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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003
 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003
 Response to General Accounting Office Findings

GAO Recommendation CIS Response

"...Determine how INS should balance its dual responsibilities Establish an organization (FDNS) separate from
of processing applications in a timely manner and detecting Adjudications, dedicated to detecting and pursuing
fraudulent applications" suspected fraud

"Develop guidance for INS...to use in deciding which benefit Develop joint CIS/ICE benefit fraud strategy and case
application fraud cases to pursue" referral criteria

"Use [a system], to track and manage benefit fraud Develop and engage a case tracking system to track all
investigations..." 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003
 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003
 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003
 Organization Considerations
There Are Two Primary
Functions Performed By
FDNS:
Preferred
1. Fraud Detection
Preferred
2. Background Checks
Operation Design and Business Plan December 30, 2003
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:
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
Centralization - Initial resolution (Tier 2) is performed in a central
Option 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
FOR FDNS USE ONLY
 FDNS Process Flow

Fraud Detection 1 CIS Fraud Detection and National Security 1 Immigration and Customs Enforcement

CIS • Proactive fraud leads are

Adjudications FDNS Fraud generated through data
(Districts and mining
Branch • Taskings are sent to FDU
Service Centers)
• Accepts or
• Fraud leads are verified rejects leads
Proactive / * Verified leads are referred to ; • Receives and
External Fraud Leads / ICE
/ assigns fraud
Agencies / ir / cases
Contacts Fraud /
Leads FDNS Operations / Fraud and Background
Benefit /
Branch ' Check Referrals to ICE
^ w rrauu
(FDU and DO Fraud Feedback from ICE
Units) Unit
\ IBIS Tier 3 hits are resolved
Background 1 i L

Checks 1 >^\t
' • Cases needing enforcement / 1 \ for serious
Referred
actions are sent to ICE / \ background
IBIS Hits
J \ check hits
b;

SACs II SACs I
.^_ CAr |_J \ Performs field
CIS bAOs | \s
Adjudications IBIS Hits FDNS Background
w — " and
(Districts and Check Branch SACs SACs enforcement
Service Centers) beare
\ IBIS Tier 2 handed in atocentralized
proposed for fraud cases
IBIS Name Submission location
(Tier 1) performed in each • Majority of the staff are (Special Agents In-Charge)
office contractors

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003
 FDNS Addresses Current and Long Standing Issues

Issues Field Office Visit Observations

> 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
> The IBIS process is not consistently applied
Checks
> The CIA Name Trace process is in need of reengineering
> Multiple chains of responsibility create a lack of accountability
Lack of
> Staff have received little formal training and have not received standard operating procedures
Standardization
> Demand for fraud detection and background check work exceeds the current staffing capacity

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003
 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003
 FDNS Organization Structure

Director

Chief Operating Officer

Fraud Branch Operation* Branch Background Check (BC) Branch Support Services Branch

Planning and Development Untt Law Enforcement Liaison Untt Planning and Development Untt Technology Support Untt

Intelligence Unit CIA Name Trace Untt FDUI

Ij Proactive Fraud Detection Section

Tier 3 Background Check
•»— mntmMfat ovcHon
nevoiunon fmfttlnn
TlerZ Background Check
Resolution UnR
PfOQfMii Anwyn S0cUon

AMss/AscMants Supervisors Administration Unit

Lead-Generated Fraud Section Contractors Training Section

FWd Office Anttfraud Units1 Contract Support Section

D Denotes HQ Positions
'Not in FDNS chain of command, but follows FDNS established guidelines D Denotes Field Positions

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 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.

Operations Branch
Branch Functions

Assist LEAs and Intelligence agencies with operational

Law Enforcement Liaison Unit requirements for CIS documents and subject information
Liaise with DHS components/LEAs on issues impacting
background checks
Service Center Fraud Detection Unit
Provide oversight and direction to fraud detection and
background check staff
Tier 3 Background Cheek
Resolution Section Resolve background checks that are national security and
public safety-related

Aides/Assistants

Lead-Generated Fraud Section > Review applications/petitions for fraud and identify fraud
trends
> Write intelligence reports and assist the Fraud Branch
FfeW Office Anti-Fraud Units
with proactive analysis
Denotes HQ Positions > Support ICE in prosecuting cases
I Denotes Field Positions

