United States Government Accountability Office

GAO Report to Congressional Requesters

IMMIGRATION 

BENEFITS 

Additional Efforts 

Needed to Help 

Ensure Alien Files Are 

Located when Needed 

October 2006 

 

GAO-07-85 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

October 2006

IMMIGRATION BENEFITS 

Additional Efforts Needed to Help Ensure 

Highlights of GAO-07-85, a report to Alien Files Are Located when Needed 

congressional requesters 

To document the interactions of 

aliens with the Department of 

Homeland Security’s (DHS) United

States Citizenship and Immigration 

Services (USCIS) and other

government entities, USCIS creates 

alien files, or A-files. While deemed

critical, especially in making

citizenship decisions, A-files are 

sometimes missing during 

adjudications. In 2002, 

naturalization was granted to an 

alien whose A-file was missing and

who was later found to be

associated with a terrorist 

organization. GAO focused its 

review on (1) how often USCIS 

adjudicates naturalization 

applications without an A-file and 

why, (2) the effect that missing 

A-files can have on the adjudication

process, and (3) steps taken to help

mitigate the risk of missing A-files. 

To address these questions, GAO 

interviewed officials and staff from

USCIS and reviewed relevant data, 

policies, and procedures related to 

processing naturalization 

applications and the automated 

file-tracking system DHS 

established to track the movement 

of A-files. 

What GAO Recommends

GAO recommends that USCIS 

require adjudicators to record 

whether an A-file was available in

naturalization adjudications and, 

with other DHS users of A-files, 

determine why staff are not 

complying with file-tracking

procedures and correct any 

deficiencies. In its comments, DHS 

agreed with our recommendations. 

A-files were not available to adjudicate naturalization applications in a small

percentage of cases. GAO found that of the naturalization applications 

adjudicated in 2005, about 30,000—or about 4 percent of them—may have 

been adjudicated without A-files. However, this number may be less because 

USCIS staff are not required to record whether an A-file was available. 

USCIS officials said that a major reason A-files were not available for 

naturalization application adjudications is that staff are not using the 

automated file-tracking system. USCIS officials suggested that staff might 

not be using the automated file-tracking system for lack of sufficient training 

on how to use the system, while local management may not be adequately 

emphasizing the importance of complying with A-file tracking policies and 

procedures. 

Missing A-files can have an impact on the process of adjudicating

naturalization applications in several ways. For example, when an A-file is 

not available at the location indicated in the automated file-tracking system, 

additional time is spent trying to locate the file, which slows the adjudication 

process and applicants may wait longer for USCIS to process their 

application. In addition, missing A-files can hinder USCIS’ s ability to 

uncover immigration benefit fraud and limit DHS’ ability to take 

enforcement actions. 

USCIS has steps in place to help mitigate the risk of adjudicating a 

naturalization application without an A-file. These steps include verifying the 

applicant’s lawful admission to the United States and conducting extra 

supervisory reviews to ensure that naturalization processing procedures 

have been followed. 

Additional Time Spent Locating A-files when A-files Are Not Initially Received at USCIS 

District Offices 

Source: GAO.

a

When an A-file is not located, a temporary file, or T-file, is created.

District office searches 

 for the A-file 

A-file located 

and requested 

and sent to 

district office 

A-file not 

located and 

determined 

to be lost 

T-filea

 merged 

with A-file 

Citizenship eligibility decision 

T-file used to 

adjudicate 

naturalization 

application 

A

?

A

T

A T A

A-file used to 

adjudicate 

application 

A

www.gao.gov/cgi-bin/getrpt?GAO-07-85.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Paul Jones at 

(202) 512-8777 or JonesPL@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 5

Extent to Which Naturalization Cases Are Adjudicated without an 

A-file Appears Low, but Compliance with File-Tracking 

Procedures Is Lacking 10 

Missing A-files Can Affect the Naturalization Adjudication Process 

in Several Ways 13 

Naturalization Quality Procedures Help to Mitigate the Risk of

Adjudicating a Naturalization Application without an A-file 15 

Conclusions 16

Recommendations for Executive Action 16 

Agency Comments and Our Evaluation 16 

Appendix I Scope and Methodology 19 

Appendix II Comments from the Department of 

Homeland Security 21 

Appendix III GAO Contact and Staff Acknowledgments 24 

Tables 

Table 1: Results from Los Angeles District File Audit for Three 

Locations 12

Figures 

Figure 1: Steps Involved in Locating A-files for Naturalization 

Applications 9

Page i GAO-07-85 Immigration Benefits
Abbreviations: 

CLAIMS Computer-Linked Application Information Management System 

CBP Customs and Border Protection 

DHS Department of Homeland Security 

FBI Federal Bureau of Investigation 

IBIS Interagency Border Inspection System

ICE Immigration and Customs Enforcement 

NFTS National File Tracking System 

NQP Naturalization Quality Procedures 

ROH Records Operation Handbook 

USCIS United States Citizenship and Immigration Services 

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Page ii GAO-07-85 Immigration Benefits
United States Government Accountability Office

Washington, DC 20548 

October 27, 2006 

The Honorable Susan M. Collins 

Chairman, Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Charles E. Grassley 

Chairman, Committee on Finance 

United States Senate 

The United States Citizenship and Immigration Services (USCIS), within 

the Department of Homeland Security (DHS), is responsible for processing 

noncitizens’ applications (sometimes commonly referred to as benefit 

applications) to live and in some cases work in the United States either 

permanently or on a temporary basis or to become a United States citizen.

