Department of Homeland Security
 

Improvements Needed for SAVE To Accurately 


Determine Immigration Status of Individuals Ordered 


Deported
 

OIG-13-11 (Revised) December 2012
 
 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

December 7, 2012 

MEMORANDUM FOR:	 Lori Scialabiba 

Deputy Director 

U.S. Citizenship and Immigration Services 

FROM:	 Frank Deffer 

Assistant Inspector General 

Information Technology Audits 

SUBJECT:	 Improvements Needed for SAVE To Accurately Determine 

Immigration Status of Individuals Ordered Deported 

Attached for your action is our revised final report, Improvements Needed for SAVE To 

Accurately Determine Immigration Status of Individuals Ordered Deported. We 

incorporated the formal comments from the U.S. Citizenship and Immigration Services 

in the final report. We are reissuing this report based on technical comments received 

from U.S. Citizenship and Immigration Services after the formal comment period. 

The report contains four recommendations aimed at improving the accuracy of the 

SAVE program. Your office concurred with all four recommendations. Based on 

information provided in your response to the draft report, we consider all four 

recommendations resolved. Once your office has fully implemented the 

recommendations, please submit a formal closeout letter to us within 30 days so that 

we may close the recommendations. The memorandum should be accompanied by 

evidence of completion of agreed-upon corrective actions. 

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.” 

Please call me with any questions, or your staff may contact Tuyet-Quan Thai, Regional 

Director, at (425) 582-7861. 

Attachment 
 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

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


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


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


USCIS’ Class of Admission Code Is Not Updated When an Individual Is Ordered 

Deported But Is Still in the United States ............................................................... 3 

Recommendations ................................................................................................. 7 

Management Comments and OIG Analysis ........................................................... 7 

Inaccurate Source Data Resulted in a High Error Rate for the Population of 

Individuals Ordered Deported..................................................................................... .. 8 

Recommendations...........................................................................................................11 

Management Comments and OIG Analysis..................................................................11 

Appendixes 

Appendix A: Objectives, Scope, and Methodology ............................................ 13 


Appendix B: Management Comments to the Draft Report ............................... 15 


Appendix C: Major Contributors to This Report ................................................ 18 


Appendix D: Report Distribution ........................................................................ 19 


Abbreviations 

CPMS Customer Profile Management System 

DHS Department of Homeland Security 

DOJ U.S. Department of Justice 

EARM ENFORCE Alien Removal Module 

EOIR Executive Office for Immigration Review 

ICE U.S. Immigration and Customs Enforcement 

ISRS Image Storage and Retrieval System 

OIG Office of Inspector General 

SAVE Systematic Alien Verification for Entitlements 

TSA Transportation Security Administration 

TWIC Transportation Worker Identification Card 

USCIS U.S. Citizenship and Immigration Services 

VIS Verification Information System 

www.oig.dhs.gov OIG-13-11 
 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary 

We audited the U.S. Citizenship and Immigration Services’ (USCIS) Systematic Alien 

Verification for Entitlements program to determine the accuracy of information used to 

validate an applicant’s immigration status when the applicant had been ordered 

deported. Our objectives were (1) to assess whether the Systematic Alien Verification 

for Entitlements program uses accurate and up-to-date information to validate 

immigration status of deportable, removable, and excludable individuals, and (2) if 

Systematic Alien Verification for Entitlements is not using accurate information, to 

determine the rate of error with respect to verification of these individuals’ status. 

The Systematic Alien Verification for Entitlements program provided information that 

was sometimes outdated and erroneous about an individual’s immigration status to 

benefit-granting agencies. This occurred because status codes in the Central Index 

System were generally not updated when the Immigration Court issued a decision to 

remove, deport, or exclude an individual from the United States. Instead, the codes 

were updated when the individual physically left the United States, which can take 

years. This problem could potentially affect the more than 800,000 individuals who 

have been ordered deported, removed, and excluded but who are still in the United 

States. Although the Systematic Alien Verification for Entitlements response in and of 

itself did not automatically result in approval of financial or other benefits by Federal, 

State, and local agencies, an erroneous response could result in agencies granting 

benefits to unentitled individuals. 

