Management Alert - U.S. 

Citizenship and 

Immigration Services’ Use 

of the Electronic 

Immigration System for 

Naturalization Benefits 

Processing 

January 19, 2017 

OIG-17-26-MA 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

January 19, 2017 

MEMORANDUM FOR: The Honorable Leon Rodriquez 

Director 

U.S. Citizenship and Immigration Services 

FROM: John Roth ~\;v_'\(a~ Inspector General 

SUBJECT: 	 Management Alert - U.S. Citizenship and 

Immigration Services' Use ofthe Electronic 

Immigration System for Naturalization Benefits 

Processing 

We are recommending that USCIS halt plans to revert to using the 

Electronic Immigration System (ELIS) to process immigrant 

naturalization applications until it successfully addresses identified 

system deficiencies. In March 2016, we previously reported system 

functionality and performance problems prevalent in two product lines 

operational in ELIS at that time. 1 Our subsequent, ongoing review is now 

discovering alarming security concerns regarding inadequate applicant 

background checks, as well as significant USCIS problems in using ELIS 

to process naturalization benefits for immigrants. Because of the 

problems encountered, USCIS decided in August 2016 to revert to legacy 

processing and discontinue using ELIS to process new naturalization 

applications. We have been informed that USCIS is now considering a 

return to processing naturalization applications in ELIS. Because of 

significant unresolved functional and technical issues surrounding ELIS, 

we advise against it until corrective actions are taken to ensure security 

and integrity in naturalization benefits processing. 

Background 

Our prior audits disclosed a pattern of problems with ELIS performance 

and functionality that have yet been addressed. Specifically, our March 

2016 report, USCIS Automation ofImmigration Benefits Processing 

Remains Ineffective, OIG-16-48, identified numerous deficiencies in 

system capabilities that users need for immigration benefits and service 

processing. The report also highlighted significant performance problems, 

1 The USCIS Immigrant Fee and the Application to replace a Permanent Resident Card (Form I-90) 

were processed in ELIS at the time of our 2016 audit. 
 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

including frequent system outages and problems with system interfaces 

that negatively affected productivity. Further, our November 2016 report, 

Better Safeguards Are Needed in USCIS Green Card Issuance, OIG-17-11, 

indicated that nearly 20,000 Green Cards had been issued in error, 

primarily due to ELIS technical and functional deficiencies. USCIS 

concurred with all 11 recommendations. To date, all of the 

recommendations are resolved, but remain open pending completion of 

USCIS’ planned actions to address them. 

Given USCIS’ slow progress in taking corrective actions to address 

system deficiencies, in December 2016 we began an assessment of 

USCIS’ current efforts to automate processing of the N-400 Application 

for Naturalization in ELIS. To date, we have reviewed voluminous ELIS 

documentation and conducted approximately two dozen interviews with 

USCIS headquarters and field operations personnel. We also visited 

USCIS’ National Benefits Center in Kansas City, Missouri, where we 

observed ELIS demonstrations and met with system users. Although we 

are only in the beginning phases of our review, we have already identified 

significant operational and security issues that pose grave concern and 

merit your attention and corrective action. We plan to complete our 

review and provide a comprehensive report with recommendations for 

improvement later in spring 2017. 

Preliminary Concerns about ELIS Processing of Naturalization Benefits 

Since its deployment on April 13, 2016, ELIS has impaired the ability of 

USCIS Immigration Services Officers and field personnel to conduct 

naturalization processing. Through our preliminary work, we have 

identified a range of ELIS technical and functional issues that have 

slowed processing and productivity. 

 Missing core ELIS functionality 

 Naturalization cases stuck in ELIS workflows, requiring manual 

intervention for case progression 

 Frequent ELIS and network outages 

 ELIS failure to connect with supporting systems 

 Multiple or erroneous cancellation of applicant interviews 

Ongoing USCIS efforts to correct technical deficiencies while 

concurrently continuing to develop system functionality have resulted in 

ELIS down time, instability, and repeated changes that interrupt 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

processing and confuse system users. Moreover, the USCIS Field 

Operations Directorate identified the following four top challenges in 

working in ELIS that field users believe must be addressed to ensure 

effective naturalization processing. We agree, based on our initial field 

work. 

1. Deficiencies in Background and Security Checks for Applicants: 

USCIS personnel are required to check applicants’ biographic data 

against U.S. Customs and Border Protection’s TECS system and 

the Federal Bureau of Investigation’s name check database. 

However, ELIS allows cases to be moved forward for processing 

despite incomplete or inaccurate background and security checks. 

According to Field Operations Directorate officials, approximately 

175 applicants were granted citizenship as of January 11, 2017 

before the problem was detected and USCIS began redoing the 

name checks to ensure they were all completed correctly. Without 

sufficient vetting, immigrants could potentially be granted U.S. 

citizenship although they are ineligible or pose national security 

threats. 

2. Inconsistent Case Management Update and Closeout: ELIS does 

not consistently update the USCIS Central Index System with final 

immigrant status once an individual is naturalized. The Central 

Index System contains official records and decisions on all 

individuals who apply for benefits. The system must accurately 

reflect final benefits decisions in order to officially close out cases, 

record applicant status, and inform DHS components such as U.S. 

Customs and Border Patrol and U.S. Immigration and Customs 

Enforcement. 

3. Printing problems: USCIS field officers cannot print naturalization 

certificates directly through ELIS, requiring time consuming 

workarounds to configure individual workstations to print through 

alternate systems. More importantly, printed certificates 

sometimes included incorrect names or lacked mandatory data 

such as photos or country of origin, rendering them invalid. Both 

issues have created backlogs in benefits delivery. 

4. Lack of Contingency Planning for Sustained Processing:	 USCIS 

field officers are unable to obtain electronic copies of applicant files 

and supporting evidence during frequent ELIS or network outages. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

A lack of contingency planning to ensure continuity of operations 

during outages hinders the field officers’ ability to conduct 

interviews and issue timely benefits approvals to applicants. 

Given such technical and functional issues, the USCIS Director decided 

in August 2016 to discontinue use of ELIS and revert to using the legacy 

Computer Linked Application Information Management System for all 

new N-400 applications received after that date. USCIS field offices and 

the National Benefits Center also had to finish processing the nearly 

250,000 cases that had been started in ELIS but not yet completed. To 

date, less than 10 percent of those ELIS cases have been completed and 

closed out. 

Recently, we learned of an impending decision by USCIS leadership to 

return to ELIS processing in late January 2017. We are concerned about 

the feasibility and risk of such a decision given all the ELIS problems 

that remain unresolved. Earlier this month, the USCIS Field Operations 

Directorate expressed similar concerns, emphasizing to the USCIS Chief 

Information Officer that the four top challenges that his directorate 

identified, described above, are minimal requirements that must be met 

before a return to processing naturalization benefits in ELIS. As such, we 

recommend that USCIS: 

1. Ensure the four minimal requirements of the Field Operations 

Directorate are met prior to returning to ELIS processing of N-400 

naturalization applications. 

2. Perform a risk-based analysis of all unresolved ELIS technical 

issues to ensure that, going forward, all system improvement 

decisions are based on potential agency operational impact and 

risk to public safety. 

I appreciate your attention to resolving this matter. Please call me with 

any questions, or your staff may contact Sondra F. McCauley, Assistant 

Inspector General for Information Technology Audits, at (202) 254-4041. 

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ADDITIONAL INFORMATION AND COPIES 

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