For certain noncitizens, such as immigrants, USCIS creates an alien file, 

called an A-file, to serve as the one central file for all of the noncitizen’s 

immigration-related applications and related documents. USCIS manages 

over 55 million A-files. Not only do USCIS staff rely on an alien’s historical 

A-file to determine eligibility for immigration benefits, but other DHS 

components, such as Immigration and Customs Enforcement (ICE), use 

A-files during criminal investigations and to determine, for example, 

whether an alien should be removed from or allowed to stay in the United

States. Information and documents from A-files may also be shared with 

other law enforcement agencies, such as the Federal Bureau of 

Investigation (FBI), to investigate individuals suspected of being involved

in terrorist activities. Consequently, it is critical that A-files be available

when needed. Because A-files are paper-based, they require physical 

transfer from one location to another. USCIS has developed an automated

file-tracking system, called the National File Tracking System (NFTS), to 

enable all DHS staff at numerous DHS locations around the country to 

locate, request, receive, and transfer A-files. NFTS users are to access 

USCIS’s NFTS intranet site via their personal computers to locate and 

request an A-file and update NFTS when they receive an A-file or transfer 

an A-file to another person or office.

Naturalization is the process whereby a noncitizen becomes a United 

States citizen. An application for naturalization is both the last step in the 

Page 1 GAO-07-85 Immigration Benefits
immigration process and the last opportunity for USCIS, through its 

benefit-granting review procedures, to prevent ineligible noncitizens from 

becoming citizens and hence remaining in the United States.1

 In 2002, 

USCIS’s predecessor, the Immigration and Naturalization Service, granted 

naturalization to a noncitizen who was later identified to be associated 

with a terrorist organization. In this case, the adjudicator had not obtained

the A-file in adjudicating the application for naturalization and deciding to

grant the benefit. Indeed, background checks conducted as part of 

USCIS’s naturalization process continue to reveal instances where 

individuals who pose a potential risk to national security have applied for 

naturalization. Because naturalization is the final benefit that USCIS can 

bestow upon a noncitizen, it is critical that USCIS staff have access to the 

full and complete history of an applicant—which is contained only in the 

A-file—before making a final eligibility decision. 

Because of the importance of the naturalization decision, we focused our 

review on the availability of A-files in adjudicating naturalization 

applications. For this report we examined (1) the extent to which USCIS 

records how often naturalization applications are adjudicated without an 

A-file, as well as the reasons why an A-file might be missing; (2) the effect 

that missing A-files can have on the adjudication of naturalization 

applications; and (3) what steps USCIS takes to help mitigate the risk of 

adjudicating naturalization applications without an A-file. 

To address these objectives, we sent e-mail questionnaires and followed 

up with phone calls to officials and staff from 13 USCIS district offices and 

reviewed relevant documents, policies, and procedures on processing 

naturalization applications. We also obtained written responses from 

another district for a total of 14 district offices. We selected these offices

because they adjudicated most of the naturalization applications. 

Specifically, USCIS data indicate that these 14 offices adjudicated nearly

two-thirds of the approximately 715,000 naturalization applications 

adjudicated in fiscal year 2005. To examine the extent to which USCIS 

records how often naturalization applications are adjudicated without an 

A-file and why A-files might be missing, we obtained summary data from a 

USCIS database containing information on whether an A-file was available 

when adjudicating a naturalization application. We also obtained summary 

 1

 Naturalization may be revoked through judicial proceedings instituted by a U.S. Attorney’s

Office on the ground that naturalization was illegally procured or procured by concealment

of a material fact or by willful misrepresentation. 8 U.S.C. § 1451. 

Page 2 GAO-07-85 Immigration Benefits
data from NFTS on A-files indicated as lost and, as having been in transit 

and yet to be recorded as received. We also interviewed officials from 

USCIS headquarters and obtained instructions and guidance about using,

locating, and requesting A-files. To determine the effect that missing 

A-files can have on the adjudication process, we interviewed USCIS 

district office officials and staff. To determine if USCIS has instituted 

additional procedures to help mitigate the risk of adjudicating a 

naturalization application without an A-file, we reviewed policies and 

procedures related to processing these applications, interviewed USCIS 

officials, and reviewed relevant documents. In a prior review we 

determined how USCIS ensures the quality and consistency of adjudicator

decisions by examining USCIS’s two quality assurance programs and 

resulting outcomes, and reviewed the findings and recommendations of an 

independent study of USCIS’s quality assurance programs.2

 To assess the 

reliability of USCIS’s system for managing naturalization applications and 

NFTS data we (1) reviewed summary data and specific data elements for 

obvious errors in accuracy and completeness, (2) reviewed related 

documentation, and (3) interviewed USCIS staff knowledgeable about 

USCIS’s system for managing naturalization applications and NFTS. We 

found the data from its system for managing naturalization applications 

and its quality assurance database were sufficiently reliable for our 

purposes. Regarding NFTS, we found that the summary data we used were 

sufficiently reliable for the purposes of this report. We conducted our 

review from August 2005 through August 2006 in accordance with 

generally accepted government auditing standards. Appendix I presents 

more details on our scope and methodology. 

