Department of Homeland Security
 

U.S. Citizenship and Immigration Services Systematic 


Alien Verification for Entitlements Program Issues 


OIG-12-125 September 2012
 
 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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

September 19, 2012 

MEMORANDUM FOR: Tammy Meckley 

Deputy Associate Director, Enterprise Services Directorate 

United States Citizenship and Immigration Services 

FROM: Frank Deffer 

Assistant Inspector General 

Information Technology Audits 

SUBJECT: U.S. Citizenship and Immigration Services Systematic Alien 

Verification for Entitlements Program Issues 

Attached for your information is our final letter report, U.S. Citizenship and Immigration 

Services Systematic Alien Verification for Entitlements Program Issues. We incorporated 

the formal comments from the United States Citizenship and Immigration Services in the 

final report. 

The report contains two recommendations aimed at improving the Systematic Alien 

Verification for Entitlements Program. Your office concurred with Recommendation 1 

and did not concur with Recommendation 2. As prescribed by the Department of 

Homeland Security Directive 077-1, Follow-Up and Resolutions for the Office of 

Inspector General Report Recommendations, within 90 days of the date of this 

memorandum, please provide our office with a written response that includes your 

1) agreement or disagreement, 2) corrective action plan, and 3) target completion date 

for each recommendation. Also, please include responsible parties and any other 

supporting documentation necessary to inform us about the current status of the 

recommendation. Until your response is received and evaluated, the recommendations 

will be considered open and unresolved. 

Consistent with our responsibility under the Inspector General Act, we are providing 

copies of our report to appropriate congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will post 

the report on our website for public dissemination. 

Major contributors to this report are Sharon Huiswoud, Director; Kevin Burke, 

Supervisory Auditor; Matthew Worner, Senior Auditor; Charles Twitty, Senior Auditor; 

and Pamela Chambliss-Williams, Senior Program Analyst. 
 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Please call me with any questions, or your staff may contact Sharon Huiswoud, Director, 

at (202) 254-5451. 

Attachment

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Background 

In response to U.S. House of Representatives Committee on Appropriations 

Report 112-91, Department of Homeland Security Appropriations Bill, 2012, we 

conducted an audit of the business processes of the Systematic Alien Verification for 

Entitlements (SAVE) program. The objectives of our review were to determine whether 

USCIS had established processes to (1) monitor user compliance with the rules of the 

SAVE program, (2) enforce actions when users were noncompliant with SAVE program 

rules, and (3) enable benefit applicants to request record corrections.1 Additionally, our 

objectives included a review to determine the average length of time USCIS took to 

adjudicate requests by applicants who received a possibly erroneous SAVE

determination.2

SAVE is an electronic system to provide immigration status to Federal, State, and local 

agencies that award various public benefits such as drivers’ licenses, public housing 

subsidies, and Federal education grants. However, SAVE does not make determinations 

on any applicant’s eligibility for a specific benefit or license. In April 2012, 

approximately 1,000 agencies were registered to use SAVE. 

The legacy Immigration and Naturalization Service created the SAVE program in 1987 in 

response to the Immigration Reform and Control Act of 1986, P.L. 99-603. This law 

required the creation and implementation of a verification system that confirms the 

immigration status of individuals applying for certain federally funded benefits. With

the creation of the Department of Homeland Security (DHS) in 2003, jurisdiction for the 

SAVE program is now under the USCIS Verification Division. 

Additional Federal legislation expanded the need for benefit-granting agencies to verify 

immigration status. For example, 

• The Illegal Immigration Reform and Immigrant Responsibility Act of 1996, 

P.L. 104-208, requires USCIS to respond to inquiries by Federal, State, and local 

benefit-granting agencies seeking to verify immigration status or naturalized or 

derived citizenship of an individual for any lawful purpose. 

1

 According to USCIS officials, SAVE and the SAVE Monitoring and Compliance Section do not engage in 

enforcement actions; rather they identify non-compliance and work with agencies to gain compliance. 

2

 According to USCIS officials, the SAVE program does not “adjudicate” SAVE cases. At USCIS, only 

members of the Officer Corps have the authority to adjudicate cases. Record corrections do not

inherently involve an adjudication. 

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

• The Personal Responsibility and Work Opportunity Reconciliation Act of 1996,

P.L. 104-193, restricts immigration status eligibility criteria for certain programs 

funded by Federal, State, and local government agencies. 

