A Review of U.S. Citizenship and 

Immigration Services’ Alien Security 

Checks 

 

 

 

DEPARTMENT OF HOMELAND SECURITY 

Office of Inspector General 

Office of Inspections and Special Reviews

OIG-06-06 November 2005
Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528

Preface 

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 

DHS oversight responsibility to promote economy, effectiveness, and efficiency within the 

department. 

This report assesses the strengths and weaknesses of the use of security checks by U.S. Citizenship 

and Immigration Services when processing applications for immigration benefits. It is based on 

interviews with employees and officials, direct observations, and a review of applicable documents. 

The recommendations have been developed to the best knowledge available to the OIG, and have 

been discussed in draft with those responsible for implementation. It is our hope that 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 
Contents 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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

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

 Results of Review .......................................................................................................................... 5 

 

 Scope of security checks should be improved with biometrics and strategic planning............ 5 

 USCIS should continue to improve accuracy and timeliness of check completion ............... 15 

 

USCIS can administer security checks more efficiently......................................................... 28 

 Recommendations ........................................................................................................................ 35 

 Management Comments and OIG Evaluation ............................................................................. 36 

Appendices 

 Appendix A: Purpose, Scope and Methodology ...................................................................... 39 

 Appendix B: Management Response to Draft Report ............................................................. 40 

 Appendix C: Security Checks for USCIS Immigration Forms ............................................... 43 

 Appendix D: Major Contributors to Report ...............................................................................46 

 Appendix E: Report Distribution............................................................................................. 47 

Abbreviations 

 BCS Background Check System 

 BSS Biometric Storage System 

 CBP Customs and Border Protection 

 CIO Chief Information Officer 

 DHS Department of Homeland Security 

 DOJ Department of Justice 

EOIR Executive Office for Immigration Review 

FDNS Office of Fraud Detection and National Security 

 FY Fiscal Year 

 GAO Government Accountability Office 

 HSPD Homeland Security Presidential Directive 

 IAFIS Integrated Automated Fingerprint Identification System 
Contents 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

 IBIS Interagency Border Inspection System 

 ICE Immigration and Customs Enforcement 

 IDENT Automated Biometric Identification System

 INS Immigration and Naturalization Service 

 ISRS Image Storage and Retrieval System 

 IT Information technology 

 NAILS National Automated Immigration Lookout System II 

 OIG Office of Inspector General 

 RAPS Refugee Asylum and Parole System 

 SOP Standard operating procedure 

 USCIS United States Citizenship and Immigration Services 

 US-VISIT United States Visitor and Immigrant Status Indicator Technology 

 

Figures 

Figure 1: USCIS Quality Assurance – Errors Found ......................................................... 17 

Figure 2: OIG Sampling Results – Total Errors Found ....................................................... 18 

Figure 3: OIG Sampling Results –Type of Errors Found ....................................................19 

Figure 4: Security Checks for USCIS Immigration Forms ...................................................43 
OIG 

Department of Homeland Security 

Office of Inspector General 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 1 

Executive Summary 

The staff of the National Commission on Terrorist Attacks upon the United 

States reported that the Immigration and Naturalization Service’s “inability to 

adjudicate applications quickly or with adequate security checks made it 

easier for terrorists to wrongfully enter and remain in the United States 

throughout the 1990s.” 1 The full Commission recommended: 

The Department of Homeland Security, properly supported by 

the Congress, should complete, as quickly as possible, a 

biometric entry-exit screening system, including a single 

system for speeding qualified travelers. It should be integrated 

with the system that provides benefits to foreigners seeking to 

stay in the United States. Linking biometric passports to good 

data systems and decision making is a fundamental goal. No 

one can hide his or her debt by acquiring a credit card with a 

slightly different name. Yet today, a terrorist can defeat the 

link to electronic records by tossing away an old passport and 

slightly altering the name in the new one.2

 

The Immigration and Naturalization Service (INS), followed by U.S. 

Citizenship and Immigration Services (USCIS), made multiple changes over 

the past decade to improve the adequacy of security checks, detect applicants 

who pose risks to national security and public safety, deter benefits fraud, and 

ensure that benefits are granted only to eligible applicants. 

As part of its ongoing responsibilities to evaluate the effectiveness of 

Department of Homeland Security (DHS) programs and activities, the Office 

of Inspector General (OIG) conducted a review of USCIS security check 

activities. Our review assessed whether USCIS (1) selected security checks of 

appropriate scope; (2) properly completed checks and concluded them with 

timely referrals and denials when appropriate; and (3) conducted the checks in 

an efficient manner. The scope and methodology of this review are discussed 

in Appendix A. 

 

1 9/11 and Terrorist Travel, staff report of the National Commission on Terrorist Attacks upon the United States, p. 99, 

August 21, 2004. 

2 The 9/11 Commission Report, National Commission on Terrorist Attacks upon the United States, p. 389, July 22, 2004. 
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USCIS has several significant changes planned and underway for the conduct 

of security checks. The Office of Fraud Detection and National Security 

(FDNS), created in May 2004, has begun to provide centralized support and 

policy guidance for security checks. In addition, USCIS has two automated 

systems in development–the Background Check System and Biometric 

Storage System–that could streamline how USCIS runs, documents, and 

monitors checks. 