A-files were not available in a relatively small percentage of naturalization

cases. USCIS officials attributed the unavailability of A-files to staff failure 

to use its file-tracking system in a timely fashion or sometimes at all. 

Although USCIS does not keep track of when naturalization applications 

are adjudicated without an A-file, data from USCIS’s database for 

managing naturalization applications indicated that A-files were available 

for 685,000 of the approximately 715,000 naturalization applications—or 

96 percent—adjudicated nationwide in fiscal year 2005, indicating that 

A-files may not have been used in 30,000 applications. However, USCIS 

officials said that A-files were probably used to process some of the 

Results in Brief 

 2

 See GAO, Immigration Benefits: Improvements Needed to Address Backlogs and Ensure 

Quality of Adjudications, GAO-06-20 (Washington, D.C.: Nov. 21, 2005). 

Page 3 GAO-07-85 Immigration Benefits
30,000 applications because adjudicators are not required to indicate in the 

naturalization database if an A-file was not used. In addition, USCIS 

conducted quality assurance audits of a sample of about 29,000 

naturalization cases adjudicated in fiscal year 2005 and found that A-files 

were not available in 129 cases, less than 1 percent. However because of 

limitations in USCIS’s sampling methodology, the results of this audit 

could not be projected to the universe of applications adjudicated in that 

fiscal year. Available data can indicate only a range of how often an A-file 

was not available (from perhaps as high as 4 percent of all cases to less 

than 1 percent). Since USCIS deems reviewing the A-file critical to the

naturalization adjudications process, the lack of precise data on when an 

A-file is not available limits USCIS’s ability to determine compliance with 

this critical step and whether additional actions are necessary to ensure 

A-files are available when needed. USCIS officials also told us that 

adjudicators sometimes had difficulty locating A-files because the A-file’s

location indicated in NFTS was incorrect or not up to date. For example, 

an April 2005 file audit by USCIS’s San Diego district office found that 

nearly 21 percent of the district’s files (11,731 of 56,092 files audited) were 

not in the location shown in NFTS. In addition, NFTS procedures require 

DHS staff receiving an A-file to “immediately” update the system. During 

our review, USCIS checked the NFTS and found over 100,000 A-files were 

shown to be in transit more than 30 days. The failure of some staff to 

update NFTS to record the movement of an A-file, such as when they 

receive or transfer one, is a major reason for delays in locating A-files or in 

not being able to locate an A-file at all. As of July 27, 2006, for the 

14 district offices we included in our review, NFTS indicated that about 

111,000 A-files were lost. USCIS officials suggested that staff may not be 

using NFTS because they may lack training (Web-based training is 

available) on how to use the system and that management may not be

emphasizing enough the importance of using NFTS. 

Missing A-files can have an impact on the process of adjudicating 

naturalization applications in several ways. They can cost staff extra time 

and effort trying to locate them. Applicants for naturalization, in turn, may 

wait longer for USCIS to process their applications. For example, USCIS 

procedures for processing naturalization applications allow USCIS to wait 

up to 3 months to try to find an A-file, thereby possibly delaying

adjudicating the application. Because an A-file might contain potentially 

disqualifying information about an applicant, adjudicating an immigration 

benefit application without an A-file also increases the risk of granting a 

benefit to an ineligible applicant. In addition, DHS may not be able to take

an enforcement action against an applicant because the necessary 

evidence is in the missing A-file. 

Page 4 GAO-07-85 Immigration Benefits
USCIS has steps in place to help mitigate the risk of adjudicating a 

naturalization application without an A-file. These steps include verifying

the applicant’s lawful admission to the United States and conducting extra 

supervisory reviews to ensure that naturalization processing procedures 

have been followed. Officials we spoke with told us that they believed 

these additional steps help mitigate the risk of adjudicating a 

naturalization application without an A-file. Available data indicate that 

these additional steps are being followed nearly all of the time. Of the 

129 quality assurance audit cases sampled in 2005 where an A-file was not 

available, USCIS staff did not follow all of the required procedures in 

5 applications. Officials from several district offices said that the standard

adjudication procedures (applicable whether or not an A-file is missing), 

such as background security checks, also help reduce the risk somewhat 

of granting naturalization to someone who is ineligible. 

In order to improve USCIS’s management information, prevent 

unnecessary delay, and more efficiently adjudicate applications, we are 

recommending that the Secretary of Homeland Security direct the Director

of USCIS to 

• require users to record or note whether an A-file was used to 

adjudicate a naturalization application and, 

• work together with other DHS users of A-files to 

• determine the extent to which staff may not be complying with 

NFTS procedures for updating the system and why, and 

• correct any identified deficiencies in file tracking compliance.

We provided a draft of this report to DHS. DHS stated that the report 

generally provided a good overview of the complexities associated with 

the process for ensuring adjudication officers have A-files when 

adjudicating naturalization applications. DHS agreed with both of our 

recommendations and cited actions it plans to take to implement them. 

Millions of noncitizens apply annually to enter the United States to live, 

work, or study. USCIS creates alien files, more commonly called A-files, 

to document the history of a person’s interaction with USCIS or any DHS 

entity involved in immigration related actions. USCIS’s Records Operation 

Handbook (ROH) provides instruction on when and how to create an 

A-file as well as how to request files and transfer them from one office to

another. USCIS maintains A-files on certain individuals, including those 

who 

Background 

Page 5 GAO-07-85 Immigration Benefits
• are immigrants or who apply for immigrant status, 

• have become citizens, or

• have applied for asylum in the United States or refugee status overseas. 

