Department of Homeland Security 

Office of Inspector General 

U.S. Citizenship and Immigration Services' 


Implementation of the Kendell Frederick 


Citizenship Assistance Act
 

OIG-10-39 January 2010 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

January 25, 2010 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of U.S. Citizenship and Immigration 

Services’ (USCIS) implementation of the Kendell Frederick Citizenship Assistance Act. 

It is based on interviews with employees and officials of relevant agencies and 

institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

Richard L. Skinner 


Inspector General 

 

Table of Contents/Abbreviations 


Executive Summary................................................................................................................1
 

Background.............................................................................................................................2
 

Results of Audit ......................................................................................................................7
 

Implementation of the Act ..........................................................................................7
 

Technology Initiatives and Challenges.....................................................................14
 

Privacy ......................................................................................................................21
 

Recommendations.....................................................................................................22 


Management Comments and OIG Analysis .........................................................................23 


Appendices

 Appendix A: Scope and Methodology.............................................................................25 


Appendix B: Management Comments to the Draft Report .............................................27 


Appendix C: Major Contributors to This Report.............................................................30 


Appendix D: Report Distribution.....................................................................................31 


Abbreviations 

BBSS Benefits Biometric Support System 

CIS Central Index System 

CLAIMS 4 Computer Linked Application Information Management System

 version 4 


DOD Department of Defense 

DHS Department of Homeland Security 

FBI Federal Bureau of Investigation 

FY fiscal year 

IDENT Automated Biometric Identification System 

IT information technology 

NSC Nebraska Service Center 

OIG Office of Inspector General 

PIA Privacy Impact Assessment 

USCIS United States Citizenship and Immigration Services 
 

 

 

 

 

Table of Contents/Abbreviations 


Figures
 

Figure 1: USCIS Organization Structure for Processing Military Naturalizations.. 3 


Figure 2: Military Naturalization Process............................................................... 4 


Figure 3: Fingerprint Resubmission Process .......................................................... 8 


Figure 4: Rejection Rate of Fingerprint Resubmissions....................................... 10 


Figure 5: Average Military Naturalization Processing Time (FY 2009).............. 11 

 

OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

In June 2008, Congress passed the Kendell Frederick Citizenship 

Assistance Act to streamline the process for U.S. military service 

members seeking to become U.S. citizens. The act directs the 

Secretary of Homeland Security to accept fingerprints submitted 

by military citizenship applicants at the time of their enlistment or 

from prior submissions to the Department of Homeland Security, 

expedite the processing of citizenship applications, and implement 

procedures to ensure rapid electronic transmission of biometric 

information and safeguarding of privacy. As directed by the 

Congress, we assessed USCIS’ implementation of (1) the act’s 

requirements, including an assessment of the technology used to 

improve the efficiency of the naturalization process for members 

of the United States Armed Forces and (2) the impact of this act on 

privacy and civil liberties. 

USCIS has taken actions to meet the act’s requirements. 

Specifically, USCIS has implemented a process to use previously 

submitted fingerprints for military naturalizations, and it tracks and 

reports processing time to ensure that it completes adjudication of 

applications timely. USCIS has also undertaken several 

information technology initiatives to improve the military 

naturalization process. However, USCIS’ information technology 

systems, such as the application processing system and background 

check support systems, do not meet all user requirements. As a 

result, personnel must devote resources to work around system 

limitations. Further, USCIS had not yet completed a privacy 

assessment for its process to obtain enlistment fingerprints from 

partner agencies. Without such an assessment, we were unable to 

assess whether that process was properly safeguarded. 

We are recommending that USCIS: (1) address those requirements 

not met by existing information technology systems through its 

ongoing information technology transformation process; (2) 

implement mobile fingerprint capabilities overseas; (3) pursue 

expanding the use of video teleconference technology in the 

naturalization process; and (4) finalize the privacy impact 

assessment for the system used to store fingerprints obtained from 

partner agencies. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Background 

More than 45,000 noncitizen soldiers serve in the United States 

military, many of them on active duty in Afghanistan and Iraq. 

The United States seeks to provide these foreign-born men and 

women the opportunity to become naturalized U.S. citizens. The 

federal government has made efforts to make it easier for 

noncitizen soldiers to apply for citizenship. In the summer of 

2002, President Bush signed Executive Order 13269 to expedite 

the naturalization process, temporarily waiving the application fee 

and the period of service requirement. Since September 2001, 

more than 47,000 service men and women, including more than 

6,000 service members naturalized in ceremonies overseas and 

onboard Navy flagships at sea, have become U.S. citizens. 

The case of one noncitizen soldier, U.S. Army Reserve Specialist 

Kendell Frederick, brought attention to needed improvements in 

the naturalization process for military personnel. Specialist 

Frederick, a citizen of Trinidad and a resident of Randallstown, 

Maryland, was on active duty in Iraq serving as a U.S. Army 

generator mechanic. He sought U.S. citizenship for more than a 

year, applying three times and filling out multiple forms. In 

October 2005, as part of the naturalization process, Specialist 

Frederick was required to submit fingerprints. While returning 

from an off-base location to submit these fingerprints, he was 

killed by a roadside bomb. 

In response to Specialist Frederick’s death, Congress passed the 

Kendell Frederick Citizenship Assistance Act (Public Law 110­

251) in June 2008 to streamline the process for soldiers seeking to 

become U.S. citizens. The act directs the Secretary of Homeland 

Security to ensure proper coordination and expedite the processing 

of citizenship applications filed by military personnel. 