Security checks need continued management attention. First, USCIS’ security 

checks are overly reliant on the integrity of names and documents that 

applicants submit; consequently, better use of biometric data is needed to 

verify applicants’ identity. USCIS has not developed a measurable, risk-based 

plan to define how USCIS will improve the scope of security checks. Second, 

except for a small number of benefits, USCIS’ management controls are not 

comprehensive enough to provide assurance that staff completes checks 

correctly. For a minority of cases, slow, inconclusive, or legally inapplicable 

security check results cause applications to stall, but USCIS is pursuing 

several solutions to conclude stalled cases. Finally, USCIS needs improved 

automation to eliminate paper-based, duplicative, and inefficient security 

check processes. Because USCIS’ management of security checks is still 

somewhat decentralized, more coordination will be required to ensure 

efficient progress in implementing the changes USCIS envisions.

We are recommending that USCIS: 1) expand the use of biometric 

identification techniques; 2) establish a comprehensive, risk-based plan for the 

selection and completion of security checks; 3) set objectives for the conduct 

and completion of checks and organize management controls to ensure they 

are met; 4) implement the Background Check Analysis Unit, Background 

Check System, and Biometric Storage System; and 5) define accountability 

and timelines for implementing these changes. 

Background 

On January 24, 2003, USCIS was created as part of the Department of 

Homeland Security. Along with Customs and Border Protection (CBP) and 

Immigration and Customs Enforcement (ICE), USCIS became responsible for 

providing services formerly provided by the Immigration and Naturalization 

Service. USCIS processes over 50 types of benefits for immigrants and nonimmigrants, including citizenship, asylum, legal permanent residence, work 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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authorization, and extension of stay. In Fiscal Year (FY) 2004, USCIS 

completed approximately 7.3 million benefit applications and received 5.9 

million more. Five large processing centers managed most applications, but 

others were processed in more than 33 district offices and sub-offices, eight 

asylum offices, and USCIS headquarters. USCIS’ FY 2004 budget of $1.8 

billion was composed of $236 million in appropriated funds and about $1.6 

billion in fee revenues. 

USCIS’ first of six strategic goals is to ensure the security and integrity of the 

immigration systems, noting that “a secure homeland depends on the integrity 

of our immigration system.”3

 During the benefit application process, USCIS 

conducts security checks in order to prevent ineligible applicants from 

obtaining benefits and to help law enforcement agencies identify people who 

pose risks to national security or public safety. Depending on the application 

submitted, USCIS conducts up to four different types of security checks: 

• Interagency Border Inspection System name checks (IBIS). 

Managed by CBP, IBIS is a database of lookouts, wants, warrants, 

arrests, and convictions consolidated from over 20 agencies. A 

complete IBIS query also includes a concurrent check of selected files 

in the Federal Bureau of Investigation’s (FBI) National Criminal 

Information Center. USCIS began conducting automated, name-based 

queries of IBIS for all USCIS applications in 2002. With an average 

of 3.7 names per application to check,4

 USCIS conducted over 27 

million IBIS checks in FY 2004. 

• FBI fingerprint check. The FBI’s Integrated Automated Fingerprint 

Identification System (IAFIS) matches criminal history records from 

federal, military, and most state apprehensions. USCIS collects and 

electronically submits applicants’ fingerprints for selected benefits 

such as naturalization, permanent residence, and asylum. IAFIS has 

been in place since 1999; before that time, INS manually submitted 

fingerprint cards for criminal history records checks. USCIS 

submitted 1.9 million fingerprints at a cost of $31.9 million in FY 

2004.

• FBI name check. This partially automated, name-based check 

searches over 86 million files documenting people who are the main 

 

3 USCIS Strategic Plan: Securing America’s Promise, p. 6, 2005. 4

 Additional names per application may include family members and aliases, such as married names. 
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subject or referenced in an FBI investigation. USCIS electronically 

submits applicant names to the FBI National Name Check Program for 

benefits such as naturalization, permanent residence, and asylum. The 

legacy INS queried the main files since 1985 but added reference files 

to security checks in 2002. USCIS submitted 1.5 million names at a 

cost of $6.0 million in FY 2004.

• Automated Biometric Identification System (IDENT). Asylum 

offices have used this automated fingerprint identification system since 

1998. Managed by US-VISIT, IDENT enables agencies to screen 

fingerprints against several different database repositories. USCIS 

enrolls aliens applying for asylum in the IDENT-Asylum database, 

screening them against previously enrolled asylum applicants, the 

immigration lookout database of criminal aliens, and the immigration 

recidivist database of repeat immigration offenders. Asylum offices 

completed approximately 146,000 applications receiving this threepart check in FY 2004. 

Appendix C summarizes which checks selected forms receive. In addition, 

depending on the benefit, USCIS checks administrative systems to review 

applicants’ prior immigration history, entry and exits into the United States, 

student records, and immigration court records. When checks result in 

confirmed derogatory information, USCIS has an established process for 

completing the cases with denials and referrals to fraud investigators, law 

enforcement, and the immigration courts. 