Our random statistical sample tests of individuals who had been ordered deported but 

still remained in the United States identified a 12 percent error rate in immigration status 

verification. In other words, these individuals had no status, but were erroneously 

identified as having lawful immigration status. The remaining 88 percent passed our 

tests because the individuals had lawful immigration status at the time of status 

verification. This includes situations where the individual (1) was ordered deported 

after the verification or (2) obtained permanent or temporary status after being ordered 

deported but before the status verification. Benefits for which individuals were verified 

ranged from airport badges and Transportation Worker Identification Cards, which 

provide individuals with access to secure areas, to food stamps, driver’s licenses, and 

education assistance. Some individuals included in our sample had committed felonies 

ranging from citizenship fraud to aggravated assault. 

We made four recommendations to the Deputy Director, USCIS, to improve the 

accuracy of the Systematic Alien Verification for Entitlements program. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

In response to the requirements of the Immigration Reform and Control Act of 1986, as 

amended, and subsequent legislation, USCIS established the Systematic Alien 

Verification for Entitlements (SAVE) program under the Verification Division to verify the 

immigration status of noncitizen applicants for Federal, State, or local benefits and 

licenses.1

 As of April 1, 2012, more than 800,000 individuals who were ordered 

deported, removed, or excluded (heretofore referred to as deportable) were still 

residing in the United States.2

 The objectives of this work were (1) to assess whether 

SAVE uses accurate and up-to-date information to validate immigration status of 

deportable individuals, and (2) if SAVE is not using accurate information, to determine 

the rate of error in SAVE with respect to verification of deportable individuals. 

SAVE is primarily a Web-based system that uses the Verification Information System 

(VIS) to provide almost instantaneous responses to immigrant status inquiries. 

Programs that are mandated to participate in status verification include Medicaid, food 

stamps, educational and housing assistance programs, and certain license-issuing 

programs. Typically, SAVE verification involves the following process: 

�	 

�	 

Applicable Federal, State, and local benefit-granting agencies review proof of 

immigration status from noncitizen applicants, such as a Permanent Resident 

Card or Employment Authorization Document. Other forms may also be used to 

demonstrate immigration status. 

Using the numerical identifier, such as an alien number, naturalization number, 

or other relevant information, the agency submits a SAVE inquiry electronically.3 

 

1

 The Personal Responsibility and Work Opportunity Reconciliation Act of 1996, Public Law 104-193, as 

amended, restricted immigrant eligibility for public benefits and required verification of immigration 

status. The Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Public Law No. 104-208, 

Division C, as amended, expanded the use of the SAVE program by Federal, State, local agencies for any 

purposes authorized by law. The REAL ID Act of 2005, Public Law 109-13, Division B, (REAL ID) established 

certain minimum standards for State-issued driver’s licenses and State-issued identification cards. 

According to Code of Federal Regulation Title 6, Part 37, States must use the SAVE program to verify the 

immigration status of applicants for driver’s licenses and identification cards. States were required to 

comply with REAL ID by May 11, 2011. The Patient Protection and Affordable Care Act, Public Law 111­

148, as amended, provides health insurance benefits for qualified “aliens lawfully present in the United 

States.” Immigration status verification of noncitizen applicants is part of the eligibility determination. 2

 Data obtained from U.S. Immigration and Customs Enforcement (ICE) reflect the number of individuals 

with an order of deportation, exclusion, or removal. Other individuals who are in the United States 

illegally but have not been ordered deported are not represented in these numbers. 3

 A paper-based verification process is also available to agencies not participating electronically. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

�	 During the initial verification process, VIS provides a response based on the 

documentary and biographic information presented. 

�	 VIS performs this verification either using data from multiple sources, including 

the Central Index System (the primary data source used to confirm immigration 

status when an alien number is presented), or through interfaces with other 

systems maintained by USCIS or other Federal agencies.4 

�	 Within a few seconds, SAVE electronically either confirms that the applicant has 

immigrant status and/or employment authorization, or prompts the inquiring 

agency to institute additional verification. 

�	 Agencies requesting identity verification compare results against source 


documents and provide additional information as necessary.
 

�	 The additional verification may require submission of supplemental information 

from the applicant. Verification staff manually review the supplemental 

information and access a number of systems that are not available during the 

initial verification process to confirm status. 

