Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

REVIEW OF THE SAVE SYSTEM’S 

PROCESSES 
Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

REVIEW OF THE SAVE SYSTEM’S 

PROCESSES 
EXECUTIVE SUMMARY


PURPOSE 

To identify deficiencies in the Immigration and Naturalization Service’s (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 “CostEflectiveness 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 alien’s INS 

documentation through this automated SAVE system. If the alien’s 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 Service’s (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 alien’s 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 applicant’s 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 alien’s 
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 alien’s 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 alien’s 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 President’s 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 alien’s 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


DECISIONS BASED ON 

PrimaryVerificationonly,no other 

documentation


Tern orary Work Authorization Card


(1-6&B)


IP448xlter Granting Permanent Residence 

~;~5ment Verification Request (Old Form 

Resident Alien Card/Alien Registration


Receipt Card (1-551 or 1-151)


Passport


Notice of Action (1-797)


A@.&)eparture Record over one year


No Queries done:


Cuban/Haitian Entrants (MAR)


TOTAL 

rable 1


FTHE SAVE PROGIUM


UFICATION PERFORMED~


CA FL IL TX TOTAL 

19 2 21 3 45 

2 0 0 7 9 

3 0 0 0 3 

1 1 1 1 4 

4 0 4 1 9 

3 0 1 0 4 

0 0 4 0 4 

2 0 10 0 12 

0 2 0 0 2 

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 State’s 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 alien’s 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 alien’s 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 alien’s 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


PAYMEN’IS 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 

alien’s 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!%e INS 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 

isn’t 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. 

Table 3


INS Unique Records 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% 

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


II 
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 Table 4. 

California 

Florida 

Illinois 

Texas 

II

II

TOTAL


in the study for our review. The numbers by State are displayed 

335 266 79 percent 

200 180 90 percent 

2001 153 76.5 percent 1 I 1 1 

200 99 49.5 percent I I 1 I 

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 contn”bute 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 State’s 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 

individual’s 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


INS’s 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 INS’s 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 m“thStates 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 

1!

II California’ I I II 

II Florida I 100 I 97 II 

II Illinois 100 I 90 II 

Texas 100 84 I 

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 us with a universe of cases from which we could 

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 

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 

3 
APPENDIX D 

AGENCY COMMENTS 

D-1 
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DEPARTMENT OF HEALTH& HUMAN SERVICES 

DATE : 

TO: 

FROM : 

SUBJECT : 

ADMINISTRATION FOR CHILDREN AND FAMILIES


Office of the Assistant Secretary, Suite 600


370 L’Enfant Promenade, S.VV.


Washington, D.C, 20447


Aqgust 16, 1995 

June Gibbs Brown 

Inspector General 

Mary Jo Bane


A~sis~an~ secreta~~~ ~---”


for Children and Families


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 System’s 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. 

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‘4 ~b.,a > The Administrator 

washiwtontD.C.20201 

DATE AUG 31995 

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 System’s 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 costeffectiveness 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 System’s 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 Svstem’s 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 States oftheSystematic Alien Verification
 forEntitlement 

(SAVE)requirements andsuggest minimal documentation tobeincluded intheStatecasefiles.


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.