Specifically, the law directs the Department of Homeland Security 

(DHS) to accept fingerprints or other biometrics information 

submitted by applicants at the time of their enlistment or from 

prior submissions to USCIS. The act also requires that DHS 

ensure that the privacy of biometric information provided by 

military personnel, including fingerprints, is safeguarded. 

USCIS is the component within DHS responsible for the 

naturalization process.1

 USCIS’ mission is to secure America’s 

promise as a nation of immigrants by providing accurate and useful 

information to its customers, granting immigration and citizenship 

1 6 U.S.C. § 271(b). 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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benefits, promoting an awareness and understanding of citizenship, 

and ensuring the integrity of the immigration system. 

The Domestic Operations Directorate, which reports to the 

Director of USCIS, leads the military naturalization process 

domestically. The International Operations Division manages the 

naturalization process overseas and works in collaboration with the 

Domestic Operations Directorate, although it is organizationally 

situated in a separate directorate. Several divisions within 

Domestic Operations are responsible for carrying out the military 

naturalization process. As part of the Service Center Operations 

Division, a specialized team at the Nebraska Service Center (NSC) 

conducts centralized processing of military naturalizations. Under 

the Field Operations Division, USCIS has four regional offices, 26 

districts with 90 field and support offices, and 136 Application 

Support Centers to carry out operations throughout the United 

States. Figure 1 shows the major organizational entities within 

USCIS responsible for the military naturalization process. 

Figure 1: USCIS Organization Structure for Processing Military Naturalizations 

To manage issues unique to military personnel effectively, USCIS 

has created a working group with members from its organizational 

divisions involved in military services, including naturalizations. 

The group meets on a weekly basis to discuss a variety of topics 

that include process improvements, policy formulation, issues 

raised by field offices and service centers, quality assurance, public 

outreach efforts, interoffice coordination, customer service 

improvements, and compliance with executive orders, laws, and 

agency directives. USCIS also conducts quarterly meetings to 

coordinate with the Department of Defense (DOD) to ensure 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

Page 3 
collaboration and communication in providing immigration 

services to military personnel. 

The Immigration and Nationality Act provides that all legal 

permanent residents may potentially become citizens through a 

process of naturalization.2

 Military service members are given 

priority to become citizens, and the process for naturalizing them is 

unique. Figure 2 shows the naturalization process for military 

applicants and supporting technology systems. 

Figure 2: Military Naturalization Process 

Service members applying for naturalization must submit to 

USCIS an Application for Naturalization, a certified Request for 

Certification of Military or Naval Service, and the Biographic 

Information Form, as well as a permanent resident card, if 

applicable; passport-style photos; and fingerprints for background 

and security checks. Service members may seek assistance from 

their designated military points of contact to complete their 

naturalization application packets. 

Processing military applications is centralized in the Military 

Naturalization Unit at the NSC. A specialized team, staffed with 

16 Immigration Service Officers, processes about 800 military 

naturalization applications each month. The team performs initial 

data entry into the Computer Linked Application Information 

Management System version 4 (CLAIMS 4). CLAIMS 4 is an 

electronic case management system that offers automated support 

for a variety of tasks associated with processing and making an 

eligibility determination for immigration benefits. CLAIMS 4 is 

used to receive applications, input application information, 

2 Immigration and Nationality Act, Public Law 82-414, Title 3, Chapter 2. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

Page 4 
schedule interviews and oath ceremonies, and track benefit 

determinations. 

The NSC also initiates the following three required background 

and security checks: 

�	 Federal Bureau of Investigation (FBI) fingerprint check – 

NSC personnel submit an applicant’s fingerprints to the 

FBI for a criminal background check. USCIS uses its 

Benefits Biometric Support System (BBSS) to submit 

fingerprints and access the results of the check. 

�	 FBI name check – NSC personnel submit an applicant’s 

name and date of birth to the FBI to check against the FBI’s 

database of personnel, administrative, applicant, and 

criminal files compiled for law enforcement purposes. 

�	 DOD record check – The NSC also obtains copies of any 

records of military investigations during the applicant’s 

period of service from a DOD database. 

Once data entry and background checks are completed, the 

application is adjudicated and the applicant is interviewed. As part 

of adjudication, an immigration officer reviews the application 

packet, as well as any information received during the background 

and security check process, that may affect the service member’s 

eligibility to naturalize. The immigration officer may conduct 

additional security checks for national security risks, public safety 

issues, current or past targets of investigation, and other law 

enforcement concerns. The immigration officer interviews the 

service member, confirms the applicant’s identity, and determines 

if he or she is eligible for naturalization. For applicants stationed 

in the United States, the NSC sends the application to a field office 

near the address provided by the applicant for adjudication. For an 

applicant being processed overseas, the NSC prepares the file and 

Certificate of Naturalization and sends the file to an overseas office 

for adjudication. 