The A-file is to contain all of the relevant documents of an alien’s 

interactions with USCIS or other DHS components. For example, the A-file

could contain an application for lawful permanent residency and petitions 

for an alien relative as well as documents related to enforcement actions 

such as an arrest warrant and the results of any immigration proceedings. 

While USCIS is the main user of A-files and the official DHS custodian for 

all of them, other DHS components, such as ICE and Customs and Border 

Protection (CBP), also use A-files for investigations or other enforcement 

actions. In addition, information and documents from A-files may be 

shared with agencies such as the FBI and Department of State. According

to senior USCIS officials, USCIS spends about $13 million each year 

transporting A-files within USCIS and to other components and agencies.3

USCIS’s long-range plans call for eventually converting paper A-files into 

electronic files, thus avoiding these transportation costs and making 

A-files available to multiple users simultaneously. In August 2006, USCIS 

awarded a 5-year $150 million contract to begin converting A-files. 

USCIS adjudicates applications for immigration benefits through a 

network of field offices that include 4 service centers, 33 district offices, 

and 8 asylum offices. In fiscal year 2005, USCIS’s budget was about 

$1.8 billion and USCIS adjudicated about 7.5 million applications, of which 

over 715,000 were applications for naturalization. Naturalization 

applications are adjudicated at USCIS district offices and require the 

applicant to, among other things, undergo a security background check, be 

interviewed by an adjudicator and, demonstrate proficiency in English and 

a basic understanding of U.S. civics. As part of the adjudications process, 

adjudicators are to review the applicant’s A-file to identify any information 

that may disqualify the applicant for naturalization, including information 

that may indicate potential fraud. Of the over 715,000 naturalization 

applications adjudicated in fiscal year 2005, USCIS denied about 64,000. 

 3

 See GAO, Information Technology: Near-Term Effort to Automate Paper-Based 

Immigration Files Needs Planning Improvements, GAO-06-375 (Washington, D.C.: 

Mar. 31, 2006). See also DHS, Office of Inspector General, USCIS Faces Challenges in

Modernizing Information Technology, OIG-05-41 (Washington, D.C.: September 2005). 

Page 6 GAO-07-85 Immigration Benefits
All applications for an immigration benefit, including naturalization, are to 

be filed in the applicant’s A-file. USCIS staff use USCIS’s Central Index 

System to locate and request the A-file from the last known office location.

However, the Central Index System can only identify the office location 

for the A-file; it does not provide precise information about where in an 

office an A-file is located. USCIS has NFTS, a system designed to provide 

more detailed information on the location of an A-file, down to a specific 

individual or file drawer. USCIS’s predecessor, the Immigration and 

Naturalization Service, began deploying NFTS in November 2002. The 

system is now deployed to all records units in USCIS district and asylum 

offices, the USCIS’s Texas Service Center and National Benefits Center, 

and all ICE and CBP units. Tentative plans call for deploying NFTS to 

USCIS’s three other service centers by March 2007.4

 NFTS is a Web-based 

system that is available to anyone in DHS who needs A-files. Users can 

obtain a user identification code that allows them to request, receive, and 

transfer A-files. Web-based training on how to use NFTS is available via 

DHS component intranet sites, including USCIS’s EdVanatage Learning

University, ICE’s Virtual University, and the CBP Learning University. In 

January 2004, USCIS, ICE, and CBP signed a Service Level Agreement in 

which USCIS agreed to provide A-files to ICE and CBP, and ICE and CBP 

agreed to follow the ROH. 

USCIS’s ROH describes the procedures that are to be followed for 

locating, sending, and receiving A-files. The ROH states that all DHS staff 

with access to NFTS should use NFTS to, for example, 

• record the creation of an A-file, 

• request A-files from other offices, 

• record when an A-file is sent or transferred out to another office, 

and 

• immediately record both when an A-file is received and the file’s 

specific location. 

 4

 Staff at the three service centers without NFTS use USCIS’s Central Index System to 

record when they request, receive, and transfer A-files. A computer interface between CIS 

and NFTS updates the A-file movement in each system so that staff who cannot use NFTS

can record the movement of an A-file. The movement will then be recorded in NFTS and 

vice versa. 

Page 7 GAO-07-85 Immigration Benefits
USCIS uses the Computer-Linked Application Information Management 

System (CLAIMS) 4, as the case management and tracking system for 

naturalization applications. CLAIMS 4 contains information from the 

naturalization application and other data, such as the results from security

background checks and whether or not the application was approved. 

CLAIMS 4 can also track the status of a request for the A-file, indicating 

whether the A-file has been requested, received by the district office 

adjudicating the application, or deemed lost. Figure 1 shows the steps 

involved in locating A-files for naturalization applications. 

Page 8 GAO-07-85 Immigration Benefits
Figure 1: Steps Involved in Locating A-files for Naturalization Applications

Source: GAO. 