USCIS’ current structure for conducting security checks has undergone many 

changes during the past decade. Previous Government Accountability Office 

(GAO) and OIG reports criticized the INS for its failure to complete 

fingerprint checks, failure to review check results during adjudication, 

inadequate controls to deter impostor applicants, inadequate security check 

procedures and training, and an improper emphasis on productivity at the 

expense of accuracy in determining whether applicants were eligible for 

benefits.5

 INS, and later USCIS, made multiple changes to the security check 

process to control the conduct and use of security checks. These include the 

 

5 Alien Fingerprint Requirements in the Immigration and Naturalization Service, Department of Justice (DOJ) OIG 

Report Number I-93-13, February 1994; INS Fingerprinting of Aliens: Efforts to Ensure Authenticity of Aliens' 

Fingerprints, GAO-GGD-95-40, December 22, 1994; INS Criminal Record Verification: Information on Process for 

Citizenship Applicants, GAO-GGD-97-118R, June 4, 1997; An Investigation of the Immigration and Naturalization 

Service's Citizenship USA Initiative, DOJ OIG, July 2000; and Immigration And Naturalization Service's Premium 

Processing Program, DOJ OIG Report Number 03-14, February 2003. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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creation of application support centers to collect applicant fingerprints and 

naturalization quality procedures to guide adjudicators. A more recent change 

is USCIS’ May 2004 creation of the Office of Fraud Detection and National 

Security to provide centralized support and policy guidance for security 

checks and anti-fraud operations. 

USCIS continues to operate under production pressures, decreasing a FY 2003 

backlog of approximately 3.7 million applications to less than one million by 

June 30, 2005. USCIS publicly attributed part of the backlog accumulation to 

the 2002 addition of IBIS name checks for all applications. Without 

compromising security, USCIS plans to eliminate the backlog by the end of 

FY 2006. 

Results of Review 

Scope of security checks should be improved with biometrics and 

strategic planning 

USCIS standards for verifying applicant identity are vulnerable to fraud, 

which lessens the reliability of security checks based on those identities. 

USCIS intends to increase use of biometric identification but has no defined 

plans to do so. However, key changes in screening policy integration and 

information technology (IT) systems design and access are outside USCIS 

control. In order to align the layers of immigrant screening, and ensure 

USCIS’ access to immigrant and screening data sources, greater DHS 

coordination is needed. 

USCIS needs to do more to verify applicants’ identity 

The security and integrity of USCIS’ benefits process is overly reliant on the 

integrity of applicants to provide accurate information about their identity and 

history. The majority of USCIS security checks examine information that 

applicants provide: names, dates and places of birth, and other biographic 

information. Name-based checks are necessary to query records such as those 

in IBIS, but they are vulnerable to identity fraud and have several other 

weaknesses. USCIS supplements name-based checks with automated and 

manual biometric checks using IDENT, IAFIS, the Image Storage and 

Retrieval System (ISRS), and paper records. Biometric checks help to verify 

identity and improve the accuracy of security check results. However, less 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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than a quarter of USCIS’ application workload is subject to fingerprint 

checks; and only two percent receive automated biometric checks that verify 

identity throughout the application process. USCIS is building a Biometric 

Storage System (BSS) that will support using fingerprints in identity 

verification. Other plans to expand biometric checks require definition. 

Relevance and accuracy of name-based security checks

Name-based checks are the majority of USCIS’ security check workload. 

They enable USCIS to review a wide variety of lookout and criminal history 

records. Depending on the benefit involved, USCIS must determine whether 

applicants meet adjudicative standards related to national security, criminal 

history, and even good moral character. Therefore, USCIS considers 

beneficial the broad, name-based checks of FBI investigative files and IBIS, 

which includes records from over 20 agencies. Checking one of IBIS’s 

sources alone, such as the FBI’s Terrorist Screening Database, would not 

provide USCIS with the broad range of information relevant to adjudication. 

USCIS screens all applicants against IBIS, about 7.3 million completed 

applications in FY 2004. Depending on the benefit, a portion of applicants 

also receives the FBI name check and name-based checks against 

administrative records such as the Student and Exchange Visitor Information 

System. These systems do not support queries based on fingerprints or other 

biometric information. 

However, the name-based checks are only as accurate as the supporting 

biographic information used to conduct them. For several reasons, USCIS has 

little assurance that the supporting biographic information is accurate and 

matches the identity of the applicant. First, the information is self-reported by 

applicants, who have an incentive to falsify the information to obtain benefits 

if they are not otherwise eligible. Second, U.S. documents that support the 

self-reported information, such as birth certificates and driver’s licenses, are 

easy to falsify6

–and USCIS accepts documents from all other countries. Plus, 

in many cases, USCIS accepts photocopied documents, which are more easily 

altered than originals. Third, USCIS does not routinely verify identity with 

alternative means, such as contacting bureaus of vital statistics to confirm 

birth certificates or crosschecking addresses with national records. GAO 

reported that alien use of fraudulent documents and identity theft is 

“extensive,” and the staff of the National Commission on Terrorist Attacks 

 

6

 GAO reported that its staff “easily” created fictitious identities and obtained driver’s licenses, birth certificates, and 

social security cards, using computer equipment “readily available to any purchaser.” Security: Counterfeit 

Identification Raises Homeland Security Concerns, GAO-04-133T, p. 1, October 1, 2003. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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reported multiple instances of terrorists obtaining and using fraudulent 

identity documents.7

 

The effectiveness of name-based checks is further limited by how the checks 

are run. Because of the manual data entry involved in creating and searching 

the records, misspellings and typographical mistakes can skew results. When 

people change their names, such as after marriage, the search may miss 

criminal records associated with the old names. Transliterations of nonEnglish and hyphenated spellings also complicate name-based searches. 

