Department of Homeland Security 

Office of Inspector General 

Management Oversight of 


Immigration Benefit Application 


Intake Processes 


OIG-09-37 March 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 25028 

March 5, 2009 

Preface 

The Department of Homeland Security Office of Inspector General was established by 

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

General Act of 1978. This is one of a series of audit, inspection, and special reports 

prepared as part of our oversight responsibilities to promote economy, efficiency, and 

effectiveness within the department. 

This report addresses the effectiveness of United States Citizenship and Immigration 

Services’ management oversight in improving timeliness of the immigration benefits 

application intake process. It is based on interviews with employees and officials of 

relevant agencies and institutions, direct observations, and a review of applicable 

documents. 

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

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

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

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

Richard L. Skinner 


Inspector General 

Table of Contents/Abbreviations 


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

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

Results of Audit ...................................................................................................................3


 Performance Management ..............................................................................................3 


Recommendation ............................................................................................................5


 Management Comments and OIG Analysis ...................................................................5 


 Pilot Programs and Knowledge Management.................................................................6 


Recommendations.........................................................................................................10


 Management Comments and OIG Analysis .................................................................10 


 USCIS and Department of State Coordination .............................................................11 


Recommendation ..........................................................................................................13


 Management Comments and OIG Analysis .................................................................13 


Appendices

 Appendix A: Purpose, Scope, and Methodology .........................................................15 


Appendix B: Intake Process..........................................................................................17 


Appendix C: Management Comments to the Draft Report ..........................................19 


Appendix D: Major Contributors to this Report ..........................................................22 


Appendix E: Report Distribution..................................................................................23 


Abbreviations 

DHS Department of Homeland Security 


GAO Government Accountability Office 


OIG Office of Inspector General 


USCIS United States Citizenship and Immigration Services 


Management Oversight of Immigration Benefit Application Intake Processes 
 

OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

Since its inception in 2003, U.S. Citizenship and Immigration Services 

has faced challenges in the timely processing of immigration benefit 

applications, including a backlog of nearly 3.7 million applications 

transferred from the Immigration and Naturalization Service. We 

reviewed U.S. Citizenship and Immigration Services’ efforts to 

improve timeliness of the application intake process. For a detailed 

description of the intake process, please see Appendix B. 

Although U.S. Citizenship and Immigration Services has taken steps to 

improve intake process timeliness, such as implementing process 

changes and pilot programs, it has not established adequate measures 

to assess performance of its application intake process. Further, the 

agency would benefit from a knowledge management system to collect 

and share information on successful, locally based pilot programs and 

field office improvement initiatives. Currently, headquarters 

management may not be aware of and does not gauge the success of 

field office pilot programs and initiatives, thereby missing an 

opportunity to leverage local success nationwide. The need for 

management oversight of improvement efforts coupled with the 

absence of a knowledge management system risk inefficient use of 

resources, duplication of effort, and lost institutional knowledge. They 

also undermine efforts to improve intake processing time and 

eliminate the backlog of immigration benefit applications. 

U.S. Citizenship and Immigration Services recognizes that Department 

of State actions could hinder its timely intake of immigration benefit 

applications and has taken steps to improve communication with the 

Department of State. However, without a formal agreement on 

coordination of the roles and responsibilities of the two agencies, there 

is no assurance that the improved communication will continue. 

We are recommending that U.S. Citizenship and Immigration Services 

develop baseline performance measurements, enhance oversight of 

pilot programs, implement a knowledge management system, and 

formalize an agreement with the Department of State to improve 

immigration benefit application processing. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 1 
Background 

Prior to March 2003, the Immigration and Naturalization Service was 

responsible for administering programs that provide qualified 

applicants with immigration benefits. These benefits include 

citizenship, lawful permanent residency, family- and employmentrelated immigration, employment authorization, intercountry 

adoptions, asylum and refugee status, replacement immigration 

documents, and foreign student authorization. 

The annual number of immigration applications received increased 

from 4,138,000 in 1994 to 6,059,000 by 2000. The Immigration and 

Naturalization Service was unable to handle the increased workload 

due to technology and staffing issues, which resulted in a backlog of 

more than 2 million immigration benefit applications by 2001.1 In 

2002, the Immigration and Naturalization Service launched a Backlog 

Elimination Plan in an effort to better manage the processing 

workload. 