The final step for approving naturalization applicants is the oath 

ceremony. Upon completion of the oath, USCIS issues a 

Certificate of Naturalization to the service member as evidence of 

U.S. citizenship. For applicants stationed in the United States, 

field office personnel update CLAIMS 4 to reflect the completion 

of that process. Field office personnel also update USCIS’ Central 

Index System (CIS), a central repository of key USCIS information 

that is used for several purposes including determination of 

immigration benefits. For overseas applicants, the immigration 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

Page 5 
officers return the files to the NSC to perform all necessary 

updates in CLAIMS 4 and CIS. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Results of Audit 

Implementation of the Act 

USCIS has taken actions to meet the requirements of the Kendell 

Frederick Citizenship Assistance Act. Specifically, USCIS has 

implemented a process to obtain and use fingerprint records that 

were taken at the time of the service member’s enlistment or those 

provided to USCIS during previous immigration applications. In 

addition, USCIS tracks and reports military naturalization 

processing time to ensure that it completes adjudication of 

applications timely. Further, to improve the military naturalization 

process and better mitigate the risk to military personnel seeking 

benefits overseas, USCIS has initiated a military outreach program 

to naturalize military personnel before they travel overseas. As a 

result, USCIS has improved the efficiency of processing military 

naturalization applications and reduced the need for military 

applicants to travel to obtain fingerprints, thereby minimizing the 

potential risks to overseas applicants. 

Use of Previously Submitted Fingerprints for Military Naturalization Applications 

The act requires the Secretary of Homeland Security to use 

fingerprints taken at the time of enlistment, or from prior 

submission to USCIS, to satisfy the requirements for background 

and security checks in connection with an application for 

naturalization.3

 Further, the act requires that the Secretary of 

Homeland Security work with DOD and the FBI to implement 

procedures to ensure the rapid electronic transmission of biometric 

data, including previously submitted fingerprints records. These 

procedures were to be in place by June 2009, 1 year after 

enactment of the law. 

After Specialist Frederick’s death in 2005, USCIS recognized the 

difficulties that service members face when attempting to submit 

new fingerprints while deployed overseas. To address these 

obstacles, USCIS developed a process for obtaining previously 

submitted fingerprints for military naturalization purposes. It 

implemented the process and began accepting previously 

submitted fingerprints in May 2006, nearly 3 years before the June 

2009 deadline. 

3

 The act applies to only those individuals applying for naturalization within 24 months of military 

enlistment. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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The process that USCIS implemented relies on collaboration with 

the FBI to obtain prior fingerprint records and resubmission of 

those prints through the existing fingerprint check system. USCIS 

has personnel located at an FBI facility who serve as liaisons with 

the FBI to assist with the background check process. The NSC 

provides the liaison a list of applicants’ names. The liaison first 

checks USCIS systems for fingerprints previously submitted to 

USCIS for immigration purposes. Specifically, the liaison checks 

BBSS to see if the applicant has a current fingerprint check result.4 

If there is no current result, the liaison checks the Automated 

Biometric Identification System (IDENT), the official biometric 

repository for DHS. If there are no prior USCIS prints, the liaison 

checks FBI repositories for fingerprints submitted by the applicant 

at the time of enlistment. 

If previous fingerprints are found, the liaison returns the fingerprint 

records on a compact disc to the NSC. Personnel at the NSC 

format these fingerprints from the compact disc and submit them 

through BBSS to the FBI for the required background check. 

Figure 3 diagrams the process for obtaining and resubmitting prior 

fingerprints. 

Figure 3: Fingerprint Resubmission Process 

The fingerprint resubmission process implemented by USCIS has 

enabled it to obtain prior fingerprint records for military applicants, 

making the naturalization process easier and minimizing the risk of 

overseas applicants being harmed. As of February 2009, USCIS 

successfully obtained and reused prior fingerprints for 5,771 

military applicants since starting the process in 2006. 

4 Fingerprint check results are current for 15 months as determined by DHS policy. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Previously Submitted Fingerprints Not Used for All Applicants 

Although successful, the fingerprint resubmission process has not 

eliminated the need for military applicants to obtain new 

fingerprints in all cases. For domestic applicants, obtaining new 

fingerprints is generally faster than locating previously submitted 

prints. In addition, previously submitted fingerprints cannot be 

found in some cases, and the FBI sometimes rejects them due to 

their poor quality. 

After notifying the applicant, the act permits USCIS to obtain new 

fingerprints for military applicants if it is quicker and more 

efficient than using previously submitted fingerprints. USCIS can 

digitally obtain fingerprints from service members at one of its 136 

Application Support Centers throughout the country. The center 

submits the fingerprints electronically to the FBI through BBSS 

and normally receives results between 2 and 24 hours after 

submission. Since the process is faster, USCIS encourages 

military applicants applying domestically to visit an Application 

Support Center to submit new fingerprints. 

In some cases, new fingerprints are necessary because previously 

submitted fingerprint records cannot be located. Fingerprints 

submitted prior to 2000, when USCIS started storing electronic 

fingerprints, are not available in IDENT. Further, fingerprints 

from the time of enlistment cannot always be found. USCIS 

reported that the FBI cannot locate 15% to 20% of requested 

prints. It can be difficult to locate enlistment prints because the 

paper-based and electronic prints are stored with the prints for all 

DOD personnel, including civilian employees and contractors. 

Therefore, locating fingerprints taken at the time of enlistment can 

be a highly labor-intensive and lengthy process. 

