United States General Accounting Office

GAO Report to the Subcommittee on National

Security, International Affairs, and

Criminal Justice, Committee on

Government Reform and Oversight,

House of Representatives

March 1998 NATURALIZED

ALIENS

Efforts to Determine If

INS Improperly

Naturalized Some

Aliens

GAO/GGD-98-62

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-276192 

March 23, 1998

The Honorable J. Dennis Hastert

Chairman

The Honorable Thomas M. Barrett

Ranking Minority Member

Subcommittee on National Security,

 International Affairs, and

 Criminal Justice

Committee on Government Reform

 and Oversight

House of Representatives

Concerns have been raised about the possibility that the Immigration and

Naturalization Service (INS) may have improperly naturalized aliens with

criminal histories (e.g., arrests or convictions). To judge if this had

occurred, INS reviewed its case files of aliens who were naturalized

between August 31, 1995, and September 30, 1996, and who the Federal

Bureau of Investigation (FBI) had identified as having criminal history

records. The Executive Office for Immigration Review (EOIR)1

 staff were to

provide quality assurance that INS’ judgments were unbiased by reviewing

a sample of the cases reviewed by INS. Also, the Department of Justice’s

Justice Management Division (JMD) contracted with KPMG Peat Marwick

LLP (KPMG) to monitor and validate INS’ review.

In response to your request and as agreed with your offices, the objectives

of this report are to (1) compare the results of the INS and EOIR case

reviews and (2) assess KPMG’s approach to monitor INS’ efforts to identify

improperly naturalized aliens. To achieve our objectives, we (1) discussed

INS’ review of aliens who may have been improperly naturalized during this

period with INS, JMD, EOIR,and KPMG officials in Washington, D.C., and with

INS and KPMG officials in INS’ Lincoln Service Center in Nebraska2 and

(2) reviewed INS and KPMG records and reports regarding the review,

including KMPG’s report to JMD.

3

 In March 1997, we visited the Lincoln

Service Center to observe the review process. At the time of our visit, EOIR

staff were not present. However, we subsequently discussed with all of the

1

EOIR is within the Department of Justice and is responsible for the immigration hearing and appeals

processes. The immigration judge function and the Board of Immigration Appeals are included within

EOIR.

2

The INS review was done mainly at the Lincoln Service Center in Nebraska. It was concluded in

Charleston, South Carolina.

3

Department of Justice, Immigration and Naturalization Service, Criminal History Case File Review,

Final Report, KPMG, December 19, 1997.

Page 1 GAO/GGD-98-62 Naturalized Aliens
B-276192 

participating EOIR staff members the process that they followed in their

review of the INS alien case files.4

To assess KPMG’s approach, we determined if KPMG used accepted social

science standards, which include (1) the use of unbiased selection

procedures, reliability checks and assessments (e.g., training and rules for

documenting the results), and procedures to ensure the quality of the data

used; (2) full disclosure of study procedures and limitations; and

(3) appropriate generalization on the basis of the data gathered and

analyzed.

We conducted our review from February 1997 to January 1998 in

accordance with generally accepted government auditing standards. We

requested comments on a draft of this report from the Attorney General

and KPMG. Their oral comments are discussed in the Agency Comments

section of this report.

Background INS processed approximately 1.3 million citizenship applications between

August 31, 1995, and September 30, 1996; 1,049,867 of the applicants were

naturalized. During this period, INS initiated a number of efforts, under a

program called “Citizenship USA,” to accelerate and streamline its process

for naturalizing citizens. In its December report, KPMG stated that while INS’

efforts greatly increased the volume of applicants who were processed and

approved, the potential for error also increased during this period.5

 In an

effort to determine if past naturalization efforts were adjudicated

correctly, INS reviewed selected naturalization cases approved between

August 31, 1995, and September 30, 1996. EOIR was to provide quality

assurance assistance for INS’ review. KPMG, under contract with JMD,

monitored and validated INS’ review.