•	 The REAL ID Act of 2005, P.L. 109-13, extends the mandate to verify immigration 

status to include all departments of motor vehicles issuing drivers’ licenses. 

SAVE Verification Process 

Following the completion of a registration process, staff from an authorized SAVE user 

agency are able to query a benefit applicant’s immigration status against DHS databases 

containing more than 100 million records. USCIS processed approximately 12 million 

SAVE queries in fiscal year 2011. According to USCIS, there was an average of 935,793 

SAVE initial verifications per month during June to August 2010. This initial verification 

step usually requires only 3 to 5 seconds. Further, this initial query about a benefit 

applicant’s immigration status is document centric; that is, the SAVE system searches 

specific databases based on the immigration document that was submitted by the SAVE 

user agency. Throughout fiscal year 2010, more than 94 percent of cases that provided 

immigration status did so without requiring additional verification. SAVE user agencies 

are charged a minimum of $25 to access SAVE each month, plus $0.50 for each initial 

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

submit SAVE queries.

If the initial verification query cannot be resolved, SAVE user agencies are to perform 

additional verification steps. The additional verification is biographic centric. That is, 

SAVE searches the various databases based on the benefit applicant’s personal 

information, such as immigration numeric identifier or name and date of birth. This 

additional verification may be performed automatically, or following submission of 

additional data by the SAVE user agency. There is a $0.50 fee for each additional 

verification query.

If the benefit applicant’s immigration status cannot be confirmed following additional 

verification, the SAVE program instructs the user agency to provide additional 

documentation for third step verification. There is no fee for third step verification. 

However, if the documentation is submitted without performing the first and additional 

query steps, there is a $2 fee. The different SAVE program fees resulted in $6 million in 

fiscal year 2010 and provide 25 percent of the funding of the SAVE program. 

www.oig.dhs.gov 4	 OIG-12-125 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Results of Audit 

USCIS’ Process To Monitor User Compliance With the Rules of the SAVE Program

USCIS has established a process to monitor compliance with the rules of the SAVE 

program. Per the SAVE program Memorandum of Agreement, the program rules 

require—

•	 The user agency staff to take the SAVE training before using the system,

•	 The user agency to pay any SAVE-related charges within 30 days or be assessed 

late fees, 

•	 Performance of any additional verification procedures documented in the SAVE 

program guide and the web-based tutorial, and 

•	 The user agency to allow USCIS’ SAVE Monitoring and Compliance Section access 

to all records related to the use, or improper use, of SAVE. 

USCIS established the SAVE Monitoring and Compliance Section to monitor agency 

compliance with the above program rules. Additionally, USCIS established the 

Integrated Monitoring Task Force to help identify specific behaviors of the user 

agencies, such as failure to deactivate SAVE user accounts. The Monitoring and 

Compliance Section, in conjunction with the Verification Division SAVE Program, has 

written technical manuals and standard operating procedures for monitoring agency 

compliance with SAVE program rules. 

The USCIS Verification Division prepares and provides SAVE-related training to user 

agencies. For example, the SAVE tutorial provides information on the cost of queries, 

documentation needed from the applicant, how to complete various screens, and the 

roles and responsibilities of SAVE users. 

Enforcement Actions When Agencies Are Noncompliant With SAVE Program Rules

USCIS’ Verification Division has established procedures to take when user agencies are 

non-compliant with SAVE program rules. For example, when SAVE user accounts have 

been inactive for a year, USCIS notifies the user agency of the inactive accounts. 

According to USCIS staff, 158 SAVE user agencies have been contacted about inactive

user accounts. Additionally, if a SAVE user agency has not paid its bills on time, USCIS 

www.oig.dhs.gov 5	 OIG-12-125 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

charges late fees and penalties. As of May 2012, 71 SAVE user agencies were 60 days 

overdue, for a total of $622,497 in fees, interest, and penalties. 

Further, USCIS’ policy requires that if user agencies do not adhere to SAVE program 

rules, SAVE access may be suspended or terminated. However, according to USCIS staff, 

restricting or terminating access to the SAVE program would have a negative effect on 

benefit applicants. Specifically, if user agencies do not have access to SAVE, they may 

not be able to verify a benefit applicant’s immigration status. If user agencies cannot 

verify immigration status, they may not be able to award the benefit.