A-file located and sent to 

service center 

Service center incorporates 

naturalization application 

and related documentation 

A-file not located 

A-file sent to the district 

office that will adjudicate 

the application 

Service center prepares a 

temporary file, or T-file, to 

process the naturalization

application 

T-file is sent to the district 

office that will adjudicate 

the application 

District office searches 

the NFTS to try to 

locate the A-file 

A-file located and 

requested and sent

to district office 

A-file not located and 

determined to be lost 

N-400 application 

received in USCIS 

service center 

Data entered into case 

management system 

Automated request 

for A-file to last known 

file location 

T-file merged 

with A-file 

Citizenship eligibility

decision 

T-file used to adjudicate 

naturalization application 

A

A ?

A

T

T

A

A

A ?

T T A

A

A-file used to 

adjudicate application 

A

ACTIVITIES THAT OCCUR WITHIN THE DISTRICT OFFICE

Page 9 GAO-07-85 Immigration Benefits
USCIS’s Adjudicator’s Field Manual provides adjudicators with guidance

on naturalization procedures and how to determine whether an applicant

meets the eligibility requirements for becoming a citizen. To improve the 

quality and consistency of all naturalization application processing, USCIS

has issued Naturalization Quality Procedures (NQP) guidelines. The NQP 

provides detailed checklists that clerical staff and adjudicators must 

complete at each stage of the naturalization process. These completed 

checklists must be included in an A-file, along with the naturalization 

application and related documents. The NQP also requires that 

adjudicators be certified as NQP trained once every 3 years. 

Our analysis of USCIS data and interviews with USCIS district officials 

indicate that A-files are missing in a relatively small percentage of 

naturalization cases but that DHS staff may not always be updating NFTS 

when files are moved, resulting in delays in locating A-files or in not 

locating them at all. The CLAIMS 4 database contains a data field that 

indicates the status of the A-file request, such as whether the file has been

received in the district office, requested but not yet received, or that the 

A-file has been declared lost. According to data from the CLAIMS 4 

database, of the approximately 715,000 naturalization applications 

adjudicated in fiscal year 2005, the district office received the A-file in 

685,000 of these cases (about 96 percent), indicating that A-files may not 

have been available in about 4 percent (about 30,000) of them. However, 

USCIS officials told us that this CLAIMS 4 data field is an optional field 

that USCIS staff may complete at various times during the adjudications

process or not at all. USCIS officials told us that of the approximately 

30,000 naturalization cases where the A-file status indicated something 

other than received in the district office, A-files were probably available in

a number of them. However, because adjudicators may not always update 

the A-file data field to indicate whether the A-file was eventually received, 

how many is unknown. In about 13,000 of the approximately 30,000 cases, 

the A-file status indicator was blank. 

Extent to Which 

Naturalization Cases 

Are Adjudicated 

without an A-file 

Appears Low, but 

Compliance with FileTracking Procedures 

Is Lacking 

Data from USCIS’s quality assurance audit of the naturalization program 

also indicate that the A-files are missing in a relatively small percentage of

cases. In fiscal year 2005, the USCIS Performance Management Division 

sampled 28,575 naturalization applications adjudicated by district offices. 

Staff found that A-files were available in all but 129 of 28,575 cases 

sampled, about 0.5 percent. However, because of limitations in its 

sampling methodology, USCIS said this percentage cannot be projected to

the universe of approximately 715,000 naturalization applications 

completed that year. Although USCIS officials from the 13 district offices 

Page 10 GAO-07-85 Immigration Benefits
we spoke with acknowledged that their offices do not track how often 

naturalization applications are adjudicated without an A-file, they believed 

the percentage was low. They estimated the percentage of naturalization 

applications in fiscal year 2005 that were adjudicated without A-files 

ranged from less than 1 percent to 10 percent. 

GAO’s Standards for Internal Control in the Federal Government states 

that information needed to achieve an agency’s objectives should be 

identified and regularly reported to management.5

 According to USCIS’s 

Naturalization Quality Procedures, having and reviewing an applicant’s 

A-file is critical to confirming that the applicant is eligible for

naturalization and that no incidents have taken place that would disqualify 

the applicant from naturalization. In a November 2005 memo, the Acting 

USCIS Director of Domestic Operations stated that not having an A-file 

should be a “rare” occurrence, but did not quantify what “rare” meant. 

Since USCIS deems reviewing the A-file critical to the naturalization 

adjudications process, the lack of precise data on when an A-file is not 

available limits USCIS’s ability to determine compliance with this critical 

step and whether additional actions are necessary to ensure A-files are 

available when needed. 

According to USCIS officials, adjudicators sometimes have difficulty 

locating A-files or cannot find them at all because the locations shown in 

NFTS are incorrect or not up to date. For example, according to a 

summary of the results of an April 2005 file audit conducted by USCIS’s 

San Diego district office records staff, nearly 21 percent of the district’s 

files (11,731 of 56,092 files audited) were not in the location shown in 

NFTS. Another 34,764 files shown to be under the control of the San Diego 

district could not be immediately located during the audit. Some of these 

files may have been in locked file cabinets that audit staff could not 

access, while others may have been transferred to another location and

were no longer in the district. NFTS showed duplicate file locations for 

464 files. Audit staff also found 281 of the files that NFTS indicated were 

lost. About half of the lost files were found within the local ICE Office of 

Investigations. The other half were found mostly within CBP. In addition, 

in June 2006 the Los Angeles district office conducted a file audit of three 

locations that had files. As shown in table 1, about 6 percent of the files 

indicated by NFTS to be at these three locations could not be found. 

