Thread: Government Accountability office (GAO) Fraud Waste and Abuse

I did I quick search for Fraud Waste and Abuse with the Government Accountability office (GAO) ... at the site listed below. If you want to see what is going on with your government

For: "FRAUD WAIST AND ABUSE"
Total Hits: 40

http://frwebgate.access.gpo.gov/cgi-bin ... maxHits=40


Immigration Benefits: Additional Controls and a Sanctions
Strategy Could Enhance DHS's Ability to Control Benefit Fraud
(10-MAR-06, GAO-06-259).

In 2002, GAO reported that immigration benefit fraud was
pervasive and significant and the approach to controlling it was
fragmented. Experts believe that individuals ineligible for these
benefits, including terrorists and criminals, could use
fraudulent means to enter or remain in the U.S. You asked that
GAO evaluate U.S. Citizenship and Immigration Service's (USCIS)
anti-fraud efforts. This report addresses the questions: (1) What
do available data and information indicate regarding the nature
and extent of fraud? (2) What actions has USCIS taken to improve
its ability to detect fraud? (3) What actions does the Department
of Homeland Security (DHS) take to sanction those who commit
fraud?
* Results in Brief
* Background
* Fraud Is A Serious Problem, But Its Full Extent Is Unknown
* Although USCIS Has Taken Steps to promote Fraud Control, Add
* Internal Control Standards and Other Guidance Provide Direct
* Consistent with Internal Control Standards and Fraud Control
* Additional Internal Controls and Use of Other Best Practices
* USCIS Has Not Adopted a Comprehensive Risk Management Approa
* USCIS Lacks a Mechanism to Ensure That Ongoing Monitoring Oc
* USCIS May Not Clearly Communicate the Importance of Fraud Co
* Adjudicators and FDNS Staff Lack Access to Important Informa
* DHS Lacks Performance Goals for USCIS's Antifraud Efforts
* Most Benefit Fraud Is Not Criminally Prosecuted, but DHS Doe
* Conclusions
* Recommendations for Executive Action
* Agency Comments and Our Evaluation
* GAO Contact
* Staff Acknowledgements
* GAO's Mission
* Obtaining Copies of GAO Reports and Testimony
* Order by Mail or Phone
* To Report Fraud, Waste, and Abuse in Federal Programs
* Congressional Relations
* Public Affairs

United States Government Accountability Office

Report to Congressional Requesters

GAO

March 2006

IMMIGRATION BENEFITS

Additional Controls and a Sanctions Strategy Could Enhance DHS's Ability to
Control Benefit Fraud

GAO-06-259

IMMIGRATION BENEFITS

Additional Controls and a Sanctions Strategy Could Enhance DHS's Ability
to Control Benefit Fraud

What GAO Found

Although the full extent of benefit fraud is unknown, available evidence
suggests that it is a serious problem. Several high-profile immigration
benefit fraud cases shed light on aspects of its nature-particularly that
it is accomplished by submitting fraudulent documents and can be
facilitated by white collar and other criminals, with the potential for
large profits. USCIS staff denied about 20,000 applications for fraud in
fiscal year 2005.

USCIS has established a focal point for immigration fraud, outlined a
fraud control strategy that relies on the use of automation to detect
fraud, and is performing risk assessments to identify the extent and
nature of fraud for certain benefits. However, USCIS has not implemented
important aspects of internal control standards established by GAO and
fraud control best practices identified by leading audit
organizations-particularly a comprehensive risk management approach, a
mechanism to ensure ongoing monitoring during the course of normal
activities, clear communication regarding how to balance multiple
objectives, mechanisms to help ensure that staff have access to key
information, and performance goals for fraud prevention.

DHS does not have a strategy for sanctioning fraud. Best practices advise
that a credible sanctions program, which includes a mechanism for
evaluating effectiveness, is an integral part of fraud control. Because
most immigration benefit fraud is not prosecuted criminally, the principal
means of sanctioning it would be administrative penalties. Although
immigration law gives DHS the authority to levy administrative penalties,
the component of DHS that administers them does not consider them to be
cost-effective and does not routinely impose them. However, DHS has not
evaluated the costs and benefits of sanctions, including the value of
potential deterrence. Without a credible sanctions program, DHS's efforts
to deter fraud may be less effective, when applicants perceive little
threat of punishment.

Minimizing Immigration Benefit Fraud through Internal Controls

Source: GAO.

United States Government Accountability Office

Contents

Letter 1

Results in Brief 4 Background 8 Fraud Is A Serious Problem, But Its Full
Extent Is Unknown 13 Although USCIS Has Taken Steps to promote Fraud
Control,

Additional Controls and Best Practices Could Improve Its Ability

to Detect Fraud 19 Most Benefit Fraud Is Not Criminally Prosecuted, but
DHS Does

Not Have an Administrative Sanctions Program 35 Conclusions 38
Recommendations for Executive Action 40 Agency Comments and Our Evaluation
41

Appendix I Scope and Methodology

Appendix II Comments from the Department of Homeland Security

Appendix III GAO Contact and Staff Acknowledgments

Figures

Figure 1: USCIS Applications Completed in Fiscal Year 2005 9 Figure 2:
Immigration Benefit Fraud Detection and Referral

Process 12 Figure 3: Internal Control Environment 20

Abbreviations

AICPA American Institute of Certified Public Accountants
BFU Benefit Fraud Unit
CBP Customs and Border Protection
CFR Code of Federal Regulations
CIS Citizenship and Immigration Services
DHS Department of Homeland Security
DOL Department of Labor
FDNS Office of Fraud Detection and National Security
FDU Fraud Detection Unit
ICE Immigration and Customs Enforcement
INA Immigration and Nationality Act
INS Immigration and Naturalization Service
NAO National Audit Office of the United Kingdom
PAS Performance Analysis System
TECS Treasury Enforcement Communication System
USCIS United States Citizenship and Immigration Services

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.