U.S. Citizenship and Immigration Services (USCIS) inherited the 

backlog when the benefit processing functions of the Immigration and 

Naturalization Service were transferred to the Department of 

Homeland Security (DHS) in 2003. In December 2003, USCIS faced 

a backlog of approximately 3.7 million applications. USCIS reviewed 

and updated the Backlog Elimination Plan in an effort to reduce 

processing times to a 6-month cycle time for all applications. USCIS 

also stated that it would increase its focus on information technology 

to ensure that backlog reduction is sustained, customer service is 

improved, new fee-for-service business models are enabled, and an 

improved technology environment is deployed. 

Our September 2005 review of USCIS’ information technology 

environment showed that USCIS had not adopted a focused approach 

to updating its legacy systems and manual workflow practices.2 

Rather, information technology planning and implementation were 

conducted in a reactive and decentralized manner across the 

organization. Additionally, USCIS relied on personnel rather than 

technology to meet its backlog reduction goals. Our report 

recommended that USCIS develop a modernization strategy, 

including short- and long-term goals, funding plans, and performance 

measures to guide USCIS entities in better accomplishing their 

citizenship and immigration services missions. 

1

 Immigration Benefits: Several Factors Impede Timeliness of Application Processing (GAO-01-488, May 


2001). 


2 USCIS Faces Challenges in Modernizing Information Technology (OIG-05-41, September 2005). 


Management Oversight of Immigration Benefit Application Intake Processes 

Page 2 
 

Subsequently, USCIS initiated an agencywide transformation program 

to improve both business processes and the supporting information 

technology systems. Our November 2006 followup report on 

transformation progress stated that USCIS was continuing its pattern 

of planning and beginning improvement initiatives, but not fully 

implementing the plans to deliver promised results.3 Our report 

identified a need for better performance measures for pilot programs 

and initiatives. A July 2007 Government Accountability Office report 

on the transformation program similarly discussed the need for USCIS 

to identify specific performance measures and targets for its pilot 

4 programs.

Results of Audit 

Although USCIS has taken steps to improve the timeliness of the 

application intake process, additional management oversight is needed. 

Specifically, USCIS has not developed adequate baseline performance 

measures to gauge timeliness of application intake processes or the 

effectiveness of pilot projects and other initiatives, many of which are 

implemented locally by USCIS field offices. USCIS also has not 

provided adequate oversight of the pilot programs and local initiatives, 

or developed a method, such as a knowledge management approach, to 

collect and share information from the various improvement initiatives 

agencywide. These shortfalls in managing improvement initiatives 

risk wasted resources, duplication of effort, and lost institutional 

knowledge through turnover and attrition. They also undermine 

USCIS’ efforts to eliminate the backlog of immigration benefit 

applications. 

Further, DHS lacks a formal agreement with the Department of State 

on their respective roles and responsibilities and how they will 

communicate and cooperate to help ensure timely processing of 

immigration benefits. 

Performance Management 

Federal guidelines in the Office of Management and Budget’s policies 

and in the Government Performance and Results Act of 19935

 address 

the importance of being able to measure and assess program outputs. 

According to the Results Act, agencies are required to express goals in 

an objective, quantifiable, and measurable form and to establish 

3 USCIS’ Progress in Modernizing Information Technology (OIG-07-11, November 2006). 
 4 USCIS Transformation: Improvements to Performance, Human Capital, and Information Technology
 

Management Needed as Modernization Proceeds (GAO-07-1013R, July 2007). 
 5 P.L. 103-62, 107 Stat. 285 (Aug. 3, 1993) (codified in various sections of titles 5 and 31 U.S.C.), Section 


4(b)(a). 


Management Oversight of Immigration Benefit Application Intake Processes 

Page 3 
performance indicators for measuring or assessing the relevant 

outputs, service levels, and outcomes of each program activity. 

USCIS has not established adequate measures to assess the 

performance of its application intake process. USCIS has established 

performance measures for some intake activities, such as lockbox and 

mailroom operations performed by contractors, but these measures are 

not sufficient to gauge the success of the overall process or 

improvement initiatives. To gauge performance, measures should 

include the length of time required at each step of the intake process, 

beginning with the receipt of benefit applications at USCIS. The 

process is wide-ranging, involving mailroom operations; file assembly; 

data collection, capture, and scanning; document preparation; fee 

collection and processing; file room operations; and Interagency 

Border Inspection System name security checks.6 Appendix B 

provides a detailed description of USCIS’ application intake process. 