 5

 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

Page 11 GAO-07-85 Immigration Benefits
Table 1: Results from Los Angeles District File Audit for Three Locations

Number Percent

Files shown in NFTS 4,169 100

Files in location shown in NFTS 3,886 93

Files not in location shown in NFTS 283 7 

Files located after physical search 36 1

Files not found 247 6

Source: GAO analysis of USCIS data. 

For some A-files, the office location recorded in NFTS is not up to date.

NFTS procedures require that a person receiving an A-file should 

“immediately” update NFTS. According to the Section Chief of the Records 

Systems Services Section of USCIS’s Office of Records Management 

Branch, once a file is sent (either via the U.S. Postal Service or a private 

package delivery service) from one office to another, it should take no 

longer than a month for the A-file to arrive at the receiving office and for 

NFTS to be updated. During our review, USCIS checked NFTS and found 

107,000 A-files that have been in transit over a month but had yet to be

recorded as received in NFTS. Nearly 63,000 had been in transit more than 

3 months. 

GAO’s Standards for Internal Control in the Federal Government also 

states that transactions and other significant events should be promptly 

recorded so that they maintain their relevance, value, and usefulness to 

management in controlling operations and making decisions. Although 

USCIS considers compliance with NFTS procedures critical to enabling it

to maintain control over A-files, DHS staff are not always complying with 

these procedures. 

According to USCIS officials, DHS staff are not always recording the 

movement of an A-file in NFTS, resulting in inaccurate information on the 

location of A-files. Officials from 10 of the 13 USCIS district offices we 

spoke with claim that the failure to record the movement of files in NFTS 

is a major reason for delays in locating an A-file, in not being able to locate 

an A-file at all, and in an A-file being declared lost. One district director 

stated that the cooperation of other DHS components in adhering to file 

transfer procedures was imperative, especially since they maintained 

A-files relating to national security investigations and other sensitive 

issues. According to USCIS records officials, the USCIS Records Division 

has not conducted a formal study or evaluation as to why NFTS users are 

not complying with all NFTS and ROH procedures. This cooperation is 

Page 12 GAO-07-85 Immigration Benefits
important, especially because USCIS has no authority to enforce 

compliance with file-tracking procedures among the other DHS 

components. The report summarizing the San Diego district’s April 2005 

file audit cited above stated that the number of files, in the thousands, that 

were not in the location shown in NFTS or could not be found was 

“staggering” and attested to the need to ensure that all personnel in all 

units and agencies use NFTS and follow procedures. According to the 

report, several locations were not using NFTS although NFTS was 

available. USCIS records officials stated that lack of compliance with 

NFTS procedures was “very prevalent.” As of July 27, 2006, for the 

14 district offices we included in our review, NFTS indicated that about 

111,000 A-files were lost. 

USCIS officials offered several reasons why some staff may not be 

complying with NFTS file-tracking procedures. According to the report 

summarizing the San Diego district’s April 2005 file audit, additional NFTS 

training is needed and compliance with the NFTS procedures should be 

mandated for all sites. The audit report recommended regular NFTS 

workshops for USCIS, CBP, and ICE staff. USCIS records officials stated 

that local management may not be emphasizing enough the importance of 

using NFTS. ICE officials we spoke to commented that they believe some 

of the NFTS file transfer procedures are cumbersome, resulting in some 

ICE staff circumventing them and not recording the file movement in 

NFTS. For example, whether sending or receiving A-files, the ROH 

requires that they all be routed through the local USCIS records unit 

whenever a file needs to be transferred from one ICE field location to 

another. This is because members of USCIS staff are the only ones allowed 

to transfer a file from one field location to another. However, according to

ICE officials, because of the urgency of the situation, ICE personnel may 

send an A-file directly from one ICE office to another, bypassing the 

USCIS records units. As a result, the file movement to the new location is 

not recorded in NFTS. USCIS records officials stated that they do not 

believe lack of compliance stems from any technical problems with using 

NFTS because the system is Web-based and relatively easy to use. 

Missing A-files can cause delays in awarding immigration benefits, hinder 

USCIS’s ability to uncover immigration fraud, and limit DHS’s ability to 

take enforcement actions. According to USCIS’s ROH, lost or missing 

A-files can cause delays or errors in awarding immigration benefits and 

can hamper investigation and enforcement actions. For example, USCIS 

procedures for processing naturalization applications allow USCIS to wait 

up to 3 months to try to find an A-file, thereby delaying adjudicating the 

application. According to several USCIS district officials, USCIS staff 

Missing A-files Can 

Affect the 

Naturalization 

Adjudication Process 

in Several Ways 

Page 13 GAO-07-85 Immigration Benefits
spend additional time and effort trying to locate files that are not in the 

location identified in NFTS, thus delaying their ability to process benefits

quickly. Officials from all of the district offices we spoke with told us that 

USCIS faces an increased risk of granting naturalization to an ineligible

applicant when the adjudicator does not have the A-file available because

the file may contain potentially disqualifying information. Officials from 

several district offices stated that the A-file is needed to look for any 

inconsistencies between the naturalization application and other 

applications that the applicant had submitted when applying for previous 

benefits like legal permanent residency. For example, a naturalization 

application may contain facts about the applicant’s marital or family 

(children) status that are inconsistent with information in the A-file, a 

possible indication of fraud that may not be uncovered without the A-file.