Finally, name-based checks create a processing burden to sort through hits 

that do not relate to the applicant searched, which occurs frequently with 

common names. After an analysis comparing name-based and fingerprintbased checks of criminal history records, the FBI reported, “The great weight 

of the evidence supports the FBI and the CJIS APB's [Criminal Justice 

Information Services Advisory Policy Board] conclusion that a name check of 

criminal history record systems is a ‘rough’ process which produces many 

‘false negatives’ (in which a criminal is not identified) and ‘false positives’ (in 

which an individual without a criminal record is identified as having a 

record).”8 

Limited use of biometric checks

Biometric information–photographs, fingerprints, iris scans, and other 

identifiers–provides a more reliable means of verifying identity and querying 

screening databases because people’s biometrics are unique and more difficult 

to falsify. They limit identity fraud as well as reduce false positive and false 

negative screening results. USCIS collects photographs with many 

applications but does not have a system for automated, facial recognition 

screening. Most of the biometric checks USCIS conducts involve 

fingerprints, which USCIS collects for about a quarter of its applications. 

Fingerprints enable USCIS to screen applicants against existing FBI and DHS 

databases. 

• The Automated Biometric Identification System (IDENT). About 

two percent of applications completed in FY 2004 were screened in 

IDENT. By comparing the stored biometric data with fingerprints and 

 

7 Identity Fraud: Prevalence and Links to Alien Illegal Activities, GAO-02-830T, p. 1, June 25, 2002; 9/11 and Terrorist 

Travel, staff report of the National Commission on Terrorist Attacks upon the United States, August 21, 2004. 8

 House Judiciary Subcommittee on Crime Regarding H.R. 3410 and Name Check Efficacy, Hearing on Crime 

Regarding HR 3410 and Name Check Efficacy, May 18, 2000 (statement of David R. Loesch, Assistant Director in 

Charge, Criminal Justice Information Services Division, FBI). 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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photographs that applicants resubmit at several points during the 

application process, the Asylum Branch “locks” an applicant’s identity 

to a single set of biometric and biographic information. This helps the 

Asylum Branch to prevent impostors from interviewing or collecting 

asylum decisions, to identify applicants who apply under more than 

one name, and to find and consolidate multiple application files. Staff 

said that IDENT has been very useful in reducing duplicate filings 

since its implementation in 1998. In FY 2004, the Asylum Branch’s 

screening against three IDENT databases (asylum enrollees, 

immigration lookouts, and immigration recidivists) yielded 2,000 

confirmed hits, mostly immigration recidivists. 

On an exception basis, when other security checks reveal derogatory 

information and the applicant’s identity is in question, some district 

office staff screen a walk-in applicant’s fingerprints with IDENT 

equipment left over from the 2002-2003 National Security Entry/Exit 

Registration.9

 However, this is an unofficial practice. District offices 

do not store and re-check fingerprints to “lock” applicant identity as 

asylum offices do. 

• FBI fingerprint check. Through IAFIS, USCIS submits applicants’ 

fingerprints to the FBI for a biometric check against criminal history 

records from federal, military, and most state apprehensions. As the 

FBI reported, the fingerprint-based check is more accurate than a 

name-based check of these records. USCIS conducted 1.9 million 

fingerprint checks in FY 2004; we calculated that almost a quarter of 

that year’s completed applications included this check. Even though it 

is fingerprint-based, this check has limited ability to verify applicants’ 

identity because the FBI does not keep fingerprints to crosscheck them 

against USCIS’ previous submissions.10 USCIS’ fingerprint storage 

system is still in development. 

• Other biometric checks. For some cases, USCIS staff performs 

visual comparisons of photographs, fingerprints, and signatures stored 

in paper application files and the automated ISRS to help verify an 

applicant’s identity. Manual review of biometric information occurs 

for about half of the application workload and before fingerprint 

 

9

 The INS deployed IDENT-ENFORCE (Enforcement Case Tracking System) equipment to district offices to collect 

fingerprints and register aliens from selected countries. CBP and ICE now administer this program. 10 USCIS checks are considered administrative. The FBI does not keep fingerprints on file unless they were checked for 

criminal purposes. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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collection at application support centers. Manual checks are slower 

and more vulnerable to error than automated ones, and they are not 

readily accessible to all staff. Staff said that paper applications are 

rarely on hand for immigration information officers handling walk-in 

appointments, and even adjudicators are sometimes unable to obtain 

files stored in different offices. In addition, staff we interviewed in 

late 2004 was still seeking access to ISRS, which the 2003 Security 

Matrix Project Recommendations Report encouraged USCIS to 

expand. 

The government is moving toward greater use of biometric screening. 

Homeland Security Presidential Directive (HSPD) 11, “Comprehensive 

Terrorist-Related Screening Procedures,” directed the Secretary of Homeland 

Security and an interagency working group to submit to the President a plan to 

improve terrorist-related screening that includes security features “that resist 

circumvention to the greatest extent possible” and that defines what identifiers 

to use in screening, including biometric ones. As of October 2004, the 

Department of State collects fingerprints and photographs from all visa 

applicants, about 7 million per year, to screen against IDENT. For applicants 

exempt from fingerprinting, such as children under 14, the Department of 

State conducts automated facial recognition screening, which along with the 

fingerprinting, serves to lock identity. Between October 2004 and March 

2005, the system identified almost 5,000 mala fide applicants. The biometrics 

collected by the Department of State are linked with United States Visitor and 

Immigrant Status Indicator Technology (US-VISIT), which also uses IDENT 

technology, and screens applicants with biometric identifiers. 

USCIS’ limited ability to verify and lock applicants’ identity poses several 

problems. Without automated biometric identification, establishing that the 

hit from a name-based check matches the identity of the applicant can be 

labor-intensive. For example, USCIS reported that one service center required 

an average of 5.4 additional database queries to verify an identity match for 

each positive IBIS name check. Delays in obtaining file biometric 

information to verify identity can interfere in acting on lookouts and warrants. 