Furthermore, fingerprints that are located are not always of 

sufficient quality to be accepted by the FBI for conducting a 

background check. Between 2006 and 2008, USCIS reported that 

approximately 15% of fingerprints from the time of enlistment 

were rejected when resubmitted. A USCIS official reported that 

when the component first implemented the fingerprint 

resubmission process, many applicants had older enlistment prints 

taken with ink and paper. These prints are of insufficient quality to 

resubmit successfully for a new background check. As the number 

of older ink-and-paper prints has decreased, the rejection rate has 

decreased. Figure 4 shows the rejection rate for fingerprint 

resubmissions since the process started in 2006. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Figure 4: Rejection Rate of Fingerprint Resubmissions 

When prior fingerprint records cannot be used, military personnel 

stationed overseas may still face challenges in obtaining 

fingerprints for naturalization purposes. Overseas applicants can 

have new fingerprints taken at a U.S. Embassy, Consulate, or 

USCIS field office. Prints taken at these locations are taken using 

a fingerprint card and are mailed to the NSC. These hardcopy 

prints, however, are not always well done and are sometimes 

unusable due to their poor quality. In addition, for military 

applicants stationed in a warzone, travelling to have fingerprints 

taken could be potentially dangerous. For this reason, USCIS now 

notifies military applicants that they should not travel to have 

fingerprints taken if it will put them in any danger. 

Tracking Processing Times 

The Kendell Frederick Citizenship Assistance Act requires DHS to 

expedite the processing of military naturalization applications and 

complete adjudication within 6 months from the receipt of all 

background check results. In addition, the Military Personnel 

Citizenship Processing Act, passed 4 months later in October 2008, 

changes the 6-month deadline for adjudication to start from the 

receipt of an application. Starting the processing metric at the time 

of receipt of the application, rather than after completion of all 

background checks, encourages USCIS to complete the 

naturalization process within a shorter timeframe. 

USCIS has implemented a process to track and report military 

naturalization processing time. The NSC date stamps all military 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

Page 10 
naturalization applications upon receipt to identify the starting 

point for the 6-month deadline. To ensure conscientious 

monitoring, USCIS produces a monthly report on the status of 

pending cases. USCIS field office personnel are responsible for 

addressing each case on the report and providing an update on 

actions taken to adjudicate the case. USCIS’ four regional offices 

and the International Operations Division oversee that the field 

offices address any pending applications that are nearing the 

deadline. If an application exceeds the 6-month deadline, the 

report tracks when the NSC notifies the applicant of the reasons for 

the delay. 

As a result of these efforts, USCIS has reduced the processing time 

for military naturalization applications. As shown in Figure 5, the 

average processing time for military naturalizations has improved 

from 9.1 months since USCIS started tracking this information in 

October 2008 to 4.2 months as of July 2009. 

9.1 8.9 8.8 8.7

8.2 8.1

7.8

6.3

5.4

4.2

0

1

2

3

4

5

6

7

8

9

10

Time (in months) 

Oct Nov Dec Jan Feb Mar Apr May Jun Jul

Figure 5: Average Military Naturalization Processing Time (FY 2009) 

In addition, the inventory of pending military naturalization 

applications has decreased. The number of pending applications at 

the NSC was reduced from 4,537 in October 2008 to 1,955 as of 

May 2009. 

Although USCIS has reduced processing time, some applications 

have taken longer than 6 months to process. Naturalization 

applications may take longer than 6 months to adjudicate for 

several reasons. For example, during initial processing at the NSC, 

obtaining fingerprints and receiving incomplete Certifications of 

Military of Naval Service are the most common causes of delays. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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At field offices, delays are attributable to USCIS’ inability to 

locate the service member due to deployment, change of duty 

station, or discharge from the military. Between October 2008, 

when USCIS started tracking applications, and February 2009, 371 

military naturalization applications that were eventually approved 

took more than 6 months to process.5 However, these applications 

comprised only 8% of the 4,489 military naturalizations processed 

during that period. 

Military Outreach 

In June 2008, just before the Kendell Frederick Citizenship 

Assistance Act was passed, USCIS began an initiative to improve 

customer service and outreach to the military. A major goal of this 

initiative was to naturalize qualified service members domestically, 

as soon after enlistment as possible and before deployment 

overseas. USCIS officials reported that one of the best ways to 

prevent placing additional military members in the situation 

Specialist Frederick faced is to complete naturalization 

domestically. In addition to the dangers they face, military 

applicants overseas are more difficult to keep track of due to 

frequent location changes. 

The military outreach initiative has two phases. First, field office 

directors are responsible for planning activities, such as identifying 

a military liaison at each military installation within their 

jurisdiction and coordinating an initial planning meeting. Second, 

field office directors are responsible for implementation activities, 

such as developing a plan with their military liaison to create a 

monthly schedule of individual service member appointments to 

discuss their specific immigration cases, and for providing services 

at the military installations whenever possible. Field offices are 

required to provide monthly reports on the outreach activities 

conducted. 

The San Diego District Office is one example of USCIS 

successfully working with local military installations to provide 

customer service. In FY 2008, the San Diego District Office 

processed the largest number of military naturalizations of any 

field office. Officials at the San Diego District Office reported that 

outreach has evolved from periodic activities, such as special 

naturalization ceremonies and quarterly staff consultation visits, to 

an integrated and comprehensive program-like effort. For 

example, the San Diego District Office holds bimonthly meetings 

with military liaisons to establish a consistent channel of 

5

 Data were not made available beyond February 2009. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

Page 12 
communication. In addition, the district has established military 

liaisons to serve as points of contact for routine case-specific 

communications as well as emergency communications to respond 

to and resolve issues efficiently. As a result of the San Diego 

District Office’s partnership with the local military, USCIS 

personnel in this district can more easily reach out and naturalize 

military personnel before they are deployed overseas. 