In the absence of adequate performance measures, USCIS senior 

management focuses on average cycle times as a means of managing 

workloads. To determine average cycle times, senior management 

first calculates the number of active pending applications, i.e., the total 

number of applications awaiting adjudication minus those applications 

that USCIS has determined are outside its control, such as applications 

awaiting Federal Bureau of Investigation name checks. From the 

number of active pending applications, USCIS subtracts the number of 

applications received in each preceding month until it reaches near 

zero. The number of months it takes to get to zero without generating 

a negative result is the approximate number of months USCIS 

determines it takes to adjudicate an application. In Table 1, August 

and July receipts are subtracted from total active pending applications 

before reaching a negative number. Thus, it is determined that the 

cycle time for this application is at least 2 months. 

Table 1: Example of Cycle Time Calculation 

Active 

Pending 

Applications 

August 2007 

Less 

August 

Receipts Net 

Less July 

Receipts Net 

Less 

June 

Receipts 

Negative 

Amount 

Number of 

Months 

Before 

Negative 

Result 

Remainder 

(921/5399) 

Cycle 

Time (in 

Months) 

11,402 5,851 5,551 4,630 921 5,399 -4,478 2.00 0.17 2.17 

6

 The Interagency Border Inspection System name check is a multi-agency effort, combining information from 

multiple agencies and databases to compile data relating to national security risks, public safety issues and other 

law enforcement concerns. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 4 
USCIS relies heavily on such cycle time calculations to determine 

needed changes to workload distribution and staff allocation. The 

agency recognizes the limitations of its current information technology 

systems, which do not provide accurate processing statistics, such as 

aging reports from which average wait times or processing times can 

be calculated based on the actual processing age of each case. Making 

workload adjustments based on average cycle time may temporarily 

alter the productivity of a specific product line. However, this method 

does not help identify bottlenecks in the process or areas where 

efficiencies may be gained agencywide. 

USCIS would benefit from developing baseline performance measures 

to evaluate the efficiency and effectiveness of its ongoing operations 

before investing resources, time, and energy in trying new methods. 

Establishing a baseline would help identify areas for improvements. 

Establishing a baseline would also provide a good benchmark against 

which to measure improvement progress. Without a baseline, USCIS 

risks wasting resources by implementing pilot programs and initiatives 

that cannot be evaluated for effectiveness in reducing processing 

times, thus undermining efforts to eliminate the backlog of 

immigration benefit applications. 

Recommendation 

We recommend that the Acting Director of USCIS: 

Recommendation #1: Develop sufficient baseline performance 

metrics for application intake processes and use them to measure 

processing timeliness and identify areas for improvement. 

Management Comments and OIG Analysis 

The Acting Deputy Director provided written comments on a draft of 

this report. A copy of USCIS’ response, in its entirety, is included as 

Appendix C. 

USCIS Response: USCIS concurred with recommendation 1 

regarding the need for baseline performance metrics. In its response, 

USCIS said that over the next 18 months the transition of its intake 

process from USCIS operated Service Centers to Department of 

Treasury sponsored lockbox facilities, i.e., a bank, will be completed. 

The Department of Treasury, in partnership with USCIS, has 

established performance expectations for the lockbox provider, which 

include a 24 hour processing time for properly completed applications 

with the appropriate fee attached. In addition, USCIS discussed 

already having specific time models for each process step in normal 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 5 
naturalization and field adjustment cases, as well as plans to expand 

them to other products. 

OIG Analysis: We consider USCIS’ proposed actions responsive to 

the recommendation. The recommendation will remain resolved, but 

open pending receipt of documentation that (1) describes the 

performance expectations that will be in place once USCIS’ intake 

process transition is complete, (2) discusses in detail the time models 

to be expanded to other product lines, and (3) identifies which 

additional product lines will use the time models. 

 Pilot Programs and Knowledge Management 

USCIS has not effectively managed its pilot programs and initiatives 

for improving application intake timeliness and efficiency. Because 

the agency has allowed field offices to implement independently new 

processing methods in an ad hoc manner to help increase productivity, 

the pilot initiatives have not always been well planned, documented, or 

evaluated. Without baseline performance measures, there is no way to 

evaluate the programs’ effectiveness. Better oversight would help 

maximize the benefits from the time and resources expended to 

improve immigration benefit application intake. 