United States Government Accountability Office Washington, DC 20548

March 10, 2006

The Honorable John N. Hostettler Chairman Subcommittee on Immigration,
Border Security, and Claims Committee on the Judiciary House of
Representatives

The Honorable Charles E. Grassley Chairman Committee on Finance United
States Senate

In fiscal year 2005, over 6 million applications were filed by those
seeking an immigration benefit-the ability of an alien to live and in some
cases work in the United States either permanently or on a temporary
basis. Most immigration benefits can be classified into two major
categories- family-based and employment-based. Family-based applications
are filed by U.S. citizens or permanent resident aliens to establish their
relationships to certain alien relatives such as a spouse, parent, or
minor child who wish to immigrate to the United States. Employment-based
applications include applications filed by employers for aliens to come to
the United States temporarily to work or receive training or for alien
workers to work permanently in the United States. Other immigration
benefits include granting citizenship to resident aliens (called
naturalization), offering asylum to aliens who fear persecution in their
home countries, and authorizing international students to study in the
United States.

U.S. Citizenship and Immigration Services (USCIS) within the Department of
Homeland Security (DHS) is the agency primarily responsible for processing
applications for immigration benefits. The former Immigration and
Naturalization Service (INS) previously had this responsibility, which
USCIS assumed when DHS was created in March 2003. USCIS's staff of
adjudicators process immigration benefits in 4 service centers and 33
district offices around the country. In some cases, applicants may try to
obtain a benefit illegally through fraud. 1 USCIS adjudicators who suspect
fraud are to refer suspicious applications and supporting evidence to
USCIS's Office of Fraud Detection and National Security (FDNS), created in
2003. FDNS staff are responsible for reviewing these potential fraud cases
and determining whether to forward them to DHS's Immigration and Customs
Enforcement (ICE)-which, among other things, is responsible for
investigating violations of immigration law, including immigration benefit
fraud. ICE may or may not decide to initiate a criminal investigation,
depending on the facts in the referral and on workloads and priorities of
its field offices.

DHS, terrorism experts, and federal law enforcement officials familiar
with immigration benefit fraud believe that individuals ineligible for
immigration benefits, including terrorists and criminals, could use
fraudulent means to enter or remain in the United States. In 2002, we
reported that immigration benefit fraud was pervasive and significant and
that INS's approach to immigration benefit fraud was fragmented and
unfocused. 2 A 2005 study by a former 9/11 Commission counsel found that
of the 94 foreign-born terrorists known to operate in the United States
between the early 1990s and 2004, 59 or two-thirds committed immigration
fraud including 6 of the September 11th hijackers. 3 To determine what
actions have been taken since our 2002 report to address immigration
benefit fraud, you asked that we evaluate current anti-fraud efforts. This
report addresses the following questions:

(1)
What do available data and information indicate regarding the
nature and extent of immigration benefit fraud?

(2)
What actions has USCIS taken to improve its ability to detect
immigration benefit fraud?

1

Immigration benefit fraud refers to the willful misrepresentation of
material fact to gain an immigration benefit. It is often facilitated by
document fraud (use of forged, counterfeit, altered or falsely made
documents) and identity fraud (fraudulent use of valid documents or
information belonging to others).

2

GAO, Immigration Benefit Fraud: Focused Approach Is Needed to Address
Problems, GAO-02-66 ( Washington, D.C.: Jan. 31, 2002).

3

See also testimony of Janice Kephart, former counsel, The National
Commission on Terrorist Attacks Upon the United States, before the
Subcommittee on Immigration, Border Security, and Citizenship and the
Subcommittee on Terrorism, Technology, and Homeland Security, Senate
Judiciary Committee, Mar. 14, 2005.

(3) What actions does DHS take to sanction those who commit benefit fraud?

To address these questions, we interviewed responsible officials at and
reviewed relevant documentation obtained from DHS and the Departments of
State, Justice, and Labor. Regarding the nature and extent of immigration
benefit fraud, we analyzed USCIS management data contained in its
Performance Analysis System (PAS), results from two fraud assessments
USCIS had completed before December 2005, information reported by DHS and
the U.S. Attorneys Offices based on investigations and prosecutions of
immigration benefit fraud, and information in fraud bulletins prepared by
one USCIS Service Center. We evaluated the methodology used in USCIS's
fraud assessments and determined that it provided a reasonable basis for
projecting the frequency with which fraud was committed within the time
period from which the samples were drawn. We assessed the data derived
from PAS and determined that these data were sufficiently reliable for the
purposes of this review. Because we selected investigations and
prosecutions to review based upon information that was available, the
information obtained from them is not necessarily representative or
exhaustive of all immigration benefits cases nationwide. Similarly,
information contained in the fraud bulletins is not necessarily
representative of immigration benefit fraud nationwide. To determine how
USCIS detects fraud during the adjudications process and to evaluate these
efforts, we interviewed USCIS headquarters officials and USCIS's FDNS
staff. We also interviewed 59 adjudicators at the 4 USCIS Service Centers
and 2 USCIS district offices with responsibility for and familiarity with
adjudicating different types of applications in a group setting, which
allowed us to identify points of consensus among these adjudicators. In
addition we interviewed ICE Office of Investigations officials from four
ICE field offices. As we did not select probability samples of
adjudicators and ICE Office of Investigations staff to interview, the
results of these interviews may not be projected to the views of all USCIS
adjudicators and ICE Office of Investigations field staff nationwide.
Further, we compared the practices in place to the Standards for Internal
Control in the Federal Government 4 and to guidance from internationally
recognized, leading organizations in fraud control, including the American
Institute of Certified Public Accountants and the United Kingdom's
National Audit Office. To determine what measures

GAO, Standards for Internal Control in the Federal Government,
GAO/AMID-00-21.3.1 (Washington, D.C.: November 1999).

Page 3 GAO-06-259 Immigration Benefits

Results in Brief

DHS has taken to sanction those who commit immigration fraud, we
interviewed knowledgeable officials at USCIS and ICE, examined fraud
investigation and prosecution statistics, and analyzed USCIS statistics
about the amount of fraud identified by its adjudicators. We conducted our
work from October 2004 to December 2005 in accordance with generally
accepted government auditing standards. Appendix I presents more details
about our objectives, scope, and methodology.