4

Five of the six EOIR staff members were immigration judges or members of the Board of Immigration

Appeals. We interviewed five of the six participating EOIR staff by telephone and interviewed the

other participant in person.

5

Over the past several years, Justice’s Office of Inspector General and we have reported on problems

related to INS’ adjudication of aliens who apply for naturalization. See the reports entitled Alien

Fingerprint Requirements in the Immigration and Naturalization Service, U.S. Department of Justice,

Office of Inspector General (Feb. 16, 1994); INS Fingerprinting of Aliens: Efforts to Ensure

Authenticity of Aliens’ Fingerprints (GAO/GGD-95-40, Dec. 22, 1994); Naturalization of Aliens:

Assessment of the Extent to Which Aliens Were Improperly Naturalized (GAO/T-GGD-97-52, Mar. 5,

1997); Naturalization of Aliens: INS Internal Controls (GAO/T-GGD-97-57, Apr. 30, 1997); and

Naturalization of Aliens: INS Internal Controls (GAO/T-GGD-97-98, May 1, 1997).

Page 2 GAO/GGD-98-62 Naturalized Aliens
B-276192 

A primary naturalization criterion is that applicants must be able to

establish good moral character to become naturalized citizens.6

 Under

certain circumstances, applicants who fail to reveal their criminal histories

or who have been convicted of certain crimes, such as crimes involving

moral turpitude (e.g., certain felonies and certain misdemeanors), cannot,

by statute, establish good moral character.7

 To judge if any citizenship

applicants have failed to establish good moral character, INS, with

assistance from the FBI, was to identify those applicants who have criminal

histories.

Previously, to identify these applicants, INS required that aliens submit

fingerprint cards with their applications for naturalization. Each

fingerprint card was to include a complete set of fingerprints and other

identifying information, such as the alien’s name and date of birth. INS was

to send each fingerprint card to the FBI for it to determine if an alien had a

criminal history record on file. Part of the naturalization process was to

include an interview between an INS adjudicator and the applicant. The

interview, which is done under oath, was to include a discussion about any

criminal history of the applicant—that is, arrests or convictions—which

should be available at the time of the interview.

Results in Brief After receiving criminal history records from the FBI, INS reviewed the case

files of 16,858 aliens with records that included a felony arrest or

conviction of a serious crime who were naturalized between August 31,

1995, and September 30, 1996. INS reviewed these criminal history records

and its case files in an attempt to judge if these aliens should have been

naturalized.

In its review of these 16,858 case files, INS designated each case as either

“proper,” “requires further action,” or “presumptively ineligible.” INS

designated 10,535 cases as proper, 5,954 cases as requires further action,

and 369 cases as presumptively ineligible. According to INS officials, a case

was designated as proper if the data in the case file supported the initial

decision to naturalize the individual. A case was designated as requires

further action if the data in the case file were insufficient to support a

proper decision yet did not appear to indicate that the individual was

6

In addition to being of good moral character, an applicant generally must demonstrate knowledge of

English and civics and must have resided in the United States for at least 5 years as a legal permanent

resident.

7

A criminal history may include felony, misdemeanor, and INS administrative arrests that are solely

related to violations of immigration laws and are solely enforced by INS (e.g., aliens who illegally work

in the United States).

Page 3 GAO/GGD-98-62 Naturalized Aliens
B-276192 

barred from being naturalized. For example, some case files did not

contain data about the dispositions of arrests that may have affected the

individuals’ eligibility for naturalization. Cases involving a failure to

disclose an individual’s criminal history also were classified as requires

further action. These classifications were made because the determination

of whether the failure to reveal the criminal history affected the

individual’s eligibility for naturalization required a legal determination that

went beyond the scope of the INS review. A case was designated as

presumptively ineligible if the data in the case file or the criminal history

appeared to indicate that the alien should have been barred from being

naturalized.

