Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
REVIEW  OF  THE  SAVE  SYSTEMS 
PROCESSES  Department  of Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
REVIEW  OF  THE  SAVE  SYSTEMS 
PROCESSES  EXECUTIVE  SUMMARY

PURPOSE 
To  identify  deficiencies  in the  Immigration  and  Naturalization  Services  (INS) 
Systematic  Alien  Verification  for Entitlements  (SAVE)  system  and  related  States 
processes. 
BACKGROUND 
The  Immigration  Reform  and  Control  Act  of 1986 (Public  Law 99-603)  established  the 
SAVE  system  to assist eligibility workers  in preventing  illegal  aliens  from  receiving 
federally  subsidized  benefits.  Attherequest  of the  Administration  for  Children  and 
Families  (ACF),  we attempted  to determine  if the  SAVE  process  is cost-effective.  We 
were  unable  to do so.  The  reasons  for this are  described  in our  report  Cost-
Eflectiveness of S4YE  (OEI-07-91-01230).  In the  course  of that  study, we discovered 
certain  deficiencies  in the  way States  use SAVE  and  also some  in the  system  itself. 
Here  in this report  we describe  those  deficiencies. 
The  Martin  Marietta  Corporation  contracts  with  INS to store  and  provide  electronic 
access  to the  SAVE  Alien  Status  Verification  Index,  a data  base  containing  more  than 
28 million  records.  Eligibility workers  are  required  to verify the  aliens  INS 
documentation  through  this automated  SAVE  system.  If the  aliens status  is not 
verified,  an Institute  Secondary  Verification  response  is generated.  Copies  of 
immigration  documents  must  then  be  forwarded  to an INS District  Office  for  a SAVE 
program  manual  review  for authentication.  Eighteen  percent  of all Aid  to Families 
with Dependent  Children  (AFDC)  and  Medicaid  primary  verification  requests, 
(October  1992- December  1993), resulted  in an Institute  Secondary  Verification 
message. 
This inspection  focuses  solely on aliens  applying  for AFDC  and  Medicaid  under  the 
Department  of Health  and  Human  Services  in which  INS generated  an  Institute 
Secondary  Verification  response.  We  chose  a purposive  sample  of four  States 
(California,  Florida,  Illinois, and  Texas)  on the  basis  of volume  of primary  queries, 
dollars  to the  States,  and  population.  We  reviewed  randomly  selected  State  cases, 
procedures,  computer  systems,  and  their  agreements  with INS on the  use  of SAVE. 
FINDINGS 
States  Are  Not Consistently Performing  The  Required  Secondary  Verification  To 
Validate  Aliens Status. 
Of the  268 cases  used  to review  for cost avoidance,  we found  92 cases  (34 percent) 
where  the  required  SAVE  secondary  verification  was not  performed.  In 45 of these 
cases,  States  improperly  made  eligibility decisions  without  full development  and  in 47 
cases,  States  improperly  relied  on unauthenticated  alien  documents  to determine 
eligibility  for payments. 
i  States  Are  Not Documenting  Their  Case  Files To  Establish That  They Have  Obtained 
Adequate  And Current  Responses  From  The  SAVE  Verification  Process  Prior  To 
Initiating Payments  To  Aliens. 
Primary  verification  requests  and  the  INS SAVE  responses  were  undated,  or there  was 
no primary  request  in the  case file.  Also in those  cases where  the  INS did not 
respond  to secondary  verification  requests,  the  eligibility worker  either  did not 
follow-up  with  INS or neglected  to document  this activity. 
States  Are  Unnecessarily  Querying The  SAVE  System. 
States  are  unnecessarily  querying  SAVE  for aliens  who have  become  naturalized  U.S. 
citizens  or for aliens  who were  not  applying  for aid.  Further,  SAVE  is not  needed 
when  an alien  applies  only for Emergency  Restricted  Medicaid.  Illegal  aliens  are 
eligible  for this aid regardless  of their  immigration  status. 
Deficiencies  Continue  To  Exist In The  Design And Operation  Of The  SAVE  Data 
System. 
SAVE  data  is not  always provided  in a timely manner;  the  SAVE  data  base  is not 
current;  INS immigration  status  responses  are  not  always clear;  and  SAVE  is prone  to 
manual  keying  errors. 
States  Are  Unable  To  Consistently Match  And Locate  Sample  Cases When  An 
Institute Secondary  Verification Message  Is Generated  From  INS. 
States  lack  sufficient  matching  points  (i.e., Last  Name/First  Name,  Date  of Birth,  Date 
of Entry...)  within  their  data  base  to identify  alien  case files in data  matches  with  the 
INS/SAVE  data  base.  Other  contributing  factors  for the  States  low success  rate  in 
matching  data  are  not  retaining  immigration  information  in the  data  base,  errors  in 
querying  the  SAVE  system,  and  system  deficiencies. 
RECOMMENDATIONS 
In our  companion  report,  Cost-Effectiveness  of SAVE  (OEI-07-91-01230),  dated 
November  1995, we reported  that  we were  unable  to determine  the  cost-effectiveness 
of the  SAVE  system.  Consequently,  there  will be  a continuing  concern  about  the 
overall  utility  of the  SAVE  requirement.  However,  the  statute  requires  that  unless  a 
waiver  is granted,  the  system  must  be used  to verify eligibility status  of aliens.  Based 
on our  review,  we believe  that  there  are  improvements  that  can be  made  in the  system 
to both  streamline  its operation  and  more  effectively  allow for future  reconciliations. 
To this  end,  we offer  the  following recommendations. 
The ACF  and the Health  Care Financing Administration  (HCFA)  should  remind  States 
of the SAW  requirements  and suggest minimal  documentation  to be included  in the State 
case files. 
ii  The ACF  and HCFA  should  work with INS  to enhance  the SAVE  program  to make  it 
more timely and user jiiendly. 
The ACF  and HCFA  should  coordinate  with States and INS  to identi.  the most  eficient 
and effective  way to designate and implement  matching points  between  their respective 
data  base systems. 
AGENCY  COMMENTS  AND  OIG RESPONSE 
The  ACF  feels  the  OIG  has inferred  that  the  fault  and  any corrective  action  on SAVE

lay primarily  on the  States.  It is their  belief  that  improvements  with  SAVE  are

primarily  the  responsibility  of INS.  We  continue  to believe  the  States  do have  a basic

role  in improving  the  SAVE  system.  These  areas  are  specified  in our

recommendations.  We  do agree,  however,  that  effective  improvements  to SAVE

should  involve  INS as well.  This  is reflected  in our  recommendations.

