IMMIGRATION 

STATUS 

VERIFICATION FOR 

BENEFITS

Actions Needed to 

Improve Effectiveness 

and Oversight

Report to Congressional Committees

March 2017

GAO-17-204

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-204, a report to 

congressional committees 

March, 2017

IMMIGRATION STATUS VERIFICATION FOR 

BENEFITS 

Actions Needed to Improve Effectiveness and 

Oversight 

What GAO Found

The Department of Homeland Security’s (DHS) United States Citizenship and 

Immigration Services (USCIS) has taken steps to assess the accuracy of the 

information reported by its Systematic Alien Verification for Entitlements (SAVE) 

system. For example, since 2014 USCIS has conducted monthly checks to 

ensure SAVE is accurately reporting information contained in its source systems. 

In addition, USCIS reports that SAVE status verifiers, who manually research a 

benefit applicant’s immigration status during a process known as additional 

verification, accurately reported the applicant’s status 99 percent of the time. 

However, from fiscal year 2012 through fiscal year 2016, GAO found that the 

majority of SAVE user agencies that received a SAVE response prompting them 

to institute additional verification did not complete the required additional steps to 

verify the benefit applicant’s immigration status. USCIS does not have sufficient 

controls to help ensure agencies are completing the necessary steps because of

inconsistent guidance, and lacks reasonable assurance that SAVE user 

agencies have completed training that explains this procedure. Improving 

guidance and ensuring training on verification requirements could help USCIS 

better ensure agencies have complete and accurate information for making 

eligibility determinations. 

USCIS has taken actions to protect the privacy of personal information related to 

SAVE, such as requiring SAVE user agencies to sign a memorandum of 

agreement (MOA) stating the intended use of the system and provisions for 

safeguarding information. USCIS has also established mechanisms for access, 

correction, and redress regarding use of an individual’s personal information; 

however, GAO found these mechanisms were largely ineffective and unlikely to 

enable benefit applicants to make timely record corrections. Specifically, USCIS 

provides a fact sheet for benefit applicants stating their immigration status could 

not be verified, along with information on contacting DHS to update or correct 

their records. However, the fact sheet’s guidance on contacting DHS was not 

specific or clear, which could hinder benefit applicants’ efforts to contact DHS. 

Without an effective method for ensuring individuals can access and correct their 

information, benefit applicants may face challenges ensuring accurate

information is used in a SAVE check and appealing potentially erroneous denials 

of benefits with the user agency in a timely manner.

USCIS’s SAVE Monitoring and Compliance (M&C) branch monitors user 

agencies’ use of SAVE in accordance with their MOA. However, SAVE M&C’s 

monitoring efforts have not improved agency compliance rates for the two 

monitored behaviors—deleting inactive user accounts and instituting additional 

verification when prompted. For example, GAO found that only 4 of 40 agencies 

monitored from fiscal years 2013 through 2015 had improved their compliance 

with requirements to complete additional verification when prompted. Further 

M&C does not have a documented, risk-based strategy for monitoring. Without

such a strategy, USCIS is not well-positioned to target its monitoring efforts on 

the agencies most in need of compliance assistance or ensure the most effective 

use of its limited resources. 

View GAO-17-204. For more information, 

contact Rebecca Gambler, (202) 512-6912, 

gamblerr@gao.gov 

Why GAO Did This Study

Millions of applicants for healthcare, 

licenses, and other benefits rely on 

DHS’s SAVE system to verify their 

immigration or naturalized or derived 

citizenship status at the request of over 

1,000 federal, state, and local user 

agencies. Agencies use the 

information from SAVE to help 

determine an applicant’s eligibility for 

benefits. Programs required or 

authorized to participate include 

Medicaid, certain license-issuing 

programs (such as driver’s licenses), 

federal food and housing assistance, 

and educational programs. The House 

Appropriations Committee Report 

accompanying the DHS Appropriations 

Act, 2016, included a provision for 

GAO to review the SAVE program. 

This report examines the extent to 

which USCIS has (1) determined the 

accuracy of SAVE information, (2) 

instituted safeguards to protect privacy 

and provide the ability to correct 

erroneous information, and (3) 

monitored user agency compliance 

with SAVE program policies. GAO 

analyzed SAVE policy documents and 

performance data, interviewed DHS 

officials, and interviewed officials from 

a non-generalizable sample of 13 

SAVE user agencies selected to reflect 

the variety of types of agencies that 

use SAVE. 

What GAO Recommends

GAO is making nine recommendations 

to USCIS, including, that USCIS 

improve guidance and ensure training 

on verification requirements; develop 

and implement a more effective 

method for record correction; and 

develop a documented, risk-based 

strategy for monitoring and 

compliance. DHS concurred with our 

recommendations.
Page i GAO-17-204 Immigration Status Verification for Benefits

Letter 1

Background 6

SAVE Provides Accurate and Timely Responses, but USCIS 

Could Better Ensure User Agencies Complete all Required 

Steps and Improve its Guidance and Training 15

USCIS Has Instituted Applicant Privacy Protections for SAVE, but 

Could Improve Efforts to Assist Applicants with Resolving 

Potential Errors 31

USCIS Monitors Agencies’ Use of SAVE in Accordance with the 

SAVE MOA, but Could Improve Overall Effectiveness of 

Monitoring Efforts 38

Conclusions 50

Recommendations for Executive Action 52

Agency Comments and Our Evaluation 53

Appendix I Objectives, Scope, and Methodology 56

Appendix II Standard Terms of Memorandums of Agreement for Agencies to 

use the SAVE System – Federal Agencies 61

Appendix III Standard Terms of Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local Government Agencies 70

Appendix IV SAVE Fact Sheet for Benefit Applicants 79

Appendix V Frequency and Percentage of SAVE Checks that did not Institute 

Additional Verification (IAV) for Monitored Agencies, Fiscal 

Years 2013 through 2015 80

Appendix VI Comments from the Department of Homeland Security 85

Contents
Page ii GAO-17-204 Immigration Status Verification for Benefits

Appendix VII GAO Contact and Staff Acknowledgments 89

Tables

Table 1: Systematic Alien Verification for Entitlements (SAVE) 

Responses Requesting Agencies to Institute Additional 

Verification (IAV), by Fiscal Year 17

Table 2: Systematic Alien Verification for Entitlements (SAVE) 

User Agencies’ Rates of Failure to Institute Additional 

Verification (IAV), by Fiscal Year 18

Table 3: Systematic Alien Verification for Entitlements (SAVE) 

Selected User Agency Reported Challenges Determining 

a Benefit Applicant’s Eligibility based upon SAVE 

Responses 27

Table 4: Examples of Actions to Address the Fair Information 

Practice Principles in the Systematic Alien Verification for 

Entitlements (SAVE) Program 32

Table 5: GAO Attempts to Follow the Instructions in the Fact 

Sheet for Benefit Applicants Denied a Benefit Because of 

a Systematic Alien Verification for Entitlements (SAVE) 

Response, Conducted June through December 2016 35

Table 6: Systematic Alien Verification for Entitlements (SAVE) 

Monitoring and Compliance (M&C) Activities 39

Table 7: Systematic Alien Verification for Entitlements (SAVE) 

Compliance Standards for Inactive User Accounts, 

According to Various SAVE Guidance and Policy 

Documents 41

Table 8: Site Visit Monitoring Statistics for Agencies that Fail to 

Institute Additional Verification (IAV), Fiscal Year 2013 

through Fiscal Year 2015 43

Table 9: Systematic Alien Verification for Entitlements (SAVE) 

User Agencies Contacted for Desk Reviews or Site Visits 

in Fiscal Year (FY) 14 and FY15 44

Table 10: Examples of Recommendations Frequently Made by 

Systematic Alien Verification for Entitlements (SAVE) 

Monitoring and Compliance after Desk Reviews, Fiscal 

Years 2013 through 2015 48
Page iii GAO-17-204 Immigration Status Verification for Benefits

Figures

Figure 1: Sample Immigration Documents used in Checks of the 

Systematic Alien Verification for Entitlements (SAVE) 

System 9

Figure 2: Process for Verifying Immigration or Citizenship Status 

Using the Department of Homeland Security’s (DHS) 

Systematic Alien Verification for Entitlements (SAVE) 

System 10

Figure 3: Systematic Alien Verification for Entitlements (SAVE) 

Source Systems 12

Figure 4: Department of Homeland Security (DHS) Immigration 

Records Correction Process 13

Figure 5: Systematic Alien Verification for Entitlements (SAVE) 

Fact Sheet for Benefit Applicants 79

Figure 6: Agencies Monitored for Instituting Additional Verification 

(IAV) Failure in Fiscal Year 2013 81

Figure 7: Agencies Monitored for Instituting Additional Verification 

(IAV) Failure in Fiscal Year 2014 82

Figure 8: Agencies Monitored for Instituting Additional Verification 

(IAV) Failure in Fiscal Year 2015 83

Abbreviations

ADIS Arrival and Departure Information System

A-Number Alien Number 

CBP U.S. Customs and Border Protection 

CIS Central Index System 

CLAIMS3 Computer Linked Application Information Management

 System, V3

CLAIMS4 Computer Linked Application Information Management

 System, V4

COA Class of Admission
Page iv GAO-17-204 Immigration Status Verification for Benefits

CPMS Customer Profile Management Service

CRCL Office for Civil Rights and Civil Liberties 

DHS Department of Homeland Security

DMV Department of Motor Vehicles

DOJ Department of Justice

EDMS Enterprise Document Management System

ELIS Electronic Immigration System

EOIR Executive Office of Immigration Review System

FIPPs Fair Information Practice Principles 

IAV Institute Additional Verification 

IBIS Interagency Border Inspection System

ICE U.S. Immigration and Customs Enforcement 

IIRIRA Illegal Immigration Reform and Immigrant Responsibility

 Act of 1996 

INS Immigration and Naturalization Service

IRCA Immigration Reform and Control Act of 1986

IRIES Immigration Review Information Exchange System

M&C Monitoring and Compliance 

MiDAS Microfilm Digitization Application System

MOA memorandum of agreement 

OMB Office of Management and Budget

PIA Privacy Impact Assessment 

PII personally identifiable information 

PRWORA Personal Responsibility and Work Opportunity

 Reconciliation Act of 1996 

RAPS Refugees, Asylum, and Parole System

RNACS Reengineered Naturalization Applicants Casework System

SAVE Systematic Alien Verification for Entitlements 

SEVIS Student and Exchange Visitor Information System

SNAP Supplemental Nutrition Assistance Program

TANF Temporary Assistance for Needy Families

TECS (not an acronym)

USCIS U.S. Citizenship and Immigration Services 

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Page 1 GAO-17-204 Immigration Status Verification for Benefits

441 G St. N.W.

Washington, DC 20548

March 23, 2017

The Honorable John Boozman

Chairman

The Honorable Jon Tester

Ranking Member

Committee on Appropriations

Subcommittee on Homeland Security

United States Senate

The Honorable John R. Carter

Chairman

The Honorable Lucille Roybal-Allard

Ranking Member

Committee on Appropriations

Subcommittee on Homeland Security

House of Representatives

Since fiscal year 2012, over 86 million immigration or citizenship status 

checks have been conducted using the U.S. Citizenship and Immigration 

Service’s (USCIS) Systematic Alien Verification for Entitlements (SAVE) 

program. SAVE is a primarily web-based system used to verify the 

immigration or naturalized or derived citizenship status of applicants for 

federal, state, or local benefits.1 To verify an immigration or citizenship 

status, the SAVE system draws information from numerous databases, 

most of which are managed by the Department of Homeland Security 

(DHS).2 Programs required or authorized to participate in status 

 1Throughout this report, we use the term “benefits” to generally refer to the range of 

federal, and state or local, public benefits, transactions, or programs for which an 

individual must have qualified immigration or citizenship status, such as cash, food,

housing, and other forms of direct assistance, as well as licenses (including driver’s 

licenses or occupational licenses), and voter registration. For the statutory definitions of 

“Federal public benefit” and “State or local public benefit,” see 8 U.S.C. §§ 1611(c), 

1621(c). Accordingly, we refer to all agencies administering these programs as benefit 

granting agencies or SAVE user agencies. Further, the SAVE program does not verify the 

citizenship status of native born U.S. citizens—status verification through SAVE refers to 

the verification of immigration, or naturalized or derived citizenship status. In this report, 

reference is made to naturalized or derived citizenship status verification, unless otherwise 

provided for by statute.

2DHS is a multi-mission federal department with responsibility for preventing terrorism and 

enhancing security, managing the U.S. borders; administering immigration laws; securing 

cyberspace; and ensuring disaster resilience. USCIS is a component of DHS.

Letter
Page 2 GAO-17-204 Immigration Status Verification for Benefits

verification through SAVE include Medicaid, federal food assistance 

programs, health insurance programs under the Patient Protection and 

Affordable Care Act, educational and housing assistance programs, and 

certain license-issuing programs.3 The number of benefit granting 

agencies using SAVE has increased since the program’s inception in 

1987, and in 2016 included over 1,141 federal, state, and local agencies. 

While SAVE was originally only used by certain federal benefit programs, 

additional provisions for SAVE usage and immigration status verification 

have since been enacted. For example, The Illegal Immigration Reform 

and Immigrant Responsibility Act (IIRIRA) of 1996 provides for 

unrestricted communication between government agencies regarding 

immigration status verification for “any purpose authorized by law,” and 

required former Immigration and Naturalization Service (INS), whose 

functions were generally transferred to DHS, 4 to respond to citizenship or 

immigration status verification inquiries from federal, state, or local 

agencies related to any individual within such agencies’ jurisdiction, for 

any lawful purpose. In addition, the REAL ID Act of 2005 requires states 

to use SAVE in verifying immigration status for driver’s license issuance 

in order for such documents to be accepted by federal agencies for 

official purposes.5 Under these and other relevant legal authorities, states 

and localities seek access to SAVE for the purpose of conducting 

immigration or naturalized or derived citizenship status checks for various 

benefits, including occupational licenses and voter registration.

 3See 42 U.S.C. § 1320b-7 and 1320b-7 note, regarding income and eligibility verification 

for certain federal programs such as Block Grants to States for Temporary Assistance for 

Needy Families (TANF); Medical Assistance Programs; Unemployment Compensation; 

Supplemental Nutrition Assistance Program (SNAP); and state programs for assistance 

for the aged, and aid to the blind and those with disabilities, and Supplemental Security 

Income (SSI). In addition, see 42 U.S.C. § 1436a (Restriction on use of assisted housing 

by non-resident aliens); 20 U.S.C. § 1091 (Eligibility for Student Assistance Programs); 

Patient Protection and Affordable Care Act, Pub. L. No. 111-148, tit. I, subtit. E, pt. I, 

subpt. B, § 1411, 124 Stat. 119, 224-31 (2010) (classified at 42 U.S.C. § 18081).

4Homeland Security Act of 2002 (Pub. L. No. 107–296, 116 Stat. 2135) dismantled the 

former Immigration and Naturalization Service (INS) and distributed its functions across 

three components within the newly created Department of Homeland Security (DHS). On 

March 1, 2003, DHS’s Bureau of Citizenship and Immigration Services, now known as 

U.S. Citizenship and Immigration Services (USCIS), officially assumed responsibility for 

the federal government’s immigration services functions, including immigration benefit 

adjudication and status verification, among other duties.

5Pub. L. No. 104-208, div. C, tit. VI, subtit. D, § 642, 110 Stat. 3009, 3009-707 (classified 

at 8 U.S.C. § 1373); see also Personal Responsibility and Work Opportunity 

Reconciliation Act of 1996, Pub. L. No. 104-193, tit. IV, subtit. D, § 434, 110 Stat. 2105, 

2275 (classified at 8 U.S.C. § 1644).
Page 3 GAO-17-204 Immigration Status Verification for Benefits

SAVE does not indicate whether a person is eligible for a particular 

benefit; rather, the benefit granting agency makes that decision based on 

benefit-specific eligibility criteria, including immigration or naturalized or 

derived citizenship status. SAVE provides an immigration or citizenship 

status verification service to the benefit granting (user) agency. However, 

questions have been raised regarding the accuracy of the immigration 

status responses, the sufficiency of applicant notification and processes 

to correct errors, and USCIS’s ability to effectively monitor and oversee 

the program, among other issues.

The report of the House Appropriations Committee accompanying the 

DHS Appropriations Act, 2016, included a provision for us to examine 

aspects of the SAVE program related to accuracy, privacy, and 

monitoring.6 This report examines the following questions:

• To what extent has USCIS determined the accuracy and timeliness of 

the information it reports in a SAVE response?

• To what extent has USCIS instituted safeguards to protect privacy 

and prevent misuse of the SAVE system, including processes that 

provide the ability to address erroneous immigration status responses 

returned by SAVE?

• To what extent is USCIS monitoring user agency compliance with 

SAVE program policies and requirements, including safeguards to 

protect privacy and prevent misuse?

To address our first objective, we analyzed USCIS performance data and 

internal policies on SAVE accuracy and timeliness from fiscal years 2012 

through 2016.7 In addition to our analysis of DHS documents and data, 

we interviewed officials from a nonprobability sample of 13 SAVE user 

agencies, of different types such as federal, state, and local agencies, as 

well as state departments of motor vehicles, to discuss the extent to 

which SAVE responses were accurate and timely, among other topics. 

The information we obtained from these user agencies during our 

 6See H.R. Rep. No. 114-215, at 95 (July 21, 2015), accompanying Pub. L. No. 114-113, 

div. F, 129 Stat. 2242, 2493-2526 (2015).

