Evaluating Vulnerabilities and Developing Mitigation Strategies to Prevent Potential Staff Malfeasance at Resettlement Support Centers
This evaluation was performed between 9/01/2014 and 12/31/2015 and the report was submitted on 12/16/2015.
Purpose of the Evaluation and Questions Addressed
Social Impact (SI) was contracted by the Bureau of Population, Refugees, and Migration (PRM) to assess the potential for fraud and staff malfeasance within the U.S.-funded Resettlement Support Centers (RSC). Tens of thousands of refugees are resettled in the U.S. every year and maintaining program integrity, particularly by mitigating vulnerabilities to internal fraud and malfeasance, is a priority for PRM. The evaluation’s four guiding questions were:
- What are the main areas of vulnerability to fraud and staff malfeasance in and across RSCs?
- What steps are being taken at RSCs to address these vulnerabilities? Are these steps effective?
- What are the most important factors in preventing internal malfeasance in and across RSCs?
- How can PRM optimize its monitoring of RSCs (including through coordination with Regional Security Offices (RSOs))?
SI used a mixed-methods evaluation design that included initial document review, an orientation to RSC processes, interviews with stakeholders, site visits, and direct observation of key RSC systems and processes. Site visits and data collection were conducted at four offices— RSC Middle East and North Africa, RSC Turkey and the Middle East, RSC Latin America, and RSC Africa.
- Lengthy processing linked to fraud: Vulnerability to fraud and malfeasance at RSCs is directly related to the length of time in which refugees are in the pipeline before departing to the United States. The longer refugees wait in the process, the more likely they are to become frustrated and desperate, making them more susceptible to being taken advantage of by RSC staff (or others) promising preferential treatment.
- Poor communication increases refugee anxiety: RSCs are only able to provide basic information to refugees when asked. This lack of proactive communication increases refugee anxiety about the status of their cases and leads them to be more willing to use fraudulent means to move their cases forward.
- Robust HR crucial in fraud prevention: A robust and forward-thinking HR department is necessary to prevent internal fraud. With consistent training, oversight and support, staff members are more likely to be invested in the organization and less likely to engage in fraud and/or malfeasance.
- Improve communication with refugees. RSCs should develop an effective strategy for proactively communicating with refugees, taking into consideration literacy level and technological capacity of the refugee populations.
- Provide staff training.RSCs should hold annual staff trainings on the definition of fraud and malfeasance, examples of fraud and malfeasance, and methods to report inappropriate behavior when observed.
- Strengthen the Human Resources systems. HR systems at all of the RSCs need the capacity to train staff, support staff and provide them with programs that focus on psycho-social welfare and the prevention of internal fraud and malfeasance. Supervisors need to be trained and competent in how to provide supervision too.
- Increase transparency for applicants. PRM should relax current norms and allow RSCs to provide applicants with more transparency regarding their case statuses.
- Coordinate with DHS to reduce the USRAP backlog. Since the major vulnerability to staff fraud and malfeasance at RSCs correlates to the length of time refugees are in the system, PRM should continue to discuss ways the DHS process can be improved and made more time efficient.
- Develop standardized training materials. PRM should develop standardized training materials on preventing fraud and malfeasance that can be adapted to each RSC’s specific conditions.
Use of Recommendations
- Evaluation findings were presented to RSC staff at PRM’s Refugee Admissions Workshop in December 2015.
- The evaluation findings continue to strengthen and reinforce PRM’s Program Integrity Guidelines for RSCs.