Results of Audit 

USCIS’ Class of Admission Code Is Not Updated When an Individual Is Ordered 

Deported But Is Still in the United States 

Central Index System, the primary system SAVE accesses to validate an 

individual’s immigrant status, is not immediately updated when the Immigration 

Court orders an individual deported, removed, or excluded.5 The ultimate 

decision to provide or deny benefits rests with the Federal, State, and local 

agencies that submitted the verification inquiry. However, by erroneously 

verifying that a deportable individual has status to receive benefits, SAVE may 

have enabled the inquiring agency to grant financial and other benefits (e.g., 

access to secure areas, education grants, and housing assistance) to people who 

are no longer eligible to receive those benefits. 

4

 In addition to the Central Index System, VIS is either updated or interfaces with other systems when 

documents with other numeric identifiers are presented, such as the Customer Profile Management 

System (CPMS), Treasury Enforcement Communications System Real-Time Arrivals, Treasury Enforcement 

Communications Systems I-94, Computer Linked Application Information Management System 4, and 

Reengineered Naturalization Application Casework System. 5

 Deportation, removal, and exclusion orders are different with regard to notice, the individual’s rights, 

procedures, burden of proof, evidence, relief, and consequences. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The Data Quality Act requires Federal agencies to maximize the quality, 

objectivity, utility, and integrity of information they disseminate.6

 The Standards 

for Internal Control in the Federal Government states that transactions should be 

promptly recorded to maintain their relevance and value to management in 

controlling operations and making decisions.7

 To achieve these goals and 

objectives (i.e., ensuring that all transactions are complete and accurate), 

agencies need to establish control activities that promote the accurate and 

timely recording of transactions and events. Without accurate and complete 

information, government agencies risk making decisions that violate laws and 

regulations. 

According to USCIS, generally, individuals who are ordered deported or removed 

lose their lawful immigration status and any benefits they may have been eligible 

to receive.8

 Lawful permanent residents can lose status if they are convicted of 

a felony such as drug trafficking, aggravated assault, burglary, robbery, or fraud; 

or if they spend too much time outside the United States and thus fail to meet 

residency requirements. Individuals with temporary status can lose status if they 

commit a crime or overstay their authorized period of stay. Deportable aliens 

can file for immigration status or relief from deportation with USCIS and/or the 

Executive Office for Immigration Review (EOIR) within the U.S. Department of 

Justice (DOJ).9

 Without specific authorization to remain in the United States 

temporarily or permanently, a deportable individual is out of status and is not 

entitled to many government benefits.10 

However, USCIS Verification Division and U.S. Immigration and Customs 

Enforcement (ICE) officials told us that the Class of Admission code is generally 

not updated when an individual is ordered deported.11 USCIS officials explained 

that these individuals have the right to appeal or apply for relief, such as 

temporary protected status if they are afraid to return home. Consequently, it is 

not until the individual departs from the United States that the Central Index 

6 Consolidated Appropriations Act, 2001, Public Law No. 106-554, § 515, 114 Stat. 2763A-153 to 2763A154 (2000) (44 U.S.C. § 3516 note). The law is referred to as the Data Quality Act. 
 7

 GAO/AIMD-00-21.3.1 (Washington, DC: November 1999).
 

8

 Generally, a specified period of time is allowed to appeal the decision. For individuals who had a lawful 


immigration status, the order is an “administratively final order of removal” and results in loss of status 


upon conclusion of administrative appeal proceedings or expiration of time permitted to file an appeal. 
 9

 EOIR includes the Immigration Courts and the Board of Immigration Appeals. Immigration Court and 


appeal decisions are maintained by DOJ.
 

10 Some licensing agencies allow licenses for illegal aliens. Additionally, in extenuating circumstances,
 

benefit-granting agencies may decide to assist someone who is in the United States illegally. 


11 The Central Index System Class of Admission is occasionally updated with the generic “IJ” code to 


indicate that the person is in proceedings, but this identification is inconsistent.
 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

System admission code is updated via an electronic interface with data 

maintained by ICE.12 As it can take years for an administratively final order of 

removal to result in an actual departure, the admission code can be out of date 

for a number of years. 

According to Verification Division officials, the accuracy of SAVE’s response 

depends on the type of information that it can access in the source systems. 

SAVE data for the period under audit showed that 77 percent of all initial 

electronic verifications most likely relied on the admission code in Central Index 

System for verification.13 As a result, erroneous admission codes resulted in 

erroneous status verification. Although a SAVE status verifier can determine 

when a person has a final deportation order by accessing the EOIR and ICE 

systems, status inquiries get to the SAVE verifier only when manual intervention 

is necessary. If the admission code appears to be valid at initial verification, the 

case rarely gets to the status verifier for additional verification. 