An immigration information officer reported an instance when he could not 

obtain a file containing biometric information in time to verify a walk-in 

applicant’s identity so that he could act on a security hit’s warrant before the 

day’s appointments ended and the applicant departed. The ultimate problem 

caused by limited identity verification, however, is that USCIS may provide 

ineligible aliens with benefits. Staff said rescission or revocation of benefits 

is rare and has a high legal threshold. Furthermore, a benefit from USCIS 
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assists aliens in applying for other benefits–driver’s licenses, social security 

numbers, bank accounts, and in some states, gun licenses–enabling the alien to 

embed into society legally. 

The ten-year business and information technology modernization plans that 

INS’s Immigration Services published in 2001 support increased use of 

biometrics, as does the USCIS Strategic Plan issued in 2005. USCIS has not 

developed a risk-based plan that outlines how, when, and for what benefits 

expansion should occur, or that assigns accountability, timelines, and 

milestones for plan implementation. Nevertheless, USCIS is expanding its 

biometric capacity on an ad hoc basis. In late 2004, USCIS added 

fingerprinting for temporary protected status holders re-registering for 

benefits. In spring 2005, USCIS awarded a contract to build, test, and 

implement BSS to store applicant fingerprints and photographs. Under 

development for several years, BSS will support FBI fingerprint checks and 

will potentially compare BSS biometrics with alien biometrics in US-VISIT 

collected by the Department of State and CBP. 

Senior officials said that USCIS’ use of biometrics has been constrained by 

the capacity of application support centers to collect the data. Application 

support centers collected 1.9 million fingerprint submissions in FY 2004, 

while USCIS’ full application volume was about 5.9 million receipts. Staff 

said that most application support centers could process more applicants, but 

they are limited by an inefficient computerized scheduling system and labor. 

Staff estimates that consolidating the five-part scheduling system could 

increase capacity by more than a million appointments per year. Draft 

information technology architecture documents from the Chief Information 

Officer discuss improving the scheduling system. USCIS is adding 173 

federal and contract staff to application support centers in FY 2005. 

USCIS should develop a comprehensive, strategic plan for enhancing 

security checks 

Since 2001, USCIS has made a number of changes to enhance the coverage of 

security checks for immigration benefits applicants. The changes USCIS has 

made to the content of security checks have been reactions to perceived gaps, 

a 2003 review, and separate office initiatives. There is no apparent effort to 

develop a strategic plan for selecting and conducting security checks. USCIS 

needs to develop such a plan, using risk assessment to prioritize efforts and 

allocate screening resources. 
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In response to incidents in 2001 and 2002 involving benefits granted to 

members of terrorist groups, staff added IBIS checks for all applications, 

greater use of entry-exit data, and FBI name check screening of reference 

files.11 In 2003, USCIS subject matter experts reviewed the battery of 

administrative and security checks to identify additional check needs and 

redundancies.12 The resulting report recommended retaining existing IBIS 

and FBI name checks, expanding biometric checks, and increasing 

adjudicators’ access to databases for further, optional checking. USCIS 

implemented several of its recommendations, such as increasing the validity 

period of IBIS checks from 35 to 90 days.13 Some recommendations were not 

completed, and at the time of our review, no staff was monitoring their 

implementation. However, discrete initiatives from FDNS and other offices 

continue to refine the security check structure. For example, the Asylum 

Branch recently added FBI name checks of asylum applicants’ aliases. 

USCIS has not used more comprehensive program analysis to allocate 

screening resources and develop a plan for security checks. In essence, 

USCIS has not determined whether the resources used for certain checks 

might be used to greater effect with other checks. USCIS has limited program 

and performance information in order to make such a determination. For 

example, there is no statistically valid measurement of the prevalence of mala 

fide applicants in different application pools.14 In addition, USCIS has 

collected little measurement information on the effectiveness of different 

checks. USCIS’ automated systems do not provide program management 

information that ties together security check results and adjudication 

outcomes. FDNS is beginning to develop both types of information. Through 

the Benefits Fraud Assessment, expected to be completed in 2005, FDNS has 

begun to measure the frequency of mala fide applicants for six benefits that 

staff considers historically prone to fraud or high-risk.15 Also in 2005, FDNS 

began manually to collect information on adjudication outcomes associated 

with a sample of positive FBI name checks. 

 

11 The Immigration and Naturalization Service’s Contacts with Two September 11 Terrorists: A Review of the INS’s 

Admissions of Mohamed Atta and Marwan Alshehhi, its Processing of their Change of Status Applications, and its 

Efforts to Track Foreign Students in the United States, DOJ OIG, May 20, 2002; Review of the Circumstances 

Surrounding the Naturalization of an Alien Known to be an Associate of a Terrorist Organization, INS Office of Internal 

Audit, December 13, 2002. 

12 USCIS, “Security Matrix Project Recommendations Report,” May 2003. 

13 Increasing the validity period reduced the number of IBIS checks USCIS conducts. 14 Immigration Benefit Fraud: Focused Approach is Needed to Address Problems, GAO-02-66, January 31, 2002. 15 USCIS processes over 50 types of benefits. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Changes to the security check structure should be guided by these kinds of 

analyses and a comprehensive, prioritized plan that assigns accountability and 

timelines for implementation. For example, although USCIS has intended to 

expand biometric identification since at least 2001, it has not determined when 

and for which forms biometric checks should be added, and it is not clear who 

is responsible for the determination. To improve its ad hoc arrangement for 

enhancing security checks, USCIS should 1) assess the risks posed by 

different applicant types and the effectiveness of checks in addressing that 

risk; 2) select improvements that maximize the benefit to the integrity of the 

immigration system while managing cost; and 3) plan for any improvements 

by assigning accountability and timelines, in order to ensure aggressive 

progress and results in meeting objectives. 