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 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 Provide system requirements for the Background Check
System

CIA Name Trace Unit

Coordinate background check process with other internal
and external organizations
(e.g., CIA, ICE, FBI)
Tier 2 Background Check
Resolution Untt > Conduct background check activities

Perform background check-related data analysis

Supervisors

Contractors

Denotes HQ Positions
I Denotes Field Positions

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 14
 FDNS 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
Operation Design and Business Plan December 30,2003
Background Check
Processes
> 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
> IBIS Tier 3 - resolving NS/PS
related hits and referring hits to
ICE
> CIA Name Trace - resolving
CIA Name Trace results that
have derogatory information
FOR FDNS USE ONLY
Integrity-Based
Processes
Integrity-Based Processing-
analytically review CIS
systems, regulations, policies,
forms, and processes to
minimize the opportunity for
fraud or abuse of the legal
immigration system
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
15
 FDNS Processes Include Involvement from Adjudications and ICE

FDNS FDNS FDNS

Process c ^D K Operations Background Adjudications ICE
Fraud Branch Branch Check Brgnch

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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 16
 Internal and External Info Sharing Processes

Law Enforcement
Community

FDNS recognizes that one of the best US. Immigrati

U.S. Citizenship ways to prevent fraud and protect and Customs
and Immigration Enforcement
national security and public safety is
Services
through on-going info sharing

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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 17
 Fraud Detection Processes

Fraud
Priorities' Proactive Enforcement Results
Fraud Fraud Referrals
Leads Enforcement
Detection
Fraud (FDNS HQ)
Evaluations Enforcement
Results

Files With Fraud

Post
Fraud Case Documentation Investigation/
Verification Cases
Development Prosecution
(FDU/DO) With (FDU/DO) Analysis Fraud
"Verified" (FDNS HQ/FDU) Evaluations
Fraud

External Reactive
Leads Case With No Fraud Found
Fraud Adjudication
Suspicious-
Detection Fraud Leads
(FDU/DO) Additional Files To Adjudicate
Applications/ and Files
Petitions

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 18
 IBIS SC Triage Process

Applications/
Petitions
Adjudicative
Positive IBIS IBIS Tier 2 - Decisions
IBIS Tier 1 - Results Resolved Hits
Name Vetting and
Documents Name Adjudication
In Files Non-NS/PS
Submission
Resolution*

Confirmed NS/PS Hits,

Unconfirmed Hits

Resolved
Hits Investigations And
IBIS Tier 3 - Subsequent*
NS/PS Cases Needing Enforcement H
Resolution* Enforcement Action

| 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.

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 19
 IBIS Background Check Processes

Concept for Centralization

Applications/
Petitions
Adjudicative
Positive IBIS IBIS Tier 2 - Decisions
IBIS Tier 1 - Results Resolved Hits
Name Vetting and
Documents Name Adjudication
In Files Non-NS/PS
Submission
Resolution*

Confirmed NS/PS Hits,

Unconfirmed Hits

Resolved
Hits Investigations And
IBIS Tier 3 - Subsequent/
NS/PS Cases Needing
Resolution* 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.

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 20
 CIA Name Check Process

Information Investigations And

from Subsequent Action
Applications Names Derog or No De,
Data Input CIA Vetts Names

Derog or No Derog

Adjudicative
Resolved
Decisions
Hits
FDNS Resolves Hit Adjudications

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 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, > 1-140 Ability to Pay
forms, other documents, and guidelines that
compromise the integrity of the legal immigration > 1-129 Business Pre-certification
system
> SC Background Check Triage Process and SOP
> FDNS HQ interfaces with various internal and
external components > IPS BAD Process

> FDNS HQ personnel actively participate in DHS > Patriot Act Section 403 A and B
and other working groups
> Terrorist Screening Center Working Group

> DHS Intelligence Working Group

> DHS/ICE Enterprise Architecture (fraud-based)

> Centralization of LEA special document requests

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 22
 Technology

FDNS Processes
Proactive
_ . Reactive
_ . c„ .
Fraud /•»„«.„
Case . Post
.. .. CIA Name
System Fraud Fraud verification Develooment lnvest'9ative Trace
Detection Detection Venficatlon Development Analysjs Tierl Tier 2 Tier 3