Our review of several high-profile immigration benefit fraud cases sheds
light on some aspects of the nature of immigration benefit fraud-
particularly that it is accomplished by submitting fraudulent documents,
that it can be facilitated by white collar and other criminals, and that
it has the potential to result in large profits. Although the full extent
of benefit fraud is not known, available evidence suggests that it is an
ongoing and serious problem. Fraudulent documents submitted included but
were not limited to marriage and birth certificates, financial statements,
business plans, organizational charts, fictitious employee resumes, and
college transcripts. White-collar and other criminals can facilitate
immigration benefit fraud. Individuals who pose a threat to national
security and public safety may seek to enter the United States by
fraudulently obtaining immigration benefits. Moreover, those facilitating
immigration benefit fraud, in some cases, have reaped large profits from
aliens willing to pay thousands of dollars to fraudulently obtain an
immigration benefit. In fiscal year 2005, USCIS denied about 20,000
applications due to fraud. In addition, in 2005, USCIS's new fraud
detection office conducted the first two in a series of planned fraud
assessments-reviews of applications for religious worker and replacement
permanent resident card benefits. Based on the results of the completed
religious worker assessment, which estimated that 33 percent of all
religious worker applications were potentially fraudulent, we project that
about 660 applications-one-third of religious worker applications
submitted over a 6-month period in 2004-may have contained fraudulent
information. Some findings of the religious worker assessment and facts
uncovered during criminal investigations and prosecutions demonstrate that
USCIS adjudicators do not always detect fraud during the adjudications
process, thus allowing applicants to receive benefits for which they were
not eligible. Moreover, USCIS's policy of issuing temporary work
authorization within 90 days to those applicants waiting for their
applications for permanent residency to be decided, although intended to
allow bonafide applicants to work as soon as possible, can be exploited by
aliens filing fraudulent applications with the intent of receiving the
temporary work authorization for which they would otherwise be ineligible.
These aliens can then use the temporary work authorization to obtain other
official documents, such as drivers' licenses. Based on an estimate from
the DHS Office of Immigration Statistics that about 85 percent of
applicants who apply for permanent residency also apply for temporary work
authorization, the Citizenship and Immigration Services Ombudsman contends
that many aliens who filed a fraudulent claim for permanent residency may
have received temporary work authorization.

To help it detect immigration benefit fraud, USCIS established FDNS as its
focal point for dealing with immigration benefit fraud, outlined a
strategy for detecting immigration benefit fraud, and is undertaking a
series of risk assessments to identify the extent and nature of fraud for
certain immigration benefits. However, USCIS has not yet implemented some
aspects of internal control standards established by GAO and fraud control
best practices identified by leading audit organizations that could
further enhance its ability to detect fraud. Specifically, USCIS's new
fraud detection office is in the initial stages of implementing a fraud
assessment program, which examines the extent and nature of fraud
associated with the immigration category being assessed. However, this
program, as currently implemented, does not provide a basis for the type
of comprehensive risk analysis we advocate. First, USCIS current
assessment plan does not include risk assessment of the majority of major
immigration benefit categories-for example, temporary work authorization.
Additionally, it focuses primarily on determining the fraud rate for
selected immigration applications and identifying procedural
vulnerabilities, for example, not routinely verifying the existence of
churches associated with religious work applications. It does not draw on
all available sources of strategic threat information to assess threats,
such as ICE's Office of Intelligence, nor does it assess the consequences
of granting a benefit to the wrong person-for example some benefits
facilitate access to critical infrastructure while others do not. More
comprehensive information about vulnerabilities, threats, and consequences
as part of its fraud assessments would allow USCIS to identify those
benefits that represent the highest risk and practice riskbased decision
making in its efforts to balance fraud detection with other organizational
priorities like reducing backlogs and improving customer service. In
addition, USCIS also lacks a mechanism to help ensure that information
gathered during the course of its normal operations and those of related
operations-including criminal investigations and prosecutions-inform
decisions about whether and what actions, including changes to policies,
procedures, or programmatic activities, might improve the ability to
detect fraud. Moreover, adjudicators we interviewed reported that
communication from management did not clearly communicate to them the
importance of fraud control; rather, it emphasized meeting production
goals, designed to reduce the backlog of applications, almost exclusively.
These adjudicators shared, for example, memos from different parts of the
agency, which they told us sent conflicting messages about how they were
to balance, during the course of their duties, fraud-prevention objectives
with service-related objectives. USCIS headquarters operations management
told us that the adjudications operations is a "high-pressure" production
environment and that they are seeking to increase production, but it was
not their intention that this should come at the expense of making
incorrect adjudication decisions. Also, our interviews with adjudicators
indicated that they have limited access to some tools that could support
their fraud detection ability such as external databases for verifying
applicant information. Interviews with USCIS staff also indicated that
adjudicators may not always receive relevant information that could
support their efforts to detect fraud, and although some information is
provided, it is not always provided in a form that adjudicators can
reasonably manage as, for example, in an electronic database. Finally,
USCIS has not established performance goals- measures and targets-to
assess its benefit fraud activities.

DHS does not have a strategy for sanctioning fraud or for evaluating the
effectiveness of sanctions. Best practice guidance issued by the United
Kingdom's National Audit Office, for example, suggests that a strategy for
sanctioning fraud, along with a mechanism for evaluating the effectiveness
of sanctions is central to a good fraud control environment. Data provided
by USCIS indicates that in fiscal year 2005 most immigration fraud
detected by USCIS did not result in ICE criminal investigations and
subsequent prosecutions. Since most fraud is not criminally prosecuted,
the principal means of sanctioning it would be administrative penalties.
The Immigration and Nationality Act does provide the authority to levy
administrative penalties; however, DHS does not currently use this
authority. This is largely because a 1998 federal court ruling enjoined
INS from implementing certain administrative penalties for document fraud
until it revised certain forms to provide adequate notice to aliens of the
immigration consequences of waiving the opportunity to challenge document
fraud fines. Although DHS has not conducted a formal costbenefit analysis,
according to ICE officials responsible for pursuing administrative
penalties, these penalties are not cost-effective because the fines are
less than the costs to impose them when a hearing is requested.
Accordingly, DHS has not made updating the forms to allow sanctions to be
administered in compliance with the court ruling a priority. Nevertheless,
according to USCIS officials, an effective administrative sanctions
program is important to its fraud deterrence efforts. The lack of a clear
strategy for how and when to punish fraud perpetrators, which considers
the nonfinancial benefit of deterrence and includes a mechanism for
evaluating effectiveness, limits DHS's ability to project a convincing
message that those who commit fraud face a credible threat of punishment
in one form or another.