Need for Increased DHS Role 

The comprehensiveness of any USCIS plan will be limited by its dependence 

on systems and policies developed outside of USCIS. In order to align the 

layers of immigrant screening, and ensure USCIS’ access to immigrant and 

screening data sources, greater DHS coordination is needed. 

The plans and policies of US-VISIT, CBP, and ICE shape the checks USCIS 

conducts: 

• The US-VISIT systems architecture houses the biometric data that 

USCIS collects for asylum applicants and plans to collect for other 

applicants. US-VISIT has the potential to permit USCIS to screen 

IDENT-Asylum and BSS enrollees against US-VISIT records of visas, 

entries, and exits, in order to establish identity and travel history. This 

capacity is not yet established, but US-VISIT staff began in 2005 to 

discuss plans to link these databases. 

• CBP manages the IBIS lookout system on which USCIS depends for 

the majority of its security checks. Currently, CBP sets the user 

profile that determines which IBIS records USCIS views. In 

December 2004, CBP folded into IBIS the National Automated 

Immigration Lookout System II (NAILS), which was USCIS’ primary 

tool for managing lookouts and fraud alerts. CBP did not fully retain 

NAILS features during the consolidation, reducing USCIS’ ability to 

adjust lookout records with information such as changes of 

immigration status that may resolve lookouts. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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• ICE sets the policy for security checks for aliens seeking benefits 

through Department of Justice’s (DOJ) Executive Office for 

Immigration Review (EOIR). USCIS staff conducts these security 

checks and provides documentation of status when the immigration 

court grants benefits. Previously, ICE had no standardized 

requirements for checking aliens applying for benefits through the 

courts, and USCIS completed checks according to its own standards 

before issuing documentation. Delays in completing USCIS security 

checks for court grantees exposed USCIS to several lawsuits. Starting 

in April 2005, ICE standardized a process that requires the completion 

of IBIS and FBI fingerprint checks and the initiation of FBI name 

checks. With limited exceptions, USCIS will no longer withhold 

documentation of status from court grantees until checks are complete 

according to USCIS standards. 

DHS could do more to coordinate screening between its components. For 

example, USCIS and ICE disagree about the cost-benefit of holding a case 

until the FBI finalizes a pending response to name check hits, which takes 

over six months for one percent of cases. For example, ICE security check 

procedures allow an applicant to receive asylum while the FBI name check is 

still pending, which means the FBI believes it has investigative records on the 

applicant but has not completed collecting and reviewing them for transmittal 

to ICE. In contrast, USCIS holds asylum applications until the FBI name 

check is complete. Also, USCIS refused to provide documentation of status to 

ICE-processed asylees until they passed an FBI name check, which USCIS 

initiated for them. DHS headquarters and the Directorate of Border and 

Transportation Security did not resolve the disagreement between USCIS and 

ICE about whether waiting for completed FBI name checks has benefits 

outweighing its costs. After discussions, USCIS agreed to continue to initiate 

FBI name checks for its own and for ICE-processed applicants, but neither 

agency will wait for ICE-processed applicants to pass the FBI name checks 

before the case decision and documentation of status. Thus, screening 

procedures for the same benefits are inconsistent. DHS should reconcile the 

inconsistent interpretations of the check’s cost-benefits to improve security 

and efficiency. 

In coordinating screening, DHS may further assist USCIS by facilitating 

information sharing, not only within DHS but also with the FBI and other 

external agencies. The Memorandum of Understanding by which USCIS 

accesses IBIS is a 1993 document between the INS and U.S. Customs. It 

should be updated to clarify USCIS and CBP responsibilities for information 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 14 

sharing. The memorandum specifies that INS must have separate agreements 

with the other users of IBIS in order to view their lookout records, which 

raises the question of whether USCIS must recreate agreements since the 2003 

division of INS, or whether other agreements within DHS provide USCIS 

with lookout access. In another example, for several years USCIS asked the 

FBI to remove restrictions on USCIS’ name-based queries of the National 

Crime Information Center. Citing the Privacy Compact of 1988, the FBI 

permits USCIS to submit fingerprint-based queries via IAFIS but restricts 

name-based ones.16 USCIS argues that name-based queries provide 

information more rapidly and efficiently. GAO recently reported that the 

Department of State visa adjudication process would be more efficient with 

greater access to these name-based queries.17 USCIS has been working with 

the Department of State to gain access. 

DHS should facilitate USCIS’ access to screening information and assist in 

the coordination of screening strategies among DHS components. Moving 

toward greater coordination of screening efforts, DHS recently established a 

Screening Integration Working Group, including USCIS and other DHS 

components, to plan a coordinated strategy for screening individuals. This fits 

the intent of HSPD-11 to emplace “a coordinated and comprehensive 

approach” to screening across immigration, law enforcement, intelligence, and 

security components throughout the government. As DHS expands its efforts 

to coordinate screening, USCIS screening should receive greater attention and 

support. Aliens are eligible for some USCIS benefits, such as interim 

employment authorization documents, even when security checks return 

derogatory results. Furthermore, USCIS serves as the sole screener of some 

immigrants who enter without inspection or visas, thereby avoiding screening 

by CBP and the Department of State. Benefits for which unscreened 

immigrants apply to USCIS include asylum, adjustment of status under INA § 

245(i), temporary protected status, and potentially, proposed guest worker 

programs. The USCIS benefits process is the government’s first opportunity 

to screen these aliens against intelligence and lookout records. 