Since October 2008, USCIS field offices have participated in more 

than 3,000 immigration-related activities on military installations 

throughout the country. These efforts have helped USCIS begin 

the naturalization process as early as possible after enlistment. For 

example, in August 2009, USCIS staff naturalized noncitizen 

Army soldiers during their basic combat training at Fort Jackson in 

South Carolina. This ceremony marked the first time that USCIS 

naturalized service members during basic training. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Technology Initiatives and Challenges 

USCIS has undertaken several IT initiatives to improve the 

military naturalization process. Specifically, USCIS has improved 

customer service through the implementation of a toll-free help 

line and web page updates. Further, USCIS has begun using 

mobile fingerprint units and video teleconferences to improve the 

efficiency of the naturalization process. However, USCIS’ IT 

systems, such as the application processing system and background 

check systems, do not meet all user requirements. As a result, 

personnel must devote resources to work around system 

limitations. As identified in prior OIG reports, improvements to 

these systems have largely been put on hold in anticipation of the 

USCIS IT modernization and transformation effort, which faces 

ongoing challenges and delays. 

Technology Initiatives 

The Paperwork Reduction Act of 1995 requires that agencies 

promote the use of information technology to increase the 

productivity, efficiency and effectiveness of their program 

operations.6

 USCIS has implemented new technology to improve 

the naturalization process domestically and to avoid endangering 

service members serving overseas. Specifically, USCIS has 

established a toll-free number and updated its websites to provide 

guidance and assistance to military personnel. In addition, USCIS 

has begun using mobile fingerprint units domestically, and is 

working to obtain them for use overseas to reduce the need for 

military applicants to travel to have fingerprints taken. USCIS has 

also used video teleconference technology for preliminary 

interviews for soldiers serving in Iraq. 

Toll-free Number and Website 

In August 2007, USCIS implemented a toll-free military helpline 

and e-mail services to assist service members who are applying for 

naturalization. The helpline staff answers questions relating to the 

forms required for naturalization and immigration petitions filed by 

military applicants or their family members. Service members also 

contact the helpline to change scheduled interview appointments 

and to update their address information. In addition, USCIS has 

established several e-mail inboxes to assist military applicants with 

their naturalization applications, including one for general 

questions and one specifically for questions relating to fingerprints. 

6 44 U.S.C. § 3506(h)(3). 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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USCIS estimates that it receives 1,400 to 1,500 helpline calls per 

month, and it has received 6,800 e-mails since the e-mail service 

was established. 

USCIS has also improved its website to provide better guidance to 

military personnel. These improvements include posting updates 

on modifications to the naturalization process, along with updating 

the website’s frequently asked questions and fact sheet 

periodically. Further, USCIS allows military personnel deployed 

overseas to enter their military mailing address on the website to 

receive additional information that is unique for overseas 

applicants. 

Mobile Fingerprint Units 

To improve customer service and avoid processing delays, USCIS 

has implemented mobile technology to capture fingerprints. 

Mobile fingerprint units, which consist of a laptop connected to a 

fingerprint scanner, allow USCIS to collect biometrics on military 

installations. Currently, there are a limited number of mobile 

fingerprint units, with one located at each of USCIS’ four domestic 

regional offices. 

Although USCIS has not yet deployed mobile fingerprint units 

overseas, it is developing plans for overseas deployment. USCIS’ 

International Operations Division’s strategic plan lists deploying 

standardized biometrics capture capability to international field 

offices as an objective. At the time of our audit, USCIS did not 

have enough of the biometrics capture devices to implement this 

plan. Until recently, USCIS was unable to obtain additional units 

because its Office of Information Technology was assessing 

suppliers and the technology, a process that lasted 2 years. 

Recently, the Office of Information Technology approved the use 

of 32 new units, and it is working with the International Operations 

Division to deploy the mobile fingerprint units overseas. USCIS 

plans to deploy the units internationally by FY 2010. 

Video Teleconference 

USCIS has also begun to implement video teleconferencing. The 

USCIS district office in Rome has used video teleconferencing 

technology to conduct preliminary interviews with members of the 

armed forces deployed in some areas of Iraq. DOD supports the 

use of remote preliminary interviews because it reduces the 

number of days a service member is away from his or her mission 

and minimizes travel for the applicants. A regular in-person 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

Page 15 
 

interview takes approximately 20 minutes. If a preliminary 

interview has been conducted via webcam, however, the in-person 

interview takes approximately 10 minutes per service member to 

complete and finalize the process. Using video teleconferencing 

also may reduce the amount of time USCIS staff are required to 

spend in war zones. The USCIS district office in Bangkok, which 

has jurisdiction over Afghanistan, is exploring the use of similar 

web-based or video conferencing technology to expedite further 

the naturalization cases of service members deployed there. 

USCIS does not, however, use video teleconference technology to 

conduct the entire interview or the oath ceremony for service 

members deployed in war zones. According to the Code of 

Federal Regulations, a USCIS officer must conduct an in-person 

interview of a naturalization applicant.7 Under the Immigration 

and Nationality Act an applicant must take the oath of citizenship 

in a public ceremony before the Attorney General or in a court 

with appropriate jurisdiction.8

 At the time of this audit, USCIS 

was reviewing whether video teleconference technology would 

meet the requirements of the law for an in-person interview and 

public oath. 

