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Travel Card Delinquencies
Report Number I-2001-008
August 2001


APPENDIX IV

OIG's Analysis of INS's Response

On June 15, 2001, the Evaluation and Inspections Division sent copies of the draft report to the Acting Commissioner, Immigration and Naturalization Service (INS). We addressed 12 recommendations to INS concerning the travel card delinquencies of INS employees. The INS responded to the recommendations on July 19, 2001. The majority of the INS's responses cite the dissemination of a revised travel card program guide as a solution to the program deficiencies noted in our review. As stated in the report, INS had issued travel card guidance but had not implemented effective procedures for monitoring program implementation. As a result, INS employees were not consistently adhering to the guidance. Issuing a revised guide is an important step to improving program implementation, but deficiencies will continue unless the INS also implements procedures to monitor adherence to the revised program guide requirements. Our analysis of INS's response follows.

Recommendation Number:

  1. Resolved-Closed. The INS concurred with the recommendation to stress to management the importance of reducing travel card delinquencies and misuse. The INS cited actions taken to address the recommendation, such as providing informational sessions on the travel card delinquency problem at various management conferences and developing and disseminating summary reports of delinquent and charged-off accounts to each office manager for action. We are closing this recommendation with the expectation that the INS will continue to provide travel card information to managers and include instructions to managers on the use of the summary reports in INS's revised travel card program guide.

  2. Resolved-Open. The INS concurred with the recommendation to require local travel card coordinators to refer cardholder accounts to supervisors when the account becomes 30 days delinquent and to location managers when the account becomes 60 days delinquent. The INS stated that the local travel card coordinators have already been instructed to take these actions. The INS further stated that it will issue a revised travel card program guide by December 31, 2001, which will include the updated procedures. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  3. Resolved-Open. The INS concurred with the recommendation to require local travel card coordinators to refer instances of travel card misuse in a timely manner to supervisors and location managers. The INS stated that this requirement will appear in their revised travel card program guide. The INS also stated that it will develop reports to assist in the identification of possible misuse. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  4. Resolved-Open. The INS concurred with the recommendation to develop and implement a standard form to be used by supervisors to document the reasons for instances of travel card delinquency or misuse and the actions taken by the supervisor to resolve the problem. The INS stated that the new form, along with the instructions for using the form, will be included in its revised travel card program guide. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  5. Resolved-Open. The INS concurred with the recommendation to require location managers to comply with INS procedures and refer all unresolved delinquencies and instance of serious or frequent misuse to the INS Office of Internal Audit for investigation. The INS stated that the revised travel program guide will emphasize this issue. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  6. Resolved-Open. The INS concurred with the recommendation to establish procedures to require the INS national coordinator to provide management information on unresolved travel card delinquencies and instances of serious or frequent misuse to a senior INS official for review and follow-up. To address the recommendation, the INS stated that it: (1) has developed summary reports to track write-offs and delinquencies by office; (2) will provide special reports to executive associate commissioners describing instances of serious delinquencies and misuse by employees in their chain of command; and (3) will develop special reports to identify potential cardholder misuse. According to INS, the summary and special reports will be developed by September 30, 2001, and information on the reports will be included in the revised travel card program guide. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  7. Resolved-Open. The INS concurred with the recommendation to deny cash advances to those employees who have had their travel cards canceled due to delinquency or misuse. INS stated that a policy memorandum has been drafted, but that implementation of the policy has been deferred pending a meeting with the Border Patrol Union. INS anticipates including the policy in their revised travel card program guide. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  8. Resolved-Closed. The INS partially concurred with the recommendation to consider automating the process by which Bank One is notified of cardholder name and hierarchy address changes. Although the INS agreed that an automated system would be effective, it stated that implementation of such a system would not be feasible under its current financial management system. The INS stated that it will consider automating the process when its financial management system is modernized. In the interim, the INS stated that it will manually review its travel cardholder records to ensure that the information is current and will take all steps possible to ensure that the information is kept current. We believe the INS's actions are responsive to our recommendation and consider the recommendation closed.

  9. Resolved-Open. The INS partially concurred with our recommendation to assess the travel requirements of INS employees and consider restricting access to travel cards. Instead of physically restricting access to travel cards by infrequent travelers, the INS proposes limiting the issuance of travel cards to those who meet the INS's definition of frequent travelers (traveling more than twice a year). Accordingly, the INS stated that it will require all manager and local travel card coordinators to identify and cancel the cards of infrequent travelers. In addition, INS's revised travel card program guide will advise managers of the option of inactivating the travel cards of employees during periods when they are not traveling. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  10. Resolved-Closed. The INS concurred with our recommendation to require all coordinators to receive formal training. The INS stated that all local travel card coordinators will receive training by March 31, 2002, and that annual training will be provided thereafter. We believe the INS's actions are responsive to our recommendation and consider the recommendation closed.

  11. Resolved-Open. The INS concurred with the recommendation to inform all managers and supervisors of their roles in the travel card monitoring process. The INS stated that this topic will be included in its supervisory training courses. The INS also will include a clearer definition of the manager's and supervisor's roles in its revised travel card program guide. We consider the recommendation resolved but will keep it open until we review the INS's revised travel card program guide.

  12. Resolved-Closed. The INS concurred with the recommendation to provide employees with regular briefings on their travel card responsibilities. The INS stated that it will: (1) include a session on travel card responsibilities in its standard orientation training of new employees; (2) work with the INS Ethics Office to expand travel card responsibility training in the employees' ethics course; and (3) continue issuing broadcast messages to all INS employees on travel card responsibilities. We believe the INS's actions are responsive to our recommendation and consider the recommendation closed.


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