7We selected this period because it followed a 2012 report from the DHS Office of the 

Inspector General with recommendations related to the accuracy and timeliness of SAVE 

responses, among other topics. See DHS Office of the Inspector General, U.S. Citizenship 

and Immigration Services, Improvements Needed for SAVE to Accurately Determine 

Immigration Status of Individuals Ordered Deported, OIG-13-11 (Revised) (Washington, 

D.C.: December 2012).
Page 4 GAO-17-204 Immigration Status Verification for Benefits

interviews is not generalizable, but provides insights into how the SAVE 

program operates.8 We analyzed USCIS data on the number of agencies 

that do not complete additional verification when prompted by the SAVE 

system—a step that is important for ensuring an accurate and complete 

response. We analyzed data from fiscal years 2012 through 2016 that 

included the total number of SAVE queries, number of queries where the 

response was to institute additional verification, and total number of 

agencies that ran SAVE checks in those years. We interviewed USCIS 

officials regarding how these data are generated and what procedures 

are in place to ensure its reliability. Based on our review of the data and 

information obtained from USCIS, we determined that these data are 

sufficiently reliable for the purposes of our report. We also interviewed 

officials from DHS’s U.S. Immigration and Customs Enforcement (ICE) 

and U.S. Customs and Border Protection (CBP) to discuss the accuracy 

and timeliness of the immigration records generated by these 

components and the extent to which USCIS SAVE has coordinated with 

these entities regarding accuracy and timeliness. Last, to gain insight into 

immigration record accuracy and other issues related to the use of SAVE, 

we interviewed officials with DHS’s Office for Civil Rights and Civil 

Liberties (CRCL) and the DHS Ombudsman Office. We compared our 

observations and findings to the principles set forth in Standards for 

Internal Control in the Federal Government and the standard terms of 

SAVE user agency memorandums of agreement (MOA) that are 

generally applicable to all user agencies, and outline agency 

responsibilities and requirements for using SAVE for the approved 

purposes(s).9

To address our second objective, we reviewed the Fair Information 

Practice Principles (FIPPs) adopted by the DHS Chief Privacy Officer and 

 8Agencies interviewed for this review included: U.S. Department of Education Federal 

Office of Student Aid; Florida Department of Children and Families; California Department 

of Motor Vehicles; Arkansas Department of Finance and Administration, Office of Driver 

Services; Idaho Transportation Department, Driver Services; New York City Human 

Resources Administration, Department of Social Services; Georgia, City of Milton; 

Alabama Home Builders Licensure Board; the Internal Revenue Service; the National 

Science Foundation; Colorado Secretary of State; North Carolina Division of Motor 

Vehicles; and the Connecticut Mashantucket Pequot Tribal Nation Gaming Commission. 

9GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). These controls update the 1999 version, which was 

applicable in fiscal year 2012 through 2015. The 2014 internal controls became effective 

in fiscal year 2016. We applied these controls to the whole time period because we 

assessed current fiscal year 2016 policies. 
Page 5 GAO-17-204 Immigration Status Verification for Benefits

assessed the extent to which USCIS has included these principles within 

the SAVE program. We also reviewed USCIS guidance on applicant 

redress and record correction. To evaluate USCIS’s efforts to track 

SAVE-related immigration record corrections, we spoke with officials from 

the SAVE program, USCIS Central and Western Region Field Offices, 

CBP, ICE, and DHS’s Office of Performance Quality. We interviewed 

officials from the 13 user agencies, as previously mentioned, to identify 

any common challenges with ensuring an accurate benefit determination 

based upon SAVE responses. We compared SAVE user agencies’

responsibilities to provide adequate written notification of the denial to the 

types of notification provided by the agencies in our sample. We 

evaluated USCIS guidance on redress and record correction by following 

the instructions presented in USCIS’s fact sheet for benefit applicants, 

which is USCIS’s main notification resource for benefit applicants, to 

determine if the information provided in the fact sheet would enable 

individuals to correct their immigration records in a timely manner. We 

conducted this work following the instructions on USCIS’s fact sheet from 

June through December 2016. Finally, we spoke with CRCL and a 

selection of immigrant advocacy organizations to gain insight into 

applicant experiences with addressing challenges with SAVE verification. 

We identified organizations that had expressed concerns with the SAVE 

program or had public comments on the SAVE program and solicited 

additional recommendations for organizations to contact from those we 

interviewed. We selected advocacy organizations to represent a range of 

type (legal advocacy, refugee assistance, etc.) and legal considerations 

related to SAVE. We selected a nonprobability sample of organizations to 

interview and, therefore, the information gathered from advocacy 

organizations is not generalizable beyond those we interviewed.

To address our third objective, we focused on SAVE Monitoring and 

Compliance (M&C) efforts since fiscal year 2012.10 We reviewed 

documentation on monitoring efforts such as annual reports, standard 

operating procedures, and other relevant documents to determine what 

monitoring and oversight policies and requirements were in place and 

what actions SAVE M&C officials had taken to help ensure user agency 

compliance with the MOA. We also interviewed SAVE M&C officials to 

determine what and how agency practices are monitored, what metrics 

and data are collected from agencies, and how current monitoring efforts 

 10We selected 2012 because the SAVE M&C branch began its oversight activities this 

fiscal year. This period also follows a 2012 report with recommendations from the DHS 

Office of the Inspector General related to SAVE.
Page 6 GAO-17-204 Immigration Status Verification for Benefits

reviewed safeguards to protect privacy and prevent misuse. We analyzed 

USCIS data regarding the failure to institute additional verification for 

fiscal years 2012 through 2016. We interviewed USCIS officials regarding 

how these data are generated and what procedures are in place to 

ensure their reliability. Based on our review of the data and information 

obtained from USCIS, we determined that the data were sufficiently 

reliable for the purposes of our report. We also interviewed user agencies 

about their interactions with SAVE M&C, observed a virtual site visit 

conducted by SAVE M&C, and observed SAVE M&C officials provide a 

demonstration of the desk review process and compared our 

observations to provisions in the SAVE MOA, Standards for Internal 

Control for the Federal Government, and Government Auditing 

Standards.11 Our full scope and methodology can be found in Appendix I.

We conducted this performance audit from February 2016 to March 2017 

in accordance with 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.

 11GAO-14-704G. These controls update the 1999 version, which was applicable in fiscal 

year 2012 through 2015. The 2014 internal controls became effective in fiscal year 2016. 

We applied these controls to the whole time period because we assessed current fiscal 

year 2016 policies.

Background

SAVE Check Process and 

Information Sources
Page 7 GAO-17-204 Immigration Status Verification for Benefits

Since the early 1970s until the inception of the SAVE Program, some 

federal programs had specified the immigration status that would qualify a 

foreign national for public benefits. Programs used various procedures for 

status verification, and in 1984, legacy INS created SAVE pilot projects, 

through which federal, state, and local benefit-granting agencies could—

on a voluntary basis—verify applicants’ immigration status.12 In 1987, 

legacy INS established the SAVE Program pursuant to the Immigration 

Reform and Control Act (IRCA) of 1986, which set requirements for the 

verification of immigration status of foreign nationals applying for benefits 

under certain federal programs, and required INS to implement a 

nationwide system to verify immigration status of such individuals and to 

make the verification system available to all the states.13 The SAVE 

program, run by USCIS, is a verification service for federal, state and 

local benefit granting agencies to verify a benefit applicant’s immigration 

 12GAO, Immigration Reform: Verifying the Status of Aliens Applying for Federal Benefits, 

GAO/HRD-88-7 (Washington, D.C.: October 1987); GAO, Immigration Reform: Federal 

Programs Show Progress in Implementing Alien Verification Systems, GAO/HRD-89-62 

(Washington, D.C.: March 1989); GAO, Immigration Reform: Alien Verification System 

Data Base Problems and Corrective Actions, GAO/IMTEC-89-52 (Washington, D.C.: June 

1989).

13Pub. L. No. 99-603, tit. I, pt. C, § 121(a), 100 Stat. 3359, 3384-90 (classified, as 

amended, at 42 U.S.C. § 1320b-7 and 1320b-7 note). The SAVE program is not to be 

used by DHS for administrative (non-criminal) immigration enforcement purposes. See id. 

§ 121(c)(1), 100 Stat. at 3391 (classified at 42 U.S.C. § 1320b-7 note).With respect to the 

eligibility of foreign nationals for public benefits, the Personal Responsibility and Work 

Opportunity Reconciliation Act (PRWORA) of 1996 generally prohibited Federal, and 

state, or local public benefits from going to foreign nationals who do not meet the statutory 

definition of “qualified alien” (with certain exceptions). Pub. L. No. 104-193, tit. IV, §§ 401, 

411, 110 Stat. 2105, 2261-62, 2268-69 (classified, as amended, at 8 U.S.C. §§ 1611, 

1621). The term “qualified alien” was defined under PRWORA as including lawful 

permanent residents, refugees, asylees, parolees, those granted withholding of removal, 

and persons granted conditional entry. The definition of “qualified alien” has since been 

expanded, and specific programs and benefits have been added as exceptions to the 

general rule that foreign nationals must be deemed “qualified aliens” to be eligible for 

federal benefits (see 8 U.S.C. §§ 1611(b)(3)-(5), 1641(b), (c)). PRWORA also provided for 

limited eligibility of qualified aliens for Supplemental Security Income (SSI), and 

Supplemental Nutrition Assistance Program (SNAP); with exceptions such as for those 

receiving benefits at the time of the enactment of PRWORA, refugees, asylees, certain 

permanent resident aliens, veterans and active duty personnel, and certain American 

Indians, among others (see 8 U.S.C. § 1612). PRWORA also made qualified aliens 

ineligible (with certain exceptions) for federal means-tested public benefits for their first 

five years after U.S. entry (see 8 U.S.C. § 1613).

SAVE Sources

SAVE checks several Department of 

Homeland Security (DHS) and non-DHS 

databases in order to verify a benefit 

applicant’s immigration status or naturalized 

or derived citizenship status.

Source: GAO analysis of DHS documents. | GAO-17-204
Page 8 GAO-17-204 Immigration Status Verification for Benefits

status, or naturalized or derived citizenship status.14 To provide this 

information, SAVE accesses multiple immigration record systems from a 

variety of DHS components such as USCIS, CBP, and ICE, as well as 

information from the Department of Justice (DOJ). SAVE itself is not a 

database—it draws an applicant’s most current immigration status 

information from one of numerous source systems. Further, SAVE does 

not make determinations on an applicant’s eligibility for a specific 

benefit—it provides information to SAVE user agencies to allow them to 

make eligibility decisions using their own criteria.

When applying for public benefits or licenses at a registered federal, 

state, tribal, or local government benefit or license granting agency that 

uses SAVE, applicants must generally present an immigration document 

or such other documents determined to be reasonable evidence of a 

satisfactory immigration status. This can include a Permanent Resident 

Card (often referred to as a “green card”), an employment authorization 

document, a valid foreign passport, or other government-issued 

document. In order to verify an applicant’s status, SAVE requires a 

numeric identifier (such as an Alien Number, I-94 number, or unexpired 

foreign passport number), name, date of birth, and the benefit the 

applicant is seeking. To confirm the person’s status, authorized personnel 

from the benefit-granting agency are to use SAVE to compare the data 

from the immigration document to what SAVE found in federal records. 

Examples of documents that can be used in a SAVE check are shown 

below in figure 1.

 14Under U.S. immigration law, there are many types of immigration benefits or forms of 

relief or protection from removal that provide lawful immigration status or presence in the 

United States whether on a temporary or permanent basis. The process for lawfully 

entering or remaining in the United States is based on a number of factors, including the 

type of immigration benefit sought, and applicable eligibility criteria. Foreign nationals may 

enter or be admitted into the United States under various immigrant and nonimmigrant 

visa categories or other forms of immigration relief or protection, including humanitarian 

relief such as asylum. A person may be eligible for naturalization after residing 

continuously in the United States as a lawful permanent resident for at least five years 

(three years for a U.S. citizen’s spouse), and meeting other requirements. Separate 

requirements apply to members of the military and their families. See 8 U.S.C. § 1427. In 

addition, a child born outside of the United States will automatically derive U.S. citizenship 

when at least one parent is a U.S. citizen, the child is under 18 years old, and the child is 

residing in the United States in legal and physical custody of the citizen parent pursuant to 

a lawful admission for permanent residence. See 8 U.S.C. § 1431. A citizen parent may 

apply for naturalization on behalf of a child born outside the United States who has not 

acquired citizenship automatically. See 8 U.S.C. § 1433. 

Initial Verification

The first step in a SAVE check is called initial 

verification and is typically completed w ithin 

seconds. 

Source: GAO analysis of DHS documents. | GAO-17-204

Additional Verification

If initial verification cannot determine a status 

or if the agency needs to resolve an ambiguity 

or to get additional data, the check proceeds 

to additional verification, which searches 

additional DHS and non-DHS systems and is 

completed by a U.S. Citizenship and 

Immigration Services status verifier. Additional 

verification typically takes 3 to 5 federal 

w orking days. If a status still cannot be 

resolved, the case goes to 3rd step 

verification, w hich takes 10-20 federal working 

days.

Source: GAO analysis of DHS documents. | GAO-17-204
Page 9 GAO-17-204 Immigration Status Verification for Benefits

Figure 1: Sample Immigration Documents used in Checks of the Systematic Alien Verification for Entitlements (SAVE) System

A SAVE check can take up to three steps to complete. The first step, 

initial verification, is an automated search of several DHS databases for 

records that match the benefit applicant’s information. According to 

USCIS, within seconds, the system provides an electronic response with 

the applicant’s current immigration status or prompts the benefit granting 

agency to institute additional verification, as shown in figure 2 below.
Page 10 GAO-17-204 Immigration Status Verification for Benefits

Figure 2: Process for Verifying Immigration or Citizenship Status Using the Department of Homeland Security’s (DHS) 

Systematic Alien Verification for Entitlements (SAVE) System

SAVE officials said that the verification process was designed as a multistep process to ensure an accurate response, since not all relevant 

immigration records can be captured in the initial verification search. 

Further, according to USCIS, approximately 9 percent of all relevant 

classes of admission will not be confirmed upon initial verification 

because they have been programmed by USCIS to automatically require 
Page 11 GAO-17-204 Immigration Status Verification for Benefits

additional verification by USCIS status verifiers.15 SAVE officials stated 

that some immigration status categories have been programmed in SAVE 

to automatically require additional verification for reasons such as privacy 

and confidentiality considerations, because the information is not readily 

available, or because a hard copy of the file needs to be requested. 

Additionally, officials stated that immigration statuses are complex and 

can change over time; thus benefit granting agencies may need additional 

information and context to make benefit eligibility decisions.

SAVE user agencies are charged a minimum of $25 to access SAVE 

each month, plus $0.50 for each initial verification query totaling over $25. 

However, there is no monthly charge if a SAVE user agency does not 

submit any SAVE queries. If the initial verification query cannot be 

resolved, SAVE user agencies are required by USCIS to perform the 

additional verification steps before denying a benefit based on a SAVE 

response. There is a $0.50 fee for any additional verification query. If an 

agency proceeds to additional verification, USCIS status verifiers can 

check additional DHS and non-DHS databases, as shown in figure 3.

 15USCIS reported that there are 1,053 classes of admission (COAs) and that 312 of these 

are programmed to automatically require agencies to institute additional verification (IAV). 

However, officials explained that many of the COAs are set to respond with IAV because 

the COA belongs to a nonimmigrant category and the individual should not have an alien 

number. If the person does, the check is sent to IAV in order to investigate further. When 

accounting for these cases, this reduces the number of COAs set to proceed to IAV to 

149, or 14 percent of all COAs. Officials explained that there are additional exceptions that 

include COAs that will never return on initial verification, thus reducing the number of 

COAs programmed for IAV to 96, or 9 percent of all COAs. 
Page 12 GAO-17-204 Immigration Status Verification for Benefits

Figure 3: Systematic Alien Verification for Entitlements (SAVE) Source Systems

The process for benefit applicants to correct or update their immigration 

records with DHS can involve multiple steps. Applicants who feel that 

they were erroneously denied benefits because of an inaccurate 

immigration status returned by SAVE should first correct or update their 

immigration records, if necessary, and then appeal the denial using the 

benefit granting agency’s existing appeals process. Applicants needing to 

correct or update their immigration records, such as name or date of birth 

corrections, are instructed by USCIS to follow the steps for the DHS 

component (USCIS, CBP or ICE) which maintains the record needing 

modification, as shown in figure 4.

SAVE Record Correction 

Process
Page 13 GAO-17-204 Immigration Status Verification for Benefits

Figure 4: Department of Homeland Security (DHS) Immigration Records Correction Process

If an individual does not know what information needs correcting, he or 

she would then file a Freedom of Information Act or Privacy Act request 

with DHS to gain copies of their immigration records to determine what 

information is inaccurate and which DHS component to contact.

To gain access to SAVE, an agency must be seeking to verify the 

immigration, or naturalized or derived citizenship status of persons within 

its jurisdiction for legally authorized purposes.16 In reviewing agency 

 16See 8 U.S.C. §§ 1373, 1644.

Process to Approve 

Agency Access to SAVE
Page 14 GAO-17-204 Immigration Status Verification for Benefits

applications to use SAVE, USCIS staff reported filtering out any 

prospective users that are not eligible to use the system (such as certain

private firms or private individuals) or that should be using it in 

conjunction with a federal, state, or local government agency. For 

example, educational institutions administering federal student aid would 

fall under the Department of Education’s authority to use SAVE and 

would therefore not need their own access. According to USCIS officials, 

all other potential SAVE user agencies are reviewed further by USCIS 

and its Office of Chief Counsel and Office of Privacy to check that the 

proposed use is authorized by law and the individuals for whom status 

verification is sought are within the agency’s jurisdiction. USCIS also 

looks at whether the agency applying is involved in any relevant ongoing 

litigation that could affect the agency’s authority to verify immigration or 

citizenship status through SAVE for particular purposes.17 If USCIS 

determines that the prospective user agency meets the eligibility criteria, 

the agency enters into a MOA (see standard MOA terms in appendix II) 

with USCIS that outlines USCIS and agency purpose and responsibilities 

for participation in, and oversight of, the program.18

 17For example, an Alabama state agency was delayed from gaining access to the SAVE 

system when a 2011 Alabama law, which, among other things, made it a felony for an 

individual not lawfully present in the U.S. to enter into a public records transaction with the 

state or a political subdivision, including applying for or renewing certain licenses, and 

required that immigration status be determined by verification with the federal government, 

faced legal challenges. The agency was eventually able to access the system, and USCIS 

specified that the agency could use SAVE to determine lawful presence, for purposes of 

valid statutory provisions under state law, but may not use the system to conclude an 

individual is in violation of U.S. immigration law. Pursuant to IRCA, the SAVE program is 

not to be used by DHS for administrative (non-criminal) immigration enforcement 

purposes. Pub. L. No. 99-603, tit. I, pt. C, § 121(c)(1), 100 Stat. at 3391 (classified at 42 

U.S.C. § 1320b-7 note). 