We identified examples of individuals who had administratively final orders of 

removal but whose status was verified by SAVE. In all cases, the SAVE responses 

were erroneous because the Class of Admission codes were not updated in the 

source systems. These individuals did not have relief from deportation or 

permanent or temporary status at the time SAVE verified their status. 

�	 One individual entered the United States and obtained lawful permanent 

resident status in 1983. After the alien was convicted of multiple felonies, 

including extortion and abuse, in April 2003, an immigration judge ordered 

the alien removed. This individual applied to the California Department of 

Health Services for assistance seven times between October 2008 and April 

2012. SAVE responded to all seven queries that the individual was a lawful 

permanent resident. 

�	 A refugee who obtained lawful permanent resident status in 1985 was 

convicted of homicide/negligent manslaughter involving a weapon in 2000 

and 2003. He was ordered deported in July 2010 during his incarceration. 

Subsequent to the individual’s release from detention, SAVE erroneously 

verified him as a permanent resident when he applied for student aid 

12 The interface takes place through ICE’s ENFORCE Alien Removal Module (EARM). EARM supports ICE’s 

processing and removal of aliens from the United States. 

13 When the agency submits an alien number as the numeric identifier, SAVE matches the alien number to 

Central Index System data and relies on the class of admission code to report status. If a numeric 

identifier mismatch occurs, SAVE automatically searches the CPMS/Image Storage and Retrieval System 

(ISRS) as a secondary source system. The CPMS/ISRS is a repository of green cards, employment 

authorization documents, and photographs from these cards. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

through the District of Columbia Education system in December 2010 and 

January 2011. ICE removed this individual in June 2011. 

�	 A lawful permanent resident since 1989 was ordered deported in September 

2000 after convictions of multiple crimes, including illegal entry, assault, 

driving while intoxicated, and carrying a concealed weapon. The individual 

filed an appeal, which was rejected in 2002. In 2009, the individual applied 

for a Transportation Security Administration (TSA) Transportation Worker 

Identification Card (TWIC), which grants access to secure areas of 

transportation facilities. Upon inquiry, SAVE erroneously confirmed the 

individual’s immigration status. Although TSA has other tools in place to 

identify criminal convictions and therefore does not rely exclusively on SAVE 

when vetting individuals for TWIC, an accurate SAVE result can improve TSA’s 

vetting process. ICE removed this individual in May 2012. 

�	 One lawful permanent resident since 1964 was ordered deported in May 

1996 following conviction of aggravated felonies for drugs and weapon 

possession. In March 2010, SAVE verified the individual’s immigration status 

for a driver’s license or State Identification card. In November 2010, TSA 

queried SAVE while vetting crewmembers, a process whereby TSA assesses 

security threats to aviation related to crewmembers on flights to, from, and 

over the United States. In both instances, SAVE responded erroneously that 

the individual was a lawful permanent resident. 

Conclusion 

SAVE erroneously confirmed immigration status for individuals who no longer 

had status yet continue to reside in the United States. If USCIS developed an 

interface between SAVE and other systems at EOIR or ICE that contains 

information on an individual’s deportation or removal, the risk of confirming that 

deportable individuals have lawful immigration status to receive benefits could 

be mitigated. Furthermore, government agencies that rely on SAVE to provide 

accurate immigrant status could make informed decisions when processing 

applications for people who may no longer be eligible for benefits. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

We recommend that the Deputy Director, U.S. Citizenship and Immigration 

Services: 

Recommendation #1: 

Determine what data interfaces are necessary for SAVE to reflect the timely 

status of individuals who have lost status as a result of a final removal order or 

expiration of time permitted to file an appeal. 

Recommendation #2: 

Develop an automated interface that will result in SAVE accurately reflecting the 

immigration status of individuals who have lost status as a result of a final 

removal order or expiration of time permitted to file an appeal. 

Management Comments and Office of Inspector General (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 its entirety at appendix B. 

We also obtained technical comments to the draft report, which we 

incorporated into the final report where appropriate. The Director of USCIS 

concurred with all recommendations. 