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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 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)

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 24
 Long-Term Technology Initiatives

Background Check System Fraud Case Tracking System

Goal: Automate name submission and checks and
enable centralized management of IBIS process
Implementation issues:
-Centralized IBIS Tier 2 cannot be implemented
without the Background Check System in place,
with SQ11 capability
> Goal: Develop case tracking system for CIS/ICE
> Implementation issues:
- Determine capacity and functionality for use CIS-
wide and by ICE BFUs
- Determine most efficient manner to track CIS fraud
cases

Proactive Data Mining Data Warehousing

Goal: Use robust tools (rule based reasoning,
statistical analysis, artificial intelligence) to identify
patterns and generate fraud leads
Implementation issues:
- Identifying applicable data fields and developing
the capability to automatically detect patterns and
trends likely to involve fraud
- Data warehousing capability is required to realize
system benefits
Goals: Consolidate data into a single architecture,
create partial replicas of data stored for each system
Implementation issues:
-A data warehouse may be developed as part of the
Benefits Application Processing System, FDNS may
need something sooner

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 25
 FDNS Staffing Plan
Director

(SES)

Chief Operating Officer

(SES)

Fraud Branch Operations Branch Background Check (BC) Branch Support Services Branch
1 Chief 1 Chief 1 Chief 1 Chief
(GS-14/15) (GS-14/15) (GS-14/15) (GS-14/15)

Planning and Development Unit Law Enforcement Liaison Unit Planning and Development Unit Technology Support Unit
2 Officers 2 Officers, 1 Officer 1 Officer 1 Officer
(GS-13/14) (GS-13/14) (GS-13/14) (GS-13/14)

Intelligence Unit Service Center Fraud Detection Unit CIA Name Trace Unit FDU Systems Support Section
2 Officers 5 Chiefs TBD 1 Specialist
(GS-13/14) (GS-13/14) (GS-13/14) (GS-12/13)

Tier 3 Background Check Tier 2 Background Check Program Analyst Section

Proactive Fraud Detection Section
Resolution Section Resolution Unit 2 Analysts or Contractors
3 Analysts
15 Officers, 135 Contractors 4 Officers (GS-12/13 equivalent)
(GS-11/12)
(GS-7/9/11/12.GS-7/9/11/12 equivalent) (GS-12/13)

Aides/Assistants Supervisors Administration Unit

10 Aides/Assistants 5 Supervisors 1 Officer
(GS-5/7 equivalent) (GS-9/11/12 equivalent) (GS-13/14)

Lead-Generated Fraud Section Contractors Training Section

3 Officers, 31 Officers 73 Contractors 1 Officer
(GS-5/7/9/11/12,13) (GS-5/7 equivalent) (GS-12/13/14)

Legend: Contract Support Section

Field Office Anti-Fraud Units
2 Contractors
2004 Staff 33 Officers
(GS-13) (GS-5 equivalent)

• New Staff
• Existing Staff D Denotes HQ Positions
• Contractors D Denotes Field Positions

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 26
 Position Descriptions
Locations Position Overview of Duties

Branch Chief Oversee the operations of an FDNS branch

(GS-14/15) Conduct and approve personnel actions within the branch
Immigration Officer (IO) (GS-13/14) Perform planning and development, intelligence activities, liaise with law
Headquarters
Intelligence Research Specialist enforcement, perform the CIA Name Trace process and oversee the Support
(IRS) (GS-13/14) 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) Assist in developing and assessing systems used by FDNS
Support Section
Serve as FDU Chief overseeing FDU operations
FDU Chief (GS-13/14)
Coordinate Immigration Officers in the Field Office Anti-Fraud Units
Perform fraud-related work verifying fraud leads for referral to ICE
IRS(GS-5/7/9/11/12)
Perform IBIS Tier 3 activities such as contacting law enforcement agencies to
FDU Senior IRS (GS-13)
obtain hit information and resolving IBIS hits

Program Analyst (GS-12/13) Assist in developing and assessing systems used by FDNS