18The MOA includes standard terms that are generally applicable to all user agencies, and 

outline agency responsibilities and requirements for using SAVE for the approved 

purpose(s).
Page 15 GAO-17-204 Immigration Status Verification for Benefits

USCIS has taken steps to assess the accuracy of the information 

reported by the SAVE system, but does not have sufficient controls to 

help ensure agencies are completing the necessary verification steps (1) 

because of guidance that does not clearly indicate what agencies are 

required to do to follow the MOA provision to perform any additional 

verification procedures the SAVE program requires and (2) because 

USCIS lacks reasonable assurance that SAVE users are completing 

SAVE training that explains the additional verification process. From fiscal 

years 2012 through 2015, USCIS exceeded its targets for providing 

agencies with timely SAVE responses, but agencies and benefit 

applicants are not always aware the SAVE response has been returned 

to them and therefore may be delayed in processing benefit 

determinations.

To help ensure initial verification accuracy, since 2014 USCIS has 

conducted monthly checks to ensure SAVE is accurately reporting 

information contained in its source systems.19 According to USCIS 

officials, as part of this check, each month USCIS generates a random 

sample of 64 verifications and then matches the alien numbers (Anumber) against the same A-numbers in select SAVE source systems to 

ensure SAVE accurately pulled the information from its source. Next, 

officials use the related A-numbers to pull all relevant I-94 numbers 

(which record arrivals to and departures from the United States) and 

passport numbers from other USCIS systems and compares them with 

SAVE’s system to ensure the information in the records is accurately 

reflected. USCIS does not track initial verification accuracy as an official 

performance measure, but officials stated in May 2016 that there is very 

rarely an instance in which the SAVE system failed to provide a response 

based upon data in the source systems.

To help ensure the accuracy of SAVE’s additional verification steps 

(referred to as “IAV,” which stands for “institute additional verification”), 

USCIS implemented a process in 2010 designed to ensure the 

immigration statuses arrived at by the status verifiers reflected the 

 19USCIS reported implementing this process in response to recommendations from the 

DHS Office of the Inspector General.See DHS Office of the Inspector General, DHS 

Office of the Inspector General, Improvements Needed for SAVE to Accurately Determine 

Immigration Status of Individuals Ordered Deported, OIG-13-11 (Revised) (Washington, 

D.C.: Dec. 7, 2012).

SAVE Provides 

Accurate and Timely 

Responses, but 

USCIS Could Better 

Ensure User 

Agencies Complete 

all Required Steps 

and Improve its 

Guidance and 

Training

USCIS Works to Ensure 

SAVE Provides Accurate 

Responses through a 

Multi-Step Process and 

Internal Reviews
Page 16 GAO-17-204 Immigration Status Verification for Benefits

immigration status on record for persons seeking benefits—in other 

words, that there were no false positives (providing a status when one 

does not exist) or false negatives (failing to provide a status when one 

exits). Drawing a monthly simple random sample of approximately 385 

verification responses, SAVE officials follow the steps of the status 

verifiers to ensure they arrive at the same response. In 2015, USCIS 

reported that its additional verification responses were 99.16 percent 

accurate (exceeding the agency’s goal of 98.4 percent accuracy). During 

fiscal year 2015, USCIS identified 30 instances in which additional 

verifications had resulted in false negatives and eight instances of false 

positives. USCIS followed up with user agencies in appropriate cases to 

ensure the agency was aware of the error and provided with a correct 

status response.

SAVE officials stated that they have taken actions to improve the 

accuracy of additional verifications since implementation of these quality 

assurance testing processes. For example, officials said they 

implemented a corrective action review process in which they generate 

reports in response to findings uncovered throughout the process and 

share these reports with SAVE supervisors for review and corrective 

action. Status verifiers must often reconcile several pieces of information 

generated at different points in time with varying periods of effect or 

applicability across multiple sources in order to accurately arrive at the 

status reflected in the source systems. For example, a 2016 corrective 

action report showed an instance where a status verifier queried 

information from three separate systems to determine that an applicant 

was employment authorized until September 2016, but did not identify 

that the applicant had also been approved for a status that conferred 

employment authorization until September 2017. The status verifier was 

provided with counseling and the correct status was provided to the 

benefit granting agency. SAVE officials also developed a SAVE response 

guide to assist status verifiers in providing quality verification responses. 

The response guide, which USCIS officials stated became effective in 

October 2015, is designed to capture real-time information changes, such 

as relevant policy changes affecting benefit eligibility or interpretation of 

immigration status.
Page 17 GAO-17-204 Immigration Status Verification for Benefits

Agencies that use SAVE are required to complete all steps in the status 

verification process, but USCIS does not have sufficient controls to help 

ensure agencies are completing the necessary steps. According to our 

analysis, from fiscal year 2012 through fiscal year 2016, the majority of 

SAVE user agencies that received a SAVE response prompting them to 

institute additional verification did not complete the required additional 

steps to further verify the benefit applicant’s immigration status, a qualitycontrol step of the SAVE process intended to help ensure that user 

agencies make a benefit eligibility determination with a fully verified SAVE 

response. Additional verification entails an in-depth query by USCIS 

status verifiers to determine the applicant’s immigration status if such 

status cannot be returned by SAVE upon initial verification. The SAVE 

MOA states that agencies agree to ensure all users perform any 

additional verification procedures the SAVE program requires or the 

applicant requests after the user agency initiates a request for verification. 

Of the over 86.6 million SAVE checks that have been conducted during 

this time frame, 16 percent of those checks (approximately 14 million), 

returned a response prompting the agency to institute additional 

verification. Of those 14 million IAV responses, agencies did not proceed 

to additional verification nearly 60 percent of the time (approximately 8.5 

million checks), as shown in table 1.

Table 1: Systematic Alien Verification for Entitlements (SAVE) Responses Requesting Agencies to Institute Additional 

Verification (IAV), by Fiscal Year

Fiscal Year

Initial SAVE 

Queries

Number of 

Reponses 

Requesting 

Additional 

Verification

Percentage of 

Responses 

Requesting 

Additional 

Verification

Times Agency 

did not proceed 

to Additional 

Verification

Percentage of 

Additional 

Verification 

Responses Not 

Completeda

Number of 

Agencies with 

Reponses 

Requesting 

Additional 

Verification

2012 11,002,453 1,711,453 15.6 966,155 56.5 461

2013 13,220,774 2,022,454 15.3 1,076,067 53.2 493

2014 20,895,020 3,054,314 14.6 1,784,234 58.4 485

2015 21,204,357 3,527,902 16.6 2,184,320 61.9 506

2016 20,308,282 3,802,141 18.7 2,450,138 64.4 494

Total 86,630,886 14,118,264 16.3 8,460,914 59.9

Source: GAO analysis of U.S. Citizenship and Immigration Services Data. | GAO-17-204

Note: This data represents those cases in w hich the SAVE system returned a response prompting the 

agency to initiate additional verification. This data does not include cases in w hich agencies elected 

to send a case to additional verification w ithout being prompted by the system.

a

There are an unknow n number of instances in w hich applicants may voluntarily w ithdraw their benefit 

applications. When agencies elect to close a case instead of initiating additional verification, USCIS 

does not currently track the reason the agency is not proceeding, such as the applicant w ithdrawing 

or the applicant presenting different documentation to run a new initial verification.

USCIS Could Improve 

SAVE Accuracy by 

Strengthening Controls to 

Help Ensure Benefit 

Granting Agencies 

Complete All Required 

Steps of a SAVE Check
Page 18 GAO-17-204 Immigration Status Verification for Benefits

There may be legitimate reasons user agencies do not proceed to 

additional verification when prompted. For example, USCIS officials 

reported that in some cases applicants may choose to withdraw their 

benefit application before the case is adjudicated, or agencies may 

choose to use their own discretion in adjudicating benefit eligibility based 

on the initial SAVE response and other evidence of satisfactory 

immigration status. There is also an unknown number of cases that may 

be duplicate submissions, according to USCIS, where an applicant could 

have provided the agency with different documentation to re-run an initial

verification, rather than instituting additional verification. However, our 

analysis of SAVE check data indicates that some user agencies are not 

instituting the required verification steps on a more systematic basis. 

Specifically, from fiscal years 2012 through 2016, 14 percent of agencies 

that had at least one SAVE response of IAV did not proceed to additional 

verification 100 percent of the time, and 57 percent of agencies did not 

proceed to additional verification at least half the time, as shown in 

table 2.

Table 2: Systematic Alien Verification for Entitlements (SAVE) User Agencies’ Rates of Failure to Institute Additional 

Verification (IAV), by Fiscal Year

Fiscal Year

Number of

Agencies Requesting

a SAVE Check that

Received an IAV Response

Number and Percentage of Agencies Not Initiating Additional Verification 

Rate of

50%or more

Rate of

75% or more

Rate of

90% or more Rate of 100%

2012 461 292 (63.5%) 157 (34.1%) 88 (19.1%) 64 (13.9%)

2013 493 328 (66.5%) 186 (37.7%) 105 (21.3%) 79 (16.0%)

2014 485 337 (69.5%) 220 (45.4%) 125 (25.8%) 79 (16.3%)

2015 506 355 (62.2%) 217 (38.0%) 116 (20.3%) 67 (11.7%)

2016 494 323 (57.3%) 178 (36.0%) 92 (18.6%) 55 (11.1%)

Average 57.3% 44.9% 25.7% 14.1%

Source: GAO analysis of U.S. Citizenship and Immigration Services Data. | GAO-17-204

Generally, the percentage of agencies not initiating additional verification 

steadily increased from fiscal year 2012 through fiscal year 

2014. However, the percentage generally decreased by fiscal year 2016 

near to or below the level in fiscal year 2012. There have also been a 

fluctuating number of agencies that have failed to institute additional 

verification 100 percent of the time in each fiscal year from 2012 through 

2016. For example, in fiscal year 2016, 494 agencies received at least 

one SAVE response that required additional verification and 55 of those 

agencies did not proceed to additional verification 100 percent of the 

time—not completing a total of 4,415 checks. When including agencies 
Page 19 GAO-17-204 Immigration Status Verification for Benefits

that did not complete IAV 98 percent of the time or more, that number 

increases to 65 agencies and over 256,000 incomplete SAVE checks.

The types of agencies that did not complete additional verification 

covered every type of SAVE user (federal, state, local, and departments 

of motor vehicles) and many types of benefits, including driver’s licenses, 

health care, and voter registration. For example, in fiscal year 2016, 

agencies that did not complete additional verification 98 to 100 percent of 

the time included a state children’s health program, a department of 

motor vehicles, a state unemployment insurance department, two 

counties (from the same state) responsible for elections and voter 

registration, a county property appraiser’s exemptions investigations unit, 

and a state health care services department. These seven agencies 

requested a combined total of over 1.7 million SAVE checks and did not 

complete additional verification over 245,000 times—approximately 14 

percent of the agencies’ total SAVE checks that fiscal year.

We found a variety of reasons agencies may not be completing each step 

of the SAVE process, when required, including (1) guidance that does not 

clearly indicate what agencies are required to do to follow the MOA 

provision to perform any additional verification procedures the SAVE 

program requires and (2) no mechanism to ensure agencies are 

completing required SAVE training that explains the additional verification 

process.20

Guidance on IAV Purpose and Requirement. The SAVE program 

provides several guidance documents and training videos for user 

agencies, but the guidance and training videos use inconsistent and 

potentially ambiguous language to describe agencies’ responsibilities for 

completing IAV. For example, the SAVE Program Guide—which USCIS 

instructs agencies to be familiar with prior to using SAVE—uses both 

permissive and mandatory language to describe additional verification 

requirements, stating in one section that agencies “must” submit an 

additional verification request to allow the SAVE program to conduct 

further research, and stating in another that it “may” be necessary to enter 

additional information in certain scenarios, such as when a user receives 

 20As previously noted, USCIS officials reported that agencies may have legitimate 

reasons to not proceed to additional verification and are not necessarily denying benefits 

at this stage.
Page 20 GAO-17-204 Immigration Status Verification for Benefits

a response to institute additional verification.21 The guide also does not 

define key verification terms, noting that agencies should proceed to 

additional verification when a status is “not confirmed,” which could be 

confusing since “not confirmed” is not a response SAVE returns.22 The 

SAVE User Reference Guide contains similarly unclear language. 

Specifically, under the section on additional verification, the guide states 

that users have the following options: (1) click “request additional 

verification” button to submit additional information for verification, (2) 

click “initiate a new case” button to request initial verification, or (3) click 

“close case” button to close the case. The guide does not provide 

instruction on how agencies should decide which option is most 

appropriate, and is further unclear since the second option—request initial 

verification—is what the user did to arrive at that set of options. In 

addition to the Reference Guide and the Program Guide, in 2015 USCIS 

developed a SAVE Self-Assessment Guide for agencies to use to assist 

with the proper use of SAVE and to improve the integrity of their SAVE 

verifications, among other goals. The SAVE Self-Assessment Guide 

provides user agencies with an explanation of SAVE’s multi-step 

 21Specifically, page 8 of the Program Guide states, “All users must perform any additional 

verification procedures the SAVE Program requires and/or the applicant requests. When 

the system returns a response of Institute Additional Verification, Resubmit Doc, or 

otherwise indicates additional verification is required, or the benefit applicant requests 

additional verification, the user must continue the verification process to ensure that SAVE 

conducts the necessary research on behalf of the benefit applicant.” In addition, page 12 

of the Program Guide notes that where status cannot be verified immediately through 

initial verification, “the user must submit an additional verification request to allow the 

SAVE Program to conduct further research.” However, page 13 of the guide, in the section 

on Additional Verification, states, “There are times with [sic] [when] it may be necessary to 

enter additional information to complete the verification process, for example: [w]hen the 

user receives a response ‘Institute Additional Verification.’” Given the examples included, 

it is not entirely clear whether this section is referring only to instances in which an agency 

needs to provide additional information to complete the verification process, or whether 

the additional verification process only occurs when the agency has additional information 

to provide. 

22Page 13 of the Program Guide states, “If the applicant’s immigration status is confirmed, 

the verification process is complete. If the status is not confirmed, or the user or applicant 

has a concern about the verification response, the verification process continues by the 

user requesting additional verification.” Prior sections (on page 8 of the Program Guide 

and as previously described) do not mention concern on the part of the SAVE user as a

reason for proceeding to additional verification after an applicant’s immigration status has 

been confirmed. It is unclear what kind of concerns could or should compel an agency to 

push a case to additional verification after an applicant’s immigration status has been 

confirmed. It is also unclear whether or how an applicant would be able to request 

additional verification since the Program Guide’s verification steps do not include sharing 

the SAVE response with the benefit applicant. 
Page 21 GAO-17-204 Immigration Status Verification for Benefits

verification requirement; however, none of the 13 agencies we met with 

reported either being aware of this guidance or using it.23

In addition to written guidance, the SAVE Program provides online 

informational videos and training. At the time of our review, the 

information available on USCIS’s SAVE Resources webpage included 

three videos (SAVE Overview, SAVE Requirements, and SAVE Features) 

and under a page for SAVE Training Opportunities, a SAVE Tutorial 

which contained four interactive lessons and a mastery test.24 The SAVE 

Tutorial has a lesson dedicated to the SAVE Verification Process that 

explains that SAVE can be a three step process and that additional 

verification is a required step when SAVE cannot verify an immigration 

status after initial verification. The tutorial also covers this requirement in 

its final mastery quiz.

However, other training videos and tutorials were less clear about the 

purpose of additional verification and agencies’ responsibilities for 

completing it. For example, we reviewed USCIS’s resources for benefit 

applicants in August 2016 and found incomplete information on additional 

 23Page 3 of the Self-Assessment guide states, “Some cases cannot be verified 

immediately. In other situations, the applicant may not agree with the SAVE determination. 

Conducting additional verification provides the opportunity for the SAVE agency or the 

applicant to present more information that may be helpful to obtain an accurate response. 

Without the additional verification, the process may be incomplete and the integrity of the 

process could be compromised. Accordingly, the MOA and Program Guide require users 

to perform all additional verification procedures that SAVE requires or the benefit applicant 

requests after initiating electronic verification.” Page 8 of the SAVE Program Guide states 

that “[a]gencies may not rely on a SAVE response to deny an application for benefits 

unless the agency has followed all SAVE verification procedures—including submitting the 

request for additional review when prompted by the system, and/or as requested by the 

applicant—and has received a response indicating the applicant’s immigration status. 

Otherwise, the user agency may deny eligible persons benefits that they are lawfully 

entitled to receive.” Of the 13 agencies we interviewed, officials from 11 had not heard of 

the Self-Assessment guide and officials from 2 reported using some USCIS guidance, 

such as the Program Guide, but did not report using the Self-Assessment.

24The four tutorial lessons are (1) SAVE Program Overview, (2) Immigration 

Classifications and Most Common Immigration Documents, (3) SAVE Verification 

Process, and (4) Setting up Your Agency and User Roles and Responsibilities. We were 

unable to access the tutorial by clicking through the SAVE webpage (which is noted as 

current as of 12/1/16 while the training opportunities page was last updated 4/15/15). 

USCIS officials provided us a link to the SAVE Tutorial, which we were then later able to 

find by typing “training opportunities” into the SAVE homepage search bar. Additionally, 

since we reviewed the SAVE Resources in August 2016, USCIS has added two additional 

videos, “How SAVE Can Help Your Agency” and “SAVE Registration.” We did not review 

these videos.
Page 22 GAO-17-204 Immigration Status Verification for Benefits

verification. Specifically, the SAVE Awareness Video for benefit 

applicants stated, “If the applicant gives the agency outdated or incorrect 

immigration documents, SAVE will prompt the agency to start a second 

step verification” and further states, “If your immigration status cannot be 

verified immediately based on incorrect, invalid, or out of date immigration 

documents, you may have to update or correct your immigration 

documents before the agency can submit an additional verification. This 

is known as third step verification.” These instructions are inconsistent 

with guidance provided to user agencies. For example, the video omits 

other situations in which additional verification occurs aside from when an 

applicant gives outdated or incorrect information. Additional verification 

can also be necessary when a particular document is not readily 

accessible by SAVE or is programmed to automatically require additional 

verification. The video also states that an applicant may have to update or 

correct their immigration documents before the agency can proceed to 

second step verification. However, an applicant’s information may not be 

out of date; rather a SAVE response may not be returned during initial 

verification if the applicant’s information is not in one of the systems 

SAVE searches on initial verification, for example. The video is also 

inconsistent with the SAVE Program Guide which states that additional 

verification must be initiated upon the benefit applicant’s request—

something that benefit applicants are not made aware of in the SAVE 

video, brochure, and fact sheet for applicants that we reviewed.25

In response to a 2012 recommendation from a DHS Office of the 

Inspector General report to determine whether SAVE is at risk of 

erroneously verifying certain populations, USCIS reported in 2013 that it 

had established internal monthly meetings to analyze trends in agencies’

failures to institute additional verification.26 USCIS officials reported that 

these meetings resulted in USCIS identifying particular classes of 

admission for further study, as well as studying which customer agencies 

 25The SAVE Privacy Impact Assessment (PIA) provides a similarly inconsistent 

description of additional verification which may further contribute to agency 

misunderstandings about IAV. Specifically, the PIA states that “the SAVE customer 

agency may initiate the additional verification procedure to...determine the applicant’s 

immigration status. At the point at which the “Institute Additional Verification” message is 

displayed, customer agencies are required to inform benefit applicants of the additional 

verification option and to pursue it if requested by the applicant.” This appears to indicate 

that additional verification is optional and completed if requested by the benefit applicant.