These types of inconsistencies cannot be checked without the A-file. In 

addition, USCIS conducts background security checks on all naturalization 

applicants via the Interagency Border Inspection System (IBIS).6

 IBIS 

guidance requires an IBIS name check on all names an applicant may have

used. According to several district officials, the A-file may contain other

names (aliases) the applicant may have used that should be checked 

against IBIS. Therefore, without the A-file, any potentially damaging 

information related to these other names may not be uncovered, 

increasing the risk of granting naturalization to an ineligible applicant.

DHS’s ability to take an enforcement action against an applicant may also 

be compromised. According to an ICE attorney, some immigration judges 

may be reluctant to, for example, order an alien removed from the United 

States without the complete A-file. 

 6

 IBIS provides the law enforcement community with access to computer-based 

enforcement files of common interest and also provides access to the FBI’s National Crime 

Information Center (NCIC). 

Page 14 GAO-07-85 Immigration Benefits
Officials we spoke with stated that the steps contained in the 

Naturalization Quality Procedures mitigate somewhat the risk of 

naturalizing someone who is ineligible. For example, adjudicators must 

take additional steps when adjudicating a naturalization application 

without an A-file. Specifically, these steps include 

• verifying the applicant’s lawful admission to the United States and that 

the applicant has lived in the United States as a lawful permanent 

resident for the required amount of time—generally, 5 years—and lack

of disqualifying information in USCIS databases, 

Naturalization Quality 

Procedures Help to 

Mitigate the Risk of 

Adjudicating a 

Naturalization 

Application without 

an A-file

• extra supervisory reviews to ensure that naturalization processing 

procedures have been followed, and

• not scheduling the oath ceremony on the same day that the 

naturalization application is adjudicated to allow sufficient time for the 

required supervisory reviews. 

Data from USCIS’s quality assurance audit of the naturalization program 

indicate that USCIS staff is following procedures nearly all of the time 

when adjudicating a naturalization application without an A-file. Of the 

129 quality assurance audit cases sampled in fiscal year 2005 where an 

A-file was not available, USCIS staff did not follow all of the required 

procedures in 5 cases. 

Officials from several district offices told us that the standard

naturalization adjudication procedures (applicable when an A-file is either 

available or missing), such as background security checks, somewhat 

reduce the risk of granting naturalization to someone who is ineligible. For 

example, as part of USCIS’s background security check, USCIS is to 

conduct an IBIS name check as well as both a fingerprint and FBI name 

check. In an April 2006 memorandum, the USCIS Director of Operations 

directed that naturalization interviews should not be scheduled until all 

background checks have been completed to ensure that all background 

security issues are resolved before USCIS interviews the applicant. 

According to officials from several district offices, the background 

security checks mitigate, somewhat, the risk of naturalizing someone who 

poses a potential national security or public safety threat. 

Page 15 GAO-07-85 Immigration Benefits
Although USCIS deems having an A-file critical to adjudicating a 

naturalization application, USCIS staff are not required to record whether 

an A-file was used to adjudicate a naturalization application. Recording 

whether an A-file was used to adjudicate a naturalization application could 

help USCIS assess the extent of the risk posed by adjudicating 

naturalization applications without an A-file and what actions may be 

necessary to address the problem. DHS staff who have access to A-files 

may not be consistently using NFTS to track the movement of A-files, 

hindering the ability to locate A-files when needed. While officials offered 

suggestions as to why staff may not be complying, such as the lack of 

NFTS training, it is unclear to what extent staff are not complying and 

why. Knowing the extent to which staff are not complying and why and 

addressing these reasons would increase DHS’s ability to locate and 

provide A-files for adjudicators and others, thereby reducing the risk 

associated with adjudicating a naturalization application and other 

immigration benefits without the A-file. 

In order to improve USCIS’s management information, prevent 

unnecessary delay, and more efficiently adjudicate applications, we are 

recommending that the Secretary of Homeland Security direct the Director

of USCIS to 

• require users to record or note whether an A-file was used to 

adjudicate a naturalization application and 

 

• work together with other DHS users of A-files to 

• determine the extent to which staff may not be complying with 

NFTS procedures for updating the system and why and 

• correct any identified deficiencies in file-tracking compliance.

We provided a draft of this report to DHS for review. On October 24, 2006 

DHS provided written comments which are shown in appendix II. DHS 

also provided technical comments which we incorporated as appropriate.

DHS agreed with both of our recommendations and stated that the report 

generally provides a good overview of the complexities associated with 

the process for ensuring adjudication officers have A-files when 

adjudicating naturalization applications. 

Conclusions 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Regarding our recommendation to require users to record or note whether 

an A-file was used to adjudicate a naturalization application, DHS stated 

that it plans to modify its CLAIMS 4 system to make the data field related 

Page 16 GAO-07-85 Immigration Benefits
to file status mandatory. USCIS plans to make this modification in early to

mid 2007. 