To provide quality assurance that INS’ decisions during the review were

unbiased, EOIR reviewed a statistically valid sample of 557 alien case files

from the universe of 16,858 aliens. EOIR and INS reached the same decisions

in 439 (or 79 percent) of the 557 cases. For 6 of the 118 cases in which

their decisions differed, INS judged that the aliens were presumptively

ineligible but EOIR judged that the naturalizations were proper in 1 case

and further action was required in the other 5 cases. For 40 of the 118

cases, INS judged that further action was required but EOIR judged that the

naturalizations were proper in 36 cases and the aliens were presumptively

ineligible in 4 cases. For the remaining 72 cases, INS judged that the

naturalizations were proper but EOIR judged that either further action was

required or the aliens were presumptively ineligible.

Although there was a 21-percent disagreement rate between the INS and

EOIR reviewers, we could not conclude that a statistically significant

difference existed between the INS and EOIR decisions. Also, the INS and

EOIR reviews produced generally similar conclusions about the percentage

of naturalization decisions that had been made properly, 65 percent and

58 percent, respectively.

INS is reviewing for potential revocation the 6,323 cases that its

adjudicators judged as requiring further action or presumptively ineligible.

However, INS initially did not plan to review the 72 cases that EOIR’s review

indicated may also have involved improper naturalization decisions.

According to one of the attorneys involved in reviewing the 6,323 cases for

potential revocation, INS was not aware of the 72 cases identified by EOIR.

On the basis of discussions with us, he said that these 72 cases are being

reviewed with the other 6,323 cases.

Page 4 GAO/GGD-98-62 Naturalized Aliens
B-276192 

In carrying out its monitoring responsibilities, KPMG used accepted social

science standards. For example, it (1) established procedures to ensure

the appropriate collection and review of FBI criminal history records and

the review of related alien case files, (2) promoted consistency in the

judgments of INS adjudicators by providing training and having the

adjudicators use a standardized worksheet, and (3) identified recurring

adjudicator errors so that corrective action could be taken. Also, KPMG’s

report (1) disclosed limitations in the study procedures followed (e.g., the

report said that a contributing factor to differences between the EOIR and

INS judgments was the need to interpret case file documentation regarding

the applicants’ acknowledgment of prior criminal histories) and

(2) discussed conditions that may have affected the accuracy and

completeness of INS’ review (e.g., the primary source of naturalization

information came from an INS system that often had been found to be

inaccurate).

Review Process INS

Used to Judge If

Aliens Were

Adjudicated Correctly

To judge if naturalization cases that were processed between August 31,

1995, and September 30, 1996, were adjudicated correctly and if the

naturalization process had adequate controls, INS reviewed selected cases

to judge, on the basis of the information in the files, if the naturalized

citizens were of good moral character. INS, with the FBI’s assistance,

identified 80,856 criminal histories for applicants believed to be

naturalized during this period with records that included felonies,

misdemeanors, or INS administrative arrests or convictions.8

 An aspect of

this review was to identify aliens who may not have revealed their arrests

or convictions.

After reviewing criminal histories provided by the FBI, INS identified 17,257

applicants who were naturalized between August 31, 1995, and

September 30, 1996, with criminal history records of arrests for felonies or

other potentially disqualifying crimes. To conduct the review, INS

requested the 17,257 case files from its field offices. Only 16,858 of the

requested case files were reviewed because INS field units could not locate

399 case files. Accordingly, INS reviewed 16,858 criminal histories and

corresponding case files in an attempt to judge if these aliens should have

been naturalized.

Under KPMG’s monitoring, INS activities included (1) collecting the

appropriate criminal history records from the FBI, (2) sorting and

8

To identify the universe of naturalized cases, INS identified all aliens who were naturalized between

August 3, 1995, and September 30, 1996. INS then requested that the FBI provide the agency with the

criminal history records, if any, for all of those naturalized citizens.