In order to enhance USCIS's ability to detect immigration benefit fraud,
we are recommending that the Secretary of Homeland Security direct the
Director of USCIS to adopt additional internal controls and best practices
to strengthen USCIS's fraud control environment, particularly by (1)
expanding the scope of its current fraud assessment program and using a
more comprehensive risk management approach; (2) establishing a mechanism
to ensure that information uncovered during USCIS's and related agencies'
normal operations feeds back into evaluations of USCIS's policies,
procedures, and operations; (3) clearly communicating to adjudications
staff the importance of both fraud prevention-related and service-related
objectives, and how these objectives are to be balanced by adjudicators as
they carry out their duties; (4) providing USCIS staff with access to
information and tools from relevant internal and external sources; and (5)
establishing outcome and output based performance goals that reflect the
status of fraud control efforts. In addition, in order to enhance DHS's
ability to sanction immigration benefit fraud, we recommend that the
Secretary of Homeland Security direct the Director of USCIS and the
Assistant Secretary of ICE to develop a strategy for sanctioning
immigration benefit fraud that takes into account the value of deterrence
and establishes a mechanism for evaluating effectiveness.

We presented a draft of this report to DHS and the Departments of State,
Justice, and Labor. State, Justice, and Labor had no comments on our
report. DHS stated that our report generally provided a good overview of
the complexities associated with pursing immigration benefit fraud and the
need to have a program in place that proactively assesses vulnerabilities
within the myriad of immigration processes. However, DHS stated that our
report did not fully portray USCIS's efforts to address immigration
benefit fraud and provided other examples of efforts USCIS has undertaken
or plans to undertake. Where appropriate, we revised the draft report to
recognize these additional efforts by USCIS. DHS generally agreed with and
plans to take action to implement four of our six recommendations and
cited actions it has already taken to address our other two
recommendations. DHS agreed on the need to expand its fraud assessment
program, provide USCIS staff access to information from internal and
external sources, and establish outcome and output performance based
goals. DHS agreed that goals were needed but did not

Background

specify what action(s) it was planning to take. DHS agreed to study the
costs and benefits of an administrative sanctions program. DHS stated that
a mechanism to ensure that information uncovered during USCIS's and
related agencies normal operations feeds back into evaluations of USCIS's
policies, procedures, and operations already exists. DHS cited examples of
how FDNS shares information with other agencies, participates in
interagency anti-fraud effort efforts, and has recommended changes to how
USCIS adjudicates religious worker applications as evidence that such
feedback takes place. Although these are all positive efforts, USCIS does
not yet have policies and procedures that specify how information about
fraud vulnerabilities uncovered during the course of normal operations- by
USCIS and related agencies-is to be gathered-from which internal and
external sources-and the process for evaluating this information and
making decisions about appropriate corrective actions. Therefore, we
continue to believe that USCIS needs to institutionalize through policies
and procedures a feedback mechanism. With respect to communicating clearly
the importance of USCIS's fraud prevention objectives, DHS stated that
USCIS leadership clearly advocates balancing objectives related to timely
and quality processing of immigration benefits, and cited the creation of
FDNS as evidence that USCIS senior leadership believes national security
and fraud detection are a high priority. However, our interviews with
adjudicators indicate that this message may not be reaching USCIS
adjudications staff. DHS disagreed with our recommendation that USCIS and
ICE establish a mechanism for the sharing of information related to the
status and outcomes of USCIS fraud referrals to ICE. DHS provided us a
February 2006 memorandum of agreement between ICE and USCIS that
establishes a mechanism for the sharing of information related to the
status and outcomes of fraud referrals; therefore, we withdrew this
recommendation.

USCIS is responsible for processing millions of immigration benefit
applications received each year for various types of immigration benefits,
determining whether applicants are eligible to receive immigration
benefits, and detecting suspicious information and evidence to refer for
fraud investigation and possible sanctioning by other components or
agencies. USCIS processes applications for about 50 types of immigration
benefits. In fiscal year 2005, USCIS received about 6.3 million
applications and adjudicated about 7.5 million applications. Figure 1
shows the percentage of applications completed by type of application in
fiscal year 2005.

Figure 1: USCIS Applications Completed in Fiscal Year 2005

Employment authorization

Nonimmigrant worker

Travel document

Naturalization

Permanent resident

Spouse & family

Replacement/renewal of permanent resident card

Other application types

Source: GAO analysis of USCIS Performance AnalysisSystem (PAS) data.

To process these immigration benefit applications, in fiscal year 2005
USCIS had a staff of about 3,000 permanent adjudicators located in 4
service centers, where most applications are processed, and 33 district
offices. 5 In fiscal year 2004, for example, service centers adjudicated
about 67 percent of all applications, and districts about 33 percent. In
general, service centers adjudicate applications that do not require an
interview with the applicant, using the evidence submitted with the
applications. District offices generally adjudicate applications where
USCIS requires an interview with the applicant (e.g., naturalization).
USCIS also has eight offices that process applications for asylum in the
United States. In fiscal year 2005, USCIS's budget amounted to just under
$1.8 billion, of which about $1.6 billion was expected from service fees
and $160 million from congressionally appropriated funds.

USCIS also employed an additional 1,475 adjudicators on a temporary basis
to support its backlog reductions efforts.

Page 9 GAO-06-259 Immigration Benefits

In fiscal year 2004, USCIS had a backlog of several million applications
and has developed a plan to eliminate it by the end of fiscal year 2006. 6
In June 2004, USCIS reported that it would have to increase production by
about 20 percent to achieve its goal of adjudicating all applications
within 6 months or less by the end of fiscal year 2005. At that time, it
estimated that it would have to increase current annual processing from
about 6 million to 7.2 million applications. Since USCIS did not plan for
further increases in staffing levels, reaching its backlog goal would
require some reduction in average application processing times, overtime
hours, and adjudicator reassignments.

With the creation of DHS in 2003, the immigration services and enforcement
functions of the former INS transitioned to different organizations within
DHS. USCIS assumed the immigration benefit functions and ICE assumed INS's
investigative and detention and removal of aliens functions. Within ICE's
Office of Investigations, the Identity and Benefit Fraud unit now conducts
immigration benefit fraud criminal investigations and ICE's Office of
Detention and Removal Operations is responsible for identifying and
removing aliens illegally in the United States.

