Virginia, US
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| Simon Haag

Holes in the Fence

In December 2015 the Auditor-General presented his findings regarding the Department of Immigration and Border Protection’s management of compliance with visa conditions. The report identifies grave lacunae in department processes and procedures relating to the use and management of information, and the conduct of investigations.
The audit found that compliance operations were ineffective in all four key areas of management of risk and intelligence; appropriately-targeted compliance activities; administrative arrangements including record-keeping; and engagement with stakeholders, clients and the community.
The review of compliance investigation teams revealed that field operations are not well managed, with weaknesses including insufficient rationalisation and documentation as to why an operation is conducted; and deficient quality assurance and performance indicators. In a majority of cases there was no rationale recorded as to why a compliance field activity was undertaken and the prioritisation of risk was not defined nor linked to the Department’s broader risk management framework. The Auditor-General also found that field jobs were not conducted in a timely manner, with 46% of cases on hand having been open for over 12 months.
Disturbingly, the audit found that significant problems have been repeatedly recognised over many years, but not addressed, in relation to governance arrangements and management oversight of data and information retained on Departmental systems. The report states that:
[w]eaknesses in the Department’s key management and administrative arrangements have been identified over many years….and include: a lack of an effective governance planning and decision-making framework; inadequate data governance, including issues with the integrity of data; the complexity surrounding policy and procedural guidelines, leading to case officers developing their own checklists; poor learning and development capability; [and] ad hoc and incomplete measures to assess the quality and consistency of decisions.
On a positive note, the Auditor-General identified significant progress in providing stakeholders access to information that encourages voluntary compliance and self-management. Particularly notable has been the strong response by employers to the Department’s online Visa Entitlement Verification Online system (VEVO) , with a doubling of the number of organisations using VEVO between 2012 and 2015 and an 80% increase in the volume of VEVO checks made over that period. The increased interest in online services is consistent with reforms Fragomen has been advocating for enhanced use of online portals to act as a ‘one stop shop’ for interaction between the Department and its clients, including the ability to access records, generate reports, and lodge documentation such as notifications and activity reports.
The Department has accepted the 13 key recommendations presented by the Auditor-General to address the identified issues, which include:
  • Improving data collection, data sharing and record keeping processes and protocols
  • Introducing rigour to the rationale for field activities
  • Improving quality assurance, performance measurement and reporting, and he quality of guidance materials and training.
It remains to be seen what reforms the Department is able to introduce within its operational and budgetary constraints.