Page 5 GAO/GGD-98-62 Naturalized Aliens
B-276192 

categorizing these records,9 (3) matching (and filing) these records with

the appropriate INS case file for the naturalized alien, (4) assigning case

files to review adjudicators, and (5) ensuring that the case files were

consistently reviewed and contained a standardized worksheet

summarizing the results of the adjudicator’s review.10 Using a standardized

worksheet, INS adjudicators reviewed the case files of these aliens and

made independent judgments about the initial adjudication decisions. KPMG

monitored the review adjudicators’ work.

In addition to the 399 alien case files that INS could not locate, another

estimated 300 criminal history records were not available for review and

therefore were not included with the 80,856 criminal histories. The 300

criminal history records apparently had been in transit between the FBI

and INS and were received too late to be included in the INS review. KPMG

reported that INS’ preliminary assessment of the approximately 300 alien

criminal history records was that most of these aliens had only old

administrative arrests or were never naturalized. Furthermore, INS

concluded that even if the case files for these aliens had been received in

time for the review, very few of them would have been included in the INS

review.

KPMG Efforts to

Ensure Consistent

Decisions Among INS

Review Adjudicators

To help ensure consistency among the INS review adjudicators in their

decisionmaking, KPMG took a number of actions. These actions included

the following:

• teaching the adjudicators how to complete the standardized worksheets in

a consistent manner,

• checking the case files and standardized worksheets after the

adjudicators’ reviews were completed,

• requiring a total review of all daily work from any adjudicators for whom

significant errors in completing the standardized worksheets were found,

• requiring senior adjudicators to verify a sample of other adjudicators’

work each day, and

• identifying adjudicators’ recurring errors and providing additional

guidance to those adjudicators to avoid the recurrence of the errors.

9

The FBI’s search for criminal history records resulted in four categories of aliens: (1) aliens for whom

FBI criminal history records were identified (and were the focus of INS’ review); (2) aliens for whom

no criminal history records were identified after completing records checks; (3) aliens for whom full

records checks were not done because the fingerprints were unclassifiable (e.g., some of the

fingerprints on the card were illegible); and (4) aliens for whom the FBI could not determine if FBI

fingerprint checks were ever conducted.

10Adjudicators were to review only cases that were adjudicated outside of their home districts.

Page 6 GAO/GGD-98-62 Naturalized Aliens
B-276192 

In addition to the above actions, KPMG activities included (1) examining

and categorizing each criminal history record and verifying that the record

was part of the review, (2) safeguarding and securing files, and

(3) promoting consistency of review adjudicator decisions by having

discussions with the adjudicators when KPMG felt these discussions were

needed.

Results of INS’

Review

The INS adjudicators reviewed the case files of the 16,858 naturalized aliens

with criminal history records that included records of arrests for felonies

or other potentially disqualifying crimes to judge if the initial adjudications

were proper. The review results were based only on the data in the case

files at the time of the adjudicators’ reviews. In some cases, data may have

been removed from or added to the INS case files after the initial decisions

were made and before the files were reviewed. Also, although the

adjudicators who made the initial decisions to approve the aliens’

naturalization applications had the benefit of discussing the naturalization

applications with the aliens, the review adjudicators did not meet with the

applicants.

As shown in table 1, in its review of these 16,858 case files, INS designated

each case as either “proper,” “requires further action,” or “presumptively

ineligible.” According to INS officials, a case was designated as proper if

the data in the case file supported the initial decision to naturalize the

individual. A case was designated as requires further action if the data in

the case file were insufficient to support a proper decision yet did not

appear to indicate that the individual was barred from being naturalized.

For example, some case files did not contain data about the dispositions of

arrests that may have affected the individuals’ eligibility for naturalization.

Cases involving a failure to disclose an individual’s criminal history were

also classified as requires further action because the determination of

whether the failure to reveal the criminal history affected the individual’s

eligibility for naturalization required a legal determination that went

beyond the scope of the INS review. A case was designated as

presumptively ineligible if the data in the case file or the criminal history

appeared to indicate that the alien should have been barred from being

naturalized.

