The Department of State's Bureau of Diplomatic Security (DS) is the Agency responsible for conducting "criminal investigations into violations of passport and visa fraud."  DS explains that "These federal felonies are often committed in connection with more serious crimes, such as international terrorism, narcotics trafficking, organized crime, alien smuggling, money laundering, pedophilia, and murder. These investigations are critical to the President's efforts to secure American borders and protect the national security of the United States.”  DS adds: “The U.S. passport is the most valuable identity document in the world as it establishes American citizenship and allows its bearer unlimited access to virtually every country in the world. People who attempt to obtain a U.S. passport illegally often are seeking to change their identities and conceal their activities and movements.”  

Criminals attempt to commit passport fraud either by tampering/misusing the passport itself, or by illegally obtaining a passport through the application process.  It is the vulnerabilities in the application process that are the focus of the Union's concerns, though the Union has protested the manufacturing of the passport book cover and electronic chip in Europe and Thailand.  

When adjudicators are forced to rush through the inspection process to meet quotas, the result is that frauds are issued in error to criminals.  NFFE Local 1998 believes this vulnerability should be addressed by providing more time, and more resources, for adjudicators to do their jobs.  

Other Vulnerabilities: 
There are other vulnerabilities as well, including insufficient permanent fraud prevention staffing, training, resources, and tools - along with too much focus on quantity at the expense of quality.  After the Union brought concerns to Congress about all of these issues in late 2003 to 2005, the Government Accountability Office (GAO) investigated.  On June 29, 2005 the GAO issued a report titled "Improvements Needed to Strengthen U.S. Passport Fraud Detection Efforts". That same day the U.S. Senate Homeland Security & Governmental Affairs Committee held a hearing titled "Vulnerabilities in the U.S. Passport System Can Be Exploited by Criminals and Terrorists". The GAO made six recommendations: 

1) consider way to improve interagency information sharing; 
2) establish a centralized and up-to-date fraud prevention library; 
3) consider augmenting fraud prevention staffing; 
4) assess the extent to which interoffice workload transfers may hinder fraud prevention; 
5) strengthen fraud prevention training; and 
6) strengthen fraud prevention oversight.

Related to the GAO's 3rd recommendation about permanent anti-fraud staffing, the Department of State's own Office of Inspector General (OIG) issued a report critical of passport anti-fraud efforts in November 2004. 

The Union has called on the Department of State to fully implement the recommendations of the 2005 GAO report and the 2004 OIG investigation, and to work with the Union to address the vulnerability caused by the quotas and the insufficient emphasis on quality work.  

Updated March 22, 2009

Protecting and Enhancing the Integrity of the Passport Issuance Process

Passport Services produces a product that is both a citizenship and identity document. This document grants its owner a free pass into the United States from any foreign port in the world. It is accepted as proof of identity by every federal and state government agency, every state motor vehicle department, every airline, and by all employers. Because of this, it is important that the integrity of the passport issuance process not be allowed to deteriorate.

Ignoring or dismissing the quality aspect of the passport adjudication process for the purpose of achieving short-term production benefits should not be tolerated. Unfortunately, we believe that emphasizing quantity over quality is the current, overriding principle governing our work, and that this reflects a need for independent review. We are concerned about passports being issued in error to identity thieves, drug smugglers, fugitives, illegal aliens, and terrorists. We are especially concerned about the national security implications of the latter. What we need is enough time to do our jobs diligently and with an emphasis on quality, and we do not have that now. We are asking for your help to rectify this situation.

The majority of the September 11th hijackers were issued visas by the Department of State’s Bureau of Consular Affairs. Passport Services is part of that bureau, and the processes for the two agencies are similar: both basically consist of employees determining whether or not to approve applications by examining the information for inconsistencies. The Union officers and bargaining unit employees of Passport Services have consistently focused on efforts to combat passport fraud and protect the integrity of the passport, especially following the September 11th attacks on our country. Yet, most of the proposals from Local 1998 to combat passport fraud have fallen on deaf ears. In fact, Passport Management is now intending to take steps that will further imperil the integrity of the passport issuance process and seriously weaken efforts to detect passport fraud.

Due to the relatively low number of specialists who examine the nation’s passport applications (approximately 420), the numbers of cases an employee is expected to review and approve per day is quite high. The numbers differ by grade and schedule, but the standard is somewhere around 200 cases per day when assigned to desk adjudication. Desk adjudication covers applications forwarded from outside acceptance facilities such as post offices and county clerks.

Counter adjudication (face-to-face identifying/reviewing of cases in the public lobby) also has high numerical standards, given that specialists are expected to interview applicants as well as review the citizenship and identity documents. These standards are extremely difficult to meet because of the unpredictable amount of counter traffic brought on by the current appointment system. Also, specialists at some agencies are required make so many trips to the cashiering section over the course of the day that the time the agents have to conduct interviews with the applicants is virtually eliminated.

