What changes to ICE detention inspection procedures were implemented after DHS OIG audits in 2016–2018, and were they effective?

1. What the OIG found and why ICE had to change

The 2018 OIG audit concluded that ICE’s inspection system—split between contractor-led inspections (Nakamoto) and ICE’s internal ODO reviews—was too broad, not consistently thorough, and did not produce sustained corrections, with field offices often inconsistent in implementing corrective action plans and allowing waivers that undermined standards ^{[1] [4]}; that report forced ICE to formally concur with OIG recommendations and commit to management actions intended to address those gaps ^[1].

2. Concrete procedural changes ICE said it implemented

In response, ICE and other DHS components moved to strengthen ODO’s role, clarified guidance on corrective action plans and follow-up, and altered contract and oversight language so that contractors and field offices faced clearer expectations and potential penalties for noncompliance; Congress and appropriations also provided additional funding intended to expand inspection frequency, including a transition toward more frequent (biannual) reviews for facilities holding people beyond 72 hours ^{[1] [2] [5]}.

3. Shifting inspection responsibility and frequency — real or rhetorical?

Policy documents and advocacy tracking show an explicit shift toward relying more on ODO and other DHS entities (e.g., ICE Health Service Corps, Office of the Immigration Detention Ombudsman) to inspect and to address specialized areas such as medical care and PREA compliance, and lawmakers funded increased inspections after 2020; in practice, however, different DHS components continued to carry overlapping responsibilities and the GAO later said DHS had not defined clear goals or performance measures to evaluate whether these programmatic shifts improved outcomes ^{[2] [3]}.

4. Did the changes lead to sustained compliance?

Independent reviews and watchdogs repeatedly found the answer to be: uneven at best. The OIG itself and civil-society groups reported that while ODO inspections were typically more effective, they remained too infrequent to catch or compel systemic fixes, and contractor inspections still suffered from superficial practices; the ACLU’s review of contractor reports in 2021 argued that “little has changed” from earlier critiques ^{[1] [6] [4]}. GAO’s broader 2025 review echoed the central problem: DHS lacked defined goals and metrics to assess whether reforms were working, making effectiveness claims difficult to substantiate ^[3].

5. Persistent weaknesses and the accountability gap

Multiple sources document recurring themes: inconsistent field office follow-through on corrective action, contractor inspections that are hard to fail, inadequate contractual levers to enforce standards, and inspection programs without outcome-based metrics—conditions that produce procedural fixes without systemic improvement ^{[1] [6] [5]}. Even where OIG and others instituted unannounced inspections and management alerts, those actions exposed problems but did not guarantee that deficiencies were remediated across the network of facilities ^{[7] [1]}.

6. Bottom line — modest procedural gains, limited effectiveness

ICE’s post‑2016 commitments produced measurable procedural changes—greater ODO involvement, clearer corrective-action processes, more funding for inspections, and heightened public scrutiny—but independent oversight through OIG, GAO, and advocates indicates these changes did not consistently produce sustained compliance or systemic improvement in detention conditions; the core failure is not the absence of reforms but the absence of rigorous, outcome-oriented performance metrics and enforceable contractual penalties to ensure corrective actions are implemented and maintained ^{[1] [3] [6]}.