Use of video teleconference for the entire interview and oath 

process could eliminate several challenges associated with 

naturalizing military personnel in a warzone. First, DOD cannot 

always accommodate a USCIS request for ceremonies in Iraq and 

Afghanistan, which can delay the naturalization process for an 

applicant. For example, a recent USCIS request to DOD to 

conduct a February 2009 naturalization ceremony in Afghanistan 

was declined. The oath ceremony was delayed 4 months, until 

Memorial Day of 2009. In addition, once allowed to enter a war 

zone, USCIS staff faces the logistical challenge of bringing 

together many service members from multiple locations to conduct 

the interviews and the oath ceremony. Again, service members 

who must travel in a warzone for naturalization purposes confront 

risks similar to those that Specialist Frederick faced when he left 

his base to have his fingerprints taken. 

Technology Challenges 

Under the Paperwork Reduction Act of 1995 and the ClingerCohen Act, agencies are required to acquire, manage, and use IT to 

7

 8 C.F.R. § 335.2(a). 


8

 Immigration and Nationality Act, Public Law 82-414, Sec. 337(a). 


U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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improve mission performance.9

 USCIS’ IT systems, however, 

could better support the military naturalization process. 

Specifically, the application support system CLAIMS 4 and the 

background check systems do not fully meet all user requirements. 

In addition, we reported previously that the existing technology 

environment did not adequately support business processes, and 

the IT transformation program to modernize USCIS IT continues 

to face challenges and delays.10 

Application Processing System 

The primary system for adjudication of naturalization applications, 

CLAIMS 4, does not meet certain business process requirements. 

USCIS uses the windows-based CLAIMS 4 database program as 

its primary system to receive naturalization applications, input 

application information, schedule interviews, track adjudication 

activity, and record completion of oath ceremonies. USCIS 

headquarters officials stated that CLAIMS 4 is a useful tool 

compared with a manual process, and it enables them to track the 

application from receipt to taking the oath. However, the system 

has data sharing, availability, and reporting limitations. 

Data Sharing 

Data transfer for completed naturalization applications from 

CLAIMS 4 to the Central Index System (CIS) is ineffective. CIS 

provides a central repository of key USCIS information that is used 

for several purposes including determination of immigration 

benefits. When a military naturalization case is completed in 

CLAIMS 4, the status is updated in CIS. However, postnaturalization mismatches can occur when the field office closes 

out the case in CLAIMS 4 and the information does not match the 

information in CIS. Data may not match if, for example, an 

individual’s name changed between the time it was first entered 

into CIS for an immigration visa and potentially many years later 

when the individual completes a citizenship application. When a 

mismatch occurs, the naturalization information does not upload 

into CIS automatically, and must be updated manually.11 

9 Paperwork Reduction Act of 1995, Public Law 104-13, May 22, 1995; and the Clinger Cohen Act of 1996,
 

Public Law 104-106, Division E, Subtitle C, February 10, 1996. 
 10 USCIS Faces Challenges in Modernizing Information Technology, OIG-05-41, September 2005; U.S.
 

Citizenship and Immigration Services’ Progress in Modernizing Information Technology, OIG-09-90, July 


2009. 


11 This ongoing data sharing issue was identified in our September 2005 report, USCIS Faces Challenges in
 

Modernizing Information Technology, OIG-05-41.
 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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As a result, USCIS personnel must devote additional time and 

resources to correct each mismatch. Specifically, each week the 

Field Operations Division publishes a post-naturalization mismatch 

report on its intranet website. This report lists all naturalization 

cases where certain data fields in CLAIMS 4 do not match the data 

fields in CIS. The field offices have 10 days after the report is 

posted to correct the errors in CIS and report to the CLAIMS 4 

service desk that the error was corrected. Once the error is 

reported to the service desk, the service desk corrects the problem 

in CLAIMS 4 and removes it from the mismatch report. Cases that 

remain unresolved are moved to the archives until the field offices 

make the necessary corrections. 

Availability 

The CLAIMS 4 system has limited availability internationally. 

Frankfurt, Rome, and Seoul are the only overseas offices with user 

access to CLAIMS 4 due to connectivity limitations overseas. 

Even at these locations, the system connectivity is weak, making it 

slow to use. Since overseas staff resources are limited, CLAIMS 4 

is inefficient to use except in certain circumstances. For example, 

the Rome office accesses CLAIMS 4 to correct an error on 

naturalization paperwork or make other simple updates to an 

applicant’s file. However, the Rome field office cannot perform 

more significant updates, such as closing an application upon 

completion of the naturalization process, because of the weak 

connectivity. 

Limited availability of CLAIMS 4 overseas is caused by 

insufficient bandwidth for accessing the system. USCIS relies on 

the Department of State (State) for network access; however, State 

cannot provide USCIS field offices with sufficient bandwidth to 

meet their requirements. A USCIS official reported that State does 

not have enough bandwidth to provide more for USCIS. To obtain 

more bandwidth, USCIS would have to contract service 

independently from State, which would be too expensive according 

to a USCIS official. 

As a result, overseas field offices rely largely on inefficient paperbased processes. For significant updates to CLAIMS 4, overseas 

offices mail the paper files to the NSC. For example, upon 

completion of the naturalization process, field offices overseas 

mail files to the NSC to close out the application in CLAIMS 4. 

The files take a week to arrive at the NSC. The NSC must then 

review, process, and backdate the information—a process that can 

take up to 3 days, depending on other NSC office priorities. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Reporting 

The CLAIMS 4 system does not provide sufficient reporting 

capability to meet business needs in all cases. For example, 

officials at the NSC reported that in order to track the status of 

military naturalizations, it must produce a high volume of reports. 