Pilot Programs 

The Government Performance and Results Act of 1993 and Office of 

Management and Budget Circular A-123, discuss the importance of 

properly managing and overseeing pilot programs to ensure their 

success. Specifically, the Results Act requires agencies to evaluate 

pilots and experimental programs that are designed to improve 

mission delivery, including efficiency, national security, and 

customer service, before implementing such programs on a large 

scale. Also, according to Revised Office of Management and Budget 

Circular A-123, Management’s Responsibility for Internal Controls, 

information should be communicated to relevant personnel at all 

levels within an organization, and such information should be 

relevant, reliable, and timely. 

However, USCIS has not effectively managed its pilot improvement 

initiatives as federal guidelines require. Typically, USCIS’ Office of 

Domestic Operations has taken a decentralized approach and relied on 

the knowledge and subject matter expertise of its field managers to 

implement pilot programs or process changes they believe would work 

well for their areas without central oversight. According to 

headquarters managers, they do not take an active role in learning what 

initiatives their field offices are implementing because they do not 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 6 
want to stifle innovation. Domestic Operations officials also have said 

that the term “pilot” is used too freely within USCIS, and that they do 

not need to oversee all of the individual projects implemented by field 

offices because they do not consider them “official pilots.” 

We identified at least three pilots and several other process changes 

implemented by USCIS field offices to improve timeliness and 

efficiency of the immigration benefit application intake process. 

Without central oversight, the pilots were not always properly planned, 

documented, or evaluated. Further, without baseline performance 

measurements, there was no objective means of assessing whether 

these initiatives improved efficiency and timeliness or whether they 

could or should be replicated to improve the immigration benefit 

application intake processes agencywide. For example: 

� 90-Day program - The National Benefits Center began this pilot in 

2005 to determine whether USCIS could provide applicants with 

final decisions on their “I-485” adjustment-of-status cases within 

90 days of receipt, thus eliminating the need for interim benefits, 

such as employment and travel authorization. To meet the 90-day 

timeframe, the National Benefits Center identified the applications 

for the test offices, attempted to complete the intake processes for 

these applications by day 50, and then forwarded the adjudicationready files to the field offices, giving them approximately 40 days 

to complete the adjudications. The National Benefits Center 

tracked the average amount of time each office took to process its 

I-485 applications under the pilot scenario. 

However, Domestic Operations officials did not monitor the test 

offices to guide them in meeting pilot objectives. As of October 

2007, more than 80% of the test offices had not met the 90-day 

cycle time. Without evaluating these results, USCIS deployed the 

pilot to its field offices, with little assurance that it could achieve 

the intended results agencywide. 

�	 I-485 Plus pilot - The Texas Service Center began this pilot to 

determine whether “bundling,” or keeping forms concurrently filed 

by an individual or members of the same family together during 

the data entry phase, would reduce total cycle times. The bundled 

forms included applications for employment-based adjustment of 

status, employment authorization, and travel documents. The field 

office’s plan for implementing this pilot did not include 

benchmarks or goals to evaluate the pilot’s success. 

� Interagency Border Inspection System pilot - The Vermont Service 

Center began this pilot in April 2005 to determine whether 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 7 
 

efficiencies could be gained by using contractors rather than 

adjudicators to perform steps within the Interagency Border 

Inspection System process. Service Center officials maintained 

some documentation on monitoring and the performance of this 

pilot, but suspended the pilot after determining that they did not 

have the baseline statistics with which to compare contractor 

efforts to government quality or efficiency levels. Vermont 

officials informally considered the Interagency Border Inspection 

System pilot a success, but USCIS decided not to implement it as 

part of its day-to-day processes owing to policy and funding issues. 

In addition to the pilot programs, field offices altered standard 

processes in attempts to gain efficiencies in their local work 

environments. However, these independent efforts generally were not 

shared and therefore were not known agencywide. Any benefits and 

efficiencies resulting from these process changes have not been 

quantified. For example: 

�	 

�	 

The Texas Service Center contacts applicants by phone during 

the intake process to obtain missing information or correct 

apparent discrepancies on applications. This way, the Service 

Center can continue processing the applications instead of 

returning them to the applicants for more information. Center 

officials said that this process has helped save time and reduce 

intake delays; however they have not quantified the efficiencies 

achieved. 