The  HCFA  concurs  with our  recommendations  and  has  outlined  specific  actions  to be

taken  to implement  them.

Both  ACF  and  HCFA  stressed  the  importance  of capturing  the  Social  Security  number

in the  INS data  base  to serve  as a matching  point.  We  hope  that  INS will give serious

consideration  to this suggestion.

The  Assistant  Secretary  for Planning  and  Evaluation  submitted  several  editorial  and

technical  changes,  which we have  incorporated  into  the  final report.

The  INS did not  provide  written  comments  to the  report,  but  verbally  indicated

concurrence  with the  findings  and  recommendations.

Copies  of ACF  and  HCFA  comments  are  included  in Appendix  D.

... 
111  TABLE  OF  CONTENTS

PAGE

EXECUTIVE  SUMMARY

INTRODUCTION.  . . . . . . . . . . . . . . . .  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

FINDINGS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...5

  Procedures  Not  Followed  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...5

  Documentation  of Cases  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6


Unnecessary  SAVE  Queries  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...7


Design  &Operation  of SAVE  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...7

  Imcation  ofCase  Files.  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  9

RECOMMENDATIONS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...12

APPENDICES

k  Sample  Case  Breakout  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  A-1

B:  Primary  Verification  ...,....  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  B-1

C  Sample  Selection  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  c-l

D:  Agency  Comments  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  D-1
 INTRODUCTION

PURPOSE 
To identify  deficiencies  in the  Immigration  and  Naturalization  Services  (INS) 
Systematic  Alien  Verification  for Entitlements  (SAVE)  system  and  related  States 
processes. 
BACKGROUND 
Legal Basis for SAW?? 
The  Immigration  Reform  and  Control  Act  of 1986 (Public  Law 99-603),  hereafter 
referred  to  as the  Act,  established  the  SAVE  program.  SAVE  is designed  to assist 
eligibility workers  in preventing  illegal  aliens  from  receiving  federally  subsidized 
benefits.  The  Act requires  States  to verify aliens immigration  status  for those  applying 
for certain  federally  funded  benefits. 
Federal  Regulations,  45 CFR  233.50, specify that  to be  eligible  for assistance  an 
individual  must  be  a United  States  citizen,  an alien  lawfully admitted  for permanent 
residence,  or an  alien  otherwise  permanently  residing  in the  U.S. under  color  of law 
(PRUCOL).  PRUCOL  includes  aliens  residing  in the  U.S. whose  presence  is known 
and  tolerated  by authorities  for an indefinite  period  of time.  Although  these 
individuals  have  not become  permanent  resident  aliens,  authorities  do not  have  plans 
to deport  them. 
The  Act  mandates  the  following  programs  and  oversight  agencies  to participate  in the 
verification  of alien  documentation:  Food  Stamp  Program;  Housing  Assistance 
Programs;  Unemployment  Compensation;  Title  IV Educational  Assistance;  Aid  to 
Families  with Dependent  Children;  the  Medicaid  Program;  and  certain  Territorial 
Assistance  Programs.  This inspection  concentrates  solely on the  AFDC  and  Medicaid 
programs  under  the  Department  of Health  and  Human  Services. 
Rogram  Processes 
The  Martin  Marietta  Corporation  contracts  with INS to store  and  provide  electronic 
access  to the  SAVE  Alien  Status  Verification  Index,  a data  base  containing  more  than 
28 million  records.  When  an alien  applies  for the  federally  funded  programs  listed 
above,  an eligibility worker  is required  to verify the  aliens status  by querying  this 
automated  SAVE  system.  The  SAVE  program  is a two part  process,  involving  a 
primary  and  secondary  verification  of alien  immigration  status.  The  primary 
verification  is an  automated  process  which  is used  to authenticate  the  alien  registration 
number  listed  on the  applicants  immigration  documents.  When  accessed  by the user 
through  a touch-tone  or computerized  system,  the  SAVE  Alien  Status  Verification 
Index  will respond  within  three  to five seconds  of the  query,  providing  the  aliens  status.  Once  a response  is received  from  INS, the  eligibility worker  uses  this 
information  to determine  if the  alien  may be eligible  to receive  benefits. 
Possible  responses  from  a primary  request  of SAVE  include: 
.  Lawful  Permanent  Resident  - Employment  Authorized;

.  Cuban/Haitian  Entrant  - Temporary  Employment  Authorized;

  Section  245A Temporary  Resident  - Temporary  Employment  Authorized;

  Section  210 Temporary  Resident  - Tempora~  Employment  Authorized;

.  Application  pending  - Temporary  Employment  Authorized;  or

  Institute  Secondary  Verification.

If the  INS responds  to a verification  request  with  Institute  Secondary  Verification, 
the  eligibility worker  is required,  according  to the  INS SAVE  manual,  to send  copies 
of immigration  documents  which  are  attached  to a Document  Verification  Request 
(Form  G-845)  to the  INS District  Office  for a SAVE  program  manual  review  for 
authentication.  This is referred  to as a secondary  verification.  The  INS staff  examines 
the  documents  and  conducts  automated  and  manual  validation  searches.  The  INS 
procedures  indicate  that  it will respond  to the  submitting  agency within  ten  working 
hays.  Responses  from  a seconda~  verification  request  might  indicate: 
  Lawful  Permanent  Resident;

  Conditional  Resident  Alien;

  Cuban/Haitian  Entrant;

  Application  Pending;

  Authorized  or Not  Authorized  Employment;

  Granted  Asylum/Refugee,  or Parolee;  or

  No determination  can be made  with documentation  presented  as the

documents  have  expired,  documents  appear  to be  counterfeit  or altered, 
documents  are  not  readable,  or not  enough  information  was provided. 
The  SAVE  manual  instructions  and  the  agreements  between  INS and  the  States

indicate  that  an  eligibility worker  is required  to perform  a primary  verification  request

and  a secondary  verification  request,  if needed,  each  time  an  alien  applies  for benefits

as an aliens immigration  status  can  change.  As an example,  lawful permanent

resident  aliens  can lose  their  immigration  status  if they  are  (a)  convicted  of a felony

offense,  (b)  convicted  of three  misdemeanor  offenses,  or (c) leave  the  U.S. without

INS permission.

