/15)
Oversee the operations of an FDNS branch Conduct and approve personnel actions within the branch
Immigration Officer (IO) (GS-13/14) Intelligence Research Specialist (IRS) (GS-13/14)
Perform planning and development, intelligence activities, liaise with law enforcement, perform the CIA Name Trace process and oversee the Support Services Technology Support and Administration Units
Program Analyst (GS-12/13)
Assist in developing and assessing systems used by FDNS
HQ, Computer Contractor (GS-12/13 equivalents) Support Section
FDU
FDU Chief (GS-13/14)
Serve as FDU Chief overseeing FDU operations Coordinate Immigration Officers in the Field Office Anti-Fraud Units
IRS(GS-5/7/9/11/12) Senior IRS (GS-13)
Perform fraud-related work verifying fraud leads for referral to ICE Perform IBIS Tier 3 activities such as contacting law enforcement agencies to obtain hit information and resolving IBIS hits
Program Analyst (GS-12/13)
Assist in developing and assessing systems used by FDNS
Assistants (GS-5/7) District Offices
Background Check Identity Resolution Unit (Tier 2)
Assist in developing and assessing systems used by FDNS
• •
Perform IBIS checks and resolutions Enter cases into the FDNS Tracking System and assist with case development
IO(GS-13)
Perform fraud-related work verifying fraud leads for referral to FDUs Perform case development for cases not pursued by ICE
IRS (GS-12/13)
Oversee and support the operations of the unit Develop operating procedures, improve processes
Supervisors (GS-9/11/12)
Supervise contractors performing Tier 2 IBIS activities
Contractor (GS-5/7 equivalents)
Perform IBIS Tier 2 activities such as name vetting and resolution of hits that are not national security or public safety related
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 27
Training
Training Requirements
IRS (GS-5/7)
IRS (GS-9/11)
IRS (GS 11/12/13)
10 (GS-13)
Immigration Process
S
S
S
Systems Training /Systems Refresher
S
S
S
S
Effective Communications (Written and Oral)
S
S
S
S
^
^
L
Immigration Law Intel Analysis School - FLETC Investigative Analysis Forensic Documents - Document Analysis Advanced Leadership and Management
^
^
^ ^
^
^*
^
* For supervisory GS-13s
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY 28
Facility Requirements
Current Facilities
Potential Short-Term Needs
Headquarters staff located in Washington, DC
> Potential need for additional file space at FDUs and/or SCs
Five FDUs located in California, Missouri, Nebraska, Texas, and Vermont
t Development of the Secure Compartmented Information Facility (SCIF)
Potential Long-Term Needs If Service Centers need to recover space in existing Centers for its own staff/work, the FDUs may need to find alternative space1 If the CIS background check centralization plan is approved, a single location will have to be identified for the centralized facility
Current facilities satisfy current staffing levels
1 The co-location of FDUs and SCs is not an absolute requirement. Should it become viable financially, we may want to consider co-locating the FDUs with Regional CIS offices, as they are also responsible for supporting centers and field offices within their respective geographic areas. This would also be consistent with ICE's Benefit Fraud Unit structure, albeit their legacy INS Regional Investigations Offices are now referred to as "areas".
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 29
SCIF Development
SCIF Description
FDNS SCIF Status
SCIFs are the only areas authorized for processing, storing, transmitting, and discussing Sensitive Compartmented Information (SCI) All personnel working in SCIFs must possess SCI access
Source: FBI SCI Program Brochure
Operation Design and Business Plan December 30,2003
> Justification for SCIF - Required for secure communications > Current Status of FDNS SCIF - A room to be used as a SCIF has been identified in the ULLICO building, but must undergo significant modifications to meet security requirements - CIS Facilities has advised that costs will be covered as a part of FDNS relocation
FOR FDNS USE ONLY 30
FY04 Budget Note on Staff Cost Categories Costs include the following: Salary Overtime and Awards Benefits Travel Change of Station Communications Registration, Training, And Supplies Assets (furniture, computer, etc.) Temporary Duty Budget
Note on Additional Training Costs include training provided to District Office Fraud Detection Staff and additional training/conference costs for FDNS staff.
Note on Capital Investments These asset costs only represent the cost associated with building a SCIF and specialized software. Additional facilities costs will be calculated when FDNS is provided with the appropriate information.