California Service Center managers determined that including 

adjudicators in the Interagency Border Inspection System Unit 

to review and adjudicate cases after Interagency Border 

Inspection System issues have been resolved is more efficient 

than returning the cases to the original adjudicators, as is done 

at other centers. The Interagency Border Inspection System 

process involves reviewing entire application packages page by 

page to identify names and aliases for applicants, petitioners, 

and beneficiaries. The names are queried against criminal 

databases, such as the National Crime Information Center, to 

identify any criminal history. Adjudication can begin only 

after all system hits are researched and resolved. 

Better oversight could ensure the planning, documentation, and 

evaluation of the various pilots and initiatives to promote their 

effectiveness. It would help maximize the benefits, both efficiencies 

and cost savings, from the time and resources expended to improve 

immigration benefit intake processes. By establishing goals and 

benchmarks, USCIS also could measure progress, eliminate initiatives 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 8 

that are not working well, and identify successful initiatives that 

should be implemented agencywide. 

Knowledge Management 

USCIS would benefit from an institutional means of storing or sharing 

the knowledge and lessons learned from its pilot programs. 

Knowledge management is the process by which organizations 

generate value from their intellectual and knowledge-based assets. 

Most often, generating value from such assets involves codifying what 

employees, partners, and customers know, and sharing that 

information among employees and departments in an effort to devise 

best practices. 

Such an approach could be extended to capturing and sharing data 

from the various pilots across the agency to improve benefits 

application intake and processing. Although USCIS identified a need 

for a knowledge management approach in its strategic plans, 

management has not implemented a method to collect and share 

agency knowledge and process improvement information. In its 2005 

strategic plan, USCIS considered knowledge management to be a 

critical element of a continuous learning culture. USCIS planned to 

foster organizational and individual achievement by promoting 

continuous learning through training, career development, and 

knowledge management within USCIS. Again, in its 2008 strategic 

plan, USCIS said it would expand its central repository for laws, 

policies, and standard operating procedures to include best practices 

and other pertinent information by creating, structuring, archiving, and 

sharing valuable institutional knowledge and making it readily 

available to employees. 

To date, USCIS has not implemented a knowledge management 

approach to gather and share information or the results of pilots and 

improvement initiatives agencywide. Therefore, USCIS risks 

duplicating efforts and wasted resources. For example, the California 

Service Center used the “bundling” process of keeping family-based 

adjustment of status (I-485) applications concurrently filed during the 

data entry phase to reduce total cycle times. Texas Service Center 

officials had implemented a similar pilot, but California officials did 

not coordinate with them before starting their initiative to leverage 

lessons learned or determine success rates. Without effective 

coordination, USCIS field offices risk duplication and cannot benefit 

from either the success or knowledge gained from each other’s 

improvement initiatives. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 9 
Similarly, the Vermont office did not coordinate with the National 

Benefits Center before starting its pilot to determine whether 

efficiencies could be gained by using contractors rather than 

adjudicators to perform steps within the Interagency Border Inspection 

System process. Central coordination could have ensured that the 

Vermont Service Center did not spend unnecessary time and money 

pilot testing processes that were already in place at the National 

Benefits Center. 

Without a knowledge management approach, USCIS also risks losing 

institutional knowledge because of the high turnover and attrition the 

agency has experienced in key positions. In the Office of Domestic 

Operations alone, 24 of 27 key management positions experienced 

turnover within from 2005 to 2008. Office directors said they could 

not speak historically about the pilot efforts because they were new to 

their positions. This matter is aggravated because USCIS meetings 

between senior management and field offices are not always 

documented. 

Implementing a knowledge management approach would help USCIS 

mitigate the loss of historical knowledge from recurring turnover. It 

would help ensure that information obtained from each pilot is 

documented, stored, and available for future use. Further, with the 

implementation of a knowledge management approach, USCIS will be 

better equipped to properly train new staff on their processes and 

improvement initiatives. 

Recommendations 

We recommend that the Acting Director of USCIS: 

Recommendation #2: Improve oversight of pilot programs and new 

initiatives to ensure they are properly planned, documented, and 

evaluated. 

Recommendation #3: Implement a knowledge management 

approach by which data from experimental processes can be stored, 

evaluated, and shared adequately to increase its usefulness. 