The  INS maintains  records  of disclosure  on all alien  registration  numbers  checked

through  the  SAVE  Alien  Status  Verification  Index  data  base.  The  INS maintains  and

discloses  these  records  in accordance  with the  Privacy Act  and  the  Freedom  of

Information  Act.

At the  request  of the  Administration  for Children  and  Family  (ACF),  we attempted  to

determine  if the  SAVE  process  is cost-effective.  We were  unable  to do so.  The

2  reasons  for this are  described  in our report  Cost-Eflectiwmess of SAV7Z 
(OEI-07-91-01230).  In the  course  of that  study, we discovered  certain  deficiencies  in 
the  way States  use SAVE  and  also some  in the  system itself.  Here  in this report  we 
describe  those  deficiencies. 
METHODOLOGY 
Inspechbn Focus 
The  inspection  focuses  on the  Institute  Secondary  Verification  process.  Guidelines 
provide  that  benefits  cannot  be denied  to an applicant  unless  a secondary  verification 
has been  performed.  Institute  messages  indicate  a possible  problem  in the 
identification  of an aliens immigration  status  which  may reveal  that  the  alien  is 
ineligible  to receive  benefits.  Following  receipt  of an Institute  Secondary 
Verification  message,  eligibility workers  are  required  to further  develop  immigration 
status.  INS reported  that  18 percent  of all primary  queries  (October  1992-
December,  1993), resulted  in Institute  Secondary  Verification  messages  and  required 
development  by eligibility workers. 
Sample Selection 
We  selected  a purposive  sample  of four  States  for review  (California,  Florida,  Illinois,

and  Texas).  We  selected  these  States  based  upon  the  volume  of primary  queries  for

Fiscal  Year  (FY)  1992, administrative  costs by the  State  AFDC  and  Medicaid

programs  for FY  1992, and  the  undocumented  alien  population  based  on the  1980

census.  Since  California  is county-administered,  we selected  a statistically  valid  sample

from  three  strata  representing  small, medium,  and  large  counties  on the  basis  of the

volume  of queries  to the  SAVE  system  during  our  study period  (September  1 -

November  30, 1993) that  resulted  in an Institute  Secondary  Verification  message.

The  three  strata  represents  97 percent  of the  queries  made  to the  SAVE  system.  Six

counties  were  randomly  chosen  including  Fresno,  Los Angeles,  Orange,  Riverside,  San

Bernardino,  and  San Francisco.  The  undocumented  alien  population  in these  States

represent  almost  70 percent  of the  2.06 million  undocumented  alien  population  in the

1980 census,  which was the  last year  that  aliens were  identified  in the  survey.  All of

the  selected  States  rank  above  non-selected  States  in one  or more  of the  categories  of

primary  queries,  costs, or undocumented  alien  population.

We worked  with the  INS and  the  sample  States  to capture  all verification  requests

made  to the  SAVE  system  for aliens  applying  for AFDC  and  Medicaid  during  our

study period.  We  contacted  staff in these  States  to assure  that  we could  identify  alien

records  and  to obtain  the  corresponding  case files.  We were  informed  of which  10

individual  applicant  identifiers  (i.e., Last  Name/First  Name,  Date  of Birth,  Social

Security  Number,  Alien  number,...)  within  the  SAVE  system  that  the  States  used  to

reconcile  their  data  files with the  INS data  base.  The  INS sent  us a data  file, including

all verification  requests  performed  by the  States  that  resulted  in an  Institute

Secondary  Verification  message.

3  We  selected  a simple  random  sample  of case files that  had  been  matched  between  the 
INSand  State  records.  Reexamined  thecase  files that  the  States  were  able  to locate 
and  reviewed  their  procedures,  computer  systems,  and  agreements  with  INS on the  use 
of SAVE.  We  also talked  to staff from  ACF,  Health  Care  Financing  Administration 
(HCFA),  INS, and  the  States. 
We  conducted  our  review  in accordance  with the  Qudy  Standkis  for Inspections 
issued  by the  Presidents  Council  on Integrity  and  Efficiency. 
4
 FINDINGS

STATES  ARE  NOT  CONSISTENTLY  PERFORMING  THE  REQUIRED

SECONDARY  VERIFICATION  TO  VALIDATE  ALIENS  STATUS.

	 We found  thut the four Statm in our sample do not consktendy  conduct a 
secondmy  verijkation  when an Institute Secon.diwyV@ation  message k 
received @m  INS. 
State  agreements  with INS and  the  SAVE  manual  require  that  queries  be

performed  to verify, the  aliens immigration  status.  While  two States  responded

that  they  routinely  perform  the  required  secondary  verifications,  we have  found

cases  in all four  States  where  this was not  performed.  As a result,  cases  may

be  incorrectly  placed  in payment  status  prior  to establishing  eligibility.