USCIS Process To Ensure That Benefit Applicants Can Correct Their Records

USCIS has established a process to help benefit applicants correct their records that 

were used in the SAVE verification process. Additionally, USCIS has distributed a fact

sheet to user agencies that specifies how SAVE benefit applicants can contact USCIS 

when they want to correct their records. Further, USCIS plans to update its public web 

pages to assist SAVE benefit applicants further. However, USCIS can do more to assist 

applicants in correcting their records. Specifically, the Verification Division should 

request that database owners report whether the applicant’s records were corrected.

For example, if a Verification Division review of a benefit applicant’s documentation 

determines that a USCIS database contains erroneous information about that applicant, 

the Verification Division notifies the USCIS Records Division about the error and 

provides a positive verification. However, according to USCIS officials, the Verification 

Division is not required to follow up with the Records Division to determine whether the 

record was corrected.3

 Also, the Verification Division is not required to inform benefit 

applicants that there was an error in their USCIS records. 

Additionally, SAVE accesses databases that are owned by U.S. Customs and Border 

Protection (CBP). For example, a CBP database accessed by SAVE contains the data 

from the Arrival-Departure Record, CBP Form I-94. When an error is identified in a CBP 

database, USCIS instructs the SAVE user agency to notify the benefit applicant to contact 

CBP. However, according to USCIS officials, the Verification Division is not required to 

follow up with CBP to determine whether the record was corrected. 

3

 According to USCIS officials, the Verification Division’s authority to provide immigration status is 

between USCIS and the SAVE user agency, not the benefit applicant; the Verification Division does not 

have the authority to require database owners to correct records.

www.oig.dhs.gov 6 OIG-12-125 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Average Length of Time To Adjudicate Applicant Requests To Correct Erroneous 

Information

USCIS staff do not collect information that would enable them to determine the average 

length of time required to adjudicate applicant requests to correct erroneous 

information. For example, USCIS does not track the number of SAVE-related 

appointments made through its InfoPass scheduling website. USCIS cannot calculate 

the average time needed to resolve SAVE-related queries without knowing how many 

SAVE benefit applicants have contacted USCIS. 4 However, we obtained information on 

95 SAVE benefit applicant queries that were referred to USCIS. USCIS resolved these 

queries in an average of 8.9 calendar days. 

Officials from the Verification Division said that they plan to track SAVE benefit applicant 

requests and referrals with a customer relationship management system capability that 

will be implemented by August 2013.

Recommendations

We recommend that the Deputy Associate Director, Enterprise Services Directorate:

Recommendation #1: 

Implement a process to compile and track SAVE benefit applicant requests and referrals. 

Recommendation #2: 

Implement a process for SAVE database owners to report to the Verification Division 

whether changes to SAVE benefit applicant records were made. 

Management Comments and OIG Analysis

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

have included a copy of the comments in their entirety at appendix B. The Director of 

USCIS concurred with the first recommendation and did not concur with the second 

recommendation. We also obtained informal technical comments from SAVE program 

officials that we addressed in the report where appropriate. 

4

 According to USCIS officials, a “query,” in the context of the SAVE program, is a verification request from 

a User Agency and is not used by the SAVE program to refer to inquiries from benefit applicants. 

www.oig.dhs.gov 7 OIG-12-125 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Recommendation #1 

USCIS concurs with this recommendation. Additionally, USCIS provided further 

information on planned improvements. These improvements include the 

implementation of the SAVE Case Check initiative and a Customer Relationship 

Management (CRM) system. The SAVE CASE Check initiative will enable SAVE benefit 

applicants to check the status of their case online. Additionally, the initial phase of a 

CRM system will track and monitor SAVE inquiries. 

OIG Analysis 

The actions described satisfy the intent of this recommendation. This recommendation 

is considered resolved, but will remain open until USCIS provides documentation to 

support that the planned corrective actions are completed. 

Recommendation #2 

USCIS did not concur with this recommendation. According to USCIS, SAVE is not the 

owner or custodian of the immigration records it uses to determine immigration status, 

some of which are outside of USCIS control, and it does not have the legal authority to 

require database owners to report corrections to applicants’ records to the SAVE 

program. However, USCIS also listed steps they could take to identify whether record 

changes have been made. For example, Quality Assurance audits conducted by the 

USCIS Verification Division could inform USCIS leadership of common data errors and

the need for policy and process changes. Additionally, the SAVE program may be able to 

leverage the CRM system to track benefit applicant queries as described in the response 

to Recommendation 1. 