USCIS Comments to Recommendation #1: 

USCIS concurs with this recommendation. The Central Index System and EARM 

interface already exists, and USCIS will work with ICE to identify the related fields 

required to confirm when an administratively final order of removal is issued and 

will initiate steps to resolve the issues in fiscal year 2013. USCIS will also initiate 

a review of other potential data sources for this information in the same 

timeframe. 

OIG Conclusion 

The actions USCIS proposes satisfy the intent of the recommendation. This 

recommendation is considered resolved, but will remain open until USCIS 

provides documentation that the planned corrective actions are completed. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

USCIS Comments to Recommendation #2: 

USCIS concurs with this recommendation. USCIS will seek and support changes 

to the EARM and Central Index System update process such that the Central 

Index System record indicates that an individual is under administratively final 

order of removal when the order becomes final rather than after the individual 

departs the United States. USCIS will initiate discussions with ICE beginning in 

fiscal year 2013 and will also initiate a review of other potential data sources for 

this information. 

OIG Conclusion 

The actions USCIS intends to take in fiscal year 2013 satisfy the intent of the 

recommendation. This recommendation is considered resolved, but will remain 

open until USCIS provides documentation that the planned corrective actions are 

completed. 

Inaccurate Source Data Resulted in a High Error Rate for the Population of 

Individuals Ordered Deported 

Our random statistical sample of nearly 177,000 inquiries with SAVE confirmation 

showed a projected error rate of 12 percent.14 That is, we are 95 percent 

confident that one out of eight deportable aliens whom SAVE confirmed as 

having valid immigration status between October 1, 2008, and April 1, 2012, was 

actually out of status. 

To test the effect of the erroneous status codes, we drew the statistical sample 

from the population of positive SAVE confirmations (i.e., where SAVE confirmed 

that an individual had status to receive benefits). Because our objective was to 

determine the rate of erroneous SAVE immigration status results for individuals 

ordered deported, we excluded from our population (1) individuals who were 

ordered deported but did not apply for benefits and (2) individuals who were not 

confirmed as having valid immigration status. Table 1 shows the derivation of 

the population from which we selected our sample. 

14 Our sample was developed to provide a 95 percent confidence level with a +/- 5 percent confidence 

interval. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1. Details of SAVE Population
 

Population Number of 

Status Inquiries 

Number of 

Individuals 

Deportable aliens in the United States -­ 849,609 

Deportable aliens who were submitted 

to SAVE for verification 

324,665 104,868 

Deportable aliens confirmed as having 

status 

176,852 76,907 

Source: Department of Homeland Security (DHS) OIG analysis of ICE and USCIS 

data. 

As table 1 shows, ICE identified nearly 850,000 individuals as deportable and 

believed to be in the United States. From October 1, 2008, through April 1, 

2012, nearly 325,000 status inquiries related to 105,000 of the deportable aliens 

were submitted to SAVE. The 177,000 inquiries that received a positive response 

from SAVE as to their immigration status became the population from which we 

selected our sample. 

A sample of 116 positive SAVE transactions selected statistically showed an error 

rate of 12 percent. The SAVE transactions that failed our tests failed because 

(1) SAVE verification occurred after the individual was ordered deported and 

(2) the individual did not apply for and get relief from deportation or temporary 

or permanent status. SAVE transactions passed our tests if, after the 

deportation ordered, the individual applied for and obtained relief or status. 

Appendix A contains further information regarding sample selection and testing. 

Table 2 summarizes the results of our statistical sample tests. The failures in our 

sample include individuals who applied for unemployment and disability 

insurance, food stamps, driver’s licenses, and other benefits. Several individuals 

had criminal records, including assault with a deadly weapon, extortion, drug 

convictions, and other convictions such as burglary, stalking, and child abuse. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2. Summary of Statistical Sample Results
 

Result 

Number of 

Transactions Reason for Result 

Fail 14 Individual had no status—SAVE verified 

immigration status after the individual 

had been ordered deported. 

Pass 102 

� Confirmed 

permanent 

resident or 

U.S. citizen 

11 Individual applied for and obtained 

lawful permanent resident or U.S. citizen 

status— 

� After being ordered deported and 

� Before SAVE verification 

� Verified 

before order 

12 Individual was ordered deported after 

the immigration status inquiry. 

� Temporary 

status 

79 Individual applied for and received 

temporary status— 

� After being ordered deported and 

� Before SAVE check 

Source: DHS analysis of SAVE verification data and relevant DHS systems. 