Regarding our recommendation that USCIS work together with other DHS 

users of A-files to determine the extent to which staff may not be 

complying with NFTS procedures and why and to correct any deficiencies 

in file-tracking procedures, DHS stated that information obtained from 

recently completed visits to USCIS, CBP and ICE field offices will help 

USCIS determine the level of compliance with file tracking procedures and 

identify remediation efforts required by each agency. This information will 

also serve as the basis for a planned joint policy on A-file management. 

DHS also cited several efforts it has taken or is planning to take to improve 

the management of A-files. For example, USCIS and CBP records 

managers have formed a partnership and are working to improve 

responsiveness to records management needs. USCIS established File 

Control Offices at several sub-offices allowing these sub-offices to move 

files to requesting offices as quickly as possible. USCIS’ Records 

Management Branch will evaluate NFTS reports to track files that are not 

transferred within a reasonable amount of time and notify appropriate 

components to ensure compliance with policies and procedures. USCIS 

will continue on-site training as NFTS continues to be deployed across 

DHS. 

As arranged with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its 

issue date. At that time, we will send copies of this report to the Secretary 

of the Department of Homeland of Security and other interested 

congressional committees. We will also make copies available to others 

upon request. In addition, the report will be available at no charge on 

GAO’s Web site at http://www.gao.gov. 

Page 17 GAO-07-85 Immigration Benefits
If you or your staff have any questions about this report or wish to discuss 

it further, please contact me at (202) 512-8777 or by e-mail at 

JonesPL@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 III. 

Sincerely yours, 

Paul L. Jones, 

Director, Homeland Security and Justice Issues 

Page 18 GAO-07-85 Immigration Benefits
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To address all of our objectives, we interviewed United States Citizenship 

and Immigration Services (USCIS) headquarters officials, reviewed 

relevant documents, and sent e-mail questionnaires and followed up with 

phone calls to officials and staff from 13 (Chicago, Dallas, Detroit, 

Houston, Los Angeles, Miami, Newark, New York City, Philadelphia, San 

Diego, San Francisco, Seattle and Washington, D.C.) of USCIS’s 33 district 

offices. We obtained written responses to our questionnaire from another 

district office (Boston). We selected these offices because they

adjudicated most of the naturalization applications. Specifically, USCIS 

data indicate that these 14 offices adjudicated nearly two-thirds, or about 

497,000, of the approximately 715,000 naturalization applications 

adjudicated in fiscal year 2005. In addition, to examine the extent to which

USCIS records how often naturalization applications are adjudicated 

without an A-file, as well as the reasons why an A-file might be missing 

and what steps USCIS takes to compensate for any lack of an A-file during 

an adjudication process we obtained data related to 

• naturalization applications adjudicated in fiscal year 2005 contained in 

the Computer-Linked Application Information Management System 

(CLAIMS) 4 database that records information from the naturalization 

application and related information, 

 

• the results from USCIS quality assurance audits of a sample of

naturalization applications reviewed in fiscal year 2005, and 

• A-files indicated as lost and, as having been in transit and yet to be 

recorded as received in USCIS’s National File Tracking System (NFTS). 

We also reviewed policies and procedures related to processing 

naturalization applications and instructions and guidance about using, 

locating, and requesting A-files. In a prior review, we determined how 

USCIS ensures the quality and consistency of adjudicator decisions by 

reviewing USCIS reports and data on accuracy rates related to its two 

quality assurance programs, interviewing USCIS officials in the 

Performance Management Division, reviewing the findings and 

recommendations of an independent study on USCIS’s quality assurance 

programs and, discussing supervisory review practices with senior 

managers at the field offices we visited. However, we did not 

independently verify the extent and quality of supervisory review. 1

 

 1

 See GAO-06-20. 

Page 19 GAO-07-85 Immigration Benefits
Appendix I: Scope and Methodology 

We assessed the reliability of CLAIMS 4 and NFTS data by (1) reviewing 

summary data and specific data elements for obvious errors in accuracy 

and completeness, (2) reviewing related documentation, and 

(3) interviewing USCIS staff knowledgeable about the CLAIMS 4 and 

NFTS systems. For NFTS, we also observed how A-files are located,

transferred, and received. However, we did not independently evaluate 

whether technical malfunctions may be a factor in the number of files with 

improperly identified locations, although we have no reason to believe that 

technical malfunctions have occurred. We found that information and 

summaries of the NFTS, CLAIMS 4, and quality assurance data were 

sufficiently reliable for the purposes of this report. We conducted our 

review from August 2005 through August 2006 in accordance with 

generally accepted government auditing standards. 

Page 20 GAO-07-85 Immigration Benefits
Appendix II: Comments from the Department Appendix II: Comments from the Department of Homeland Security

of Homeland Security 

Page 21 GAO-07-85 Immigration Benefits
Appendix II: Comments from the Department 

of Homeland Security

Page 22 GAO-07-85 Immigration Benefits
Appendix II: Comments from the Department 

of Homeland Security

Page 23 GAO-07-85 Immigration Benefits
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 24 GAO-07-85 

Appendix III: GAO Contact and Staff 

Acknowledgments 

Paul L. Jones, (202) 512-8777 

In addition to the above, Michael Dino, Assistant Director; 

Richard Ascarate; Jenny Chanley; Frances Cook; Carlos Garcia; 

Julian King; and Brian Lipman were key contributors to this report. 

GAO Contact 

Staff 

Acknowledgments 

(440430) Immigration Benefits
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