Because the immigration service and enforcement functions are now handled
by separate DHS components, these components created two new units to,
among other things, help coordinate the referral of suspected immigration
benefit fraud uncovered by adjudicators to ICE's Office of Investigations.
First, USCIS created FDNS in 2003 to, among other things, receive fraud
leads from adjudicators and determine which leads should be referred to
ICE's Office of Investigations. To accomplish this task, FDNS has Fraud
Detection Units (FDU) at all four USCIS service centers and the National
Benefits Center. 7 When fraud is suspected, the applications are to be
referred FDUs. The FDUs, comprised of Intelligence Research Specialists
and assistants, are responsible for further developing suspected
immigration fraud referrals to decide which leads should be referred to
ICE for possible investigation. FDU staff are also to refer to

6

See GAO, Immigration Benefits: Improvements Needed to Address Backlogs and
Ensure Quality of Adjudications, GAO-06-20 (Washington D.C.: November
2005).

7

The National Benefits Center serves as a hub for applications adjudicated
at USCIS field offices. Among other things, the center performs initial
evidence review and conducts background checks before sending the file to
the appropriate district office for adjudication.

Page 10 GAO-06-259 Immigration Benefits

ICE or other federal agencies applicants who may pose a threat to national
security or public safety or who are potentially deportable. FDUs are
responsible for following up on potential national security risks
identified during background checks of immigration benefit applicants.
FDUs also perform intelligence analysis to identify immigration fraud
patterns and major fraud schemes. In addition to establishing FDUs, in
January 2005 FDNS assigned 100 new Immigration Officers to USCIS district
offices, service centers, and asylum offices to work directly with
adjudicators to handle fraud referrals and conduct limited field
inquiries. Second, ICE's Office of Investigations created four new Benefit
Fraud Units (BFU) in Vermont, Texas, Nebraska, and California located
either at or near the four USCIS service centers. The ICE BFUs are
responsible for reviewing, assessing, developing, and when appropriate,
referring to ICE field offices for possible investigation immigration
fraud leads and other public safety leads received from the FDUs and
elsewhere. Specifically, the ICE BFUs are intended to identify those
referrals that they believe warrant investigation, such as organizations
and facilitators engaged in large-scale schemes or individuals who pose a
threat to national security or public safety, and refer them to ICE field
offices. In turn, ICE field offices will investigate and refer those cases
they believe warrant prosecution to the

U.S. Attorneys Offices. Figure 2 illustrates the typical immigration
benefit fraud referral and coordination process.

Figure 2: Immigration Benefit Fraud Detection and Referral Process

Immigration Benefit Fraud Detection & Referral Process

DHS DOJ

Accepts fraud referralsbased on individual SAC prioritiesand overall ICE
goals

Performs field investigation and enforcement action

Source: USCIS.

The Homeland Security Act of 2002 created the office of the Citizenship
and Immigration Services Ombudsman. The ombudsman's primary function is
to: assist individuals and employers in resolving problems with USCIS;
identify areas in which individuals and employers have problems in dealing
with USCIS; and propose changes in the administrative practices of USCIS
in an effort to mitigate problems. The ombudsman has issued two annual
reports that have highlighted issues related to prolonged processing
times, limited case status information, immigration benefit fraud,
insufficient standardization in processing, and inadequate information
technology and facilities.

Other federal agencies also play important roles in the immigration
benefit application process. The Department of State is responsible for
approving

Fraud Is A Serious Problem, But Its Full Extent Is Unknown

and issuing a visa allowing an alien to travel to the United States. The
Department of Labor's (DOL) Division of Foreign Labor Certification
provides national leadership and policy guidance to carry out the
responsibilities of the Secretary of Labor under the Immigration and
Nationality Act (INA) concerning foreign workers seeking admission to the
United States for employment. DOL provides certifications for foreign
workers to work in the United States, on a permanent or temporary basis,
when there are insufficient qualified U.S. workers available to perform
the work at wages that meet or exceed the prevailing wage for the
occupation in the area of intended employment. The DOL Office of the
Inspector General's Office of Labor Racketeering and Fraud Investigations
is responsible for investigating fraud related to these labor
certifications.

Fraudulent schemes used in several high-profile immigration benefit fraud
cases sheds light on some aspects of the nature of immigration benefit
fraud-particularly that it is accomplished by submitting fraudulent
documents, that it can be committed by organized white-collar and other
criminals, and that it has the potential to result in large profits for
these criminals. The benefit fraud cases we reviewed involved individuals
attempting to obtain benefits for which they were not eligible by
submitting fraudulent documents or making false claims as evidence to
support their applications. Fraudulent documents submitted included but
were not limited to birth and marriage certificates, tax returns,
financial statements, business plans, organizational charts, fictitious
employee resumes, and college transcripts. For example, in what ICE
characterized as one of the largest marriage fraud investigations ever
undertaken, 44 individuals were indicted in November 2005 for their
alleged role in an elaborate scheme to obtain fraudulent immigrant visas
for hundreds of Chinese and Vietnamese nationals. According to a USCIS
fraud bulletin, this scheme may have been ongoing for 10 years. Another
major investigation revealed evidence that an attorney had filed about 350
applications on behalf of aliens seeking permanent employment as religious
workers at religious institutions in the United States. Investigators
found evidence that most of these aliens were unskilled laborers who were
not pastors or other religious workers and had little or no previous
affiliation with the religious institution. According to this
investigation, some religious institutions appeared to specialize in
obtaining legal status for aliens in the country who were not eligible for
religious worker immigration benefits. In another investigation involving
at least 2,800 apparently fraudulent marriage and fiancee applications
identified in 2002 and investigated through 2004, a U.S. citizen appeared
to have submitted multiple applications with as many as 11 different
spouses.

One USCIS Service Center prepared fraud bulletins using information from
various State Department Consular posts overseas describing immigration
fraud uncovered by these posts. Our analysis of the bulletins issued from
July 2004 through December 2004 prepared by USCIS's California Service
Center revealed that aliens from 23 different countries were believed to
have sought a variety of immigration benefits fraudulently. For example,
individuals apparently sought to enter the United States through fraud by
falsely claiming they were: (1) legitimately married to or a fiance of a
U.S. citizen; (2) a religious worker; (3) a performer in an entertainment
group;

(4)
a person with extraordinary abilities, such as an artist, race car
driver, or award winning photographer; (5) an executive with a
foreign company;

(6)
a child or other relative of a citizen or permanent resident; or
(7) a domestic employee of an alien legally in the United States,
such as a diplomat or business executive. According to one of the
bulletins, in one case State Department consular officers
suspected illegal aliens were entering the United States under the
guise of membership in a band. According to another bulletin, two
individuals were suspected of smuggling children into the United
States. In this case, the alleged parents submitted a
non-immigrant visa application for their "daughter," and provided
a fraudulent birth certificate and passport for her. The "parents"
eventually admitted to taking children to the United States as
their own to reunite them with their illegally working family
members.