As table 2 shows, of the 116 SAVE positive results we tested, 102 transactions 

passed our statistical test while 14 transactions failed, for a projected 12 percent 

error rate.15 In other words, one in every eight verifications was erroneous. Of 

the 14 individuals who failed our tests, 12 had criminal convictions. For example, 

�	 Two individuals were involved in fraud ranging from forgery to identity theft, 

including two convictions of illegal use of credit cards. 

�	 At least 10 individuals had aggravated felony convictions involving extortion, 

aggravated assault, burglary, or dangerous drugs. 

USCIS performs quality assurance reviews of additional verification with a 

performance target of 98 percent of cases with a correct status determination. 

However, USCIS had not conducted reviews of the initial electronic verification 

process to determine the (1) extent to which SAVE relies on accurate information 

or (2) overall rate of errors. 

15 Applying the 12 percent projected error rate to the 177,000 inquiries from deportable aliens who received 

SAVE confirmation results in more than 21,000 inquiries that may have erroneous SAVE responses. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Conclusion 

We identified a high SAVE error rate when confirming the status of individuals 

who had been ordered deported for identification purposes, financial assistance, 

or access to secure facilities. If USCIS performed periodic evaluation of initial 

verification to assess the accuracy of information SAVE used to determine 

immigration status and analyzed the resulting errors, USCIS could increase the 

accuracy of SAVE responses and potentially identify other populations at risk of 

erroneous verification. 

Recommendations 

We recommend that the Deputy Director, U.S. Citizenship and Immigration 

Services: 

Recommendation #3: 

Conduct periodic evaluations to validate the accuracy of SAVE initial verification. 

Recommendation #4: 

Analyze the periodic evaluation results to determine whether SAVE is at risk of 

verifying other populations erroneously. 

Management Comments and OIG Analysis 

USCIS Comments to Recommendation #3 

USCIS concurs with this recommendation. USCIS continuously evaluates the 

accuracy of additional verifications through the SAVE program’s quality 

assurance efforts and will leverage that process and apply it to initial verification. 

USCIS will initiate this process in fiscal year 2013. 

OIG Conclusion 

The actions that USCIS proposes 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 

implemented. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

USCIS Comments to Recommendation #4: 

USCIS concurs with this recommendation. USCIS will analyze the periodic 

evaluations identified in Recommendation 3. USCIS already analyzes the results 

of its additional verifications through the SAVE program’s quality assurance 

efforts and will leverage that process and apply it to initial verification. USCIS 

will initiate this process in fiscal year 2013. 

OIG Conclusion 

The actions USCIS intends to take in fiscal year 2013 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 implemented. 

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 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. 

This audit was initiated in response to concerns that the SAVE program provided 

erroneous responses as to immigration status of individuals. Our objectives were (1) to 

assess whether SAVE uses accurate and up-to-date information to validate immigration 

status of deportable, removable, and excludable individuals, and (2) if SAVE is not using 

accurate information, to determine the rate of error in SAVE with respect to verification 

of these individuals. 

We interviewed USCIS, ICE, and U.S. Department of Justice (DOJ) officials regarding the 

SAVE process, key data elements used in verification, and the system interfaces relied 

upon by SAVE. We reviewed relevant criteria, policies, and other guidance affecting 

orders of deportation, removal, and exclusion, and conducted walk-throughs of the 

verification process. We obtained USCIS data containing the results of more than 

37 million SAVE verifications and a list of nearly 850,000 deportable aliens from ICE.16 

The population from which we selected our transactions for testing was the nearly 

177,000 inquiries from October 1, 2008, to April 1, 2012, in which SAVE verified that the 

deportable individual had immigration status. Because our objective was to determine 

the rate of erroneous SAVE immigration status results for individuals ordered deported, 

we excluded records of individuals whose immigration status was not positively 

validated. 

Our sample plan was developed to provide a 95 percent confidence level with an 

expected error rate of 5 percent and a precision of no more than plus or minus 5 

percentage points on all attributes that apply to the entire population of transactions. 

