1). ICE Formulates Its Budget Request According to DHS Guidance, But Does Not Have a Documented Review Process to Ensure Accuracy of Budget Calculations

		ICE Follows DHS Guidance and Uses Key Variables to Formulate its Budget Request

ICE follows budget formulation guidance from DHS, and uses two key  variables—the bed rate and ADP—when formulating its budget request. 3). 3) and the ADP and bed rate figures  provided in the budget request and compared it with ICE’s requested  amount. Without a  documented review process, ICE is not positioned to demonstrate the  credibility of its budget requests. Although the formula outlined in figure 4 summarizes ICE’s adult bed rate  methodology, ICE’s guidance notes that situations may occur in which it  is advisable to adjust national bed rate projections to account for new  trends or other changes. Although ICE’s bed rate model is based on historical costs, from fiscal  year 2014 through fiscal year 2017 ICE’s adult bed rate projections  underestimated the actual bed rate. 5). For illustrative purposes, underestimating the bed rate by $5 per day,  assuming an ADP of 34,000, yields a more than $62 million  underestimation in the detention budget request. For example, in  the fiscal year 2018 CBJ, ICE did not independently determine the  projected ADP for use as an input into its cost estimate. Officials said the final ADP figure is based on policy  decisions that account for factors that could affect the detainee  population—for example, delays in immigration courts or the number of  asylum officers on staff. While the ADP used in its budget requests may be developed based on  policy decisions, documenting the calculations and rationale by which the  figure was developed would help to demonstrate how the number was  determined and that it was based on sound decisions. ICE Does Not Fully Meet GAO Best Practices For Estimating Detention Costs

ICE’s cost estimate for immigration detention resources does not fully  meet best practices outlined in GAO’s Cost Estimating and Assessment  Guide. As noted in  table 2, ICE’s cost estimate for fiscal year 2018 substantially met the  comprehensive characteristic, partially met the well documented and  accurate characteristics, and minimally met the credible characteristic. However, ICE did not provide  evidence that it analyzes the reasons behind the variances between the  cost estimate and actual numbers for each year, and as mentioned  previously, we identified issues with the inflation rates used to project the  bed rate and the inclusion of family facilities in the adult bed rate. In recent years, ICE has consistently transferred  and reprogrammed millions of dollars of funds to account for budgeting  too little or too much for immigration detention costs. By improving the  budget estimation to better reflect cost estimating best practices, ICE  could ensure a more reliable budget request. Conclusions

As an agency, ICE operates the immigration detention system on a  budget of nearly $3 billion. Developing and implementing a documented review process for its  annual budget request calculations could help ICE better ensure that its  budget requests are consistently credible and reliable. Additionally,  assessing its bed rate model and addressing the identified inaccuracies in  its methodology could help ICE more accurately project the bed rate in  upcoming years. Recommendations for Executive Action

We are making the following five recommendations to ICE:
The Director of ICE should take steps to document and implement its  review process to ensure accuracy in its budget documents. The Director of ICE should take steps to determine the most  appropriate way to project the ADP for use in the congressional  budget justification and document the methodology and rationale  behind its ADP projection. The Director of ICE should take steps to ensure that ICE’s budget  estimating process more fully addresses cost estimating best  practices. To our second recommendation,  DHS stated that ICE has completed multiple third-party assessments of  its bed rate methodology. We are sending copies of this report to the appropriate congressional  committees and the Secretary of the Department of Homeland Security. Appendix I: GAO Analysis of U.S. Immigration and Customs Enforcement’s Fiscal Year 2018 Bed Rate Model

U.S. Immigration and Customs Enforcement (ICE) calculated a bed rate  for fiscal year 2018 using a bed rate model built in Excel with data from its  Federal Financial Management System and Enforcement Information  Database. ICE officials did not provide  documentation of this separate analysis.
Why GAO Did This Study

In fiscal year 2017, ICE operated on a budget of nearly $3 billion to manage the U.S. immigration detention system, which houses foreign nationals whose immigration cases are pending or who have been ordered removed from the country. In recent years, ICE has consistently had to reprogram and transfer millions of dollars into, out of, and within its account used to fund its detention system. The explanatory statement accompanying the DHS Appropriations Act, 2017, includes a provision for GAO to review ICE's methodologies for determining detention resource requirements. This report examines (1) how ICE formulates its budget request for detention resources, (2) how ICE develops bed rates and determines ADP for use in its budget process, and (3) to what extent ICE's methods for estimating detention costs follow best practices. GAO analyzed ICE's budget documents, including CBJs, for fiscal years 2014 to 2018, examined ICE's models for projecting ADP and bed rates, and evaluated ICE's cost estimating process against best practices.

What GAO Found

U.S. Immigration and Customs Enforcement (ICE) formulates its budget request for detention resources based on guidance from the Office of Management and Budget and the Department of Homeland Security (DHS). To project its detention costs, ICE primarily relies on two variables—the average dollar amount to house one adult detainee for one day (bed rate) and the average daily population (ADP) of detainees.
U.S. Immigration and Customs Enforcement's (ICE) Formula to Calculate Detention Costs
GAO found a number of inconsistencies and errors in ICE's calculations for its congressional budget justifications (CBJs). For example, in its fiscal year 2015 budget request, ICE made an error that resulted in an underestimation of $129 million for immigration detention expenses. While ICE officials stated their budget documents undergo multiple reviews to ensure accuracy, ICE was not able to provide documentation of such reviews. Without a documented review process for reviewing the accuracy of its budget request, ICE is not positioned to ensure the credibility of its budget requests.
ICE has models to project the adult bed rate and ADP for purposes of determining its budget requests. However, ICE consistently underestimated the actual bed rate due to inaccuracies in the model, and it is unclear if the ADP used in the budget justification is based on statistical analysis. GAO identified factors in ICE's bed rate model—such as how it accounts for inflation and double counts certain costs—that may lead to its inaccurate bed rate projections. For example, in fiscal year 2016, ICE's projections underestimated the actual bed rate by $5.42 per day. For illustrative purposes, underestimating the bed rate by $5 per day, assuming an ADP of 34,000, yields a more than $62 million underestimation in the detention budget request. By assessing its methodology and addressing identified inaccuracies, ICE could ensure a more accurate estimate of its actual bed rate cost. Additionally, ICE reported that the ADP projections in its CBJs are based on policy decisions that account, for example, for anticipated policies that could affect the number of ICE's detainees. While ICE's projected ADP may account for policy decisions, documenting the methodology and rationale by which it determined the projected ADP would help demonstrate how the number was determined and that it was based on sound assumptions.
ICE's methods for estimating detention costs do not fully meet the four characteristics of a reliable cost estimate, as outlined in GAO's Cost Estimating and Assessment Guide . For example, while ICE's fiscal year 2018 detention cost estimate substantially met the comprehensive characteristic, it partially met the well-documented and accurate characteristics, and minimally met the credible characteristic. By taking steps to fully reflect cost estimating best practices, ICE could better ensure a more reliable budget request.

What GAO Recommends

GAO recommends that the Director of ICE: (1) document and implement its review process to ensure accuracy in its budget documents; (2) assess ICE's adult bed rate methodology; (3) update ICE's adult bed rate methodology; (4) document the methodology and rationale behind the ADP projection used in budget requests; and (5) take steps to ensure that ICE's detention cost estimate more fully addresses best practices. DHS concurred with the recommendations.