Page 7 GAO/GGD-98-62 Naturalized Aliens
B-276192 

Table 1: Results of INS Adjudicators’

Review of Alien Case Files Review results Number of cases Percentage of cases

Proper 10,535 62a

Requires further action 5,954 35

Presumptively ineligible 369 2

Total 16,858 100b

aKPMG rounded 62.49 percent to 63 percent.

bTotal does not add to 100 percent due to rounding.

Source: KPMG report.

INS is reviewing, for potential revocation, the 369 cases of those aliens who

were judged to be presumptively ineligible as well as the 5,954 cases

requiring further action.

EOIR Efforts to

Provide Quality

Assurance to the INS

Review

EOIR independently reviewed case files of previously naturalized aliens to

provide quality assurance that INS’ decisions during the review were

unbiased. EOIR reviewed a statistically valid sample of 557 alien case files

from the universe of 16,858 cases involving aliens who had criminal

history records. EOIR’s review was done separately from the INS

adjudicators’ review.

In conducting the review, EOIR teams of two staff each reviewed the alien

case files at the Lincoln Service Center. The initial EOIR team received an

orientation regarding the mechanics of properly completing the

standardized worksheet. The lead EOIR staff member returned to the

service center to provide the orientation to each subsequent team.

The EOIR reviewers and the INS review adjudicators had the same decisions

in 439 of the 557 cases (or 79 percent). Specifically, EOIR and INS

independently judged that 288 cases were proper, 147 cases required

further action, and 4 cases were presumptively ineligible (see table 2).

Page 8 GAO/GGD-98-62 Naturalized Aliens
B-276192 

Table 2: Comparison of INS and EOIR Decisions

EOIR decision

Decision type INS decision Proper

Requires further

action

Presumptively

ineligible Differences

Proper 360 288 68 4 72

Requires further action 187 36 147 4 40

Presumptively ineligible 10 1 5 4 6

Total 557 325 220 12 118

Note: The numbers shown in the table reflect the case files reviewed.

Source: KPMG report.

The results for the 118 cases in which INS and EOIR reached different

decisions were as follows:

• in 6 cases, INS judged that the aliens were presumptively ineligible, while

EOIR judged that in 1 of these cases the initial adjudication decision was

proper and in the other 5 cases further action was required by INS field

units;

• in 40 cases, INS judged that further action was required by its field units,

while EOIR judged that in 36 of these cases the initial adjudication

decisions were proper and in the other 4 cases the aliens were

presumptively ineligible; and

• in 72 cases, INS judged that the initial adjudication decisions were proper,

while EOIR judged that in 68 of these cases further action was required by

INS field units and in the other 4 cases the aliens were presumptively

ineligible.

Regarding the differences between the INS and EOIR decisions, KPMG

reported that much of the naturalization process and the review of case

file information required the reviewers to make subjective analyses.

Therefore, according to KPMG, it was highly improbable that the reviewers

would reach full agreement on all of the cases. KPMG stated that the major

contributing factor to differences in INS’ and EOIR’s judgments was the

interpretation of case file documentation regarding the applicants’

acknowledgment of prior criminal histories. KPMG added that, in many

cases, EOIR and INS reviewers had to make subjective decisions as to

whether sufficient case file documentation existed to justify their

decisions. KPMG concluded that a 79-percent agreement rate between EOIR

and INS reviewers was the most that could be reasonably expected when

considering that the two groups worked independently, had varied

Page 9 GAO/GGD-98-62 Naturalized Aliens
B-276192 

backgrounds, and had to make many subjective analyses. KPMG provided

no basis or analysis in its December report to support its conclusion that a

79-percent agreement rate was reasonable.

Our Analysis of the INS

and EOIR Review Results

We recognize the subjective nature of the reviews by the INS and EOIR

reviewers (i.e., the reviewers had to interpret the data in the case files).