We drew a statistical sample of 116 transactions from the population of transactions 

where SAVE confirmed the immigration status of individuals who had been ordered 

deported. 17 

16 ICE provided data for close to 850,000 aliens who had been ordered deported, removed, or excluded. 

17 We drew a sample totaling 130 transactions to allow for replacements transactions if necessary. We 

replaced one transaction where the biographic data from ICE did not match those from USCIS. 

www.oig.dhs.gov 13 OIG-13-11 
 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We tested each transaction to determine (1) whether SAVE verified immigration status 

prior or subsequent to the date the individual had been ordered deported (if SAVE 

verified immigration status prior to the date the individual had been ordered deported, 

then SAVE had provided an accurate response and therefore passed our test), and 

(2) whether the individual had obtained relief or had applied to USCIS for temporary 

authorization, such as an employment authorization document, to have lawful 

immigration status to work and/or receive benefits (in this case, a positive response on 

immigration status is also a pass). 

To determine the accuracy of the positive SAVE response, we reviewed the sampled 

individual’s lawful immigration status in various USCIS, ICE, and DOJ EOIR systems, and 

compared the date of the deportation order against any relief from deportation to the 

date of the SAVE request. We also confirmed the results that failed our tests with USCIS 

personnel and the underlying support for the information recorded in the systems that 

SAVE accessed. Given the results of our work, we are 95 percent confident that the 

population deviation rate is between 6.76 percent and 19.42 percent for deportable 

aliens. 

The results of the sample were projected only to the population of individuals who had 

been ordered deported, had applied for benefits, and had their immigration status 

positively verified by SAVE. The results did not include all SAVE verifications, such as 

(1) individuals who had not been ordered deported, (2) deportable individuals who did 

not undergo a SAVE verification, or (3) deportable individuals who applied for and failed 

to obtain a positive SAVE result. Because we followed a probability procedure based on 

random selections, our sample is only one of a large number of samples that we might 

have drawn. Since each sample could have provided different estimates, we express 

our confidence in the precision of our particular sample’s results as 95 percent 

confidence intervals (i.e., plus or minus 5 percentage points). These are the intervals 

that would contain the actual population value for 95 percent of the samples we could 

have drawn. 

We conducted this performance audit between April and October 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 14 OIG-13-11 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

U.S. ~p.r1mtnt or ll om~l d Security 

U.S. Citizcnship lind Immigrntion Scnrk:cs 

Offlct 0/11t<- Dfr«lor (MS 2000) 

W:ashinglon, DC 20529·2000 

U.S. Citizenship 

and Immigration 

Services 

OCT 22 2012 

Memorandum ~ 

TO; Frank Deffe, 

Assistant Inspector Ge . I, In rma

M 

ti chnology Audits 

FROM: Alejandro N, Mayorkas 

Director 

SUBJECT: Office oflnspector General Draft Report: Us. Citizenship and Immigration 

Services Improvements Needed/or SAVE /0 Accurately Determine Immigration 

Slaflls of Individuals Ordered Deported (OIG-12-023-ITA-USCIS) 

U,S, Citizenship and Immigration Services (USCIS) appreciates the opportunity to respond to the 

subject report and generally agrees with the Office of Inspector General (OIG) summary of the 

issues identified. USCIS concurs that automated data interfaces will improve the timeliness and 

accuracy of immigration status data, and agrees that periodic evaluations of the accuracy of 

Systematic Alien Verification for Entitlements (SAVE) verifications can help mitigate the risks 

of erroneously verifying current immigration status. uscrs would also like to note that it is 

committed to providing the most current immigration status infonnation available. In this light. 

USCIS has dedicated resources for conducting routi ne quality assurance reviews of all 

verification processes and shares its findings with data partners throughout the Department of 

Homeland Security (DHS) on a quarterly basis. These efforts have resulted in increased 

awareness of common data accuracy and data latency issues to help with troubleshooting and 

diagnostics. in addition, immigration status verification is often only one part of the eligibility 

detennination that an agency must consider before granting a benefit to an individual. Other 

safeguards, such as criminal background checks, help ensure the integrity of providing benefits 

only to eligible individuals. 

In response to the report, USCIS would li ke to note that multiple offices within USCIS and 

multiple DHS components. including U.s. Immigration and Customs Enforcement (ICE), 

manage record systems used by the SAVE program, While the SAVE program is neither the 

owner nor the custodian of these immigration records, USCIS recognizes the need to interact 

effectively with the other offices and components to ensure the data is up-to-date and accurate 

for verification and otber purposes. 