 

16 These fingerprint- and name-based queries of the National Crime Information Center review federal and state criminal 

history records (charges and convictions) in the Interstate Identification Index. Currently, USCIS uses name-based 

queries of the National Crime Information Center only when other screening indicates the applicant has a criminal 

history. The FBI name check discussed elsewhere in this report, which is conducted through the National Name Check 

Program, reviews records of previous and ongoing FBI investigations. 

17 Strengthened Visa Process Would Benefit from Improvements in Staffing and Information Sharing, GAO-05-859, 

September 13, 2005. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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USCIS should continue to improve accuracy and timeliness of check 

completion 

USCIS quality assurance and OIG sampling show that USCIS staff completes 

most required security checks. However, USCIS does not have 

comprehensive controls to prevent and identify mistakes when they occur. 

Further, USCIS has difficulty creating and retrieving historical records that 

show what checks were done when. Additionally, for a minority of cases, 

delayed and inconclusive security check results stall application processing 

for long periods. USCIS is strengthening its structure for processing security 

check hits and concluding cases that involve fraud or national security 

concerns with timely denials and law enforcement referrals. 

Management controls to ensure check completion need improvement 

Because of the manual effort and judgment involved in adjudicating 

immigration benefits, including security checks, the process is vulnerable to 

human error. Although USCIS staff performs most security checks in 

compliance with procedures, file sampling conducted during routine USCIS 

quality assurance and our inspection revealed security check errors for every 

form type reviewed. The errors vary in significance from incomplete file 

documentation to the approval of benefits without review of positive security 

check hits. They also vary in frequency, from less than one percent per 

sample, which meets USCIS’ designated acceptable quality level, to over 

95 percent for one form sampled. Though there are few reports of USCIS 

approving benefits for the mala fide, incomplete checks present a security 

vulnerability. Management controls to ensure check completion, including 

documentation and quality assurance reviews, are not comprehensive and 

should be improved. 

In its March 2005 Backlog Elimination Plan report, for the fourth quarter of 

FY 2004, USCIS indicated that application processing errors are controlled: 

For cases reviewed during the fourth quarter of 2004, USCIS achieved 

an overall processing accuracy rate of 99.6% and a critical processing 

accuracy rate of 99.7%, exceeding the minimum acceptable accuracy 

rates of 96% and 99% respectively. In all cases, corrective actions to 

prevent future problems were implemented. It was also verified that in 

applications where errors were detected, no applicant received a 

benefit for which he/she was not eligible. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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“Critical” errors, which may occur in no more than one percent of forms 

reviewed in order to meet the acceptable quality level, include errors in 

security checks. In fact, security check errors are the most common critical 

error found during national quality assurance reviews. For the quarter 

described, the 80 critical processing errors involved IBIS name checks (72 

instances) and FBI fingerprint checks (three instances). Critical errors found 

in the remainder of FY 2004 are in similar proportion. USCIS’ fourth quarter 

FY 2004 quality assurance report added, “Although, the Service is 

experiencing a trend in IBIS errors (a trend indicates that there is a system, 

process or procedural problem that needs to be addressed), the errors are 

within the Acceptable Quality Levels.” The trend continued in the first 

quarter of FY 2005, and USCIS reported it was studying IBIS name checks 

and anticipating improvements in procedures and training.18 

However, these reports do not reflect all USCIS application processing. The 

national quality assurance program discussed above involves only the N-400 

Application for Naturalization, which was 8.7 percent of USCIS’ completed 

applications in FY 2004. Because the N-400 is completed with different 

automated systems and standard operating procedures (SOPs), its quality 

results are not indicative of other forms’. In February 2005, USCIS added 

national quality assurance reviews for the I-485 Application to Register 

Permanent Residence or to Adjust Status, covering service center and district 

office processing. Additional monthly quality assurance reviews are 

conducted by Service Center Operations, which in FY 2004 reviewed the I485, I-130 Petition for Alien Relative, and I-539 Application to 

Extend/Change Nonimmigrant Status. Service Center Operations suspended 

review of the I-539 in June 2004 and began reviewing the I-130 in August 

2004. In sum, each month up to a third of USCIS’ completed applications is 

subject to random sampling for quality assurance. 

Overall error rates are higher for the I-539, I-130, and I-485 than for the N400. Furthermore, errors in the I-130 and I-485 samples exceed the one 

percent acceptable quality level for critical errors. Although USCIS does not 

monitor the proportion of security check errors as a whole, we extrapolated 

the following from monthly and quarterly reports: 

 

18 “Quality Management Summary, Consolidated Service-Wide Quality Results – 1st Quarter FY 2005,” April 14, 2005. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Figure 1: USCIS Quality Assurance – Errors Found 

Form Months 

reviewed 

Files 

reviewed

Files with

errors 

Proportion 

of files 

with errors 

Files with 

security check 

errors19

Proportion of 

files with security

check errors 

I-130 

Petition for Alien Relative 8/04-9/04 2,707 177 6.5% 44 1.6% 

I-485

Application to Register Permanent 

Residence or to Adjust Status 

10/03-9/04 9,521 539 5.7% 190 2.0% 

N-400

Application for Naturalization 7/04-9/0420 10,246 272 2.7% 75 0.7% 

I-539 

Application to Extend/Change 

Nonimmigrant Status 

10/03-6/04 12,399 533 4.3% 70 0.6% 

To extend our assessment of the risk of security check errors among USCIS 

applications, we sampled eight of the remaining forms that do not receive 

quality assurance reviews from USCIS. The eight forms represent an 

additional 51.3 percent of USCIS’ FY 2004 workload and require different 

combinations of IBIS name checks, FBI fingerprint checks, and FBI name 

checks. We narrowed our sample to FY 2004 approvals in order to identify 

whether applicants received benefits despite incomplete checks. For further 

description of the sampling methodology, see Appendix A. 