26See DHS Office of the Inspector General, Improvements Needed for SAVE to 

Accurately Determine Immigration Status of Individuals Ordered Deported, OIG-13-11 

(Revised) (Washington, D.C.: Dec. 7, 2012).
Page 23 GAO-17-204 Immigration Status Verification for Benefits

ran the queries and what immigration documents the applicants 

presented as proof of status. However, in May 2016, officials stated these 

reports had been used to identify ways to reduce the number of 

responses requiring additional verification and have more checks 

completed upon initial verification. Nonetheless, since fiscal year 2012, 

the number of checks requiring IAV has grown each fiscal year, from 

about 16 percent of checks in 2012 to about 19 percent in 2016. 

Reducing the number of checks that return a response of IAV is an 

important goal, but does not help user agencies understand their roles 

and responsibilities with respect to the nearly 4 million IAV responses 

SAVE returned in fiscal year 2016. The SAVE agency MOA states that 

user agencies agree to ensure all users perform any additional 

verification procedures the SAVE program requires or that the applicant 

requests after the user agency initiates a request for verification. Further, 

Standards for Internal Control in the Federal Government call for 

agencies to implement controls, such as communicating quality 

information and demonstrating commitment to competence (including 

quality guidance and training), to enable an agency to achieve its 

objectives.27 Taking action to ensure that SAVE guidance clearly and 

accurately reflects user agencies’ responsibilities for completing each 

step of a SAVE check could help reduce the number of SAVE checks that 

fail to complete each required step and help USCIS ensure that user 

agencies are receiving and using accurate and complete information.

Methods for Ensuring Agencies are Completing Training on SAVE 

IAV Procedures. Under the SAVE MOA, agencies agree to ensure all 

users complete required training, but USCIS does not track or monitor 

whether users have completed training and therefore does not have 

reasonable assurance that users have mastered SAVE policies and 

procedures prior to accessing the system.28 The SAVE user agencies we 

met with reported a variety of ways in which they trained new users on 

their roles and responsibilities for using SAVE, including procedures for 

completing additional verification. Six of 13 agencies reported showing 

 27GAO-14-704G.

28The MOA states that agencies agree to “ensure that, prior to using [SAVE], all users 

performing verification procedures complete SAVE required training, including: reading the 

SAVE Program Guide, taking the latest version of Web tutorial(s) and maintaining a 

working knowledge of requirements contained therein and in this MOA, as updated.” It 

also states that agencies agree to “ensure all users performing verification procedures 

comply with all requirements contained in the SAVE Program Guide, web-based tutorial, 

and this MOA, and updates to these requirements.” 
Page 24 GAO-17-204 Immigration Status Verification for Benefits

new users USCIS’s SAVE training videos or the SAVE tutorial, 3 

agencies reported using the SAVE Program Guide as a source of 

guidance, and 4 agencies reported that their users learned SAVE policies 

and procedures through on-the-job training. Two of 13 agencies reported 

that they relied on their MOA for guidance, while 4 agencies were not 

sure of the location or contents of their MOA.29

Officials from 9 of 12 agencies that commented on additional verification 

said they fully understood the requirement to proceed to IAV. However, 

only 3 of the 9 agencies completed IAV more than half of the time in fiscal 

year 2015.30 Of the agencies we met with, 3 of the 4 with the highest 

number of checks in fiscal year 2015 that did not institute additional 

verification reported developing their own in-house training using SAVE 

materials.31 Of these 3, one agency reported teaching new SAVE users 

on-the-job and another agency said it had no additional training needs. 

Further, a state DMV we spoke with that did not complete additional 

verification approximately 77 percent of the time in fiscal year 2015 

reported that the SAVE training was very helpful and that they had no 

additional training needs. A senior official from this DMV further stated 

that it was the agency’s understanding that a SAVE response that does 

not verify on initial verification (meaning the agency should institute 

additional verification) was an indication that the applicant’s documents 

were counterfeit, and the agency would only proceed to additional 

verification at the discretion of the individual licensing agent or when 

faced with an applicant that strongly insisted he or she had no other 

documentation to provide—which is not consistent with USCIS’s guidance 

or the SAVE MOA. The official from this agency reported that, in general, 

 29Total does not add to 13 since not all agencies had a comment on their agency’s use of 

the MOA.

30Specifically, these 3 agencies requested approximately 1.07 million SAVE checks in 

fiscal year 2015. Approximately 147,000 of those checks returned a response of institute 

additional verification. Agencies completed additional verification in approximately 136,000 

of these cases—or 92 percent of the time. In contrast, the other 6 agencies requested 

approximately 1.3 million SAVE checks, of which about 253,000 returned a response of 

institute additional verification. Agencies completed additional verification approximately 

68,000 times—or 27 percent of the time.

31Of these 3 agencies, officials from one state DMV reported that a lack of legal status 

was not a barrier to obtaining a license in their particular state. Therefore, the lack of 

completed verifications may not signify a negative impact on applicants in their state. In 

fiscal year 2015, this state DMV submitted approximately 914,000 SAVE queries, of which 

about 150,000 were returned with a response of “institute additional verification.” The 

DMV submitted the check for additional verification in about 44,000 of these cases. 
Page 25 GAO-17-204 Immigration Status Verification for Benefits

the agency will request an applicant return with different documentation 

and then will run another initial verification, and about half of applicants 

do not return.

USCIS officials stated that users are required, per the MOA, to complete 

training prior to using the system, but USCIS does not track whether 

users have taken the training because it is the user agencies’

responsibility to do so. USCIS officials said they would like to have a 

tracking capability in the future, but competing priorities and limited 

funding have prevented them from doing so thus far. Officials explained 

that they hoped to develop an update to SAVE that would require all new 

users to pass a SAVE mastery test prior to accessing the system, but 

officials were uncertain when this capability would be added. However, 

officials stated it is ultimately it is each agency’s responsibility to ensure 

its SAVE users have completed the necessary training. The SAVE 

Monitoring and Compliance (M&C) Branch (discussed in detail later in this 

report), analyzes the extent to which agencies are completing additional 

verification, but does not monitor the extent to which agencies are 

completing SAVE training and does not evaluate the extent to which 

agency training sufficiently addresses SAVE MOA provisions for 

completing additional verification.

The SAVE MOA states that user agencies agree to ensure that all users 

performing verification procedures complete SAVE required training, 

including reading the SAVE Program Guide, taking the latest version of 

Web tutorial(s), and maintaining a working knowledge of requirements 

contained therein and in the MOA. Taking steps to track whether user 

agencies are appropriately training their SAVE users would provide 

USCIS, as the agency responsible for managing and overseeing SAVE, 

with reasonable assurance that SAVE information is being accessed and 

used properly. Further, Standards for Internal Control call for agencies to 

establish expectations of competence for key roles, including possessing 

the necessary knowledge, skills, and abilities, and training individuals 

appropriately.32 Without a mechanism to oversee agencies’ completion of 

training—such as through requiring annual completion of the SAVE 

Tutorial as a condition for access to the system—USCIS cannot ensure 

agencies are aware of the importance of additional verification in ensuring 

an accurate SAVE response.

 32GAO-14-704G.
Page 26 GAO-17-204 Immigration Status Verification for Benefits

SAVE user agencies we met with reported facing challenges interpreting 

certain SAVE responses and effectively using them to make benefit 

eligibility determinations, and USCIS has provided tools and guidance 

aimed at addressing these challenges. A SAVE initial verification 

response returns an individual’s immigration or naturalized or derived

citizenship status as 1 of 1,053 possible codes, along with other 

information to help agencies clarify what the code means. User agencies 

interpret the code and any additional clarifying information returned by 

SAVE and compare that information against documentation provided by 

the applicant and their specific benefit-eligibility criteria. For example, 

some states require individuals to show proof of satisfactory immigration 

status when applying for a driver’s license. The applicant would have to 

provide the department of licensing with information supporting his or her 

lawful presence, which would be submitted through SAVE. The SAVE 

result would not indicate whether the applicant has lawful status or 

presence, per se—rather it would provide that individual’s current status 

as indicated by source systems (such as “student,” indicated by the code 

F-1, or “Cuban Haitian Entrant,” indicated by the code CH6). The 

department of licensing would then interpret this response to determine if 

that status meets immigration requirements, and for temporary statuses, 

how long the applicant will be lawfully present in order to grant the proper 

benefit. The benefit granting agencies we met with identified a range of 

challenges they faced in making these determinations and in using SAVE 

responses to adjudicate benefit eligibility, as shown in table 3.

USCIS Has Worked to 

Help User Agencies Use 

SAVE Responses to 

Determine Benefit 

Eligibility
Page 27 GAO-17-204 Immigration Status Verification for Benefits

Table 3: Systematic Alien Verification for Entitlements (SAVE) Selected User Agency Reported Challenges Determining a 

Benefit Applicant’s Eligibility based upon SAVE Responses 

Challenge Example

Interpreting eligibility of 

unique statuses and 

designations

Agency officials we interviewed reported facing challenges with understanding certain immigration 

statuses and designations, such as Cuban/Haitian Entrant, based upon SAVE responses. 

Cuban/Haitian Entrant is a special immigration parole status for nationals of Cuba or Haiti that affords 

eligibility for certain benefits and services and such individuals may obtain additional statuses or 

designations such as temporary protected status or lawful permanent resident status provided they 

satisfy the applicable eligibility requirements.aAn agency may not be aware of these various 

designations and, as a result, may not adjudicate benefits appropriately. 

Provided dates not 

applicable for determining 

benefit eligibility

Some agencies award benefits for shorter or longer durations depending upon an applicant’s 

eligibility, but agency officials we interviewed reported that SAVE responses do not easily allow 

agencies to make those determinations. For example, some departments of motor vehicles (DMVs) 

we spoke with stated that the ‘duration of stay’ response is confusing for their purposes and they are 

unsure whether to issue a short or long term license given the SAVE response.

Additionally, according to officials from a few user agencies we spoke with, SAVE often provides the 

‘date of entry’ field as the date of the applicant’s most recent change in status instead of the actual 

date of entry into the United States. They said that this can be confusing for user agencies, require 

additional time and research on their part to determine the actual date of entry as opposed to the 

date of admission under a particular status, and have a potentially negative impact on eligibility for 

certain benefits that require a particular duration of time in the U.S.

Response differs from 

applicant’s documentation

The SAVE response may be more or less favorable for the applicant’s benefit eligibility than the 

document the applicant presents, thus requiring the user agency to decide which one is authoritative 

for purposes of a benefit determination. For example, officials from a DMV we spoke with stated that 

an applicant presented an employment authorization card, which would authorize the applicant for a 

2 year license. However, the SAVE response stated that the applicant was a lawful permanent 

resident, meaning the DMV could issue a 5 year license. This situation was more favorable for the 

applicant, but the DMV was unsure if the response was accurate.

Source: GAO analysis of interviews with SAVE user agencies. | GAO-17-204

a

See Matter of L-T-P-, 26 I. & N. Dec. 862, 869 (BIA 2016) (citing Refugee Education Assistance Act 

of 1980, Pub. L. No. 96-422, § 501(e), 94 Stat. 1799, 1810 (classified, as amended, at 8 U.S.C. § 

1522 note)). “[T]he purpose of the [Cuban/Haitian Entrant] provision w as to treat Cuban and Haitian 

migrants as refugees for purposes of the Federal refugee resettlement program and most other 

Federal benefits and assistance.” Id. (citing Cong. Research Serv., RS21349, U.S. Immigration Policy 

on Haitian Migrants 8-9 (2011)).

To help user agencies better understand and interpret SAVE responses, 

USCIS has provided guidance and tools aimed at addressing some of the 

challenges mentioned by user agencies we selected. For example, 

USCIS has provided user agencies with fact sheets for interpreting 

complex immigration designations, such as Cuban-Haitian Entrants or 

Temporary Protected Status Beneficiaries. USCIS has also held an 

annual virtual forum for user agencies since 2012 to discuss SAVE 

initiatives and customer support efforts, which includes a period of time 

for questions and concerns from agencies. In addition to guidance, 

USCIS established a hotline for user agencies that need assistance with 

interpreting a SAVE response. The hotline is also a resource for other 

inquiries, including responding to agencies wishing to check on the status 
Page 28 GAO-17-204 Immigration Status Verification for Benefits

of a pending SAVE response, prospective user agencies with questions 

on registering for SAVE, and those wishing to request SAVE trainings. 

According to our analysis, in fiscal year 2015, 37 percent of SAVE users 

that had at least one SAVE check that year (212 of 572 agencies) called 

the hotline. Further, in fiscal years 2014 and 2015, approximately 20 

percent of all calls to the hotline were related to clarifying a SAVE 

response. Seven of the user agencies we met with called the hotline in 

fiscal year 2015 with questions and officials from 4 of those agencies 

reported that calling the hotline typically resolved the challenges they 

faced. Officials from some user agencies we spoke with reported that 

when challenges arise, they address them by reviewing SAVE’s online 

resources and guidance. For example, officials from one agency stated 

that when they have questions, they find the information they need by 

checking the SAVE system homepage, including utilizing the help button. 

Further, USCIS provides user agencies with a help e-mail address.

In addition to USCIS’s current guidance and tools, in February 2016, 

USCIS initiated a mandated independent evaluation of the SAVE 

program.33 According to the evaluation project summary, the evaluation 

will assess how user agencies are integrating SAVE into their business 

processes as well as their satisfaction with the SAVE program. Some of 

USCIS’s specific questions will include whether SAVE users know how to 

access help when needed, whether there are common 

misunderstandings about the purpose or function of SAVE, and what 

support users need to more fully and properly use SAVE. The project 

summary further states that results of the evaluation are expected in July 

2018. USCIS officials said they have long sought to better understand 

customer use and implementation of SAVE as a means of improving the 

program and that this study would help them in this goal.

 33The mandate for this evaluation originated with the Fiscal Year 2015 Office of 

Management and Budget (OMB) pass back guidance to DHS stating: “Guidance requests 

that the FY2015 program funding level for SAVE be set at a level that supports an 

independent evaluation of the SAVE program. This independent evaluation...should 

analyze how the program is implemented by user agencies and the experience of 

individuals attempting to correct their records in response to SAVE issued information.”

Department of Homeland Security 2015 Guidance, Jan. 22, 2014, pg. 25. 
Page 29 GAO-17-204 Immigration Status Verification for Benefits

From fiscal years 2012 through 2015, USCIS exceeded its targets for 

providing agencies with timely SAVE responses, but agencies and benefit 

applicants are not always aware the SAVE response has been returned 

to them and therefore may be delayed in processing benefit 

determinations. From fiscal year 2012 through fiscal year 2015, USCIS 

exceeded its targets for returning information to user agencies within 3 to 

5 federal working days for second-step verifications and within 20 days 

for third-step verification.34 Specifically, USCIS’s target percentage for 

SAVE requests responded to within 3 federal workdays of receipt was 97 

percent each fiscal year, according to its guidance. USCIS exceeded this 

target each year, meeting its turnaround target 98.9 to 99.8 percent of the 

time. When there have been delays, USCIS officials said they believed 

that user agency business processes or delays in the systems searched 

by SAVE were the reason, such as records not being uploaded in a timely 

manner, and therefore not being accessible by SAVE.35

Delays in the SAVE process can also occur when user agencies are 

unaware that the SAVE case status has been returned and the case is 

ready for adjudication at the user agency level. Specifically, 8 of 9 user 

agencies we met with reported that they would like to receive updates or 

communication during the additional verification period or notification from 

SAVE when the case is ready for adjudication—that is, when SAVE has 

completed the additional verification.36 Currently, some agencies reported 

developing business processes to manually check the individual statuses 

of all cases undergoing additional verification, which for some agencies 

could be thousands of cases. Officials from 8 of 9 agencies that 

commented on additional verification timeliness said that having a 

notification from SAVE would be helpful for ensuring the timely 

adjudication of benefit applications. For example, officials from a state 

department of motor vehicles that was prompted to initiate approximately 

29,000 additional verifications in fiscal year 2015 stated that users must 

log into SAVE to check on the status of their cases and may have to click 

through 10 pages of cases to identify which cases they are working on 

 34USCIS officials reported that SAVE did not have a timeliness metric for initial 

verifications, but reported that these verifications are generally completed in seconds.

35This would, in turn, result in an individual’s status not being returned in the SAVE check, 

since the underlying record would not yet be accessible. The applicant would have to 

return at a later date to try the initial check again, or the agency would have to request 

additional verification, which takes an additional 3 to 5 days. 

36We interviewed officials from 13 agencies, but officials from 4 agencies did not comment 

on additional verification and/or had not had a case proceed to additional verification.

USCIS is Meeting SAVE 

Timeliness Response 

Goals, but Improved 

Notification and Guidance 

Could Help Agencies and 

Benefit Applicants
Page 30 GAO-17-204 Immigration Status Verification for Benefits

and if there are any updates. Officials from a federal agency that was 

prompted to initiate 257 additional verifications in fiscal year 2015 also 

agreed that notification from SAVE that a case is complete would be 

helpful, but said their agency had developed business processes to 

manually check cases.