In the  companion  inspection,  Cost-Effectiveness  of SAVE, we were  able  to

review  only 268 AFDC/Medicaid  and  Medicaid-only  cases  for cost  avoidance

from  the  original  935 (Appendix  A identifies  cases  by type  and  those  that  were

dropped  from  review).  Out  of these  268 cases, we found  92 cases  (34 percent)

where  eligibility  decisions,  resting  only on alien  status,  were  improperly  made

without  performing  the  required  secondary  verification  (Table  1 breaks  down

the  92 cases).  Forty-five  of these  cases were  not  fully developed,  while  in 47

cases  the  eligibility workers  improperly  relied  on unauthenticated

documentation  to determine  alien  status  in lieu  of performing  the  secondary

rable 1

FTHE SAVE PROGIUM

UFICATION PERFORMED~

DECISIONS BASED ON  CA  FL  IL  TX  TOTAL 
PrimaryVerificationonly,no other 
documentation
 19  2  21  3  45 
Tern  orary  Work  Authorization  Card

(1-6&B)
 2  0  0  7  9 
IP448xlter  Granting  Permanent  Residence 
3  0  0  0  3 
~;~5ment  Verification  Request  (Old  Form 
1  1  1  1  4 
Resident  Alien  Card/Alien  Registration

Receipt  Card  (1-551 or 1-151)
 4  0  4  1  9 
Passport
 3  0  1  0  4 
Notice  of Action  (1-797)
 0  0  4  0  4 
A@.&)eparture  Record  over one year

2  0  10  0  12 
No Queries  done:

Cuban/Haitian  Entrants  (MAR)
 0  2  0  0  2 
TOTAL  34  5  41  12  92 
1 None  of these  cases were denied  for reasons  other  than  citizenship. 
5  One  State  does  not  require  a secondary  verification  for eligibility 
redeterminations  if a prior  secondary  verification  was performed  and  the  query 
response  is located  in the  file.  The  States  instructions  indicate  that  once  alien 
status  has been  verified  through  SAVE,  it is not  necessary  to re-verify  alien 
status  unless  it is a temporary  status  which is subject  to change... 
Staff in another  State  told  us that  it does  not  perform  secondary  verifications  if 
it previously  determined  the  aliens status.  They  believe  that  once  a legal 
permanent  resident  alien,  always a legal  permanent  resident  alien. 
We  found,  however,  that  there  are  circumstances  when  a person  who  is a legal 
permanent  resident  alien  can lose this immigration  status  (i.e., convicted  of a 
felony  offense,  convicted  of three  misdemeanors,  or leaving  the  U.S. without 
INS permission).  This supports  the  requirement  that  determining  alien  status 
is necessary  when  each  alien  applies  for benefits. 
.	 When Institute Secondiwy Ven&ation  messagm OCCW,States somethws 
improperly rely only on an alkmh documenfi  to dktennine eligibilityforpayrnents. 
By accepting  the  aliens INS document  without  completing  the  INS Form  G-845 
for a secondary  query,  eligibility workers  in the  sample  States  have  not 
authenticated  the  legitimacy  of the  document  nor  have  they validated  that  the 
document  has  not  been  altered,  stolen,  or forged.  (Table  1) 
On  the  other  hand,  staff from  one  State  responded  it prefers  to use  SAVE 
because  it helps  eligibility workers  make  decisions  whether  to grant  benefits  to 
alien  applicants  for AFDC  or Medicaid.  It feels  the  SAVE  responses  provide 
documentary  support  to eligibility workers  on the  aliens immigration  status, 
greatly  lessening  the  need  that  eligibility workers  rely only on their  own 
judgment. 
Refer  to the  companion  report  for further  details  on cost avoidance  cases. 
STATES  ARE  NOT  DOCUMENTING  THEIR  CASE  FILES  TO  ESTABLISH

THAT  THEY  HAVE  OBTAINED  ADEQUATE  AND  CURRENT  RESPONSES

FROM  THE  SAVE  VERIFICATION  PROCESS  PRIOR  TO  INITIATING

PAYMENIS  TO  ALIENS.

We  reviewed  a sample  of case  files to determine  if the  States  are  accessing  and 
documenting  the  SAVE  primary  verification  system properly  and  found  that  the  INS 
SAVE  responses  were  undated.  We  found  other  cases where  there  was a primary 
request  in the  file; however,  it was not  for the  month  of the  application.  There  were 
also  cases where  there  was no primary  verification  request  in the  case  file. 
6
 In some  cases, when  the  INS did not  respond  to secondary  verification  requests,  the 
eligibility worker  did not  follow-up  with INS or neglected  to document  this  activity. 
For  further  details  on primary  verification  and  lack of documentation,  refer  to 
Appendix  B. 
STATES  ARE  UNNECESSARILY  QUERYING  THE  SAVE  SYSTEM.

States  perform  multiple  primary  queries  anticipating  that  the  SAVE  system will be 
updated  and  the  Institute  Secondary  Verification  message  will change  to reveal  the 
aliens immigration  status.  Once  the  SAVE  system is updated  after  multiple  primary 
queries  are  performed,  the  eligibility worker  bypasses  the  required  secondary 
verification  request.  For  example,  one  State  performed  28 primary  queries  on one 
alien  registration  number.  Although  we are  not  able  to project  the  actual  costs  of 
these  unnecessary  queries,  they  are  time-consuming,  labor-intensive,  and  costly. 
We  found  a large  number  of other  situations  in which  States  unnecessarily  queried 
SAVE  to determine  benefit  eligibility.  Three  examples  are  included  in Table  2. 
Emergency Restricted Medicaid -
illegal aliens are entitled to this type 
of aid regardless of immigration status  53  15  29  3  100 
Reference  only - payment on another 
case, but used as reference to the file  27  25  1  1  54 
U.S. Citizen  3  0  0  2  5 
TOTALS  83  40  30  6  159 
DEFICIENCIES  CONTINUE  TO  EXIST  IN TkIE  DESIGN  AND  OPERATION  OF

THE  SAVE  DATA  SYSTEM.

