What recommendations did the DHS OIG make after its excessive-use-of-force audit, and which were implemented between 2016 and 2019?

1. The audit and its core recommendations: central oversight, better tracking, updated policies

The OIG’s review of excessive-use-of-force practices across DHS components concluded that the Department lacked consistent, departmentwide oversight and management of use-of-force activities, and recommended establishing a central coordinating mechanism to oversee component policies and incidents, implementing case-management changes to identify excessive-force allegations, and updating DHS-level policy and training guidance to ensure consistent investigations and accountability ^{[3] [1] [2]}.

2. Specific technical fixes OIG demanded: case management and data integration

Among the more concrete prescriptions were requirements that DHS and components modify their case-management systems to flag excessive-force allegations, incorporate related data such as assaults on agents that did not result in force into trend analysis, and develop formal reporting procedures so that misconduct allegations are handled uniformly and captured for departmentwide analysis ^{[5] [1] [4]}.

3. How DHS responded between 2016 and 2019: concurrence, SOPs, and partial rollouts

DHS formally concurred with several OIG recommendations and took incremental steps: components reported actions such as developing standard operating procedures (OCHCO produced a SOP in response to the audit), and DHS announced coordination mechanisms and timelines intended to implement recommendations across components, with target completion dates noted in OIG follow-ups (for example actions tied to 2017 and a September 30, 2019 completion estimate) ^{[4] [3]}. The Department’s concurrence is documented in OIG materials that also reference planned or completed deliverables ^{[2] [4]}.

4. What was actually implemented by 2019 — measured, not assumed

OIG follow-up documents show that DHS implemented some administrative steps — notably the development of at least one standard operating procedure through OCHCO and commitments to modify information systems — but OIG continued to classify several recommendations as “resolved—open” or unresolved because the Department had not demonstrated full, verifiable implementation across components or provided sufficient evidence to close the recommendations ^{[4] [3]}. DHS concurrence and partial system/SOP changes occurred, but OIG’s own analyses indicated that comprehensive, departmentwide oversight, full case-management integration, and uniform disciplinary process changes were not completed to OIG’s satisfaction by 2019 ^{[4] [3]}.

5. The OIG’s view and the residual accountability gap

The OIG warned that without full implementation of its recommendations DHS risked persistent oversight gaps and inconsistent handling of use-of-force allegations; OIG explicitly tied closure of recommendations to tangible evidence such as modified systems, issued policies, and department-level coordination memos, and noted that concurrence alone was insufficient to consider recommendations closed ^{[3] [2]}. In short, DHS took steps and agreed with the fixes, but OIG records through 2019 show incomplete implementation and continued monitoring was required ^{[4] [3]}.

6. Competing perspectives and implicit incentives

DHS’s responses emphasized resource and implementation timelines and framed SOP development and planned system upgrades as proof of progress, while OIG maintained a standards-driven posture that prioritized verifiable, auditable outcomes before closing recommendations; this tension reflects implicit organizational incentives—DHS to show remediation quickly and OIG to insist on durable, cross-component change backed by documentation ^{[4] [3] [2]}.