Management Comments and OIG Analysis 

USCIS Response: USCIS concurred with recommendation 2 

regarding the need for improved oversight of pilot programs and 

initiatives. In its response, USCIS acknowledged that improvements 

need to be made in the implementation, management, and analysis of 

pilot programs, and stated that establishing baseline performance 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 10 

 

measures are an absolute necessity to determine whether or not the 

protocols being pilot tested are feasible and effective. USCIS stated it 

will begin using successfully managed pilot templates and protocols 

established by its Transformation Program Office for future 

headquarters-sponsored pilots. USCIS will also use performance 

measurements to accurately gauge the effectiveness of future pilot 

programs. 

OIG Analysis: We consider USCIS’ proposed actions responsive to 

the recommendation. The recommendation will remain resolved but 

open pending receipt of documentation describing in detail USCIS’ 

improvements, including pilot program templates and protocols for 

managing headquarters-sponsored pilot programs, and policies and 

procedures for using performance measurements for pilot programs. 

USCIS Response: USCIS concurred with Recommendation 3. In its 

response, USCIS agreed with the need for a knowledge management 

approach and is conducting an assessment of how best to meet this 

requirement. As noted in its Strategic Plan, USCIS will work to 

implement a plan that can benefit multiple components of the agency. 

OIG Analysis: We consider USCIS’ proposed actions responsive to 

the recommendation. The recommendation will remain resolved but 

open pending receipt of documentation indicating that a knowledge 

management approach has been implemented, and that said approach 

provides for a method to store, evaluate, and share data from 

experimental processes. 

USCIS and Department of State Coordination 

USCIS and the Department of State have joint responsibility for the 

timeliness of immigration benefits. For example, USCIS immigration 

benefits are dependent on the availability of visas issued by the 

Department of State. USCIS has taken steps to improve 

communication with the Department of State to help manage the 

impact of its visa availability decisions on the timeliness of 

immigration benefits processing. However, these steps could be 

formalized to ensure lasting coordination. 

Visa Bulletin Effect on USCIS 

By statute, the Department of State determines the number of available 

family- and employment-based visas. An immigrant visa is considered 

available, and an adjustment of status application can be filed and 

processed, when the applicant has a priority date earlier than the cutoff 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 11 
 

date identified on the visa bulletin.7 USCIS cannot accept an 

application and begin the adjudication process in advance of visa 

availability. USCIS also cannot limit the number of applications 

accepted in a given month to the actual number of visas available. 

Rather, USCIS is required to process all applications qualifying for 

adjustment of status based on the visa bulletin. 

In July 2007, USCIS recognized the need for improved 

communication with the Department of State when the department’s 

visa bulletin resulted in a surge of employment-based immigration 

applications. The Department of State issued visa bulletins making 

visas available for all qualified candidates in nearly every 

employment-based category. USCIS was required to accept all 

employment-based applications filed that month, which flooded 

USCIS with approximately 800,000 applications. USCIS was delayed 

in the intake of these applications because the volume received 

exceeded its processing capacity. 

Interagency Communication 

To better manage the impact of these visa availability decisions, 

USCIS enhanced its monthly meetings with the Department of State. 

USCIS now provides the Department of State with information on the 

number of adjustment of status applications it has on hand, by country, 

to help the Department of State better determine the cutoff date for the 

visa bulletin each month. This improved communication has benefited 

both agencies by assisting the Department of State in better managing 

visa allocations to ensure that annual limitations are not exceeded, and 

by improving USCIS’ ability to target production to ensure that it uses 

all available visas when there is sufficient demand. In its May 2008 

visa bulletin, the Department of State acknowledged, “Many of the 

employment cut-off dates have continued to advance more rapidly 

than might ordinarily be expected. This is a result of consultations 

with USCIS regarding their pending demand....” 

Representatives from both agencies continue to meet monthly, but 

without a formal memorandum of understanding to firmly establish 

these procedures, there is no assurance that these improvements will 

be sustained. For example, although the agencies communicated in 

meetings hosted by the USCIS ombudsman at the time, this less formal 

arrangement was not sufficient to prevent the July 2007 surge of 

applications. 

7

 The priority date determines when a person can apply for an immigrant visa. In family immigration, the 

priority date is the date when the petition was filed at a U.S. Citizenship and Immigration Services office or 

submitted to an embassy or consulate abroad. In employment immigration, the priority date may be the date the 

labor certification application was received by the Department of Labor. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 12 
This memorandum of understanding would not be the first between the 

agencies. In May 2006, USCIS and the Department of State, through 

the Bureau of Consular Affairs, signed a memorandum of 

understanding that set forth the communication protocols for sharing 

data from their various information systems. 8 The memorandum of 

understanding gave USCIS access to a history of visa applications and 

adjudications for subjects applying for immigration and other benefits. 