SAVE officials have not developed a system to notify user agencies when 

cases are ready for adjudication after additional verification because they 

instead have focused their efforts on implementing an online tool for 

benefit applicants (rather than user agencies) to check their own case 

status. This tool—known as Case Check—was implemented in 2012 in 

order to better meet the needs of applicants as well as to assist agencies 

by reducing the number of calls and walk-ins from individuals wanting to 

know the status of their case. According to the Case Check fact sheet, 

benefit applicants can use Case Check to see whether their case has 

been adjudicated so they know when to return to the benefit granting 

agency. In other words, benefit applicants can use Case Check to alert 

the agency when their case is ready for adjudication. However, none of 

the 4 agencies we met with that discussed Case Check were making 

applicants aware of this tool because either the agencies were unaware 

of it themselves, they misunderstood its purpose (thinking it was for the 

agencies’ use—not the benefit applicants), or it was not applicable based 

on their agency’s use of SAVE.37 Over the course of our review, USCIS 

updated its online Case Check guidance to clarify how benefit applicants 

can use the system, and also reported making enhancements to the 

system to make it easier for applicants to use. However, Case Check 

does not provide a notification to the applicant (or to the agency, in those 

cases where agencies may be using the system) when his or her case is 

ready for adjudication—the applicant must log into the system each day 

to check the status of his or her case. Standards for Internal Control in the 

Federal Government state that agencies should communicate quality 

information so that external parties can achieve agency objectives and 

address related risks.38 Without timely notification to user agencies that a 

case is complete, user agencies may be required to spend time and 

 37Specifically, Department of Education officials reported being aware of Case Check, but 

since applicants for federal student aid apply through an automated process, officials said 

there is no need for Case Check. Additionally, SAVE officials said that other federal 

agencies, including the Department of Health and Human Services, did not want their 

benefit applicants to use Case Check because it interfered with their established business 

processes. 

38GAO-14-704G. 
Page 31 GAO-17-204 Immigration Status Verification for Benefits

resources manually checking cases and applicants may be delayed in 

receiving time sensitive benefits such as voter registration.

USCIS has taken actions to minimize risks to the privacy of benefit 

applicants’ personal information that is checked through SAVE.39 The Fair 

Information Practice Principles (FIPPs), adopted in a 2008 memorandum 

from DHS’s Chief Privacy Officer, are the basis for the department’s 

privacy policy. These principles are Transparency, Individual 

Participation, Purpose Specification, Data Minimization, Use Limitation, 

Data Quality and Integrity, Security, and Accountability and Auditing. 

USCIS has taken actions in the SAVE program related to these 

principles, as shown in table 4.

 39As provided in IRCA, the system used to check immigration status of foreign nationals 

applying for certain federal benefit programs is to protect the individual’s privacy to the 

maximum degree possible. See 42 U.S.C. § 1320b-7(d)(3)(B).

USCIS Has Instituted 

Applicant Privacy 

Protections for SAVE, 

but Could Improve 

Efforts to Assist 

Applicants with 

Resolving Potential 

Errors

USCIS Has Taken Actions 

to Protect the Privacy of 

Personal Information 

Checked through SAVE
Page 32 GAO-17-204 Immigration Status Verification for Benefits

Table 4: Examples of Actions to Address the Fair Information Practice Principles in the Systematic Alien Verification for 

Entitlements (SAVE) Program

Principle Description

Examples of how

U.S. Citizenship and Immigration Services (USCIS)

Addressed the Principle in the SAVE Program

Transparency The Department of Homeland Security 

(DHS) should be transparent and provide 

notice to the individual regarding its 

collection, use, dissemination, and 

maintenance of personally identifiable 

information (PII).

USCIS published updated Privacy Impact Assessments (PIA) 

in 2012 and 2013. DHS also published an updated System of 

Record Notice in 2016. The PIAs defined parameters for the 

use of information within the SAVE program, including setting 

limits on DHS’s collection and use of personal information.

Individual Participation DHS should, to the extent practical, seek 

individual consent for the collection, use, 

dissemination, and maintenance of PII and 

should provide mechanisms for appropriate 

access, correction, and redress regarding 

DHS’s use of PII.

USCIS established mechanisms for access, correction, and 

redress regarding use of an individual’s personal information 

for the SAVE program. 

Purpose Specification DHS should specifically articulate the 

authority that permits the collection of PII 

and specifically articulate the purpose or 

purposes for which the PII is intended to be 

used.

USCIS published updated PIAs in 2013 and 2014 and 

System of Records Notice in 2016. The PIAs defined specific 

legal authorities, arrangements, and/or agreements that 

permit the collection of PII for the SAVE program and also 

described all uses of the information.

Data Minimization DHS should only collect PII that is directly 

relevant and necessary to accomplish the 

specified purpose(s) and only retain PII for 

as long as is necessary to fulfill the specified 

purpose(s).

To mitigate the risk of unauthorized release of information, 

SAVE user agencies are categorized and coded according to 

the type of benefit they administer and, according to USCIS, 

only the minimum data required for accurate verification of an 

individual checked through SAVE is returned to the user 

agency according to the agency’s legally authorized use. We 

did not independently verify the extent to which the minimum 

data necessary was provided to user agencies. 

Use Limitation DHS should use PII solely for the purpose(s) 

specified in the notice. Sharing PII outside 

the department should be for a purpose 

compatible with the purpose for which the 

PII was collected.

USCIS required all SAVE customer agencies to sign a 

memorandum of agreement (MOA) stating the intended use 

of the system, including provisions for safeguarding of 

information obtained from the system. Further, SAVE 

program officials reported reviewing all applications to use 

SAVE to confirm data would be used only for authorized 

purposes.

Data Quality and 

Integrity

DHS should, to the extent practical, ensure 

that PII is accurate, relevant, timely, and 

complete.

USCIS established procedures for status verifiers to manually 

review cases where SAVE is unable to automatically verify an 

individual’s status and search other DHS databases in an 

attempt to verify an individual’s status. 

Security DHS should protect PII (in all forms) through 

appropriate security safeguards against risks 

such as loss, unauthorized access or use, 

destruction, modification, or unintended or 

inappropriate disclosure.

USCIS included provisions of compliance with relevant 

sections of the Privacy Act and the Federal Information 

Security Management Act to safeguard and protect data from 

potential misuse in all SAVE MOAs and Computer Matching 

Agreements signed by user agencies.aWe did not assess 

security protection or the oversight thereof.
Page 33 GAO-17-204 Immigration Status Verification for Benefits

Principle Description

Examples of how

U.S. Citizenship and Immigration Services (USCIS)

Addressed the Principle in the SAVE Program

Accountability and 

Auditing 

DHS should be accountable for complying 

with these principles, providing training to all 

employees and contractors who use PII, and 

auditing the actual use of PII to demonstrate 

compliance with these principles and all 

applicable privacy protection requirements.

USCIS included provisions in MOAs that all SAVE users 

complete SAVE training, web tutorials, and other guidance; 

however we found that USCIS was not tracking the extent to 

which agencies were completing this training. Additionally, 

the USCIS Verification Division’s Monitoring and Compliance 

Branch monitors agencies’ use of SAVE in accordance with 

provisions outlined in the SAVE MOA.

Source: GAO analysis of DHS information. | GAO-17-204

a

The Federal Information Security Modernization Act of 2014 (Pub. L. No. 113-283, 128 Stat. 3073) 

replaced the Federal Information Security Management Act of 2002 (Pub. L. No. 107-347, tit. III, 116 

Stat. 2899, 2946-61) w ith generally similar provisions. In addition, w e w ould note that our audit w ork 

w as conducted prior to the issuance of an Executive Order signed by the President on January 25, 

2017, w hich included a provision for agencies to update their Privacy Act policies. See Exec. Order 

No. 13768, § 14, 82 Fed. Reg. 8799, 8802 (Jan. 30, 2017); see also John Kelly, Enforcement of the 

Immigration Law s to Serve the National Interest 5 (Feb. 20, 2017).

As noted above, USCIS has established a mechanism for access, 

correction, and redress regarding use of an individual’s personal 

information in the SAVE program; however, we found that this 

mechanism does not provide clear information to help benefit applicants 

make timely corrections to their records. USCIS’s mechanism for access, 

correction, and redress is described in the SAVE agency MOA, which 

states that user agencies agree to provide individuals who are denied a 

benefit based solely or in part on a SAVE response with (1) adequate 

written notice of the denial and (2) the information necessary to contact 

DHS so that the individual may correct their records in a timely manner, if 

necessary. User agencies also agree to allow applicants denied benefits 

based on a SAVE response to use the agencies’ existing appeals 

processes and to contact DHS to correct their records prior to a final 

decision, if necessary.

To help agencies provide adequate written notice of a denial and the 

information necessary to contact DHS, USCIS officials developed a fact 

sheet for benefit applicants—a one page document stating, among other 

information, that a person’s immigration status could not be confirmed 

using SAVE and providing information on correcting immigration 

records—as their standard for adequate written notification; however, we 

found that user agencies were not consistently providing this type of 

USCIS Could Improve the 

Notification User Agencies 

Provide to Applicants Who 

Are Denied Benefits 

Based on a SAVE 

Response to Assist in 

Resolving Potential Errors
Page 34 GAO-17-204 Immigration Status Verification for Benefits

notification.40 Specifically, of the eight agencies we interviewed that 

reported having denied a benefit based on information from a SAVE 

response, officials from each reported providing information on the factors 

that led to the denial of benefits, such as informing applicants that the 

reason for denial was for lacking satisfactory immigration or derived or 

naturalized citizenship status. However, officials from three agencies 

reported that they did not provide written notice of the denial and officials 

from three agencies reported that they did not provide applicants with 

information to contact DHS.41 Further, only one agency reported providing 

USCIS’s fact sheet to denied applicants.

According to USCIS, the fact sheet for benefit applicants is also intended 

to help agencies meet the SAVE MOA provision to provide applicants 

with the information necessary to contact DHS to correct or update their 

records. However, we found that the fact sheet’s guidance on contacting 

DHS was not specific or clear, which could hinder benefit applicants’

efforts to contact DHS components. At various times from June through 

December 2016, we attempted to follow the instructions presented in the 

most recent fact sheet and encountered the following challenges, shown 

below in table 5.42

 40The fact sheet is attached to the standard SAVE MOA, provided in the SAVE Program 

Guide, and located on USCIS’s public website where it is available in seventeen 

languages. See copy of fact sheet in appendix III. 

41Two agencies were unsure if applicants denied benefits due to SAVE were provided 

information on contacting DHS to update or correct their immigration record. Agencies that 

did not provide information on contacting DHS reported various reasons for this, such as 

not having direct contact with applicants who were applying for benefits through a third 

party. 

42The 2014 fact sheet included information on scheduling an appointment with USCIS 

Infopass and submitting a request in writing to the Freedom of Information Act/Privacy Act 

Office to obtain copies of records. This information was not included in the 2015 version of 

the fact sheet. 43The Accountability and Auditing principle of the FIPPs states that DHS 

should audit the actual use of PII to demonstrate compliance with the fair information 

practice principles and all applicable privacy protection requirements, among other 

actions.
Page 35 GAO-17-204 Immigration Status Verification for Benefits

Table 5: GAO Attempts to Follow the Instructions in the Fact Sheet for Benefit Applicants Denied a Benefit Because of a 

Systematic Alien Verification for Entitlements (SAVE) Response, Conducted June through December 2016

Option provided in Fact 

Sheet for Benefit 

Applicants GAO Results when Following Fact Sheet Directions 

Visit the U.S. Citizenship 

and Immigration Services 

(USCIS) website at 

www.uscis.gov

GAO found multiple circuitous or unrelated links and non-specific information.

• Clicked first result, “How to Correct your Immigration Records.”

• Routed to a page specific to resolving Tentative Non-confirmations for the E-Verify Program.

• Clicked second result, “Fact Sheet: How to Correct your Records with USCIS.”

• Result said to visit www.uscis.gov, call the National Customer Service Center, or visit 

CBP.gov or ICE.gov/SEVIS.

• Clicked third result, “How to Correct Your Records.”

• Results displayed a page of “Information for Applicants” listed in 17 languages. Clicked on 

information in English. Linked back to the general Fact Sheet for Benefit Applicants stating to 

visit www.uscis.gov, call the National Customer Service Center, or visit CBP.gov or 

ICE.gov/SEVIS.

• Clicked fourth and fifth results, “Fact Sheet: How to Correct USCIS Records.”

• Routed to PDFs with instructions on resolving a tentative non-confirmation in the E-Verify 

Program.

• Clicked sixth result “Questions about your records?”

• Result said to visit www.uscis.gov, call the National Customer Service Center, or visit 

CBP.gov or ICE.gov/SEVIS.

Call the National Customer 

Service Center at 1-800-

375-5283

GAO called and found multiple layers of prompts, none of which related to correcting a record.

GAO spoke with a call center employee who directed us to USCIS Infopass online to schedule an 

in-person appointment with a local field office to make a record correction.

Visit the U.S. Customs and 

Border Protection (CBP) 

website at 

www.cbp.gov/contact

GAO found information unrelated to correcting CBP issued documents and non-working contact 

numbers.

• GAO searched CBP’s Question and Answer tool for the term “Correct my I-94”

• Returned general results on the Form I-94 and nothing related to how to correct a record.

• GAO clicked “Information Correction Request”

• Routed to a webpage on how to correct errors found on CBP’s internet site. This page stated 

that individuals looking to have personal records reviewed or corrected to visit the 

Department of Homeland Security’s Traveler Redress Inquiry Program (TRIP) page.

• GAO Called the Contact Number listed for CBP on the Contact Page

• GAO called on multiple occasions from June 2016 through December 2016 and found this to 

be a non-working number on 4 occasions (i.e., no tone or message). The number connected 

to a prerecorded message on one occasion which stated that the center was closed. 
Page 36 GAO-17-204 Immigration Status Verification for Benefits

Option provided in Fact 

Sheet for Benefit 

Applicants GAO Results when Following Fact Sheet Directions 

Visit the U.S. Immigration 

and Customs Enforcement 

(ICE) website at 

www.ice.gov/SEVIS

GAO found general information on the Student and Exchange Visitor Program but with no 

obvious links to correcting records.

• GAO clicked the homepage link, “For Students”

• No information on correcting records

• GAO clicked the homepage link, “SEVIS (Student and Exchange Visitor Information System) Fact 

Sheets”

• No information on correcting records

• GAO called the SEVP response center

• Did not speak to a representative, but followed prompts to one that asked if the caller had 

been denied a driver’s license, ID card, or other USCIS-administered benefit. 

Source: GAO analysis. | GAO-17-204

Immigrant advocacy groups we interviewed also reported that the 

notifications provided by user agencies to benefit applicants who have 

been denied benefits based on a SAVE response have been inadequate 

for supporting individuals needing to correct their records in a timely 

manner. For example, officials from one organization said that individuals 

will receive a notice when they are denied a benefit and are told to go to 

any one of several DHS components to obtain more information—a 

daunting process for individuals with limited English proficiency or other 

barriers. Officials from a legal aid services organization stated that 

correcting immigration records with DHS and appealing an erroneous 

denial with a user agency can take anywhere from three months to over 

two years to complete and can result in hardship for families while 

benefits are pending. Advocacy groups and user agencies reported that 

some benefit applicants addressed these and other challenges by 

contacting their local elected representatives or seeking the assistance of 

an attorney, who may charge fees.

Further, in a 2015 internal departmental memorandum, DHS’s Office of 

Civil Rights and Civil Liberties (CRCL) noted that individuals may receive 

incomplete or inaccurate information from user agencies and 

recommended that USCIS require user agencies to provide standardized 

written notification letters (created by USCIS) that described SAVE, 

explained user agency responsibilities, explained why the particular 

agency was using SAVE, identified the information provided to SAVE and 

the SAVE response, and explained the individual’s right to resolve data 

discrepancies before the agency took any adverse action.

SAVE Program officials told us that their program does not maintain or 

manage the immigration records used in a SAVE check and therefore 
Page 37 GAO-17-204 Immigration Status Verification for Benefits

does not have the ability to directly update or change records held by 

other branches of USCIS or by CBP or ICE. Further, officials told us that 

the SAVE program’s purpose is to work with user agencies and not with 

the benefit applicants themselves, thus limiting their ability to provide 

applicants with mechanisms for access, correction, and redress beyond 

the information shared in the fact sheet. However, during the sixth annual 

SAVE user forum, SAVE officials recognized that USCIS can help ensure 

the needs of benefit applicants are addressed in SAVE program policies 

and procedures and reported that a working group had been exploring 

ways to assist user agencies to better meet the needs of benefit 

applicants. Such plans are a positive step toward aligning SAVE program 

policy with the Individual Participation principle of the FIPPs, which 

provides that DHS should provide mechanisms for appropriate access, 

correction, and redress. However, USCIS has not yet developed an 

effective mechanism for accomplishing this principle, thus limiting the 

ability of benefit applicants to ensure their personally identifiable 

information is correct. Developing and implementing a more effective 

method for ensuring that individuals are aware of how they can access 

and correct their information could help benefit applicants ensure the 

most current information is used in a SAVE check and to appeal any 

potentially erroneous denials of benefits in a timely manner.

USCIS has limited visibility into the overall effectiveness of the record 

correction process, including data on the number of applicants who are 

denied a benefit due to potentially erroneous information returned by 

SAVE, but is taking actions to better understand the challenges

applicants face. When an applicant needs to correct an immigration 

record, he or she typically begins the process by making an appointment 

at a USCIS field office; however, USCIS does not know how often this 

happens because USCIS does not have the capability to report or track 

this information given limitations in system software. In addition to making 

record corrections with USCIS field offices, applicants can also make 

record corrections with CBP and ICE. However, CBP and ICE officials 

reported that they also do not track SAVE-related record corrections 

because SAVE is one of many programs they provide records to.

To better understand how user agencies are implementing the program 

and applicants’ experiences correcting immigration records in response to 

SAVE issued information, in 2015, USCIS contracted for an independent 

evaluation of the SAVE program. According to the evaluation project 

summary, USCIS expects to have results of this study in July 2018. 

Additionally, in September 2016, DHS announced an Immigration Data 

USCIS is Unable to 

Determine How Many 

Requests for Immigration

Record Corrections are 

SAVE-Related, but is 

Taking Steps to Better 

Understand Applicants’

Experiences Correcting 

Records
Page 38 GAO-17-204 Immigration Status Verification for Benefits

Integration Initiative with long term goals to ensure that immigration 

records are connected across all DHS systems, so that DHS can analyze 

immigration benefits data at the individual level or demographic level, as 

well as by DHS component or Field Office. Although these initiatives are 

ongoing, they are positive steps toward obtaining data that could provide 

USCIS greater awareness about the use and effectiveness of its record 

correction process.