h-or  Studies Note INS Systems Problems 
One  study  conducted  by the  General  Accounting  Office,  Information  Management: 
Immigration  and  Naturalization  Services  Lacks  Ready  Access  to Essential  Data, 
September  1990 (GAO/IMTEC-90-75),  and  an INS study, SAVE  Program  User 
Satisfaction  Survey Analysis  Report,  September  1994, found  INS data  was sometimes 
inadequate  and  not  timely  or current,  and  that  States  data  systems  are  incomplete  and 
sometimes  inaccurate.  Our  study confirmed  problems  similar  to those  raised  in these 
other  reports.  I%obkrns still tit  with the SAVE system 
  SAVE dhta is not alwaysprovided in a timely manner. 
While  the  INS operating  procedures  state  that  a response  for a secondary 
request  will be given within  10 working  days from  the  date  the  request  is 
received,  we found  that  the  response  time  varies  widely, depending  on the 
workload  at the  responding  INS office. 
Two States  report  they receive  secondary  responses  within  1 week  to 3 months 
from  the  time  of the  secondary  verification  request.  Two of the  States  report 
they  receive  secondary  responses  from  INS within  10 days to 2 weeks. 
Our  analysis  of 49 of these  State  verification  requests  resulted  in an average 
response  time  of 18.3 days.  Responses  from  INS in 22 of the  49 requests 
(45 percent)  exceeded  the  10 working  day limit.  One  response  took  84 days. 
.  i!%eINS lMIL?Zdata base k not current. 
The  INS, in its formal  agreement  with the  States,  agreed  to update  its SAVE 
data  base,  as necessary,  to ensure  that  current  and  accurate  information  is 
available  to the  States.  However,  we found  that  the  SAVE  data  base  often 
does  not  have  recently  arrived  aliens  in the  system for extended  periods  of time 
after  their  arrival  (often  exceeding  six months).  Further,  we were  advised  that 
cases  exist for aliens  who have  resided  in the  U.S. for over  20 years,  but  they 
were  not  included  in the  SAVE  data  base. 
.	 States report that the INS is able to ver@  alien immiyahon  status in most cases. 
Howeve~ for aliens who are permanently restig  in the U.S. &r  color of law 
(PRUCOL),  the INS status responses are not always clear. 
Two States  cite problems  with  aliens who fall under  PRUCOL  status,  since  it 
isnt always clear  if the  clients  are  eligible  for benefits.  The  INS does  not 
always complete  the  G-845 Forms  appropriately  for  aliens  under  PRUCOL. 
For  example,  we found  a PRUCOL  case where  the  INS SAVE  response  to a 
secondary  verification  request  was incomplete.  The  response  revealed  that  the 
alien  was temporarily  eligible  to work;  however,  it did not  provide  the  specific 
immigration  status  which was needed  to determine  eligibility for benefits. 
  SAVE  k prone  to system keying errom 
Two States  noted  that  matching  problems  are  caused  by staff keying  errors  in 
which  an incorrect  alien  registration  number  (A number)  is transmitted.  This 
is primarily  due  to confusion  on how to enter  A numbers  into  the  SAVE 
system  that  have  7, 8, 9, or even  10 digits.  Furthermore,  the  two States 
indicated  that  their  system  automatically  drops  the  last  digit of the  alien 
number  when  too  many  digits are  entered.  This  causes  an Institute  Secondary 
Verification  message  to be  sent  to the  State,  which  results  in performing  an 
unnecessary  secondary  verification,  and  an increase  in administrative  costs. 
8  All alien  registration  numbers  begin  with the  letter  A followed  by 7, 8, 9, or 
10 digits.  This number  is assigned  to an alien  at the  time  the  alien  file is 
created.  The  INS instructions  require  the  letter  A to be  converted  to a zero 
before  querying  SAVE.  However,  if this conversion  is not  made  or made 
incorrectly,  it could  result  in an Institute  Secondary  Verification  message,  and 
subsequent  requests  for a secondary  verification  when,  in fact,  no such 
verification  was needed. 
Furthermore,  the  two States  indicated  that  when  an eligibility worker  adds  zero 
to the  alien  registration  number  but  retains  the  letter  A prefix,  this  causes  the 
last  digit in the  number  to be  erased.  When  this query  is submitted  to  INS for 
verification,  it will also result  in an Institute  Secondary  Verification  message  to 
the  State.  An unnecessary  secondary  verification  will then  be  performed, 
resulting  in increased  administrative  costs. 
STATES  ARE  UNABLE  TO  CONSISTENTLY  MATCH  AND  LOCATE  SAMPLE

CASES  WHEN  AN  INSTITUTE  SECONDARY  VERIFICATION  MESSAGE  IS

GENERATED  FROM  INS.

  Sample States are unable to consistently match cases to INS recora%. 
In the  INS/State  matching  process,  INS sent  us a data  file of all records  in our 
study period  where  the  State  had  performed  a primary  query  which  resulted  in 
an Institute  Secondary  Verification  message.  The  States  then  matched  their 
case  files to these  INS alien  records.  Table  3 breaks  down the  number  of 
records  in the  INS data  file and  the  records  that  States  were  able  to match  to 
them. 
Table3

INSUniqueRecords  22,659  8,283  2,996  6,584

//IIWState  Match  I  23.2262  I  1998  I  168  I  993

]]Percent Matched  I  103%  I  24%  I  670  I  50%  II 
1 For  further  details  on  the  INS/State  data  file  match,  refer  to  Appendix  C. 
2 Number larger due to multiple queries made by the State as a result of aliens 
applying in more than one county which establishes a separate record in 
each county. 
3 Due to resource limitations and the inability to conduct automated 
matches in Texas, we provided a sample of 200 data files to match with 
their State records rather than have them match their data files to the full 
6,584 data files.  Manually matching the 200 INS data files resulted in a 
total of 99 matches. 
9
 All States  but  California  had  insufficient  data  available  to reconcile  their  files 
with  INS data  files as a result  of inconsistent  methods  of designing  and  storing 
data  information  in their  computer  systems.  California  is the  only county 
administered  State  in our  sample.  As a result,  it is extremely  difficult  for the 
States  to create  an audit  trail.  Although  California  as a State  could  match  all 
files, counties  within  the  State  were  not  able  to match  with  INS records. 
SAVE  has  10 data  elements  in its data  base.  However,  States  can  only match 
on a minimum  of 3 data  elements  to a maximum  of 6 elements.  The  three 
most  common  elements  were:  Last  Name/First  Name,  Date  of Birth,  and  Social 
Security  Number.  With  insufficient  matching  points,  it is difficult  to reconcile 
State  records  with the  INS data  base. 
The  INS uses  the  alien  registration  number  as one  of the  10 data  elements. 
However,  most  States  are  not  able  to match  their  records  with  this number. 
The  primary  reason  indicated  was that  they  are  not  required  to maintain  this 
number  in their  data  base. 
.  Sample States were unable to consktently locate cases in our sampk 
Our  review  called  for samples  to be taken  from  cases  matched  between  INS 
and  the  States.  The  four  States  were  able  to locate  only 75 percent  of the 
sample  cases  in the  study for our  review.  The  numbers  by State  are  displayed 
in Table  4. 
California  335  266  79 percent 
Florida  200  180  90 percent 
IIIllinois  2001  153  76.5 percent 
1 I 1  1 
IITexas  200  99  49.5 percent
I I 1  I 
TOTAL