However, CLAIMS 4 does not provide reports with sufficient 

detail to meet reporting requirements, specifically with regard to 

the reasons cases are pending. 

As a result, the NSC is devoting staff resources to create and 

maintain its own independent database. The NSC developed the 

Access Military Database, an ad hoc database using Microsoft 

Access, to meet reporting requirements. Personnel at the NSC 

enter data on each application into the Access Military Database to 

track the specific reasons the application is pending and any forms 

that are still required. NSC officials said that keeping up with the 

reporting requirements for oversight is time consuming because 

data entry into the Military Access Database takes several hours a 

day. 

Additionally, CLAIMS 4 reporting limitations created a challenge 

for tracking compliance with the 6-month performance target. 

Although USCIS was able to identify how long cases had been 

pending in CLAIMS 4, the system did not contain information on 

which field offices were responsible for processing each case. 

This information was contained in another system, CIS. The 

Northeast Regional Office created a combined report with data 

from CLAIMS 4 and CIS; however, officials said the report was 

difficult and time consuming to create and required specialized 

skills. 

Background Check Systems Not Consolidated 

USCIS conducts numerous background and security checks, but 

these results are not integrated into a single system. While each 

background and security check may have a different purpose, there 

is no single location for adjudicators to access the results of these 

checks. USCIS undertook an effort to create a single repository for 

background and security check information, the Background 

Check System, but the effort was unsuccessful. The system was 

intended to be an adjudicator-accessible database that stored the 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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results of various background security checks on an individual 

applicant. Based on a comprehensive review, USCIS canceled this 

initiative and is considering whether another biometric storage 

system in development can be used to store all background security 

check results. 

In addition, USCIS has two systems for fingerprint submission and 

storage that have largely redundant functionality. In addition to 

the BBSS, which is used to manage electronic fingerprint records, 

USCIS maintains an older system originally used to track paper 

fingerprint records. USCIS maintains the older system because not 

all field personnel have access to BBSS because of the IT 

infrastructure limitations of many field offices. As a result, data 

must be updated, stored, and secured in two separate systems. 

USCIS plans to replace these two systems with a new system, the 

Customer Profile Management System, in 2010. 

Long-term IT Modernization and Transformation Efforts 

Incremental improvements to existing IT systems have largely 

been put on hold due to USCIS’ overarching IT modernization 

effort underway as part of the IT transformation program. USCIS’ 

IT systems, such as CLAIMS 4 and BBSS, are old, inefficient to 

maintain and due for replacement. We reported in September 2005 

that inefficiencies in the USCIS IT environment hindered its ability 

to carry out its immigration benefits processing mission.12 

Specifically, USCIS adjudicators used multiple, nonintegrated IT 

systems to review application forms and supporting data, which 

reduced productivity and data integrity. 

In addition, we have reported extensively on USCIS’ efforts to 

modernize its IT environment through the IT transformation 

program. In July 2009, we reported that, although USCIS has 

taken a number of steps to improve its transformation program, 

including establishing a program office and governance approach, 

challenges remained.13 Specifically, pilots have had limited 

success, business process reengineering efforts are incomplete, and 

stakeholder participation levels have fluctuated, leading to 

inconsistent business and IT involvement. These challenges affect 

all USCIS systems, including those used for processing military 

naturalization applications. 

12 USCIS Faces Challenges in Modernizing Information Technology, OIG-05-41, September 2005. 13 U.S. Citizenship and Immigration Services’ Progress in Modernizing Information Technology, OIG-09­

90, July 2009. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Privacy 

The Kendell Frederick Citizenship Assistance Act requires that 

DHS implement procedures for the rapid electronic transmission of 

biometric information provided by military personnel, including 

fingerprints received from DOD or the FBI, and that the 

procedures are privacy-safeguarded. USCIS used a system for 

electronic transmission of biometric data prior to the passage of the 

act, and because that system has not changed, the act has not had 

an impact on privacy. 

In May 2006, however, USCIS developed transmission procedures 

to obtain previously submitted electronic fingerprints from the FBI 

for input into the Biometric Benefits Support System (BBSS). In 

December 2007, USCIS submitted a Privacy Threshold Analysis to 

the DHS Privacy Office for a determination on whether a Privacy 

Impact Assessment (PIA) was required for BBSS. The Privacy 

Office reviewed that analysis and determined that a PIA was 

required. Although USCIS has prepared a draft PIA, it has not 

been finalized as of August 2009. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Recommendations 

We recommend that the Director of USCIS: 

Recommendation #1: Ensure that requirements not met by the 

existing application support system, CLAIMS 4, and the lack of a 

consolidated background check system are addressed through the 

IT transformation process. 

Recommendation #2: Implement mobile fingerprint units for 

military naturalization purposes overseas to improve fingerprint 

capture capabilities and reduce the burden on military personnel. 

Recommendation #3: Pursue expanding the use of video 

teleconference for the naturalization interview and oath in 

extraordinary situations such as when military personnel are 

deployed overseas in a warzone. 

Recommendation #4: Finalize the PIA for BBSS, and ensure that 

the process to obtain and resubmit prior fingerprint records from 

partner agencies is included in this PIA. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Management Comments and OIG Analysis 

We obtained written comments on a draft of this report from the 

Director, U.S. Citizenship and Immigration Services. We have 

included a copy of the comments in their entirety in Appendix B. 

In the comments, the Director concurred with our 

recommendations and expressed general agreement with the 

content of the report. Additionally, the Director provided details 

on steps being taken to address specific findings and 

recommendations in the report. We have reviewed management’s 

comments and provided an evaluation of the issues outlined in the 

comments below. 