Management
Headquarters
FDU Sites
Contractors
Additional Training Capital Investments
Budget ($,OOOs) Sub Totals 543
Sub Totals
Budget ($,OOOs) 5,349
Sub Totals
Budget ($,OOOs) 10,457
Consulting IT BPA Sub Totals
Budget ($,OOOs) 1,050 308 21,136 22,493
Sub Tola Is
Budget ($,OOOs) 198
Budget ($,OOOs) Sub Totals 635
Total
Budget ($, OOOs) 39,674
Total Cost of New Staff Members ($ ,000s) Total Training Budget ($ ,000s) Total Contractor Cost ($ ,000s)
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 31
FY05 Budget Considerations
> Increased costs due to the potential addition of new staff * Cost reduction due to 45 new staff hired in 2004 being fully on-board > Development of proactive fraud capability could result in highly variable IT development costs > Decision regarding IBIS Check centralization could result in the hiring of a sizable contract staff > Decision regarding ICE's ownership stake in the background check process could greatly reduce FDNS financial requirements
Operation Design and Business Plan December 30, 2003
FOR FDNS USE ONLY
32
Key FDNS Priorities
> Develop FDNS organizational structure, mission, and functions > Develop joint CIS/ICE Anti-Fraud Strategy, case referral criteria, process, and MOU > Develop MOU containing respective CIS and ICE guidelines regarding referral of NS/PS cases > Enhance current reactive (leads-based) data mining and pattern analysis efforts > Develop proactive anti-fraud processes > Develop case management tracking system that will track referrals and case progress > Review the integrity of CIS policies, procedures, operations, and other activities to identify and remove systemic vulnerabilities > Develop standardized IBIS triage process at each SC and field office > Evaluate the feasibility of centralizing the IBIS Process > Develop training modules for fraud detection and background check resolution activities > Serve as primary conduit to/from ICE and other LEAs emphasizing the importance of info sharing between agencies > Develop centralized/controlled policy and process to provide immigration documents and other benefits to informants and other LEA cooperatives > Participate in DHS intelligence, LEA information sharing, and Terrorist Support Center working groups
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY
33
Short-Term Initiatives (less than 4 months)
Develop and implement human resource recruiting strategy Hire, train, and place 45 new staff Finalize positions and position descriptions within FDNS Standardize PWPs and identify performance standards Derformance work measures that correspond to Implement Service Center Triage and FDU process Obtain approval on referral criteria for IBIS and fraud with ICE Approve MQU with ICE Approve case referral criteria with ICE Develop process for moving cases/files between CIS and ICE Implement short term ICE Fraud Referral Plan Set and communicate fraud priorities and formalize referral process in a written SOP Establish initial set of fraud indicators for short-term proactive data mining Standardize critical processes and collect PAS data Develop and implement Phase 1 of the CIA Name Trace Re-engineering process Establish regular communication vehicles to outside organizations and within FDNS Develop proactive data mining capability (auto check of new receipts to fraud indicators) Develop MOUs with all organizations owning systems/data needed for proactive data mining (RAPS, SEVIS, etc.) Ensure Background Check System includes FDNS functional requirements Finalize requirements for Case Tracking System Obtain server for FDNS Incorporate FDNS training needs into overall CIS training initiative Communicate new Case Tracking Systems Procedures
•^^^•BBBBl^BBBBi
Finalize and deliver the Organizational Overview Document Finalize FY05 budget Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 34
Mid-Term Initiatives (greater than 4 months)
Implement To-Be processes from Operational Design & Business Plan document Finalize CIA name trace process Determine information warehousing strategy Develop proactive data mining capability (pattern recognition over all data and relational display of information) Develop a case tracking program within confines of to-be developed DHS System Establish plan for Oracle implementation svstem redundancies Establish recovery/back up system strat Develop training course content Develop training for each standardized process Begin FY'06 budget development
Operation Design and Business Plan December 30,2003
FOR FDNS USE ONLY 35
FDNS Communications Strategy
Grass Roots Communication
Stakeholder Education
> Standardize FDNS Correspondence: -Referrals from Adjudications -Referrals to ICE -Memoranda of Investigation -Fraud Findings
Inform Adjudications, ICE, CBP, DHS, etc.: -Develop communications to service center personnel -Provide training module to Adjudications -Develop guidelines for fraud indicators and FDU contact information -Communicate importance of fraud at the highest level of adjudications management
> Consider FDNS name branding > Involve field in developmental activities > Increase routine communications: -Management conferences and teleconference calls -All hands meetings -Town Hall Meetings (in-person/telephonic) -Field Office Visits -Work with OPA and Intercom on a communications strategy and plan (initial roll-out of anti-fraud initiative and ongoing national security and other accomplishments)
Operation Design and Business Plan December 30,2003
Liaise with Law Enforcement Community: -Share fraud analyses -Info sharing -Issuance of special request documents -Response to other needs
FOR FDNS USE ONLY 36
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