Consistent with the Accountability and Auditing principle of the FIPPs, 

SAVE M&C audits user agencies for two behaviors related to protecting 

privacy and preventing misuse of the program; however, SAVE M&C 

does not have a documented, risk-based strategy related to these 

efforts.43 Specifically, SAVE M&C monitors agencies for (1) the failure to 

deactivate inactive user accounts (inactive user accounts) and (2) the 

failure of user agencies to institute additional verifications when 

necessary (IAV failure). Inactive user accounts can pose a threat to 

privacy if, for example, former employees of the agency continued 

accessing SAVE after leaving their positions, or employees of the agency

without a legitimate need to use SAVE accessed the system using 

another employee’s account. According to the SAVE MOA and program 

policies, user agencies are to deactivate inactive user accounts and to 

institute additional verification when prompted. To assist agencies in 

meeting these responsibilities, SAVE M&C engages in compliance 

assistance activities, which include compliance assistance phone calls, 

desk reviews, and site visits, as detailed in table 6 below. SAVE M&C 

 43The Accountability and Auditing principle of the FIPPs states that DHS should audit the 

actual use of PII to demonstrate compliance with the fair information practice principles 

and all applicable privacy protection requirements, among other actions.

USCIS Monitors 

Agencies’ Use of 

SAVE in Accordance 

with the SAVE MOA, 

but Could Improve 

Overall Effectiveness 

of Monitoring Efforts

The SAVE Monitoring and 

Compliance Branch Audits 

User Agencies, but Does 

Not Have a Risk-based 

Strategy for its Monitoring 

Efforts
Page 39 GAO-17-204 Immigration Status Verification for Benefits

also provides the SAVE program with recommendations for ways that the 

SAVE program can provide additional assistance and/or training to the 

agency.

Table 6: Systematic Alien Verification for Entitlements (SAVE) Monitoring and Compliance (M&C) Activities

Activity type Activity description Behavior monitored

Activities conducted 

from Fiscal Year

(FY) 13 through FY 15

Documentation 

Provided by SAVE

to User Agency

Compliance 

Call

A phone call to inform user 

agencies that they have inactive 

user accounts that should be 

deactivated or logged into

Inactive user accounts 1,601 calls to agencies Not applicable

Desk Review A virtual process in which 

documentation on user agency 

policies and procedures regarding 

their use of SAVE is collected and 

analyzed by SAVE M&C officials

Primarily the failure to 

institute additional 

verification, but can 

include inactive user 

accounts

23 desk reviews Recommendation report

Site Visit An on-site or virtual session in 

which user agencies learn about 

the SAVE program and compliance 

requirements and ask questions of 

SAVE M&C officials

Primarily the failure to 

institute additional 

verification, but can 

include inactive user 

accounts

17 site visits Recommendation report

Source: GAO analysis of U. S. Citizenship and Immigration Services information. | GAO-17-204

Note: According to USCIS, virtual site visits—conducted online via Adobe® ConnectTM—are 

substantively the same as an in-person site visit. Officials stated that conducting visits virtually w ill 

allow them to reach a greater number of user agencies, given limited travel resources.

Although SAVE M&C conducts these compliance and monitoring 

activities to help ensure agencies are using SAVE in accordance with the 

MOA, SAVE M&C does not have a documented, risk-based strategy that 

addresses:

• a risk-based approach to selecting behaviors or MOA provisions to 

monitor,

• compliance standards for selected behaviors, and

• a risk-based process for how to prioritize and select agencies for 

compliance actions.

Selecting Behaviors or MOA Provisions to Monitor. The two 

behaviors currently monitored by SAVE M&C are related to protecting 

privacy and preventing misuse and address some of the FIPPs—which 
Page 40 GAO-17-204 Immigration Status Verification for Benefits

are the basis for DHS’s privacy policy.44 M&C officials stated that these 

two behaviors were selected for monitoring because they were easily 

quantified using the current data analysis system; however, M&C has not 

used a risk-based approach for selecting these behaviors.

The SAVE MOA outlines the aspects of SAVE use that user agencies 

agree to allow SAVE M&C to monitor. This includes the two currently 

monitored behaviors, but the MOA also establishes that SAVE M&C can 

monitor any aspect of the MOA, including training records, or the extent to 

which agencies provide benefit applicants with adequate written 

notification if they are denied a benefit due to a SAVE response.45

However, SAVE M&C officials have not evaluated the various MOA 

provisions to determine which are most critical for achieving the SAVE 

program’s objectives and how M&C should prioritize its monitoring 

activities.

SAVE M&C officials told us in September 2016 that they intend to monitor 

additional behaviors in the future, but have not documented plans for 

future monitoring efforts and thus it is unclear the extent to which these 

plans will be based on an analysis of risk. Standards for Internal Control 

in the Federal Government state that management should define 

objectives clearly to enable the identification of risks.46 Such an analysis 

would include defining program objectives, including selecting behaviors 

to monitor and why they were selected as well as related risk tolerances; 

identifying and analyzing risks to achieving those objectives; and 

developing appropriate responses. In its 2015 memorandum to the 

 44The FIPPs are Data Quality and Integrity (DHS should, to the extent practicable, ensure 

that PII is accurate, relevant, timely, and complete, within the context of each use of the 

PII), Use Limitation (DHS should use PII solely for the purpose(s) specified in the notice. 

Sharing PII outside the department should be for a purpose compatible with the purpose 

for which the PII was collected), and Security (DHS should protect PII (in all forms) 

through appropriate security safeguards against risks such as loss, unauthorized access 

or use, destruction, modification, or unintended or inappropriate disclosure).

45Monitoring training could also address the FIPPs, including the principles of 

accountability and auditing. These principles state that DHS should be accountable for 

complying with these principles, providing training to all employees and contractors who 

use personally identifiable information (PII), and auditing the actual use of PII to 

demonstrate compliance with these principles and all applicable privacy protection 

requirements.Additionally, monitoring whether agencies provide adequate written notice 

to all benefit applicants who are denied benefits could help address the FIPPs principle of 

transparency, which states that DHS should be transparent and provide notice to the 

individual regarding its collection, use, dissemination, and maintenance of PII.

46GAO-14-704G. Principles: 6.01.
Page 41 GAO-17-204 Immigration Status Verification for Benefits

USCIS Director, DHS CRCL noted civil rights concerns and made 

recommendations to ensure consistent and uniform procedures, accurate 

SAVE responses and agency determinations, and consistent and fair 

treatment of benefit applicants. While all of the MOA provisions are 

important, using a risk-based approach to prioritize which provisions 

should be monitored now and which can be monitored with additional 

resources or at a future date could help officials better ensure a more 

effective monitoring program.

Setting Compliance Standards. M&C has not established or 

communicated consistent compliance standards for the two behaviors it 

currently monitors. For example, SAVE documentation, both internal and 

external, varies in its definition of what constitutes an inactive user 

account, ranging from 45 days to 360 days of nonuse, as shown in 

table 7.

Table 7: Systematic Alien Verification for Entitlements (SAVE) Compliance Standards for Inactive User Accounts, According 

to Various SAVE Guidance and Policy Documents

Source Standard that indicates account is inactive

Memorandum of Agreement No standard specified

Standard Operating Procedures No standard specified

Technical Manual 60 days

Compliance Call Effectiveness Report Fiscal Year (FY) 13 and 

Annual Report Summary for FY14

360 days

Recommendation Reports in FY14 45 days

Annual Report Summary for FY15 180 days and 360 days

Website Announcement 270 days

Interviews with GAO November 2016 180 days 

Source: GAO analysis of U.S. Citizenship and Immigration Services Information. | GAO-17-204

SAVE M&C officials explained in November 2016 that the threshold was 

180 days and that previously published standards have evolved along 

with the maturity of the audit program. Nevertheless, SAVE M&C has not 

provided consistent information to user agencies on how long an account 

can be inactive before it is considered a risk to privacy and therefore 

eligible for review by audit. Regarding IAV failure, SAVE M&C officials 

told us that they seek to monitor agencies with what they referred to as 

“egregious non-compliance.” The threshold for “egregious” is not defined 

in the technical manual for monitoring, although a “high” level of failure is 

discussed as both over 60 and 90 percent in different parts of the manual. 

SAVE M&C officials told us in May 2016 that they considered egregious 
Page 42 GAO-17-204 Immigration Status Verification for Benefits

noncompliance as failure to institute additional verification 80 percent of 

the time, but in September 2016 officials stated that they sought to 

monitor agencies between 60 and 89 percent failure rates with desk 

reviews, and agencies with 90 percent or greater failure rates via site 

visits.47 However, these thresholds are not documented in the standard 

operating procedures for desk reviews or site visits, nor are they 

documented in guidance provided to SAVE user agencies.

SAVE M&C officials said that the monitoring program, which was started 

in 2008, is still being developed and some aspects of the program, such 

as the compliance standards that guide whether or not M&C will conduct 

compliance activities, have not yet been documented or finalized, and 

officials did not provide information on when they planned to make final 

determinations on compliance standards. Standards for Internal Control in 

the Federal Government state that objectives should be clearly defined in 

specific terms so they are understood at all levels of the entity.48

Additionally, Government Auditing Standards requires evaluation against 

criteria.49 Without clear criteria for what triggers compliance actions, 

USCIS is not well-positioned to target its monitoring efforts on the 

agencies most in need of compliance assistance or ensure most effective 

use of its resources. Further, user agencies may not know how often they 

need to log in to avoid being labeled inactive or how soon to deactivate 

accounts that are no longer needed.

Selecting Agencies for Monitoring. SAVE M&C also does not have a 

risk-based process for selecting or prioritizing agencies for oversight and 

compliance assistance and has not followed its own criteria for agency 

selection. For failure to institute additional verification, from fiscal year 

2013 through fiscal year 2015, the majority of agencies (11 of 17) SAVE 

M&C selected for site visits had IAV failure rates below the “egregious”

noncompliance level of 90 percent failure to institute additional 

verification. For example, one agency selected for a site visit in fiscal year 

2015 had failed to institute additional verification 43 percent of the time (a 

 47For analysis of M&C efforts, we used the most recent standards discussed—60-89 

percent failure qualifying for a desk review and 90 percent and above qualifying for a site 

visit. Therefore in our analysis, any agency with a 60 percent or higher failure to IAV 

qualifies for monitoring.

48GAO-14-704G. 

49GAO, Government Auditing Standards, GAO-12-331G (Washington D.C.:December 

2011). Principle 2.10.
Page 43 GAO-17-204 Immigration Status Verification for Benefits

total of 208 times), while 123 unmonitored agencies that year had failure 

rates above 90 percent. Table 8 below illustrates the number of agencies 

that qualified for site visit monitoring activities compared to those that 

were selected for monitoring.

Table 8: Site Visit Monitoring Statistics for Agencies that Fail to Institute Additional Verification (IAV), Fiscal Year 2013

through Fiscal Year 2015

Agencies Monitored by Site Visit

Agencies Not

Monitored by Site Visit

Fiscal year of monitoring

Total number of agencies 

receiving an Monitoring & 

Compliance (M&C) site visit 

Number of

agencies with an IAV

failure rate under 90 percent

Number of

agencies with IAV failure

rates of 90 percent or above

2013 4 3 87

2014 7 4 102

2015 6 4 123

Total 17 11 312

Source: GAO analysis of Systematic Alien Verification for Entitlements M&C data. | GAO-17-204.

Note: The agencies monitored by site visit columns include only agencies that M&C completed the 

site visit for in the given fiscal year.

Furthermore, 8 of the 17 agencies selected for monitoring from fiscal 

years 2013 through 2015 had failed to complete IAV less than 1,000 

times, while 235 agencies not selected failed to complete IAV at least 

1,000 times.50

SAVE M&C officials stated that given their limited resources to ensure 

agencies participate in compliance actions, they selected the most readily 

available and responsive agencies for review, such as visiting agencies in 

person that were in the same geographic location. However, Standards 

for Internal Control in the Federal Government state that management 

should identify, analyze, and respond to risks related to achieving 

objectives.51 Given SAVE M&C’s limited resources, a risk-based process 

for selecting user agencies to monitor compliance with the SAVE system 

 50For the agencies that were monitored by site visit in fiscal year 2013, the total number of 

IAV failures for all agencies was 11,718. That same fiscal year, there were 8 unmonitored 

agencies that each had more than 11,718 IAV failures per agency—in other words, 8 

agencies each had more failed IAVs than all the monitored agencies combined. Similarly 

in fiscal years 2014 and 2015, there were 13 and 4 individual unmonitored agencies, 

respectively, each with more IAV failures than all of the monitored agencies combined. 

51GAO-14-704G. Principle 7.01. 
Page 44 GAO-17-204 Immigration Status Verification for Benefits

would help SAVE M&C better prioritize its resources to address the most 

non-compliant agencies for monitoring and assistance.

USCIS and SAVE M&C do not have effective processes for conducting 

compliance activities, including contacting agencies, holding agencies 

accountable for participating in compliance activities, and tailoring 

monitoring efforts and recommendations to agencies’ specific needs.

According to USCIS officials, the SAVE program maintains a list of user 

agency points of contact (POCs) and SAVE M&C relies on this 

information to contact user agencies for compliance activities, among 

other things. However, the list of POCs is not kept up to date and the 

SAVE program does not have a systematic process for ensuring the 

POCs are current and accurate, which presents challenges for SAVE 

M&C when contacting agencies for site visits or desk reviews.

For example, in fiscal years 2014 and 2015, our analysis showed that 

SAVE M&C was unable to schedule monitoring activities with 

approximately 31 percent of the agencies it selected (23 out of 74 

agencies) for compliance assistance because agencies that were 

contacted for compliance did not respond or answer SAVE M&C calls and 

e-mails, as shown in table 9. During the same timeframe, 15 additional 

agencies were referred to the SAVE program to update information or 

establish a new point of contact and these agencies did not receive 

compliance assistance in any subsequent fiscal years as of the end of 

fiscal year 2016.

Table 9: Systematic Alien Verification for Entitlements (SAVE) User Agencies 

Contacted for Desk Reviews or Site Visits in Fiscal Year (FY) 14 and FY15

Fiscal 

Year

Total

agencies 

contacted

Agencies with

a non-response

or non-answer

Percent of

agencies not receiving

compliance assistance 

2014 42 15 36 percent

2015 32 8 25 percent

Total 74 23 31 percent

Source: GAO analysis of U.S. Citizenship and Immigration Services Information. | GAO-17-204

Note: The Annual Reports produced by SAVE Monitoring & Compliance use both non-response and 

non-answer, but do not differentiate between the terms.

Under the current process for updating POCs, it is the user agency’s 

responsibility to make sure accurate and current contact information is 

USCIS Does Not Have 

Effective Processes for 

Conducting Compliance 

Activities

USCIS Faces Challenges 

Contacting User Agencies
Page 45 GAO-17-204 Immigration Status Verification for Benefits

provided to the SAVE program; however, we found several reasons 

agencies may not be doing so. For example, SAVE program officials said 

that some agencies have high turnover rates among SAVE users, which 

can make it difficult to maintain updated POC information, and that 

ultimately (per the MOA) it is the agency’s responsibility to contact USCIS 

with POC updates. Five of the 12 user agencies we spoke with were not 

aware that their SAVE MOA includes a provision to provide updated 

contact information to the SAVE program and SAVE M&C.52 Additionally, 

some user agencies we spoke with said that they did not know how or 

whom to contact in the SAVE program, and some user agency officials 

said they did not know who their agency’s primary point of contact was or 

should be.

Standards for Internal Control in the Federal Government state that 

management is responsible for communicating quality information 

externally through reporting lines so that external parties can help the 

entity achieve its objectives and address related risks.53 By developing 

and communicating a process to ensure that user agencies consistently 

provide updated and relevant contact information, USCIS would better 

ensure that SAVE M&C efforts to contact agencies for compliance 

activities are achievable.

USCIS and SAVE M&C do not require agencies selected for monitoring 

and compliance activities participate in them, undermining the 

effectiveness of SAVE oversight activities. For example, from fiscal year 

2014 through 2016, 9 out of 72 agencies selected by SAVE M&C for desk 

reviews declined to participate. One agency that began a desk review in 

fiscal year 2015 declined to continue the process and one agency 

selected for review in fiscal year 2014 and in fiscal year 2016 declined in 

both times. The 9 agencies that declined to participate in monitoring 

activities had failed to initiate additional verification an average of 85 

percent of the time over this time period (11,535 times out of 13,592 

cases requiring additional verification). In its annual monitoring and 

compliance reports and call scripts used to schedule desk reviews and 

site visits, SAVE M&C states that agency participation is voluntary. For 

example, the desk review call script states “the purpose of this call is to 

 52We spoke with 13 user agencies, but Department of Education officials said they have a 

Computer Matching Agreement rather than an MOA with the SAVE Program, although the 

information and responsibilities are the same in each document.

53GAO-14-704G. Principles: 15.03. 

SAVE M&C Does Not Require 

Agencies to Participate in 

Monitoring and Compliance 

Reviews
Page 46 GAO-17-204 Immigration Status Verification for Benefits

let you know that your agency has been selected for a voluntary desk 

review. . . Is this something you would like to pursue with us?” M&C 

officials said that they try to work with agencies’ schedules and to not 

overburden them, and accordingly, will allow agencies up to two fiscal 

years to reschedule their compliance review. However, as of the end of 

fiscal year 2016, none of the agencies that declined a desk review since 

fiscal year 2014 had received a desk review in subsequent years.

M&C officials said in May 2016 that they do not have the law enforcement 

authority permitting them to compel participation in monitoring activities or 

compliance actions—such as mandatory production of documents, 

testimony or witnesses—and that is why they allow agencies to decline or 

delay participating in compliance activities. However, the SAVE MOA 

states that agencies agree to allow SAVE M&C to conduct desk audits 

and/or site visits, and that USCIS could terminate their SAVE MOA if they 

fail to comply with established SAVE procedures. In response to our 

questions, M&C officials indicated in September 2016 that they were 

considering updating call scripts in 2017 to better reflect the MOA and 

clarify that agencies are, in fact, required by their SAVE MOA to consent 

to monitoring activities. Until SAVE M&C takes these or other actions to 

ensure user agencies participate in monitoring reviews when selected for 

them, SAVE M&C is missing opportunities to improve agency compliance 

with SAVE policy and ensure participants use the SAVE program 

consistent with program guidance.