• Perform IBIS checks and resolutions

Assistants (GS-5/7)
• Enter cases into the FDNS Tracking System and assist with case development
Perform fraud-related work verifying fraud leads for referral to FDUs
District Offices IO(GS-13)
Perform case development for cases not pursued by ICE
Oversee and support the operations of the unit
IRS (GS-12/13)
Background Develop operating procedures, improve processes
Check Identity
Resolution Unit Supervisors (GS-9/11/12) Supervise contractors performing Tier 2 IBIS activities
(Tier 2)
Perform IBIS Tier 2 activities such as name vetting and resolution of hits that
Contractor (GS-5/7 equivalents)
are not national security or public safety related

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 27
 Training

IRS IRS IRS 10

Training Requirements (GS-5/7) (GS-9/11) (GS 11/12/13) (GS-13)
L

Immigration Process S S S

Systems Training /Systems Refresher S S S S

Effective Communications
S S S S
(Written and Oral)

Immigration Law
^ ^
Intel Analysis School - FLETC
^ ^
Investigative Analysis
^

Forensic Documents - Document Analysis

Advanced ^ ^
Leadership and Management
^* ^

* For supervisory GS-13s

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 28
 Facility Requirements

Current Facilities Potential Short-Term Needs Potential Long-Term Needs

Headquarters staff located in > Potential need for additional file If Service Centers need to
Washington, DC space at FDUs and/or SCs recover space in existing Centers
t Development of the Secure for its own staff/work, the FDUs
Five FDUs located in California,
Missouri, Nebraska, Texas, and Compartmented Information may need to find alternative
Vermont Facility (SCIF) space1
If the CIS background check
Current facilities satisfy current
centralization plan is approved, a
staffing levels
single location will have to be
identified for the centralized
facility

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".

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 29
 SCIF Development
SCIF Description
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
FOR FDNS USE ONLY
Operation Design and Business Plan December 30,2003
FDNS SCIF Status
> 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
30
 FY04 Budget

Note on Staff Cost Categories

Costs include the following: Budget ($,OOOs)
Salary Management
Sub Totals 543
Overtime and Awards
Benefits Budget ($,OOOs)
Travel Headquarters
Sub Totals 5,349
Change of Station
Communications Budget ($,OOOs)
Registration, Training, And Supplies FDU Sites
Sub Totals 10,457
Assets (furniture, computer, etc.)
Temporary Duty Budget Budget ($,OOOs)
Consulting 1,050
Note on Additional Training Contractors IT 308
BPA 21,136
Costs include training provided to Sub Totals 22,493
District Office Fraud Detection Staff
and additional training/conference Additional Budget ($,OOOs)
costs for FDNS staff.
Training Sub Tola Is 198

Note on Capital Investments Capital Budget ($,OOOs)

Investments Sub Totals 635
These asset costs only represent the
cost associated with building a SCIF Budget ($, OOOs)
and specialized software. Additional Total
39,674
facilities costs will be calculated
when FDNS is provided with the
appropriate information.

Total Cost of New Staff Members ($ ,000s)

Total Training Budget ($ ,000s)
Total Contractor Cost ($ ,000s)

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30, 2003 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

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 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
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Finalize and deliver the Organizational Overview Document
Finalize FY05 budget

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 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
Establish recovery/back up system strat svstem redundancies

Develop training course content

Develop training for each standardized process

Begin FY'06 budget development

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 35
 FDNS Communications Strategy

Grass Roots Communication Stakeholder Education

> Standardize FDNS Correspondence: Inform Adjudications, ICE, CBP, DHS, etc.:
-Referrals from Adjudications -Develop communications to service center personnel
-Referrals to ICE -Provide training module to Adjudications
-Memoranda of Investigation -Develop guidelines for fraud indicators and FDU
contact information
-Fraud Findings
-Communicate importance of fraud at the highest level
> Consider FDNS name branding of adjudications management
> Involve field in developmental activities Liaise with Law Enforcement Community:
> Increase routine communications: -Share fraud analyses
-Management conferences and teleconference calls -Info sharing
-All hands meetings -Issuance of special request documents
-Town Hall Meetings (in-person/telephonic) -Response to other needs
-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)

FOR FDNS USE ONLY

Operation Design and Business Plan December 30,2003 36