Some individuals seeking immigration benefits pose a threat to national
security and public safety, and white collar and other criminals sometimes
facilitate immigration benefit fraud. For example, according to FDNS, each
year about 5,200 immigration benefit applicants are identified as
potential national security risks, because their personal information
matches information contained in U.S. Customs and Border Protection's
Interagency Border Inspection System, a database of immigration law
violators and people of national security interest. Additionally,
according to federal prosecutors, immigration benefit fraud may involve
other criminal activity, such as income tax evasion, money laundering,
production of fraudulent documents, and conspiracy. Also, organized crime
groups have used sophisticated immigration fraud schemes, such as creating
shell companies, to bring in aliens ostensibly as employees of these
companies. In addition, a number of individuals linked to a hostile
foreign power's intelligence service were found to have been employed as
temporary alien workers on military research.

Investigations have revealed that perpetrating fraud on behalf of aliens
can be a profitable enterprise. For instance, in 2003 and 2004, one USCIS
service center identified about 2,800 apparently fraudulent marriage
applications between low-income U.S. citizens and foreign nationals from
an Asian country. The U.S. citizens appeared to have been paid between
$5,000 and $10,000 for participating in the marriage fraud scheme. In
another example from an investigation by DOL's Inspector General, to
fraudulently obtain the labor certifications needed to work in the United
States, at least 900 aliens allegedly paid a recruitment firm an average
of $35,000, with some aliens paying as much as $90,000, resulting in at
least $31 million in revenue for this firm. In one of the largest labor
certification fraud schemes ever uncovered, federal investigators found
evidence that a prominent immigration attorney in the Washington, D.C.,
area submitted at least 1,436 and perhaps as many as 2,700 fraudulent
employment applications between 1998 and 2002. According to the sworn
testimony of a DOL special agent, this attorney and his associates are
alleged to have made at least $11.4 million for the 1,400 applications
that the agent reviewed, in all of which he found evidence of fraud, and
perhaps as much as $21.6 million if all 2,700 applications were
fraudulent, as he strongly suspected. In another case, an attorney
allegedly charged aliens between $8,000 and $30,000 to fraudulently obtain
employment-based visas to work in more than 200 businesses that included
pizza parlors, auto parts stores, and medical clinics.

Although the full extent of immigration benefit fraud is unknown,
available USCIS data indicate that it is a serious problem. According to
USCIS PAS data, in fiscal year 2005, USCIS denied just over 20,000
applications because USCIS staff detected fraudulent application
information or supporting evidence during the course of adjudicating the
benefit request. Three application categories accounted for more than
three-quarters of the fraud denials: temporary work authorization (36
percent), application for permanent residency (30 percent), and
application for a spouse to immigrate (14 percent). These three
application types also accounted for almost half of all applications
adjudicated by USCIS in fiscal year 2005. Moreover, in fiscal year 2005,
USCIS denied approximately 800,000 applications for other reasons, such as
ineligibility for the benefit sought or failure to respond to information
requests. USCIS adjudications staff and officials told us that it is
likely that some of these applications denied for other reasons also
involved fraud.

Information provided by State Department and DOL officials also indicates
that fraud is a serious problem. Once USCIS approves a sponsor's
application on behalf of an alien to immigrate, the application is sent to
the State Department's National Visa Center, which forwards the
application to the appropriate State Department overseas consulate post,
which then interviews the alien to determine whether a visa should be
issued. According to National Visa Center officials, out of 2,400
applications returned on average each month to USCIS by the National Visa
Center, that are denied or withdrawn for various reasons, about 900
involve fraud or suspected fraud as determined by consular officers
overseas. When the DOL Inspector General audited labor certification
applications filed in 2001, it also found indications of a significant
amount of fraud. According to the Inspector General, of the approximate
214,000 applications filed from January 1, 2001, through April 30, 2001,
and not subsequently cancelled or withdrawn, 54 percent (about 130,000)
contained false-possibly fraudulent-information. 8

In June 2005, the FDNS completed the first in a series of fraud
assessments. The results from this assessment of religious worker
applications indicate that about 33 percent of the 220 sampled
applications resulted in a preliminary finding of potential fraud. 9 Based
on a 33 percent rate, we estimate that, during the 6-month period of
fiscal year 2004 from which the sample was drawn, about 660 out of
approximately 2,000 applications may have been fraudulent. 10 Of the 72
potential fraud cases discovered in the fraud assessment, about 54-percent
(39 cases) showed evidence of tampering or fabrication of supporting
documents; 44-percent (32 cases) of the petitioners' addresses did not
reveal a bona fide religious institution; about 42-percent (30 cases) may
have misrepresented the beneficiaries' qualifications; and 28-percent (20
cases) did not provide the salary noted in the application. The assessment
also uncovered one case where law enforcement had identified an applicant
as a suspected terrorist.

Information from other investigations and prosecutions of benefit fraud
also reveal that, in some cases, applicants may have submitted fraudulent

8

DOL Inspector General, Restoring Section 245(i) of the Immigration
Nationality Act Created a Flood of Poor Quality Foreign Labor
Certification Applications Predominantly for Aliens Without Legal Work
Status, Report No: 6-04-004-03-321 (Washington, D.C. : Sept. 30, 2004).

9

USCIS reviewed applications submitted on behalf of religious workers-such
as ministers, or other individuals who work in a professional capacity in
a religious vocation or occupation-seeking an immigrant visa in order to
work in the United States. FDNS chose this application because based upon
past experience FDNS believed there was a high prevalence of fraud.
According to FDNS, most of the fraud involved religious institutions that
were not affiliated with a major religious organization.

10

However, with a sampling margin of error of 5 percent, the fraud rate
could be between 28 percent and 38 percent.

documents and made false statements that were not detected before the
applicant obtained an immigration benefit. For example, while
investigating one fraud scheme, investigators identified more than 2,000
apparently fraudulent applications where there was evidence that some
aliens, fraudulently claiming to be managers and executives of foreign
companies with U.S. affiliates, acquired benefits that granted them the
ability to work in the United States. To execute this scheme, organizers
allegedly prepared application packages that included fraudulent business
and employee related documents including financial statements, business
plans, organizational charts, and fictitious employee resumes.

