What specific GAO recommendations have been implemented to prevent misidentification of U.S. citizens by ICE?

1. What GAO actually recommended: clearer guidance and better case tracking

The GAO’s 2021 review identified inconsistent ICE guidance on handling claims of U.S. citizenship—specifically recommending that ICE standardize procedures so officers reliably interview and verify citizenship claims (e.g., interviewing claimants with a supervisor) and systematically track encounters where citizenship is asserted or in question; GAO also urged ICE and CBP to develop better data to show how often U.S. citizens are stopped, detained, or placed in removal-related processes ^{[1] [2]}.

2. What ICE/DHS agreed to and where it moved first

The public status documents show DHS has, in some areas, concurred with GAO recommendations and taken steps to improve oversight data capture—for example, ICE implemented a system to record facility inspection results in a format conducive to analysis and now conducts trend analyses for inspections, which GAO noted as implemented ^[4]. GAO’s implementation-status reporting also notes DHS-level actions and that some recommendations—such as directing ICE and CBP to develop guidance on compliant mechanisms—were tracked by DHS, though the status varies by recommendation ^[3].

3. Recommendations specifically tied to misidentification: limited full implementation

For the recommendations most directly aimed at preventing citizen misidentification—standardizing investigative guidance, consistently requiring supervisor involvement, and systematically recording and reporting encounters involving asserted U.S. citizenship—the record is mixed: GAO highlighted persistent inconsistencies in ICE guidance and gaps in tracking ^{[1] [2]}, and follow-up reporting and outside commentary indicate some of those recommendations have not been fully implemented across frontline operations ^[5]. GAO’s later and separate reports on ICE data reporting likewise emphasize that ICE’s public detention numbers understate totals and that data systems need strengthening—steps that relate indirectly to preventing misidentification by improving visibility ^[6].

4. New technology (facial recognition) complicates implementation and risk

Independent reporting shows ICE’s increasing use of facial-recognition tools without mandated extra vetting creates a practical impediment to GAO’s aims: if biometric matches are treated as definitive without additional checks, the risk of misidentifying U.S. citizens persists even where policies exist, and GAO’s administrative-data recommendations do not by themselves neutralize errors introduced by unvetted technology (The Guardian reporting on ICE facial recognition use) ^[7].

5. Political and oversight context: pressure, proposed legislation, and advocacy

Members of Congress and advocacy groups continue pushing for statutory and appropriations restraints—such as amendments to bar ICE from detaining U.S. citizens during civil immigration enforcement—and for implementation of GAO findings; those policy pressures reflect dissatisfaction with the pace and scope of agency changes and suggest that GAO recommendations alone have been insufficient to close the accountability gaps GAO identified ^{[8] [9]}.

6. Bottom line and limits of reporting

In short, GAO’s concrete recommendations—to standardize guidance for citizenship investigations and to systematically track encounters involving asserted U.S. citizenship—have been partially adopted in adjacent oversight and data-reporting practices (notably inspection-data systems) but have not been comprehensively implemented across ICE operations according to the available status updates and reporting; independent journalism raises additional concerns about technology and frontline practice that are not fully addressed by the implemented measures, and available sources do not provide a complete, up-to-date inventory tying each GAO recommendation to a final agency action ^{[4] [3] [5] [7]}.