MATCHED  935  698  75 percent 
1 We conducted an INS/State match using Illinois entire universe of cases in our 
study period and could only match 168 cases.  Therefore, only 168 rather than 200 
cases could be used to conduct our review. 
We found  that,  while  the  State  of California  obtains  the  alien  number  for initial  claims 
processing,  it is not  maintained  on file by the  State  or county  offices.  Although  the 
State  could  match  all data  files, California  counties  were  unable  to match  and  locate 
all cases  in our  sample.  Also, in the  State  of Florida  capturing  the  alien  number  was 
10  voluntary  which  caused  matching  problems  with the  universe  (Table  3).  The  State  of 
Florida  was able  to match  cases  in our  sample  only through  a manual  process. 
.  Other factom  contnbute to the States low success rate in identijjkg  and matching 
w. 
One  State  indicated  that  40 percent  of AFDC  and  Medicaid  cases  are  denied, 
and  for these  cases  information  such as the  alien  number  is not  retained  in the 
data  base.  Since  only general  information  such as name,  case  number,  and 
reason  for the  denial  of benefits  is retained  in the  States  system,  it was unable 
to match  and  locate  INS data  for these  denied  cases. 
One  State  responded  that  its data  file structure  does  not  permit  entry  of the 
alien  number.  Our  review,  however,  showed  that  alien  numbers  provide  a 
more  effective  match  than  is obtained  by other  data  elements  such  as the 
individuals  name. 
11
 RECOMMENDATIONS

In our  companion  report,  Cost-Effectiveness  of SAVE  (OEI-07-91-01230),  dated 
November  1995, we reported  that  we were  unable  to determine  the  cost effectiveness 
of the  SAVE  system.  Consequently,  there  will be  a continuing  concern  about  the 
overall  utility  of the  SAVE  requirement.  However,  the  statute  requires  that  unless  a 
waiver  is granted,  the  system  must  be  used  to verify eligibility  status  of aliens.  Based 
on our  review, we believe  that  there  are  improvements  that  can be  made  in the  system 
to both  streamline  its operation  and  more  effectively  allow for future  reconciliations. 
To this end,  we offer  the  following recommendations. 
Ihe ACF  and HCFA  should remind States of the SAVE requiremen~ and suggest 
minimal documentation  to be inchuied in the State case files. 
The  ACF  and  HCFA  should  remind  States  to perform  the  required  secondary 
verification  requests  when  instructed  to do so by INS, not  relying  solely on immigration 
documents  in determining  alien  status,  and  only querying  the  SAVE  system when 
necessary. 
In relation  to verifying  alien  status,  ACF  and  HCFA  should  suggest  minimal  case  file 
SAVE  documentation  such as: 
  Dating  primary  and  secondary  verification  requests.

.  Documenting  INS responses  from  verification  requests.

  Documenting  follow-up  information  on secondary  verification  requests  and  the

INSs responses. 
Z4e ACF  and HCFA  should work with INS to enhance the SAW  program to make it 
more timely and user jiiendly. 
The  ACF  and  HCFA  should  work with  INS to achieve  responses  to secondary 
verification  requests  within  10 working  days as required  by INSs memoranda  of 
understanding  with  States. 
The  ACF  and  HCFA  should  request  INS to modify  the  SAVE  system  to  allow 
eligibility workers  to enter  alien  numbers  into  the  touch-tone  system  or other  system, 
exactly  as it is shown  on the  Alien  Registration  Card.  This would  eliminate  eligibility 
worker  confusion  on converting  this number  and  should  reduce  unnecessary  secondary 
verifications. 
l%e ACF  and HCFA  should coordinate mthStates and INS to identifi the most ej@ient 
and g&ective way to dim~ate  and impkvnent matching poina  between their respective 
dkta base systems. 
These  parties  should  explore  the  implementation  of efficient  and  effective  minimum 
matching  points  between  INS and  States  data  bases.  We found  that  States  currently  have  the  following  minimum  data  elements,  with some  States  also using the  alien 
number: 
  Last  Name/First  Name 
  Date  of Birth 
.  Social  Security  Number 
States  will benefit  by establishing  universal  matching  points  in their  systems,  the  ability 
to create  an  audit  trail  to ensure  only eligible  aliens  are  receiving  benefits,  and  the 
ability  to reconcile  records  with the  INS data  base. 
AGENCY  COMMENTS  AND  OIG RESPONSE 
The  ACF  feels  the  OIG  has inferred  that  the  fault  and  any corrective  action  on SAVE 
lay primarily  with the  States.  It is their  belief  that  improvements  with  SAVE  are 
primarily  the  responsibility  of INS. 
We  continue  to believe  that  the  States  do have  a role  in making  improvements  to the 
SAVE  program.  Based  on our review  of the  SAVE  program  and  the  States  systems, 
we have  specified  in our  three  recommendations  those  areas  needing  improvements. 
We  do agree,  however,  that  effective  improvements  to SAVE  should  involve  INS as 
well.  This  is reflected  in our  recommendations. 
The  HCFA  concurs  with  our recommendations  and  has  outlined  specific  actions  to be 
taken  to implement  them. 
Both  ACF  and  HCFA  stressed  the  importance  of capturing  the  Social  Security  number 
in the  INS data  base  to serve  as a matching  point.  We  hope  that  INS will give serious 
consideration  to this suggestion. 
The  Assistant  Secretary  for Planning  and  Evaluation  submitted  several  editorial  and 
technical  changes,  which we have  incorporated  into  the  final report. 
The  INS did not  provide  written  comments  to the  report,  but  verbally  indicated 
concurrence  with  the  findings  and  recommendations. 
Copies  of ACF  and  HCFA  comments  are  included  in Appendix  D. 
13
 APPENDIX  A