OIG Analysis 

USCIS is the owner of some of the databases accessed by SAVE. USCIS should be able to 

develop internal procedures to report to the SAVE program whether USCIS records have 

been changed. Additionally, USCIS enters into agreements with other components for 

SAVE access to their databases. USCIS could use these agreements as a basis for 

establishing change reporting processes with other DHS components. This 

recommendation is considered unresolved and will remain open until USCIS provides 

documentation to support the implementation of corrective actions. 

www.oig.dhs.gov 8 OIG-12-125 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

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

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

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

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

efficiency, and effectiveness within the Department. 

We performed an audit to determine whether USCIS established programs and 

processes to: (1) monitor user compliance with the rules of the SAVE program, 

(2) enforce actions when users were noncompliant with SAVE program rules, and 

(3) enable benefit applicants to request record corrections. Additionally, our objectives 

included a review to determine the average length of time USCIS took to adjudicate 

requests by applicants who received a possibly erroneous SAVE determination. Our 

audit focused on the requirements outlined in U.S. House of Representatives Committee 

on Appropriations Report 112-91, Department of Homeland Security Appropriations Bill, 

2012. We reviewed DHS and USCIS guidance and procedures. We also interviewed 

various DHS personnel regarding SAVE. Additionally, we interviewed staff from several 

SAVE user agencies concerning their use of SAVE. 

We conducted this performance audit between April and July 2012 pursuant to the 

Inspector General Act of 1978, as amended, and according to generally accepted 

government auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our

findings and conclusions based upon our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based upon our 

audit objectives. 

www.oig.dhs.gov 9 OIG-12-125 
 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

Management Comments to the Draft Letter Report 

U.S. n t.lll1rtmfllt ur II/lmd:lIld Sf( uril~ 

U.S. Citizenship IIncl lmmigmliGn Services 

Office ()/Ihe Direcfr}r MS-2000 

WQsh"glon, DC 20529-2000 

u. S. Ci tizenshi p 

and Immigration 

Services 

SEP 13 1011 

Memorandum 

TO: Frank DetTer 

Assistant Inspector Gen al ' Infonnatj:7 i Tee ogy Audits 

FROM: Alejandro N. Mayorkas 

Director 

SUBJECT: Office oflnspeelor Genera l (010) Drafl Reporl: US. Citiztmship and Immigrati()n 

Service's (USCIS) Systematic Alien Verification/or Entitlements (SA VE) Program 

Issues (job code OIG~12-J34) ~ FOUO 

USCIS appreciates the opportunity to respo nd and generally agrees with the O IG summary o f the 

issues ident ified in the report. USCIS OJncurs that the SAVE prol:,Tfam has established processes 

to monitor user compliance with the policies of the SAVE program and follows up when users 

are noncompliant with SAVE program requirements. USCIS also agrees that the SAVE program 

enables benefit applicants to request record corrections, but is concerned about USCIS's scope of 

authority to cany out some of the recommendatio ns because USCIS io;; not the custodian of all n f 

the databases accessed by SAVE. 

USCIS would like to highlight our demonstrated commitment to transparency for SAVE benefit 

applicants and our efforts to ensure that SAVE user agencies comply w ith program requirements. 

USCIS IS launching several majo r initiatives to provide better access to information to support 

benefit seeking applicants, such as the SAVE Case Check initiative, which a llows applicants 

seekillg benefils to obtain inf(mnatwm 1m lhl! stl:ltus ortheir SAVE cases. The SAVE Case 

Chcck initiative will be available on September 15, 2012, with a phased roll-out to customers 

planned for a several month period during the 1st Quarter of Fiscal Year 2013. SAVE Case 

Check is a free service to benefit applicants and will save the applicants time by reducing repeat 

visits to a benefit-granting agency. USCIS aL'io recently launched the first phasl! 0 r a Customer 

Relationship Management (CRM) s)'stem that prov ides a mechanism for tracking and managing 

all incoming SA VE~re lated calls and inquiries. USCIS recently developed a pilot between 

USCI S Field Offices and SAVE program staff to faci lita te benefit applicant requests that may 

require a visit to a USCIS field office. And in FY 20 J 2, the SA VE program released the SA VE 

Self-Assessment Guide to educate user agencies and help them comply wit h SAVE program 

requirements. 