SAVE M&C does not tailor its monitoring efforts and recommendations to 

address issues facing specific user agencies. Our analysis of SAVE M&C 

compliance data showed that, in general, SAVE M&C’s monitoring efforts 

have not resulted in improved agency compliance rates for the two 

monitored behaviors—deleting inactive user accounts and instituting 

additional verification when prompted. With respect to inactive user 

accounts, from fiscal years 2013 through 2015, M&C’s compliance calls 

resulted in agencies updating 17 percent of the identified inactive user 

accounts, or roughly 25,000 inactive accounts; however, approximately 

124,000 of these user accounts remained inactive after M&C’s calls 

during that time period.

USCIS Has Limited 

Processes to Ensure User 

Agencies Take Corrective 

Actions

Monitoring Efforts and 

Recommendations are Not 

Tailored to Specific User 

Agencies
Page 47 GAO-17-204 Immigration Status Verification for Benefits

SAVE M&C’s efforts to improve agencies’ rates of compliance with IAV 

have also had limited effectiveness. Our analysis of SAVE M&C data 

showed that 4 of the 40 agencies that received a desk review or a site 

visit in fiscal years 2013-2015 were meeting M&C’s threshold for 

sufficiently completing additional verification at least 60 percent of the 

time by the end of fiscal year 2016 and did not qualify for future desk 

reviews or site visits. Of the other 36 agencies remaining above the 

threshold qualifying for future monitoring, 21 showed failure rate 

percentages increased after monitoring by the end of fiscal year 2016. In 

addition to increased percentages of failures, the total number of IAV 

failures increased by the end of fiscal year 2016. For example, in fiscal 

year 2015, M&C monitored 17 agencies, using fiscal year 2014 as the 

base year.54 Of the 17 agencies, 2 had failure percentages under M&C’s 

60 percent threshold, 6 showed lower IAV failure percentages, and 9 

showed higher IAV failure percentages. The total number of IAV failures 

for these 17 agencies increased from 114,503 in fiscal year 2014 to 

132,020 in fiscal year 2016. Additional information on IAV failure rates for 

fiscal years 2013-2016 can be found in Appendix IV.

SAVE M&C does not consistently identify the root cause of 

noncompliance and develop or tailor recommendations specific to each 

agency and cause as part of its compliance activities. For compliance 

calls, SAVE M&C staff read off a prepared call script, which does not 

include prompts or sections to gather information about why a specific 

agency may not be complying with inactive user policies or additional 

verification requirements. During a virtual site visit we observed in fiscal 

year 2016, SAVE M&C explained the importance of instituting additional 

verification, but not specifically in reference to the user agency, and did 

not ask why the user agency was not instituting additional verification or 

note the fact that the agency’s IAV failure rate was the primary reason for 

the site visit.55

In addition, most recommendations that M&C makes to user agencies 

after a desk review or site visit use general language and are not targeted 

to each user agency’s specific challenges. For example, SAVE M&C’s 

recommendations to monitored agencies frequently have been the same 

 54The base year is the fiscal year before M&C monitoring efforts take place, and therefore

varies for each agency. For example, M&C compliance activities occurring in fiscal year 

2014 are based on data from fiscal year 2013.

55Virtual site visits—conducted online via Adobe® ConnectTM—are substantively the same 

as an in-person site visit, according to USCIS. 
Page 48 GAO-17-204 Immigration Status Verification for Benefits

or nearly identical each year from fiscal years 2013 to 2015. As a result, 

agencies may be provided with broad and general recommendations—

such as a recommendation to ensure all users perform any additional 

verification procedures required under the MOA—that reiterate an 

agency’s responsibility. For agencies that are unaware of the MOA and its 

provisions, these types of recommendations may be beneficial. But for 

other agencies, more tailored and specific recommendations—such as, 

for example, a recommendation for supervisor level SAVE users to run 

monthly reports to identify specific users that are not completing 

additional verifications, and to provide specific feedback and training to 

those users—could help agencies meet their responsibilities and help 

address the root causes of noncompliance. Table 10 below demonstrates 

examples of the recommendations given to agencies following desk 

reviews, which tend to reiterate the agency’s duties rather than identify 

and address why the agency may not be meeting those duties.

Table 10: Examples of Recommendations Frequently Made by Systematic Alien Verification for Entitlements (SAVE) 

Monitoring and Compliance after Desk Reviews, Fiscal Years 2013 through 2015

Frequency Recommendation language

23 of 23 desk reviews All users should be familiar with the memorandum of agreement (MOA) requirements and the SAVE 

Program Guide; this will ensure policies and procedures are applied consistently.

23 of 23 desk reviews “Super-users” and supervisors should use the Web Agency Audit Report to identify users who do 

not institute additional verifications and may need additional training on instituting additional 

verification (IAV).

22 of 23 desk reviews Users should refer to MOA Part IV Responsibilities (h) Ensure all users perform any additional 

verification procedures.

23 of 23 desk reviews Users should take advantage of SAVE training opportunities including Webinar Training offered by 

the SAVE program.

Source: GAO analysis of U. S. Citizenship and Immigration Services documentation. | GAO-17-204

SAVE M&C officials told us they conduct their monitoring activities in this 

manner because they view the reviews as training and outreach 

opportunities, as opposed to compliance enforcement or auditing. 

However, Standards for Internal Control in the Federal Government state 

that management should evaluate and document internal control issues 

and determine appropriate corrective actions for those deficiencies on a 

timely basis.56 Similarly, Government Auditing Standards state that a 

purpose of audit reports is to communicate the results of audits to those 

charged with governance, the appropriate officials of the audited entity, 

 56GAO-14-704G. Principle: 16.01. 16.09, and 17.01, 17.05, 17.06.
Page 49 GAO-17-204 Immigration Status Verification for Benefits

and the appropriate oversight officials to make the results less susceptible 

to misunderstanding.57 Further, the Accountability and Auditing Principle 

of the FIPPs (as discussed earlier in this report) also states that USCIS 

should be accountable for auditing compliance with all applicable privacy 

protection requirements. Without identifying root causes of 

noncompliance and developing recommendations targeted toward each 

agency’s issues, SAVE M&C is not well positioned to address user 

agency compliance in accordance with SAVE MOA provisions.

SAVE M&C monitoring and oversight efforts have generally not improved 

agency compliance with SAVE MOA provisions. This is in part because 

SAVE M&C does not engage in escalating compliance assistance actions 

for those agencies that remain noncompliant and because SAVE M&C 

does not ensure agencies take corrective actions after receiving 

recommendations. SAVE M&C has not instituted escalating compliance 

assistance actions—or penalties—against user agencies because, 

according to SAVE M&C officials, the user agencies’ right to immigration 

status information from SAVE supersedes USCIS’s authority to restrict 

agency access.58 Further, SAVE M&C does not have a process to follow 

up on recommendations to user agencies to ensure corrective actions 

have been taken following a monitoring visit. SAVE M&C officials told us 

they call user agencies two weeks after a recommendation report is 

issued to answer any questions about the report; however, the two user 

agencies we met with that had received a desk review or site visit from 

the SAVE M&C officials did not recall any follow-up contact or 

discussions. SAVE M&C officials confirmed that they did reach out to 

these agencies to ensure they received their recommendation reports, but 

stated that the agencies did not respond with any questions about the 

recommendations.

SAVE M&C officials stated that they are exploring options for collecting 

evidence to close recommendations or to follow-up beyond two weeks. 

 57GAO, Government Auditing Standards, GAO-12-331G (Washington D.C.: December 

2011). Principle: 7.05.

58DHS is statutorily required to respond to requests from Federal, State, or local agencies 

seeking to verify the immigration or citizenship status of individuals within their jurisdiction, 

for any purpose authorized by law. See 8 U.S.C. § 1373. There are numerous other 

actions that SAVE M&C could take without rescinding an agency’s access to SAVE for 

repeated misuse. For instance, issuing warning notices, providing performance reports, 

and issuing temporary access denials to individual users are examples of progressive 

compliance actions that SAVE M&C could take.

USCIS has Limited 

Mechanisms for Ensuring User 

Agencies Take Corrective 

Actions
Page 50 GAO-17-204 Immigration Status Verification for Benefits

M&C officials said that they have the ability to refer issues of continued 

noncompliance to SAVE program staff for further referral to the DHS 

CRCL or DOJ. However, as of September 2016, there had been no 

referrals made from the SAVE Program to CRCL or DOJ. In a 2015 

internal departmental memorandum, CRCL recommended that USCIS 

identify steps that user agencies that violate program rules must take to 

continue to use SAVE, such as increased monitoring and reporting or 

additional training. Further, an official from CRCL told us that CRCL has 

encouraged USCIS to establish a progressive means of oversight with 

policies and procedures for continued violation, including procedures to 

rescind access of non-compliant individual users. M&C officials also told 

us in September 2016 that they are planning to develop an escalating 

oversight model that involves agencies receiving a call first and 

progressing to a site visit for continued non-compliance. Officials said that 

escalating oversight is important because it will increase compliance; 

however, M&C did not have a plan or timelines for implementing this 

model.

Standards for Internal Control in the Federal Government state that audit 

resolution is only completed after actions have been taken that correct 

identified deficiencies or produces improvements.59 Further, ensuring that 

corrective actions are being addressed would help USCIS ensure more 

efficient and effective use of its limited monitoring resources. Standards 

for Internal Control in the Federal Government also state that 

management should conduct the audit resolution process and monitor the 

status of remediation efforts so that they are completed on a timely basis. 

Without developing and implementing a process for ensuring that user 

agencies implement corrective actions such as through a system of 

escalating compliance assistance actions and for recommendation followup, SAVE M&C is not well positioned to determine if its efforts are making 

a positive impact or if changes to compliance actions are needed.

Each year, USCIS’s SAVE system is used to verify the immigration or 

citizenship status of millions of individuals applying for housing, health 

care, and other benefits. Agencies that use SAVE to verify individuals’

status rely on the program to provide information that is accurate and 

timely. Applicants rely on USCIS to provide sufficient avenues through 

which they can correct or challenge incorrect information. Last, the SAVE 

 59GAO-14-704G. Principle: 17.06. 

Conclusions
Page 51 GAO-17-204 Immigration Status Verification for Benefits

MOA states that USCIS is expected to monitor agencies to prevent 

misuse of the system. USCIS has worked to improve the SAVE system 

and better meet the needs of the agencies that use SAVE, but could take 

a range of additional actions to strengthen its management and oversight 

of the program. In particular, clarifying SAVE guidance to more clearly 

and accurately reflect user agency responsibilities for completing each 

step of the SAVE process could help ensure agencies are using the most 

accurate immigration status information available when making benefit 

eligibility determinations. Additionally, developing and implementing a 

mechanism to oversee agencies’ completion of training on SAVE policy—

including the requirement to complete all required steps of a SAVE 

check—could also help ensure agencies are using accurate information. 

Last, while USCIS has met or exceeded its targets for providing timely 

SAVE responses to agencies, providing notification that a check is

complete could help ensure user agencies are aware the case is ready 

for adjudication and help prevent benefit delays to applicants, including 

time-sensitive benefits.

When agencies choose to deny benefits based on information from a 

SAVE response, they agree to provide adequate written notification of 

that denial and an opportunity for applicants to correct their immigration 

information, if necessary. Developing and implementing a more effective 

method for ensuring that individuals are aware of how they can access 

and correct their information could help benefit applicants ensure the 

most current information is used in a SAVE check and to appeal any 

potentially erroneous denials of benefits through the user agency in a 

timely manner.

USCIS’s SAVE M&C has been monitoring the SAVE program since 2008, 

but has not taken a risk-based approach to selecting behaviors or MOA 

provisions to monitor; setting standards for compliance; or prioritizing 

agencies for monitoring. Without a risk-based approach to monitoring and 

compliance, SAVE M&C is not well-positioned to focus its limited 

monitoring resources towards the agencies most in need of oversight. 

Further, without developing a process to ensure user agencies are 

providing updated and relevant contact information, per the MOA, SAVE 

M&C is not well-positioned to contact agencies for compliance activities, 

and ensuring that user agencies participate in monitoring reviews when 

selected could help SAVE M&C improve selected agencies’ compliance 

with SAVE policy. Although SAVE M&C has reported taking a trainingand-outreach approach to oversight, by not identifying root causes of 

agencies’ noncompliance and developing recommendations targeted 

toward each agency, SAVE M&C efforts are less likely to successfully 
Page 52 GAO-17-204 Immigration Status Verification for Benefits

strengthen user agency compliance with SAVE MOA provisions. Last, 

without a process for ensuring that agencies implement recommendations 

resulting from compliance activities, SAVE M&C cannot determine if its 

efforts are making a positive impact or if changes to compliance actions 

are needed to prevent misuse of the system.

To improve management and oversight of the SAVE program, we 

recommend that the director of USCIS take the following 9 actions:

• Ensure SAVE guidance, including written materials and instructional 

videos, clearly and accurately reflects user agencies’ responsibilities 

for completing each step of a SAVE check, as outlined in each 

agency’s memorandum of agreement.

• Develop and implement a mechanism to oversee agencies’

completion of training on additional verification in accordance with 

SAVE MOA provisions and program policies.

• Provide notifications to user agencies when a case is ready for the 

user agency to review.

• Develop and implement a more effective method for ensuring that 

individuals are aware of how they can access and correct their 

immigration records, such as by updating and improving the Fact 

Sheet for Benefit Applicants.

• Develop and implement a documented, risk-based approach to 

monitoring and compliance, including (1) a risk-based approach to 

selecting behaviors to monitor; (2) standards for what triggers 

compliance actions for the selected behaviors; and (3) a risk-based 

process for how USCIS will prioritize and select agencies for 

compliance actions.

• Develop and communicate a process for user agencies to update 

contact information.

• Ensure that user agencies participate in compliance reviews when 

selected, in accordance with SAVE MOA provisions and USCIS 

policy.

• Identify the root causes of agencies’ noncompliance with SAVE MOA 

provisions and program policies and tailor agency recommendations 

to those identified causes.

• Develop and implement a process for ensuring user agencies 

implement corrective actions such as through a system of escalating 

compliance assistance actions and follow-up.

Recommendations for 

Executive Action
Page 53 GAO-17-204 Immigration Status Verification for Benefits

We provided a draft of this report to DHS, IRS, and Education for review 

and comment. IRS did not have comments and Education provided 

technical comments, which we incorporated as appropriate. DHS 

provided written comments, which are noted below and reproduced in 

Appendix VI, and technical comments, which we incorporated as 

appropriate. DHS concurred with the nine recommendations in the report 

and described actions to address them, as noted below. 

With regard to our first recommendation to ensure SAVE guidance clearly 

and accurately reflects user agencies’ responsibilities for completing each 

step of a SAVE check, DHS concurred. DHS stated that the Verification 

Division of USCIS’s Immigration Records and Identity Services 

Directorate has taken action to revise and republish the SAVE Program 

Guide to ensure written materials clearly and accurately reflect user 

agencies’ responsibilities with respect to additional verification steps. 

USCIS plans to complete all necessary revisions to written materials by 

September 30, 2017. DHS also stated that other actions will be taken, 

such as revising and updating instructional videos. These efforts are 

expected to be completed by March 31, 2018.

With regard to our second recommendation to develop and implement a 

mechanism to oversee agencies’ completion of training on additional 

verification, DHS concurred. DHS stated that the Verification Division 

intends to have a new plan for providing additional training for SAVE 

users in place by September 30, 2017 and associated required system 

enhancements by March 31, 2018. 

With regard to our third recommendation to provide notifications to user 

agencies when a case is ready for the user agency to review, DHS 

concurred. DHS stated that the Verification Division will make system 

enhancements and updates to policy and training materials. Officials 

expect to have a plan in place by September 2017 with full 

implementation by March 2018. 

With regard to our fourth recommendation to develop and implement a 

more effective method for ensuring that individuals are aware of how they 

can access and correct their immigration records, DHS concurred. DHS 

reported that the Verification Division will update the relevant materials 

regarding how individuals may access and correct their records by June 

30, 2017. 

With regard to our fifth recommendation to develop and implement a 

documented, risk-based approach to monitoring and compliance, DHS 

Agency Comments 

and Our Evaluation
Page 54 GAO-17-204 Immigration Status Verification for Benefits

concurred. DHS stated that the Verification Division will identify, 

document, and implement ways to incorporate a risk-based approach to 

its monitoring and compliance for all risk-based measures. DHS expects 

to complete these actions by June 30, 2018.

With regard to our sixth recommendation to develop and communicate a 

process for user agencies to update contact information, DHS concurred. 

DHS stated that the Verification Division will make the appropriate system 

enhancements by June 30, 2018. 

With regard to our seventh recommendation to ensure that user agencies 

participate in compliance reviews when selected, DHS concurred and 

stated that the Verification Division will review current procedures and 

implement appropriate changes. DHS noted, however, that a balanced 

approach is necessary whenever considering appropriate compliance 

enforcement measures for an MOA, including balancing agencies’ 

authority to receive current immigration status information against DHS’s 

responsibilities for administering the SAVE program in such a way as to 

protect privacy and ensure information is used in an appropriate manner. 

DHS expects to complete actions related to this recommendation by 

September 30, 2017.

With regard to our eighth recommendation to identify root causes of why 

agencies are not compliant with SAVE MOA provisions and program 

policies and to tailor agency recommendations to those identified causes, 

DHS concurred. DHS stated that the Verification Division will evaluate the 

root causes for agency non-compliance and will also review existing 

program policies and procedures to identify areas in need of 

improvement. DHS expects to complete these actions by June 30, 2018.

With regard to our ninth recommendation to develop and implement a 

process for ensuring user agencies implement corrective actions, DHS 

concurred and stated that the Verification Division will identify ways to 

incorporate escalating compliance assistance models into its procedures. 

DHS expects to complete these actions by March 30, 2018. DHS’s 

planned actions, if implemented effectively, should address the intent of 

our recommendations. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of the Department of Homeland Security, and 

other interested parties. In addition, the report is available at no charge on 

the GAO website at http://www.gao.gov.
Page 55 GAO-17-204 Immigration Status Verification for Benefits

If you or your staff have any questions about this report, please contact 

me at (202) 512-8777 or gamblerr@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

Appendix V.