We agree with the need to separate the two groups of reviewers to help

enhance EOIR’s quality assurance role. However, consistent with accepted

social science standards regarding training, it would have been helpful in

reviewing and interpreting the results of their reviews if the two groups

had received similar training. For example, before reviewing the case files,

the INS review adjudicators received training on the standardized

worksheet that they were to complete and received a training manual to

help them complete the standardized worksheet. On the standardized

worksheet, adjudicators were required to summarize the data in the aliens’

case files (e.g., arrest and conviction information) and evaluate the

naturalization decision to be made regarding the alien—that is, proper,

presumptively ineligible, or further action is required. The initial EOIR team

was provided with an orientation and the lead EOIR staff member was

responsible for providing the orientation to the other teams. However, the

EOIR staff did not receive the same training provided to the INS review

adjudicators even though they had to review the same files and complete

the same standardized worksheet. Thus, the lack of such training may

have contributed to some of the disagreement on the case files.

For the 21 percent of the cases where INS and EOIR reviewers disagreed, the

results were divided regarding which reviewer was more likely to judge

that a particular naturalization was proper. For example, in 68 cases that

INS judged were proper, EOIR judged that further action was required; in 36

other cases, EOIR judged them to be proper, but INS judged that further

action was required. Although in these examples more of the INS

judgments were in agreement with the initial adjudication, we could not

conclude that a statistically significant difference existed between the INS

and EOIR decisions. The agencies’ overall judgments produced generally

similar conclusions about the percentage of the naturalization decisions

that had been made properly. For example, INS and EOIR judged that

65 percent (360 divided by 557) and 58 percent (325 divided by 557) of the

cases were proper, respectively, and both INS and EOIR judged that

2 percent (10 divided by 557 and 12 divided by 557, respectively) of the

cases were presumptively ineligible.

Page 10 GAO/GGD-98-62 Naturalized Aliens
B-276192 

As previously discussed, INS is reviewing the 6,323 cases—that is, the 5,954

cases that INS judged as requiring further action and the 369 cases that INS

judged the aliens to be presumptively ineligible—for potential revocation.

However, INS initially did not plan any additional action regarding the 72

cases in which EOIR disagreed with INS’ judgment that the initial INS

adjudicators’ decisions were proper, which left unresolved questions

about the soundness of INS’ decisions in these cases. According to the INS

attorney involved with the review of the 6,323 cases for potential

revocation, INS did not know about the 72 cases. After we questioned what

was being done with these cases, the attorney said that the 72 cases would

be included with the 6,323 cases being reviewed. According to KPMG, JMD

requested a list of the 72 cases, which KPMG provided on January 23, 1998.

According to INS, it has located the 72 case files to be reviewed for

potential revocation.

Limiting Conditions of

the INS Review

In its December report, KPMG identified a number of conditions that may

have had an effect on the accuracy and completeness of INS’ review of its

initial naturalization decisions. KPMG could not quantify the degree to

which these conditions may have affected the ultimate decisions that the

INS review adjudicators reached. These limiting factors included the

following:

• The primary source of naturalization information came from an INS data

system (Central Index System) that often has been found to be inaccurate.

• The differences in the INS and FBI information systems made it difficult to

compare the INS records of naturalized citizens with the FBI criminal

history records on aliens.

• INS was unable to locate 399 case files at the time of its review.

• The case file documentation varied significantly among INS offices;

therefore, the case file documentation cannot be relied upon to definitively

determine if the naturalization occurred.

• The INS review adjudicators’ decisions may not be the same as the

decisions they might have made in their home units for various reasons,

such as multiple state penal codes with which the review adjudicators had

little experience and criminal history records that had unclear descriptions

of arrests and very often did not record the ultimate disposition of arrests.

In our opinion, another limiting condition of the adjudicators’ review was

their need to totally rely on the information in the case files. Information

may have been added to or removed from the case files after the initial

adjudication was made and before KPMG took control of the files.