Technological and other changes in the Passport system have had a significant, negative impact on the ability of the nation’s Passport Specialists to meet the production numbers expectations, standards that have been in place prior to when these changes were instituted. When work processes continually change to make the process slower, while the quantity expectations remain the same, an environment is created where more and more unqualified applicants are issued passports.

Simply put, the Union is concerned with the negative repercussions on quality that result from employees rushing to meet the expectations set for them. Unfortunately, the ability to detect passport fraud and identity theft is still largely a function of the amount of time spent examining the application and citizenship evidence. Management is proposing performance standards for 2004 that require employees to work even faster. If these standards go into effect, more fraudulent passports will be issued in error as Passport Specialists strive to meet unrealistic production quotas. A greater ease in illegally obtaining passports will have severe consequences for the safety of the nation as well as the security of personal identities.

An article in the November 9, 2003 edition of the Washington Post reported on ten passports being switched at the quality control stage and then mailed out to the wrong applicants. Even though this error by a processing section employee was unrelated to adjudication duties, it was likely caused by a demand to achieve high numbers rather than laziness or indifference from the worker.

The mistakes that can occur in the adjudication section, such as approving a passport to a fraud or non-citizen, have more serious ramifications. These errors are rarely corrected, as the criminal receiving the passport obviously has no incentive to notify the agency of the error, and the agency does no post-issuance audit to determine who was issued a passport.

The issue being brought to your attention is not about Passport Specialists’ ability to issue high numbers of passports. Each specialist could issue 200, 500, even 1000 passports per day – it takes no skill or training to sign a name on an application. Skill and training – and time – are needed only if we want to do the job right. This issue is about the amount of time that should be spent on each application and how much emphasis should be focused on quality. Given the current fees for passports ($85 for a routine application, $145 for an expedited application), can the Department justify allocating two minutes or less to review an application (especially when a disproportionate amount of the two minutes is devoted to manual processes, such as un-stapling and folding documents)?

Following September 11th, demand for passports dropped slightly across the nation, a situation that has yet to change dramatically. Despite this opportunity to give a renewed emphasis to quality, Passport Management is heading in exactly the opposite direction: their plan for 2004 is designed to result in a record number of issuances, despite the likelihood that there will be no such need to issue at a record-setting pace.

The methodology used at the proposed 2004 standards was to undertake what Passport Management termed a “study”. The study was not at all scientific, as it consisted solely of going back and adding up production numbers from previous days. The problem with this approach is that employees are already at the point where they must employ numerous shortcuts in order to achieve the current standards. Passport Management has repeatedly been made aware of this. Even so, Management’s study revealed production number results that were lower than the current minimum for a “fully successful” rating. Since the results of even this flimsy study were not to their liking, Passport Management is proposing a slightly modified version of the current standards.

The Passport agency has not compiled or studied the quantity of frauds issued in error, but a number of recent frauds issued by senior employees and even managers were blatant enough to have been detected by even the most junior specialist. And although the Privacy Act prevents us from providing you with copies of these applications, the past several years have seen well-known snipers, scam artists and child molesters fraudulently apply for passports. When these people are incorrectly issued a passport, it opens up a world of opportunities for them to commit additional crimes.

In the past month, Passport Management has made yet another decision that will weaken the agency’s ability to fulfill its fraud-detection duties. All of the regional Assistant Fraud Program Managers, some with as many as 15 years devoted exclusively to fraud prevention, will now be removed from their assignments. These duties will soon be relegated to other Passport Specialists in quarterly rotations. This change means that the main regional Fraud Program Managers will now have to devote a large portion of their time to train Passport Specialists rather than focus on their primary tasks of sorting the legitimate applicants from fraudulent ones.

This represents the fourth consecutive year in a row that the production standards have effectively become harder to achieve. Employees who are already employing numerous shortcuts to meet these goals are now facing the prospect of having to choose between scrutinizing the applications and approving enough applications to keep their jobs. There is only one inevitable outcome of such a trend: more undetected identity theft and a decreasing ability of the government to be aware who is in the country.

The writing on the wall could not have been clearer at Visa Services. The work pressures at our sister agency resulted in focusing on simply issuing and getting the work out. September 11th was an almost predictable result of this process. Why does the federal government always wait until a disaster happens until it fixes the problem?

We are asking that you inquire on our behalf, and on behalf of the traveling public, for the sake of enhancing the integrity of the process. We are asking Congress to investigate this issue, to help ensure that quality is given the emphasis that it deserves.

This site is owned & maintained by IAMAW FD1 NFFE FL1998, the union that represents the bargaining unit employees of Passport Services (a division of the Department of State's Bureau of Consular Affairs). The views expressed here are those of the Union and not the federal government.