The  table  below  breaks  down the  total  number  of cases  in our  original  sample,  those 
cases  that  were  eliminated  and  the  reasons  for their  elimination,  and  cases  reviewed 
for cost avoidance. 
Original number in sample  335  200  2001  200  935 
Less  Cases not found bv States  69  20  47  101  237 
Less Denied - alien had too much income or 
resources or failed to cooperate  26  37  10  25  98 
Less Food Stamps  13212110145198 
Less Emergency Restricted 2  53  15  29  I  3  100 
Less Refugee Cases  20  19  010  39 
Less Reference  Only 2- payment on 
another case, but used as reference to the 
file  27  25  1  1  54 
Less  Cases  not  in Study  Period  5  18  012  25 
Less  U.S. Citizens  2  1310101215 
Medicaid Onlv  142122t59171130 
A-1
 APPENDIX  B

PRIMARY  VERIFICATION  SAMPLE  REVIEWED 
I  I  II 
II California 
II Florida  I  100  I  97  II 
I  II 
II Illinois  100  90 
1! I 
Texas  100  84 
1 CA was unable  to access its system to provide  us with a universe  of cases from which we could 
select a samde. 
DOCUMENTATION  OF  THE  PRIMARY  VERIFICATION 
Texas 2  13  20  49  2 0 
1 CA was unable  to access its system to provide  universe  of cases from which we could 
us  with  a 
select  a sample. 
2 Both  Florida  and Texas use the touch-tone  method  of accessing the SAVE  system for prima~ 
verification  queries.  This is a manual  system which relies on eligibility workers  to enter  the alien 
identification  number  into  the SAVE  system. 
3 Illinois  uses an automated  system to make  primary  verifications  queries.  As part  of the  claims 
process,  the eligibility  workers  enter  the alien identification  number  into  an automated  query 
system which batch  processes  SAVE  queries.  This results  in a primary  query response.  Although  we 
found  the State  was consistently  using this process,  ~  of the primary  verification  requests  are dated. 
B-1
 APPENDIX  C

PROCESS  OF  SAMPLE&  IDENTIFICATION  SELECTION 
CALIFORNIA 
File  Summarv 
INS Data  Files sent toga  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  22,6591 
CA Data  Files  Matched  to INS  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  36,1521 
Unique  Records  Matched  th ins.....  . . . . . . . . . . . . . . . . . . . . . ...23.2262 
Unique  Sample  Size  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...335 
Number  ofCase  Files  Found.  . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...266 
1 includes  multiple  primary  verification  queries  which resulted  in duplicate  files 
2 universe  from  which  sample  was selected  (number  larger  than  INS data  files 
due  to multiple  queries  made  by the  State  as a result  of aliens  applying 
in more  than  one  county,  which  establishes  a separate  record  in each  county) 
FLORIDA 
File  Summarv 
INS Unduplicated  Data  Files sent to Florida  . . . . . . . . . . . . . . . . . . . .  8283 
Number  of FL Data  Files  that  Matched  . . . . . . . . . . . . . . . . . . . . . . . .  23001 
Unique  FL  Data  Files  that  Matched  INS records  . . . . . . . . . . . . . . . . .  19982 
Sample  Size  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...200 
Number  of Case Files found  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  180 
1 includes  duplicates 
2 universe  from  which  sample  was selected 
c-1  PROCESS  OF  SAMPLE  SELECTION  CONTINUED 
ILLINOIS 
File  Summarv 
INS Data  Files with Duplicates  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  3551 
INS Data  files without  Duplicates..  . . . . . . . . . . . . . . . . . . . . . . . . . . .  2996 
IL Data  Files with Duplicates  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  11,4081 
Unique  IL Data  Files with Alien  Number  . . . . . . . . . . . . . . . . . . . . . .  6,731 
IL Data  Files with SSN  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  8,8492 
Entire  Universe  Matched  (INS and IL matches)  . . . . . . . . . . . . . . . . . .  168  3 
Data  Files  Matched  by Alien  Number  . . . . . . . . . . . . . . . . . . . . . . . . . .  88 
Data  Files  Matched  by SIN  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6 
Number  of Case  Files  found  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  153 
I includes  Lawful  Permanent  Resident  Aliens,  Institute  Secondary  Verification 
messages,  and  the  40 percent  denied  cases  (the  cases  are  retained  in the 
data  only by Last  Name/First  Name,  case number,  and  reason  for denial  -
which  could  not  be  located  in the  State/INS  match) 
2 includes  duplicates 
3 entire  universe  used  for the  review  (not  a sample),  no duplicates 
TEXAS 
File  Summarv 
INS Data  Files for TX  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6584

INS Data  Files  stripped  of Files with A#  only and

Duplicates  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  17941

Sample  Size  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  200

Number  of Case  Files  found  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  99

1 Texas  could  not  match  on the  alien  registration  number.  This  produced  the

universe  from  which  the  sample  was selected.

c-2  APPENDIX  D 
AGENCY  COMMENTS 
D-1  *
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.+  DEPARTMENT  OF HEALTH&  HUMAN  SERVICES 
: 
:
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4~t,,m 
ADMINISTRATION  FOR CHILDREN  AND  FAMILIES

Office  of the Assistant  Secretary,  Suite  600

370 LEnfant  Promenade,  S.VV.

Washington,  D.C,  20447

Aqgust  16,  1995 
DATE  : 
TO:  June  Gibbs  Brown 
Inspector  General 
FROM :  Mary Jo Bane