\\"W"" t1 sri~ .g \. 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

010 Draft Report: USCIS', SAVE Program Issue, (job code 010-12-134) - FOUO 

Page 2 

Although our responses to the recommendations are outlined below in detail, USCIS would also 

like to clarify that the SAVE prognun does not "adjudicate" SAVE cases. At USCIS, only 

members of the Officer Corps have the authority to adjudicate cases. The SAVE program is only 

responsible for determining whether the information submitted by the SAVE user agency on 

behalf of the benefit applicant is consistent with the data found in federal databases. Further, the 

SAVE program does not engage in enforcement activities but identifies non-compliance and 

assists agencies as necessary. 

And finally, another area in the OIG report that users would like to address is the finding that 

the SAVE program is not required to inform benefit applicants that there was an error in their 

record. This is because our current authority to confum immigration status is between USCIS 

and the SAVE user agency, not between USCIS and the benefit applicant. However, under 

current practice we do advocate on behalf ofthe benefit applicant ifthere is a record change or 

update that we can do in coordination with other parts of USC IS and, if contacted by a benefit 

applicant, we will refer the benefit applicant to the appropriate USCIS or Department of 

Homeland Security (DHS) component. 

DBS OIG recommends tbat tbe Deputy Associate Director, Enterprise Services 

Directorate: 

Recommendation 1: Develop a process to compUe and track SAVE benefit applicant 

requests and referrals. 

USCIS response: USCIS concurs with this recommendation. Although the process is not yet 

formalized, the SAVE program does take inquiries from benefit applicants through its customer 

support hotIine publicized on the SAVE website. Benefit applicants can ask questions relating to 

the status of their SAVE verification case, or ask general questions about the program 

Questions regarding the status ofthe benefit that the applicant applied for are referred back to the 

federa~ state or local agency where the individual applied. The above-mentioned SAVE Case 

Check initiative will also help to reduce telephone inquiries ofthis nature, as benefit applicants 

will be able to check the status of their case online. 

USCIS also just launched the initial phase ofa CRM system that will track and monitor SAVE 

inquiries and the SAVE program will develop a plan for a dedicated benefit applicant hotIine, to 

be used in conjunction with the CRM tracking and monitoring effort. A dedicated benefit 

applicant hotJine is necessary to allow the SAVE program to leverage CRM to better track 

benefit applicant inquiries and redirect calls to other parts of USC IS ifrecord follow-up is 

necessary. However, the implementation of this plan is contingent on the SAVE program 

obtaining additional resources to develop the capability and implement the boUrne necessary to 

leverage CRM. 

Recommendation 2: Develop a process for SAVE database owners to report to the 

Verification Division whether cbanges to SAVE benefit applicant records were made. 

USCIS response: USCIS non-concurs with this recommendation. SAVE is not the owner or 

custodian of the immigration records it uses to determine immigration status, some of which are 

www.oig.dhs.gov 11 OIG-12-125 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

OIG Draft Report: USCIS's SAVE Program Issues (job code 0IG-12-13I/) - FOUO 

Page 3 

outside of USC IS control, and does not have the legal authority to require database owners to 

report back to the SAVE program. Each database has policies and procedures in place that allow 

staff to determine how to address data errors or updates and often the SAVE program andlor 

USCIS will not have any oversight. Whether or not the SAVE program is aware of when a 

record is updated does not address the root cause of data accuracy. Other efforts, such as looking 

at the results of Quality Assurance (QA) audits conducted by the USCIS Verification Division, 

could infollll USCIS leadership of common data errors and the need for policy and process 

changes. However, the SAVE program will develop a process to track USCIS record correction 

responses or updates as part of the plan to leverage the CRM system to track benefit applicant 

queries as described in the response to Recommendation I. USCIS will detennine how best to 

track these actions and consolidate any contacts made with the SAVE program by the benefit 

applicants in question. 

www.oig.dhs.gov 12 OIG-12-125 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix C 

Report Distribution 

Department of Homeland Security

Secretary

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs

Assistant Secretary for Office of Legislative Affairs 

Director of USCIS 

USCIS Audit Liaison 

Acting Chief Privacy Officer 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 13 OIG-12-125 
 

ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this document, please call us at (202) 254-4100, fax your 

request to (202) 254-4305, or e-mail your request to our Office of Inspector General 

(OIG) Office of Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

For additional information, visit our website at: www.oig.dhs.gov, or follow us on Twitter 

at: @dhsoig. 

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other kinds of criminal or noncriminal misconduct relative to Department of Homeland 

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Should you be unable to access our website, you may submit your complaint in writing 

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