In response to recommendation one, the Director stated that USCIS 

plans to implement one easily accessible, user-friendly interface to 

consolidate all background check activities and applicant 

information as part of the IT transformation effort. In addition, the 

Director identified plans to expand USCIS’ ability to obtain 

previously submitted fingerprints from other government agencies 

to eliminate the need to collect fingerprints from military 

applicants. The Director envisioned a user-friendly portal to 

exchange such information, and will provide us with a list of 

actions and milestones toward achieving this result. We believe 

that such efforts are a good step toward addressing our 

recommendation and look forward to learning more about 

continued progress and improvements in the future. 

Responding to recommendation two, the Director stated that 

USCIS has purchased mobile fingerprint units and has begun 

deploying these units overseas. The Director, however, listed 

several challenges that USCIS will face when using mobile 

fingerprint units overseas. These challenges include USCIS’ 

limited ability to travel or securely transmit captured fingerprints 

within a warzone. Nevertheless, USCIS expects the use of mobile 

fingerprint capture technology to reduce the burden of obtaining 

and submitting fingerprints for military personnel seeking 

naturalization while deployed overseas. USCIS’ actions to 

implement mobile fingerprint technology overseas are positive 

steps toward addressing our recommendation. 

In response to recommendation three, the Director indicated that 

USCIS supports the idea of conducting naturalization interviews 

through methods other than face-to-face interviews, including 

video teleconference. Accordingly, USCIS has piloted the use of 

these methods and is reviewing the feasibility of this 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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recommendation. We recognize this action as a positive step 

toward addressing recommendation three. 

Responding to recommendation four, the Director stated that 

USCIS has submitted a PIA to the DHS Privacy Office that covers 

the BBSS system. Additionally, the Director indicated that USCIS 

intends to update this PIA to include the process for obtaining 

fingerprint records from partner agencies, if necessary. We look 

forward to receiving and reviewing the finalized PIA in order to 

close this recommendation. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Appendix A 

Scope and Methodology 

We began our audit work by conducting background research to 

gain an understanding of the Kendell Frederick Citizenship 

Assistance Act, the technology and processes implemented by 

USCIS in response to the act, and any privacy and civil liberties 

implications caused by the implementation of the act. We reviewed 

a USCIS report to Congress on the act, USCIS reports on the 

naturalization process for military applicants, and congressional 

testimony. We met with congressional staffers to coordinate 

efforts with the Government Accountability Office and further 

define responsibilities. We met with OIG’s Office of Counsel to 

obtain information and guidance on privacy laws in relation to this 

report. 

To obtain information on the current status of the act, how it is 

being implemented, and any privacy concerns associated with it, 

we obtained PIAs for CIS, CLAIMS 4, and the IDENT system, 

along with a draft of the Immigration Benefits Background 

Systems PIA. We reviewed the USCIS International Operations 

Strategic Plan FY 2009–2012, along with internal memos drafted 

by the USCIS Office of Policy and Strategy. We examined the 

documents describing the Military Working Group, which works 

with DOD to facilitate military naturalizations, along with 

fingerprint charts which describe the steps taken by USCIS to 

obtain fingerprints depending on the situation and location of the 

applicant. We reviewed the 2008 and 2009 USCIS Ombudsman 

reports. We also researched the USCIS website to obtain relevant 

information on the military naturalization process, along with the 

component’s strategic plan. 

We conducted our audit fieldwork from May to July 2009 at 

USCIS headquarters in Washington, DC. We met with the 

Domestic Operations Directorate, International Operations 

Division, Information Technology Office, Office of Policy and 

Strategy, and the Field Operations Division, all of which play a 

role in the military naturalization process. We met with the Office 

of Transformation to learn about new technologies that USCIS 

plans to implement that could have an effect on military 

naturalizations. Additionally, we met with the USCIS Privacy 

Office, the Office of Chief Counsel, and the DHS Privacy Office, 

which are responsible for making decisions on privacy and 

protecting the privacy of individuals applying for naturalization. 

We visited the NSC, where military applications for naturalization 

are processed in Lincoln, Nebraska, and the USCIS district office 

in San Diego, California, to gain a more complete understanding of 

the military naturalization process, including military liaisons’ 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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roles and responsibilities, the technology used, and issues or 

concerns related to military processing. 

We also teleconferenced with USCIS regional offices in 

Burlington, Vermont, and Laguna Niguel, California, to discuss 

their responsibilities relating to the military naturalization process, 

technologies used, and issues or concerns related to military 

processing. 

We conducted this performance audit according to generally 

accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

The principal OIG points of contact for this audit are Frank Deffer, 

Assistant Inspector General for Information Technology Audits, 

and Richard Harsche, Director, Information Management. Major 

OIG contributors to the audit are identified in appendix C. 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Appendix B 

Management Comments to the Draft Report 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 


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Appendix C 

Major Contributors to This Report 

Information Management Division 

Richard Harsche, Director 

Steven Staats, Audit Manager 

Elizabeth Argeris, Auditor-in-Charge 

Kia Smith, Auditor 

Craig Adelman, Auditor 

Eun Suk Lee, Referencer 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Policy 

Chief of Staff for Operations 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

CIS Director for Domestic Operations 

CIS OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

U.S. Citizenship and Immigration Services’ Implementation of the Kendell Frederick Citizenship Assistance Act 

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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.