A~sis~an~  secreta~~~  ~---

for Children and Families

SUBJECT  :  Comments  - OIG Report:  Review of the SAVE System and

Processes.  OEI-O?-91-01231

As requested,  we have reviewed the subject Report and found that 
from an overall  perspective, we would have liked the OIG review 
to have resulted  in a more definitive answer to the question  of 
the Systematic  Alien  Verification  for  Entitlements  (SAVE) 
programls  cost  effectiveness.  However,  we  understand  why  this 
was  not  possible,  not  only  by  virtue  of the reasons  described  in 
the OIG Report,  Cost Effectiveness of SAVE  (OEI-07-91-01230) , 
but also, under  the approach the OIG used for conducting  the 
analysis. 
Also,  the Review  and companion, Cost-Effectiveness  Reports  find 
fault with the way both the Immigration and Naturalization 
Service  (INS) and the States operate and use the SAVE program. 
However,  the tone of the reports and the study recommendations 
appear to put much of the onus for this, and any  corrective 
actions,  on the States.  For example, the recommendation  to 
improve the match points between State and SAVE data is to us, 
principally,  a  responsibility  of  the  INS  and  not  the  States.  Our 
corrments  on  the  specific  recommendations  made  i.n  the  Reports 
reflect  our  concern  in  this  regard. 
Regarding  the  recommendations  contained  i.n  the  Review  of  the 
SAVE  Systems  Processes,    we  have  the  following  comments: 
RECOMMENDATION:  The  ACF and the Health Care Financing 
Administration  (HCFA) should remind States of the SAVE 
requirements  and suggest minimal documentation  to be included  in 
the State case files. 
RESPONSE:  The Immigration and Naturalization  Service  (INS) is

responsible  for providing the States with the necessary

instructions  for operating the SAVE program to include minimal
 Page 2 - June Gibbs Brown

documentation  in the State case files.  The INS should be 
aware  that  the  States  require  the  latest  and best  information  in 
this  regard  i.n  order  to  properly  use  the  SAVE program. 
RECOMMENDATION:   The  ACF  and  HCFA should  coordinate  with  INS to

enhance  the  SAVE program  to  make  it  more  timely and user

friendly.

RESPONSE:  We have in the past and will in the future work with

INS to improve the SAVE program.

RECOMMENDATION :  The ACF and HCFA should coordinate  with the

States and the INS to identify the most efficient  and effective

way to designate  and implement matching points between  their

respective  data base systems.

RESPONSE:  In our opinion,  the best way of improving  the ability

to match State files with the SAVE database is for the INS to

make every effort to capture and include the social  security

number in SAVE records.  It is our understanding  that the SAVE

system is designed  to store this information, but the INS is not

diligent  in capturing  and maintaining  it.  We would  add that

making  it easier in the future to determine the cost

effectiveness  of SAVE is probably  insufficient justification  for

compelling  the INS to do a better job of maintaining  this

information.

If you have any questions concerning these comments,  contact

Robert Shelbourne  at  (2o2) 401-5051 or Robert Laue at (2o2) 401-

5040. 
*4+,.  s$m.%  ~%   
:z  DEPARTMENTOF  HEALTH&HUMAN  SERVICES  HealthCareFinancingAdministration 
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The  Administrator 
washiwtontD.C.
20201 
AUG  31995 
DATE 
TO	 June  Gibbs  Brown 
Inspector  General 
FROM	 Bruce  C. Vladec +Wi!( 
Administrator 
SUBJECT	 Office  of Inspector  General  Draft  Reports  Entitled  Cost-Effectiveness 
of SAVE  (OEI-07-91-O 1230) and  R-eView of SAVE  Systems Processes 
(OEI-07-91-01231) 
We  reviewed  the  above  reports  which provide  information  on the  Immigration  and 
Naturalization  Services  (INS)  Systematic  Alien  Verification  for  Entitlement  (SAVE) 
system  and  related  State  processes.  Report  OEI-07-91-01230  addresses  the  cost-
effectiveness  in verifying  immigration  status  of aliens  applying  for Aid  to Families  with 
Dependent  Children  (AFDC)  and  Medicaid.  The  companion  report,  OEI-07-91-01231, 
describes  the  deficiencies  in the  INS  and  related  State  systems. 
Report  OEI-07-91-01230  contains  no specific  recommendations.  The  Health  Care 
Financing  Administration  concurs  with  the  three  recommendations  presented  in the 
report  on Review  of SAVE  Systems Processes.   Our  response  has  been  coordinated 
with  the  Administration  for  Children  and  Families. 
Thank  you  for the  opportunity  to review  and  comment  on these  reports. 
Attachment  Health Care Financinq Administration (HCFA) Comments on

Ofilce of Insuector  General (OIG) Drafi Reuort: Entitled Cost-Effectiveness  of SAVE

(OEI-07-91-01230)  and Review of SAVE Svstems Processes-- (OEI-07-9 1-01231)

OIG Recornrnendation  1 
The Administration  for Children and Families (ACF) and the Health Care Financing 
Administration  (HCFA)  should  remind  Stateosf theSystematAilci enV erificatfioornE
ntitlement 
(SAVE)requiremenatnsd suggesmti nimadlo cumentatitoonb eincludeidnt heStatceasefiles.

HCFA Res~onse 
We concur.  State workers need current, precise instructions on how to meet SAVE system 
requirements  and how to properly use the query system. The Immigration and Naturalization 
Semite  (INS) should make certain that States have up-to-date  INS user manuals. 
OIG Recommendation  2 
The ACF and HCFA should work with INS to enhance the S.4VE program to make it more 
timely and user friendly. 
HCFA Response 
We concur.  HCFA will formally request INS to modify the SAVE system to allow eligibility 
workers  to enter alien numbers into the touch-tone-system  or other system exactly as they are 
shown on the Alien Registration  Card.  We will continue to work with the INS to facilitate 
improvement  in responses to secondary verification requests. 
OIG Recommendation  3 
The ACF and HCFA should coordinate with States and INS to identi~  the most efficient, 
effective way to designate and implement matching points between their respective data base 
systems. 
HCFA ResDonse 
We concur.  HCFA recommends that the INS investigate with the Social Security Administration 
the feasibility of adding the Social Security number to the INS data base to serve as a matching 
point.