One joint law enforcement investigation, previously mentioned, uncovered
evidence that an attorney and his associate had filed at least 1,436
applications on behalf of legitimate companies-mostly local
restaurants-that did not actually request these workers. In this case
there was evidence that they forged the signatures of company management
on the applications. Another investigation involving marriage fraud found
evidence that U.S. citizens were recruited and paid to marry Vietnamese
nationals. The fraud organizers appeared to have assisted the U.S.
citizens in obtaining their passports, scheduled travel arrangements, and
escorted them to Vietnam where they arranged introductions with Vietnamese
nationals whom the citizens then married. These citizens then filed
applications that facilitated these Vietnamese nationals' entry into the
United States as spouses even though it appeared that they did not intend
to live together as husband and wife.

Even when adjudicators rejected applications based on fraud, some of these
applicants had already received interim benefits while their applications
were pending final adjudication allowing them to live and work in the
United States, and in some cases obtain other official documents, such as
a driver's license. Under current USCIS policy, for example, if USCIS
cannot adjudicate an application for permanent residency and the
accompanying application for work authorization within 90 days, the
applicant is entitled to an interim work authorization, an interim benefit
designed to let applicants work while awaiting a decision regarding
permanent residency. 11 According to the Citizenship and Immigration
Services Ombudsman's fiscal year 2004 and 2005 annual

8 C.F.R. S: 274a.13(d). 8 CFR S: 274a.12(c) states that USCIS has the
discretion to establish a specific validity period for an employment
authorization document, and 8 C.F.R. S: 274a.13(d) provides that such
period shall not exceed 240 days in the case of an interim authorization.

Page 17 GAO-06-259 Immigration Benefits

reports and our discussion with him, for many individuals the primary goal
is to obtain temporary work authorization regardless of the validity of
their application for permanent residency. That is, aliens can apply for
temporary work authorization, knowing that they do not qualify for
permanent residency, with the intent of exploiting the system to gain work
authorization under false pretenses.

Once a temporary work authorization is fraudulently obtained, an alien can
use it to obtain other valid identity documents such as a temporary social
security card and a driver's license, thus facilitating their living and
working in the United States. According to the FDNS Director, once such
fraud scheme involved at least 2,500 individuals in Florida who allegedly
filed frivolous applications for employment authorization and then used
the receipt, showing they had filed an application, to obtain Florida
State driver's licenses or identification cards. 12 ICE agents we
interviewed also said that they suspected that many individuals apply for
permanent residency fraudulently simply to obtain a valid temporary work
authorization document. The interim benefit remains valid until it expires
or until it is revoked by USCIS.

In his 2005 report, the Ombudsman cites a DHS Office of Immigration
Statistics estimate-which the ombudsman's office confirmed with USCIS's
division of performance management-that about 85 percent of applicants for
permanent residency also apply for temporary work authorization. As a
result, according to the ombudsman, many aliens have received temporary
work authorizations, for which they were later found to be ineligible. Our
analysis of PAS data shows, for example, that from fiscal year 2000
through 2004, USCIS denied 26,745 applications due to fraud out of the
approximately 3 million applications received for permanent residency.
These data illustrate that, if aliens that filed fraudulent applications
for permanent residency also requested temporary work authorization at a
rate consistent with the 85 percent cited by the Office of Immigration
Statistics, then thousands of aliens received temporary work authorization
based on their fraudulent claims for permanent residency during fiscal
year 2000 through 2004.

USCIS subsequently informed Florida's Department of Highway Safety and
Motor Vehicles, and the American Association of Motor Vehicles
Administration issued a national advisory notifying other state motor
vehicle departments that they should not accept the application receipt as
evidence of lawful immigration status.

Page 18 GAO-06-259 Immigration Benefits

Although USCIS Has Taken Steps to promote Fraud Control, Additional Controls
and Best Practices Could Improve Its Ability to Detect Fraud

To help it detect immigration benefit fraud, USCIS has taken some
important actions consistent with activities prescribed by the Standards
for Internal Control in the Federal Government and with recognized best
practices in fraud control. Specifically, it has established an internal
unit to act as its focal point for addressing immigration benefit fraud,
outlined a strategy for detecting immigration benefit fraud, and is
undertaking a series of fraud assessments to identify the extent and
nature of fraud for certain immigration benefits. However, USCIS has not
applied some aspects of internal control standards and fraud control best
practices that could further enhance its ability to detect fraud.

Internal Control Standards and Other Guidance Provide Direction for
Establishing Good Fraud Control Practices

The Standards for Internal Control in the Federal Government provide an
overall framework to identify and address, among other things fraud,
waste, abuse, and mismanagement. Implementing good internal control
activities and establishing a positive control environment is central to
an agency's efforts to detect and deter immigration benefit fraud. The
standards address various aspects of internal control that should be
continuous, built-in components of organizational operations, including
the control environment, risk assessment, control activities, information
and communications, and monitoring.

As with work we have previously published related to managing improper
payments, fraud control would typically require a continual interaction
among these components in keeping with an agency's various objectives. 13
For example, internal controls that promote ongoing monitoring work
together with risk assessment controls to provide a foundation for
decision making. Also, as internal control standards advise, a
precondition to risk assessment is the establishment of clear, consistent
agency objectives. Once established, risk assessment controls must also
work together with information and communication controls to ensure that
that every level of the agency is cognizant of the commitment and approach
to both controlling fraud and meeting other agency objectives. Similarly,
conditions governing risk change frequently, and periodic updates are
required to ensure that risk information-including threats,
vulnerabilities, and consequences-stays current and relevant. Information
collected

13

GAO, Strategies to Manage Improper Payments, Learning from Private Sector
Organizations, GAO-02-69G ( Washington, D.C.: October 2001).

Page 19 GAO-06-259 Immigration Benefits

through periodic assessment, as well as daily operations can inform the
assessment, and particularly, the analysis of risk. As shown in figure 3,
the control environment surrounds and reinforces the other components, but
all components work in concert toward a central objective, which, in this
case, is to minimize immigration benefit fraud.

Figure3: Internal Control Environment

Source: GAO.