The Department of State obtained access to information about USCIS 

adjudications of benefits or petitions and other decisions relating to 

nonimmigrant and immigrant visas and naturalization cases. This 

agreement provided a foundation for information sharing, but it was 

not enough to prevent the Department of State from issuing the July 

2007 visa bulletin. 

USCIS needs to clearly identify the type and frequency of 

communication needed to influence Department of State visa bulletin 

decisions and formalize these agreements in an official document. 

Similar communication could be established with the Department of 

State regarding other issues such as family-based adjustment of status 

visa bulletins, which affect the number of family-based immigration 

benefit applications filed. The capacity limits of family-based 

immigration benefit applications and the impact of these visa bulletins 

have not been included in the monthly discussions because, to date, 

they have not been problematic for USCIS. Nonetheless, establishing 

formal communication on these issues could help prevent future 

problems. 

Recommendation 

We recommend that the Acting Director of USCIS: 

Recommendation #4: Develop a memorandum of understanding with 

the Department of State to formalize agreements to ensure continued 

communication and coordination regarding visa bulletins and to 

mitigate their impact on USCIS benefits application processing. 

Management Comments and OIG Analysis 

USCIS Response: USCIS did not concur with Recommendation 4 on 

formalizing agreements with the Department of State to coordinate on 

visa availability. In its response, USCIS did not agree that a new 

8

 Memorandum of Understanding between Bureau of Consular Affairs, Department of State, and U.S. 

Citizenship and Immigration Services, Department of Homeland Security, for the Exchange of Visa and 

Immigration Data, May 2006. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 13 
memorandum of understanding with the Department of State is 

necessary to ensure the two agencies communicate effectively. 

Rather, USCIS discussed that since the summer of 2007, USCIS has 

worked very closely with the Department of State to facilitate and 

establish visa availability cut-off dates for the upcoming months, and 

has met monthly with Department of State in person to discuss and 

resolve issues relevant to visa issuance. In addition, USCIS stated that 

the ongoing working sessions and continued dialog with immigration 

partners at Department of State is more effective than another 

intergovernmental memorandum of understanding. 

OIG Analysis: We maintain our position that a memorandum of 

understanding between USCIS and the Department of State is 

necessary to ensure continued communication and cooperation. We 

commend USCIS efforts to build stronger, more effective relationships 

with its immigration partners at Department of State; however, we 

request that USCIS reconsider its non-concurrence with the need for a 

memorandum of understanding and provide updated information on 

implementation activities within 90 days of the date of this final report. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 14 
Appendix A 

Purpose, Scope, and Methodology 

Our objective was to determine the efficacy of management 

oversight of application intake activities to improve the timeliness 

of immigration benefit processing. We did not limit our audit to a 

specific type of benefit or application, but rather focused on 

management oversight of processes for intake of all types of 

immigration benefit applications filed domestically via direct mail. 

Application intake includes processes needed to assemble an 

application so that it will be ready for adjudication. Such 

processes include mailroom operations, file assembly, data capture 

and collection, fee collection and receipting, file room operations, 

and Interagency Border Inspection System checks. 

We toured and physically observed the processes at USCIS’ 

National Benefits and National Records Centers, and the Texas and 

California Service Centers. In addition, we performed multiple 

site visits to USCIS’ Office of Domestic Operations. We reviewed 

prior DHS OIG, Government Accountability Office, and USCIS 

ombudsman’s reports discussing USCIS’ application intake 

process and related USCIS challenges. 

We identified USCIS’ application intake locations and the 

procedures and responsibilities of the National Benefit Center, the 

National Records Center, and the Texas and California Service 

Centers. 

In addition, we interviewed USCIS managers and personnel and 

reviewed documents and records to determine areas potentially 

affecting the timely intake of applications, including: 

�

�

�

�

�

Internal and External Communication 

Central Monitoring of Domestic Operations Pilot Programs 

Documentation of Meetings and Best Practices 

Attrition and Management Turnover 

Use of a Knowledge Management Approach 

We conducted our audit at USCIS headquarters in Washington, 

DC, and at the National Benefits Center and the National Records 

Center in Lee’s Summit, MO. Also, we performed fieldwork at the 

Service Centers in Dallas, TX, and Laguna Nigel, CA. 