Page 11 GAO/GGD-98-62 Naturalized Aliens
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Conclusions INS reviewed the case files of 16,858 aliens with criminal history records

who had been naturalized between August 31, 1995, and September 30,

1996. Subject to the limitations KPMG and we identified, INS judged that the

case files of 6,323 aliens did not have sufficient information to determine if

naturalization was proper or contained information that the aliens may

have been improperly naturalized. INS is reviewing these cases for

potential revocation.

To provide quality assurance that INS’ decisions during the review were

unbiased, EOIR reviewed a statistically valid sample of 557 alien case files

from the universe of 16,858 aliens. Our analysis showed that EOIR’s and INS’

overall judgments produced generally similar conclusions about the

results—that is, the proportion of naturalization cases found to be proper,

to require further action, and to be presumptively ineligible.

However, for 72 of the cases that INS review adjudicators had judged were

properly naturalized, EOIR staff judged that further action was required to

decide whether the initial adjudications were proper or the aliens were

presumptively ineligible. At the time of our review, INS initially was not

planning any further action to judge if the naturalization decisions for the

72 cases were appropriate, thus leaving unresolved questions about the

soundness of INS’ decisions in these cases. After we discussed the 72 cases

with an INS attorney involved with reviewing the cases for potential

revocation, he said that these cases are being reviewed with the other

6,323 cases.

The overall approach KPMG employed to monitor INS’ judgments followed

accepted social science standards. The standards KPMG used included

(1) establishing procedures to ensure the appropriate collection and

review of FBI criminal history records and the review of related alien case

files, (2) promoting consistency in the judgments of INS adjudicators by

providing training and using a standardized worksheet, and (3) identifying

recurring adjudicator errors so that corrective action could be taken. In

addition, KPMG’s report disclosed limitations in the study procedures

followed and discussed conditions that may have affected the accuracy

and completeness of INS’ review.

KPMG concluded that the 79-percent agreement rate between INS and EOIR

reviewers was the most that could be expected. Although KPMG did not

disclose its basis for this conclusion, it seems reasonable to us that

providing the EOIR staff with training similar to that provided to INS’ review

Page 12 GAO/GGD-98-62 Naturalized Aliens
B-276192 

adjudicators might have helped to reduce any differences in how the two

groups reached their decisions.

Agency Comments

and Our Evaluation

On February 19, 1998, we met with officials from JMD, INS, EOIR, and KPMG

who represented those organizations responsible for the data discussed in

our report and provided the views of those organizations. The officials

represented the Director of the Management and Planning Staff, JMD; the

Director, EOIR; the Commissioner, INS; and the Principal, KPMG. These

officials agreed with our draft report, including its conclusions, and

provided clarifying suggestions, which we included in this final report

where appropriate.

Our draft report contained a recommendation that the Commissioner of

INS ensure that its Office of General Counsel follow through with its plans

to analyze the 72 cases along with the other 6,323 cases that INS is

reviewing for potential revocation. During our discussion with the

officials, they said that INS is now taking action to review these 72 case

files. Accordingly, we deleted the recommendation from this report.

We are providing copies of this report to the Attorney General; the

Commissioner, INS; the Director, EOIR; the Director, Management and

Planning Staff, JMD; the Director, Office of Management and Budget; KPMG;

and other interested parties. Copies will also be made available to others

upon request.

Major contributors to this report were James M. Blume, Assistant Director;

Barry Jay Seltser, Assistant Director; James M. Fields, Senior Social

Science Analyst; Ann H. Finley, Senior Attorney; Michael H. Little,

Communications Analyst; and Charlotte A. Moore, Communications

Analyst. If you need any additional information or have any questions,

please contact me on (202) 512-8777.

Norman J. Rabkin

Director, Administration

 of Justice Issues

(183610) Page 13 GAO/GGD-98-62 Naturalized Aliens
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