Rebecca Gambler

Director, Homeland Security and Justice
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-17-204 Immigration Status Verification for Benefits

The report of the House Appropriations Committee accompanying the 

DHS Appropriations Act, 2016, included a provision for us to examine 

aspects of the Systematic Alien Verification for Entitlements (SAVE) 

program related to accuracy, privacy, and monitoring.1 This report 

examines the following questions:

• To what extent has U.S. Citizenship and Immigration Services 

(USCIS) determined the accuracy and timeliness of the information it 

reports in a SAVE response?

• To what extent has USCIS instituted safeguards to protect privacy 

and prevent misuse of the SAVE system, including processes that 

provide the ability to address erroneous immigration status responses 

returned by SAVE?

• To what extent is USCIS monitoring user agency compliance with 

SAVE program policies and requirements, including safeguards to 

protect privacy and prevent misuse?

To address our first objective, we analyzed USCIS data and internal 

policies related to the accuracy and timeliness of SAVE responses. We 

compared these policies and actions to the practices and principles set 

forth in Standards for Internal Control in the Federal Government.2 First, 

we reviewed fiscal years 2012 through 2016 internal performance data on 

the accuracy and timeliness of SAVE initial verifications in order to 

determine the extent to which USCIS has met its internal accuracy and 

timeliness targets.3 We interviewed USCIS officials regarding the 

methodology for determining initial verification accuracy and timeliness 

and compared that to USCIS internal documentation on how it calculates 

performance. We determined that USCIS’s performance data on initial 

verification accuracy and timeliness were sufficiently reliable for our 

reporting purposes. For additional verification errors identified by USCIS, 

we reviewed all related corrective action reports to identify the actions 

 1See H.R. Rep. No. 114-215, at 95 (July 21, 2015), accompanying Pub. L. No. 114-113, 

div. F, 129 Stat. 2242, 2493-2526 (2015).

2GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). These controls update the 1999 version, which was 

applicable in fiscal year 2012 through 2015. The 2014 internal controls became effective 

in fiscal year 2016. We applied these controls to the whole time period because we 

assessed current fiscal year 2016 policies.

3We selected this period to follow a 2012 report from the DHS Office of the Inspector 

General that included recommendations related to the accuracy and timeliness of SAVE.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 57 GAO-17-204 Immigration Status Verification for Benefits

USCIS took in response and whether there were any trends in the types 

of records that resulted in errors (a total of 53 reports).

To evaluate USICS’s internal policies and procedures for ensuring 

accurate SAVE responses, we reviewed the SAVE Program Guide, SAVE 

User Guide, the standard terms of SAVE user agency memorandums of 

agreement (MOA) which spell out USCIS and user agency responsibilities 

for the accuracy and timeliness of SAVE responses, among other 

responsibilities; attended a live demonstration of the SAVE system by 

USCIS staff; and reviewed other documentation on SAVE source-record 

systems, including privacy impact statements and system of record 

notices for the various DHS systems that are queried in a SAVE check.4

We compared these policies and guidance to principles and standards 

outlined in Standards for Internal Control in the Federal Government.5 We 

reviewed SAVE training and outreach materials and compared this 

training to provisions in the SAVE memorandum of agreement. To 

determine the extent to which USICS is carrying out its policies for 

ensuring accurate and timely SAVE responses, we analyzed USICS data 

on the number of agencies that do not complete additional verification 

when prompted by the SAVE system. We analyzed data from fiscal years 

2012 through 2016 that included the total number of SAVE queries, 

number of queries where the response was to institute additional 

verification, and total number of agencies that ran SAVE checks in those 

years. To evaluate user agency use of the SAVE customer support 

hotline, we obtained and analyzed data from fiscal years 2014 and 2015 

on user agency calls to the SAVE user agency hotline and reviewed 

USCIS guidance on the hotline. We interviewed USCIS officials regarding 

how these data are generated and what procedures are in place to 

ensure their reliability. Based on our review of the data and information 

obtained from USCIS, we determined that these data were sufficiently 

reliable for the purposes of our report.

In addition to our analysis of DHS documents and data, we interviewed 

officials from a nonprobability sample of 13 SAVE user agencies to 

discuss the extent to which SAVE responses were accurate and timely, 

among other topics. The user agencies were selected to represent many 

 4The MOA includes standard terms that are generally applicable to all user agencies, and 

outlines agency responsibilities and requirements for using SAVE for the approved 

purpose(s).

5GAO-14-704G. 
Appendix I: Objectives, Scope, and 

Methodology

Page 58 GAO-17-204 Immigration Status Verification for Benefits

different types of SAVE users. Specifically, we selected federal, state, 

and local agencies, including state departments of motor vehicles. We 

selected users covering a range of benefits, including health care, cash 

assistance, housing, educational financial assistance, voting eligibility, 

licensing (for home builders and gaming), federal contract employment, 

and REAL ID-compliant drivers licenses and identification cards.6 We 

selected agencies that had (and had not) been audited by the SAVE 

Monitoring and Compliance Branch and that were geographically 

dispersed and therefore likely to have interaction with different immigrant 

populations.7 The information we obtained from user agencies during our 

interviews is not generalizable, but the examples we obtained provide 

important insights into how the SAVE program operates. We also 

interviewed officials from the Department of Homeland Security’s (DHS)

U.S. Immigration and Customs Enforcement (ICE) and U.S. Customs and 

Border Protection (CBP) to discuss the accuracy and timeliness of the 

immigration records generated by these components and the extent to 

which USCIS SAVE has coordinated with these entities regarding 

accuracy and timeliness. We interviewed officials with the DHS Office of 

Performance Quality regarding efforts underway to enhance the accuracy 

of immigration records across the department and attended two Data 

Stewardship Tactical Working Group meetings in July 2016. Last, to gain 

insight into immigration record accuracy impacts and challenges within 

DHS, we interviewed officials with DHS’s Office for Civil Rights and Civil 

Liberties (CRCL) and the DHS Ombudsman Office.

To address our second objective, we analyzed USCIS internal policies on 

applicant redress processes. To determine the extent to which USCIS 

 6Throughout this report, we use the term “benefits” to generally refer to the range of 

federal, and state or local, public benefits, transactions, or programs for which an 

individual must have qualified immigration or citizenship status, such as cash, food, 

housing, and other forms of direct assistance, as well as licenses (including driver’s 

licenses or occupational licenses), and voter registration. For the statutory definitions of 

“Federal public benefit” and “State or local public benefit,” see 8 U.S.C. §§ 1611(c), 

1621(c).

7Agencies interviewed for this review included: U.S. Department of Education Federal 

Student Aid Office; Florida Department of Children and Families; California Department of 

Motor Vehicles; Arkansas Department of Finance and Administration, Office of Driver 

Services; Idaho Transportation Department, Driver Services; New York City Human 

Resources Administration, Department of Social Services; Georgia, City of Milton; 

Alabama Home Builders Licensure Board; the Internal Revenue Service; the National 

Science Foundation; Office of the Colorado Secretary of State, Elections Division; North 

Carolina Division of Motor Vehicles; and the Connecticut Mashantucket Pequot Tribal 

Nation Gaming Commission. 
Appendix I: Objectives, Scope, and 

Methodology

Page 59 GAO-17-204 Immigration Status Verification for Benefits

has instituted safeguards to protect privacy and prevent misuse of the 

SAVE system, we reviewed the Fair Information Practice Principles 

(FIPPs) adopted by the DHS Chief Privacy Officer and identified ways in 

which USCIS had addressed privacy principles within the SAVE program. 

Specifically, we reviewed the SAVE Privacy Impact Assessment and 

System of Records Notice in relation to the FIPPs to assess the extent to 

which USCIS has incorporated privacy principles within the SAVE 

program. To evaluate USCIS’s efforts to track SAVE-related immigration 

record corrections, we spoke with officials from the SAVE program, 

USCIS Central and Western Region Field Offices (selected because they 

encompassed 15 of USCIS’s 26 districts), CBP, ICE, and DHS’s Office of 

Performance Quality. We also attended two meetings of DHS’s Data 

Stewardship Tactical Working Group and obtained documentation from 

the group about new data integration initiatives that may impact USCIS’s 

efforts to track SAVE related corrections. To evaluate the notification 

provided to benefit applicants denied benefits due to a SAVE response, 

we compared user agencies’ responsibilities to provide adequate written 

notification of the denial (as detailed in the SAVE agency MOA) to the 

types of notification provided by the agencies in our sample. We 

evaluated USCIS guidance on redress and record correction by following 

the instructions presented in USCIS’s fact sheet for benefit applicants, 

which is USCIS’s main notification resource for benefit applicants, to 

determine if the information provided in the fact sheet would enable 

individuals to correct their immigration records in a timely manner. Finally, 

we spoke with DHS’s CRCL and a selection of immigrant advocacy 

organizations to gain insight into applicant experiences with addressing 

challenges with SAVE verification. We identified organizations that had 

expressed concerns with the SAVE program or had public comments on 

the SAVE program and solicited additional recommendations for 

organizations to contact from those we interviewed. We selected 

advocacy organizations to represent a range of type (legal advocacy, 

refugee assistance, etc.) and considerations related to SAVE. We 

selected a nonprobability sample of organizations to interview and, 

therefore, the information gathered from advocacy organizations is not 

generalizable beyond those we interviewed.

To address our third objective, we identified and analyzed the SAVE 

Monitoring and Compliance (M&C) Branch’s current monitoring efforts 

and compared these efforts to principles on monitoring and compliance 

set forth in Standards for Internal Control in the Federal Government and 
Appendix I: Objectives, Scope, and 

Methodology

Page 60 GAO-17-204 Immigration Status Verification for Benefits

Government Auditing Standards.

8 We collected documentation on 

monitoring efforts such as annual reports, technical manuals, standard 

operating procedures, and other relevant documents. We reviewed this 

documentation to determine what monitoring and oversight policies and 

requirements were in place and what actions SAVE M&C officials had 

taken to help ensure user agency compliance with the MOA. For 

example, the annual reports from fiscal years 2014 and 2015 compiled 

information made about compliance calls and all the report 

recommendations from that year’s site visits and desk reviews. We also 

interviewed SAVE M&C officials to determine how monitoring activities 

are conducted, what agency practices are monitored, what documents 

from agencies, and how current monitoring efforts reviewed safeguards to 

protect privacy and prevent misuse. In order to fully understand the 

monitoring process we also interviewed user agencies about their 

interactions with SAVE M&C, observed a virtual site visit, and observed 

SAVE M&C officials provide a demonstration of the desk review process. 

In addition, we analyzed USCIS data on agency performance regarding 

the failure to institute additional verification from USCIS for fiscal years 

2012 through 2016.9 We analyzed these data to determine if agencies 

that were monitored showed an improvement in compliance after 

receiving a site visit or desk review from SAVE M&C and to determine 

how many agencies not selected for monitoring were also noncompliant 

with SAVE M&C’s standards for instituting additional verification. We 

interviewed USCIS officials regarding how these data are generated and 

what procedures are in place to ensure their reliability. Based on our 

review of the data and information obtained from USCIS, we determined 

that these data were sufficiently reliable for the purposes of our report.

We conducted this performance audit from February 2016 to March 2017 

in accordance with 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.

 8GAO-14-704G.

9We selected this time period because the SAVE M&C branch became operational in 

fiscal year 2012. Additionally, this period follows a 2012 report from the DHS Office of the 

Inspector General with several recommendations related to the SAVE program. 
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 61 GAO-17-204 Immigration Status Verification for Benefits

Appendix II: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – Federal Agencies
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 62 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 63 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 64 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 65 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 66 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 67 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 68 GAO-17-204 Immigration Status Verification for Benefits
Appendix II: Standard Terms of Memorandums 

of Agreement for Agencies to use the SAVE 

System – Federal Agencies

Page 69 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 70 GAO-17-204 Immigration Status Verification for Benefits

Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 71 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 72 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 73 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 74 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 75 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 76 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 77 GAO-17-204 Immigration Status Verification for Benefits
Appendix III: Standard Terms of 

Memorandums of Agreement for Agencies to 

use the SAVE System – State or Local 

Government Agencies

Page 78 GAO-17-204 Immigration Status Verification for Benefits
Appendix IV: SAVE Fact Sheet for Benefit 

Applicants

Page 79 GAO-17-204 Immigration Status Verification for Benefits

Figure 5: Systematic Alien Verification for Entitlements (SAVE) Fact Sheet for 

Benefit Applicants

Appendix IV: SAVE Fact Sheet for Benefit 

Applicants
Appendix V: Frequency and Percentage of 

SAVE Checks that did not Institute Additional 

Verification (IAV) for Monitored Agencies, 

Fiscal Years 2013 through 2015

Page 80 GAO-17-204 Immigration Status Verification for Benefits

The three tables in Appendix IV show how frequently agencies did not 

institute additional verification (IAV) before and after receiving a site visit 

or desk review (i.e., monitoring) from U.S. Citizenship and Immigration 

Services’ (USCIS) SAVE Monitoring and Compliance (M&C) branch. The 

tables show rates at which agencies did not institute additional verification 

the year prior to monitoring (or “base year”—the performance year USCIS 

uses to select which agencies to monitor); the fiscal year in which the 

agency was monitored; and the fiscal years after monitoring.

Agency performance is shown for fiscal years 2013, 2014, and 2015. Red 

text indicates that an agency had a higher failure rate in either frequency 

or percentage of IAVs not completed when prompted by the SAVE 

system. Black text indicates that the agency completed additional 

verification (in frequency or percentage) after being monitored. Agencies 

agree to institute additional verification when prompted by the SAVE 

system.

The tables depict both the total number of SAVE checks with a response 

of IAV that were not completed, as well as the percentage of that 

agency’s total SAVE checks that were incomplete.

Appendix V: Frequency and Percentage of 

SAVE Checks that did not Institute Additional 

Verification (IAV) for Monitored Agencies, 

Fiscal Years 2013 through 2015
Appendix V: Frequency and Percentage of 

SAVE Checks that did not Institute Additional 

Verification (IAV) for Monitored Agencies, 

Fiscal Years 2013 through 2015

Page 81 GAO-17-204 Immigration Status Verification for Benefits

Figure 6: Agencies Monitored for Instituting Additional Verification (IAV) Failure in 

Fiscal Year 2013

a

Percentages represent the number of times agencies did not proceed to additional verification out of 

the total number of Systematic Alien Verification for Entitlements (SAVE) responses prompting the 

user agency to institute additional verification.

b

The base year data is the result of an agency’s performance for a particular behavior the fiscal year 

before monitoring efforts take place. For example, monitoring in fiscal year 2013 is based on data 

from fiscal year 2012 – the base year for 2013 monitoring activities.

c

A site visit is an on-site or virtual training session in w hich user agencies learn about the SAVE 

program and compliance requirements and ask questions to SAVE Monitoring & Compliance (M&C) 

officials.

d

A desk review is a virtual process in w hich documentation on user agency policies and procedures 

regarding their use of SAVE is collected and analyzed by SAVE M&C officials.
Appendix V: Frequency and Percentage of 

SAVE Checks that did not Institute Additional 

Verification (IAV) for Monitored Agencies, 

Fiscal Years 2013 through 2015

Page 82 GAO-17-204 Immigration Status Verification for Benefits

Figure 7: Agencies Monitored for Instituting Additional Verification (IAV) Failure in 

Fiscal Year 2014

a

Percentages represent the number of times agencies did not proceed to additional verification out of 

the total number of Systematic Alien Verification for Entitlements (SAVE) responses prompting the 

user agency to institute additional verification.
Appendix V: Frequency and Percentage of 

SAVE Checks that did not Institute Additional 

Verification (IAV) for Monitored Agencies, 

Fiscal Years 2013 through 2015

Page 83 GAO-17-204 Immigration Status Verification for Benefits

b

The base year data is the result of an agency’s performance for a particular behavior the fiscal year 

before monitoring efforts take place. For example, monitoring in fiscal year 2013 is based on data 

from fiscal year 2012 – the base year for 2013 monitoring activities.

c

A site visit is an on-site or virtual training session in w hich user agencies learn about the SAVE 

program and compliance requirements and ask questions to SAVE Monitoring & Compliance (M&C) 

officials.

d

A desk review is a virtual process in w hich documentation on user agency policies and procedures 

regarding their use of SAVE is collected and analyzed by SAVE M&C officials.

Figure 8: Agencies Monitored for Instituting Additional Verification (IAV) Failure in Fiscal Year 2015
Appendix V: Frequency and Percentage of 

SAVE Checks that did not Institute Additional 

Verification (IAV) for Monitored Agencies, 

Fiscal Years 2013 through 2015

Page 84 GAO-17-204 Immigration Status Verification for Benefits

a

Percentages represent the number of times agencies did not proceed to additional verification out of 

the total number of Systematic Alien Verification for Entitlements (SAVE) responses prompting the 

user agency to institute additional verification.

b

The base year data is the result of an agency’s performance for a particular behavior the fiscal year 

before monitoring efforts take place. For example, monitoring in fiscal year 2013 is based on data 

from fiscal year 2012 – the base year for 2013 monitoring activities.

c

A site visit is an on-site or virtual training session in w hich user agencies learn about the SAVE 

program and compliance requirements and ask questions to SAVE Monitoring & Compliance (M&C) 

officials.

d

A desk review is a virtual process in w hich documentation on user agency policies and procedures 

regarding their use of SAVE is collected and analyzed by SAVE M&C officials.
Appendix VI: Comments from the Department 

of Homeland Security

Page 85 GAO-17-204 Immigration Status Verification for Benefits

Appendix VI: Comments from the 

Department of Homeland Security
Appendix VI: Comments from the Department 

of Homeland Security

Page 86 GAO-17-204 Immigration Status Verification for Benefits
Appendix VI: Comments from the Department 

of Homeland Security

Page 87 GAO-17-204 Immigration Status Verification for Benefits
Appendix VI: Comments from the Department 

of Homeland Security

Page 88 GAO-17-204 Immigration Status Verification for Benefits
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 89 GAO-17-204 Immigration Status Verification for Benefits

Rebecca Gambler, (202) 512-6912 or gamblerr@gao.gov

In addition to the contact named above, Adam Hoffman (Assistant 

Director) and Charlotte Gamble (Analyst-in-Charge) managed this 

assignment. David Alexander, Natalie Block, Marisol Cruz, John de 

Ferrari, Eric Hauswirth, Susan Hsu, Sasan J. “Jon” Najmi, Cristina 

Norland, David Plocher, and Edith Sohna made key contributions to this 

report.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100591)
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