We conducted this performance audit between September 2007 

and July 2008 according to generally accepted government 

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

on our audit objectives. We believe that the evidence obtained 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 15 
Appendix A 

Purpose, Scope, and Methodology 

provides a reasonable basis for our findings and conclusions based 

on our audit objectives. 

We would like to extend our appreciation to USCIS for the 

cooperation and courtesies extended to our staff during this audit. 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 16 
Appendix B 

Intake Process 

Within USCIS, the Office of Domestic Operations is responsible 

for the intake, or receipt, of most immigration benefit applications. 

Intake of application packages occurs primarily by direct mail at 

five locations: four Service Centers and the National Benefits 

Center. Although the intake processing at each location is similar, 

there are some variations to the processes among the locations, as 

discussed below. 

National Benefits Center 

The National Benefits Center uses a lockbox facility to accept and 

begin processing for adjustment of status and other immigration 

benefit applications. The lockbox is administered by a bank under 

contract with the Department of the Treasury responsible for fee 

receipting, fee deposit, and initial data entry. 

The intake process at the lockbox differs from the service centers 

because it uses scanning technology to transfer data automatically 

to USCIS’ information systems. Lockbox personnel ensure that 

basic information is included with an application package, but 

render no decision on an applicant’s eligibility for benefits. If a 

problem with an application package is discovered, the application 

package is returned to the applicant with a description of the 

error(s). Files are assembled for properly filed cases and 

forwarded to the National Benefits Center for further intake 

processing. At the National Benefits Center, contractors ensure 

that files are assembled correctly, conduct initial background 

security checks, and complete initial evidence reviews for each 

application package. If evidence is missing or incomplete, a 

request for evidence letter is sent to the applicant. Ultimately, the 

National Benefits Center forwards applications requiring 

interviews to USCIS’ district offices for interview and 

adjudication. The Center also adjudicates interim benefits that do 

not require an interview. 

Service Centers 

Most other applications, including employment-based benefits and 

naturalization applications, are mailed to one of four Service 

Centers. Generally, intake of applications at the Service Centers 

involves the following steps: 

Mailroom Operations: Applicants file application packages with 

specific post office boxes based on application type. Contractors 

pick up the mail from the post office or receive applications 

submitted by courier directly at the Service Center. Once received, 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 17 
Appendix B 

Intake Process 

the application packages are opened, sorted, logged, date stamped, 

and, based on application type, routed to the appropriate area for 

data collection. 

Data Collection: Contractors review the applications for 

completeness, jurisdiction, signature, and correct fee. When the 

application is incomplete, such as missing a signature or a fee, it 

can be rejected and a letter explaining the deficiency is sent to the 

applicant. Once an application is accepted, the clerk manually 

enters the applicant’s information into USCIS’ information system, 

and the fee is receipted. Once receipted, a letter is generated by 

the system and sent to the applicant with a receipt date. 

File Room Operations and Interagency Border Inspection System 

Checks: After data collection, applications are forwarded to the 

file room, where Interagency Border Inspection System checks are 

conducted. For most forms, the Interagency Border Inspection 

System check requires a review of the entire application package to 

identify the names and aliases of applicants, petitioners, and 

beneficiaries. The names are queried against criminal databases, 

such as the National Crime Information Center, to identify any 

criminal history. A decision to grant an application can occur only 

after all Interagency Border Inspection System hits are researched 

and resolved. Applications are stored in the file room until an 

adjudication officer requests them for review. 

Applications filed with the Service Centers are not checked for 

initial evidence during the intake process. 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 18 

Appendix C 

Management Comments to the Draft Report 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 19 

Appendix C 

Management Comments to the Draft Report 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 20 

Appendix C 

Management Comments to the Draft Report 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 21 

Appendix D 

Major Contributors to this Report 

Phillip Maulden, Division Director 

Yesi Starinsky, Audit Manager 

Andrew Herman, Auditor 

Virginia Feliciano, Auditor 

Sandra Ward-Greer, Auditor 

 Pamela Lokeman, Auditor 

 Dennis Deely, Referencer 

Management Oversight of Immigration Benefit Application Intake Processes 

Page 22 
Appendix E 

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 Public Affairs 

Assistant Secretary for Legislative Affairs 

Acting USCIS Director 

USCIS Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Management Oversight of Immigration Benefit Application Intake Processes 


Page 23 

ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4199, 

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

OIG HOTLINE 

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

misconduct relative to department programs or operations: 

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

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

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

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