Other audit organizations have published guidance that includes discussion
of sound management practices for controlling fraud that complement the
internal control standards. Among these are the American Institute of
Certified Public Accountants (AICPA) guidance on management of antifraud
programs and controls to help prevent and deter fraud 14 and a fraud
control practices guide developed by the United Kingdom's National Audit
Office (NAO) entitled "Good Practices in Tackling External Fraud." The NAO
guidance outlines a risk-based

Excerpt from Statement on Auditing Standards, No. 99, Considerations of
Fraud in a Financial Statement Audit.

Page 20 GAO-06-259 Immigration Benefits

Consistent with Internal Control Standards and Fraud Control Best Practices,
USCIS Has Established a Fraud Focal Point, Related Strategies, and a Fraud
Assessment Program

strategic approach to combating fraud that also includes evaluating the
effectiveness of sanctions.

According to internal control standards, factors leading to a positive
control environment include clearly defining key areas of authority and
responsibility, establishing appropriate lines of reporting, and
appropriately delegating authority and responsibility for operating
activities. Similarly, the NAO fraud control guidance advises agencies to
develop specific strategies to coordinate their fraud control efforts and
to ensure that someone is fully responsible for implementing the plans in
the way intended and that sufficient resources are in place. Consistent
with internal control and best practice guidance, USCIS established the
FDNS office to enhance its fraud control efforts by serving as its focal
point for addressing immigration benefit fraud.

Established in 2003, FDNS is intended to combat fraud and foster a
positive control environment by pursuing the following objectives:

* develop, coordinate, and lead the national antifraud operations for
USCIS;
* o oversee and enhance policies and procedures pertaining to the
enforcement of law enforcement background checks on those applying
for immigration benefits;
o identify and evaluate vulnerabilities in the various policies,
practices and procedures that threaten the legal immigration process;
o recommend solutions and internal controls to address these
vulnerabilities; and
o act as the primary USCIS conduit and liaison with ICE, U.S. Customs
and Border Protection (CBP), and other members of the law enforcement
and intelligence community.

In September 2003, in support of its objectives, FDNS outlined a strategy
for detecting immigration benefit fraud in USCIS's National Benefit Fraud
Strategy. According to the strategy, because most immigration benefit
fraud begins with the filing of an application, a sound approach to fraud
prevention begins at the earliest point in the process-the time an
application is received. Accordingly, USCIS established FDNS Fraud
Detection Units (FDU) in each of the service centers in order to help
identify potential fraud and process adjudicator referrals. Subsequently,
FDNS appointed staff to serve as Immigration Officers working directly
with adjudicators at the service centers and district offices to identify
potential fraud and, to some extent, verify fraud through administrative
inquiries-once it was determined that ICE had declined to investigate a
referral-in order to assist adjudicators in making eligibility
determinations.

The strategy also discusses various technological tools to help the FDUs
detect fraud early in the process-in particular, by enabling FDNS staff to
check databases to confirm applicant information and by developing new
automated tools to analyze application system data using known fraud
indicators and patterns to help identify potential cases of fraud. USCIS
has hired a contractor to develop for FDNS an automated capability to
screen incoming applications against known fraud indicators, such as
multiple applications received from the same person. According to FDNS, it
plans to deploy an initial data analysis capability by the third quarter
of fiscal year 2006 and release additional data analyses capabilities at
later dates, but could not predict when these latter capabilities would be
achieved. However, according to an FDNS operations manager, the near and
midterm plans are not aimed at providing a full data mining capability. In
the long term, USCIS plans to integrate these data analyses tools for
fraud detection into a new application management system being developed
as part of USCIS's efforts to transform its business processes for
adjudicating immigration benefits, which includes developing the
information technology needed to support these business processes. Also,
in the long term, according to the FDNS Director, a new USCIS application
management system would ideally include fraud filters to screen
applications and remove suspicious applications from the processing stream
before they are seen by adjudicators.

FDNS has adopted as one of its objectives the identification and
evaluation of vulnerabilities in USCIS policies, practices, and procedures
that threaten the immigration benefit process. Consistent with this
objective and good internal control practices, in February 2005, FDNS
began to conduct a series of fraud assessments aimed at determining the
extent and nature (i.e., how it is committed) of fraud for several
immigration benefits that FDNS staff determined, based on past studies and
experience, benefit fraud may be a problem. To conduct these assessments,
FDNS first selected a statistically valid sample of applications. 15 FDNS
field staff then attempted to verify whether key

For each of assessment, USCIS plans to review a sample of applications
designed to achieve a 95 percent confidence interval. Reviews will be
conducted by Immigration Officers in district offices.

Page 22 GAO-06-259 Immigration Benefits

Additional Internal Controls and Use of Other Best Practices Could Further
Improve USCIS's Ability to Detect Benefit Fraud

USCIS Has Not Adopted a Comprehensive Risk Management Approach to Help
Guide Its Fraud Control Efforts

information on the applications was true. They did this by doing such
things as comparing information contained in benefit applications with
information in USCIS data systems and law enforcement and commercial
databases, conducting interviews with applicants, and, in some cases,
visiting locations to verify, for example, whether a business actually
existed. As of December 2005, FDNS had completed its assessment of the
religious worker application and replacement of permanent resident card
applications, and was in the process of completing the assessment of two
immigrant worker application subcategories. 16 As of December 2005, FDNS
planned to initiate two other assessments in January 2006 and another at a
later time. 17

Although USCIS has taken some important steps consistent with internal
control standards and other good fraud control practices, it has not yet
implemented some aspects of internal control standards and fraud control
best practices that could further enhance its ability to detect fraud.
Specifically, it lacks (1) a comprehensive approach for managing risk, (2)
a monitoring mechanism to ensure that knowledge arising from routine
operations informs the assessment of policies and procedures, (3) clear
communication regarding how to balance multiple agency objectives, (4) a
mechanism to help ensure that adjudicators staff have access to important
information, and (5) performance goals related to fraud prevention.

Although FD

What burns me up is the they are policeing themselve same as our goverment nothing ever gets solved that way when they have the ability to sweep it under the rug

At this point it all falls up hill to capotal hill and thats got us back to where we started Fraud Waste and Abuse!!!

I wasn't able to read and understand this whole thing, However I did keep seeing the phrase "Amount unknown"

Here is something that if we use their figures of $7000 per student we get a total of 455,000 (The article says 4 million)

Also there has to be some bribery somewhere for our border patrol officers to not see 650 children a day crossing the border in the same place 5 days a week.

This one really burns me, Who is accountable?

http://www.congress.org/congressorg/bio ... 1430097256