With res~ct to identifying persons who have been issued an administratively final order of 

removal but whose records have not been updated in the Central Index System (CIS) database, 

I An order of removal beeomes an admi nistratively final order of removal upon the earlier of either a determination 

by the Board of Immigration Appeals (BIA) affirming the order or the expiration of the period in which the 

individual may seek review of the order by the BIA, 8 U.S.C. § 110 I (aX47}(B), Specifically, an order orremoval 

www.uscis,gov 

 

www.oig.dhs.gov 15 OIG-13-11 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

010 Draft Report: U.S. Citizenship and Immigratioll Services Improvemellts NeededforSA VE 

to Accurately Determine Immigration Status of Individuals Ordered Deported (OIG-12-023-ITAUSCIS) 

Page 2 

this is an issue ofDHS component cooperation and communication and USCIS will work more 

closely with its DHS partners, including ICE, to resolve this issue. In short, records concerning 

administratively final orders of removal belong to ICE and are passed to CIS from ICE's 

Enforcement Alien Removal Module (EARM) database. Currently these updates arc not made to 

CIS until after the individual has physically left the United States. As noted in the audit report, a 

considerable amount of time may elapse between the issuance of the administratively final order 

ofrcmoval and actual departure. USClS will work with ICE to map a way forward to ensure that 

more timely information is shared. 

OIG recommends that the Deputy Director, USCIS: 

Recommendation] : Dctcrminc what data interfaces are necessa...y for SAVE to rcflect the 

timely status of individuals who have lost status as a result of a final removal ordcr or 

expiration of time permitted to file an appcal. 

USCIS response: USCIS concurs with this recommendation. The CIS and EARM interface 

already exists. and USCIS will work with ICE to identify the related fields required to confinn 

when an administratively final order of removal is issued and will initiate steps to resolve these 

issues in fiscal year 20 13 (FYI 3). USCIS will also initiate a TCview of other potential data 

sources for this infonnation in the same time frame. 

Recommendation 2: Devclop an automated interface that will result in SAVE accurately 

reflecting the immigration stat'us of individuals who have lost status as a result of a final 

removal order or expiration of time permittcd to file an appeal. 

USClS response: USClS concurs with this recommendation. As stated in the response to 

Recommendation I, USCIS will seek and support changes to the EARM and CIS update process 

such that the CIS record indicates that an individual is under an administratively final order of 

removal when the order becomes final rather than after the individual departs the United States. 

USCIS will initiate discussions with ICE beginning in FYI3 and will also initiate a review of 

other potential data sources for this information in the same time frame. 

Recommendation 3: Conduct periodic evaluations to validate the accuracy of SAVE initial 

verification. 

USCIS response: USCIS concurs with this recommendation. USCIS continuously evaluates 

the accuracy of additional verifications through the SAVE program's quality assurance efforts 

and will leverage that process and apply it to initial verification. USCIS will initiate this process 

in FYJ3. 

becomes final when the BIA dismisses an appeal, an appeal is waived by the respondent, an appeal is not timely 

fi led, the BIA or immigration j udge certifies a subsequent removal order. an order of removal is entered in absenlia, 

or where an alternate order of removal is issued, if the individual overstays a period of voluntary departure or fails to 

timely post a vol untary departure bond. 8.CFR 1241.1. . 

 

www.oig.dhs.gov 16 OIG-13-11 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Draft Report: u.s. Citizenship and immigration Services Improvements Needed/or SAVE 

(0 Accurately Determine immigralirJn Status of Individuals Ordered Deported (OIG-12-023-ITAUSCIS) 

Page 3 

Recommendation 4: Analyze the periodic cnluation results to determine whether SAVE is 

at risk of verifying other populations erroneously. 

USCIS response: USCIS concurs with this recommendation. USCIS will analyze the periodic 

evaluations identified in Recommendation 3. USCIS already analyzes the results of its 

additional verifications through the SAVE program's quality assurance efforts and will leverage 

that process and apply it to initial verification. users will initiate tltis process in FY I3. 

www.oig.dhs.gov 17 OIG-13-11 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Major Contributors to This Report 

John Kelly, Director 

Tuyet-Quan Thai, Regional Director 

Beverly Burke, Forensic Audit Manager 

Josh Wilshere, Forensic Auditor 

Bola Somade, Student Intern 

www.oig.dhs.gov 18 OIG-13-11 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

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 19 OIG-13-11 
 

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