Every form type in our sample showed files with undocumented, untimely, or 

missing security checks. For the N-400, USCIS guidelines consider all these 

error types, including incomplete file documentation, to be critical errors. 

Although our sample and the quality assurance samples are not strictly 

comparable because of their different methodology, we note that the same 

types of errors occurred in higher proportion in every form in our sample, than 

in the forms receiving routine quality assurance reviews. 

 

19 Individual errors noted on the reports included missing, untimely, unresolved, or undocumented IBIS name checks, 

FBI fingerprint checks, and FBI name checks. Untimely checks are ones processed after adjudication or more than 90 

days prior for IBIS, or 15 months prior for FBI fingerprint checks. Unresolved checks are ones with hits confirmed on 

the applicant but not explained in the required resolution memorandum. The I-539 and I-130 receive only IBIS name 

checks. 

20 National quality assurance for the N-400 included all months of FY 2004, but until the fourth quarter, staff reported 

results by review item rather than by application file. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Figure 2: OIG Sampling Results – Total Errors Found 

Form FY 2004 

approvals 

Files 

reviewed 

Files with 

security check 

errors 

Proportion of 

reviewed files 

with security 

check errors 

I-765 

Application for Employment Authorization 1,213,534 112 10 8.9% 

I-90 

Application to Replace Permanent Resident Card 1,016,146 100 15 15.0% 

I-129 

Petition for A Nonimmigrant Worker 486,051 116 11 9.5% 

I-821 

Application for Temporary Protected Status 66,356 66 8 12.1% 

I-881

NACARA–Suspension of Deportation or

Application for Special Rule Cancellation of Removal

31,106 69 3 4.3% 

I-730 

Refugee/Asylee Relative Petition 24,492 47 30 63.8% 

I-589 

Application for Asylum 14,331 69 2 2.9% 

I-192 

Application for Advance Permission to

Enter as Nonimmigrant

84 52 50 96.2% 

In a follow-up to the sample, USCIS was able to demonstrate with automated 

and other records that many of the checks that appeared to be missing were in 

fact conducted but not documented in the file. Four form types showed errors 

solely in documentation and did not appear to be missing security checks. 

The following table reflects the common error types we observed: 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Figure 3: OIG Sampling Results –Type of Errors Found 

Error type for missing, untimely, or unresolved security checks 

IBIS 

Name check 

FBI 

Fingerprint check 

FBI 

Name check Form 

Total 

files with 

security 

check 

errors 

Files with 

improperly 

documented 

checks 

Files with 

missing, 

untimely, or 

unresolved 

security 

checks 

Missing Untimely Missing Untimely Missing 

I-765 10 10 0 0 0 NA NA NA 

I-90 15 15 0 0 0 NA NA NA 

I-129 11 10 1 0 1 NA NA NA 

I-821 8 4 4 1 1 1 1 NA 

I-881 3 3 0 0 0 0 0 0 

I-730 30 16 1421 6 8 NA NA NA 

I-589 2 2 0 0 0 0 0 0 

I-192 5022 0 50 0 0 0 3 49 

In particular, the I-192, I-730, and I-821 show substantial errors in processing 

security checks. For the IBIS check to appear missing in both the paper file 

and the automated case history, as seven I-730 and I-821 forms show, 

indicates that an automated IBIS check resulted in a positive hit, but the 

adjudicator did not review or resolve it before approving the case.23 The other 

major error our sampling shows is a lapse in following the guidelines to 

conduct FBI name checks for I-192 forms. Of 52 files, 49 (94.2 percent) 

lacked FBI name checks. Staff at Vermont Service Center, which processed 

most of the I-192s in our sample, questioned whether the FBI name check is 

required for the I-192. But Chapter 42 of the Adjudicators Field Manual and 

several headquarters documents require the FBI name check and fingerprint 

check for the I-192. 

Management controls to ensure check completion are inadequate

One explanation for the number of security check errors is that USCIS has not 

implemented sufficient management controls to limit errors. The low 

 

21 USCIS claims that 13 of the missing or untimely I-730 IBIS checks may be solely documentation errors. The USCIS 

paper and automated records show no current check, but original forms were forwarded to Department of State for visa 

processing. For nine other original I-730 forms returned to USCIS, eight showed current IBIS checks and one did not. 

22 Because some files contained more than one error type, the number of files with errors is not a sum of errors found. 23 All of the forms in our sample, which excluded forms processed manually at the district offices, receive automated 

IBIS checks for the primary name that is data-entered. According to the processing rules, the Interim IBIS program 

updates the CLAIMS 3 automated case history when the IBIS check results in no hit. If a check results in a hit, 

CLAIMS 3 history will show no record of it; therefore, a history that is blank regarding IBIS checks implies an IBIS hit. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 20 

proportion of errors now shown on N-400s is achieved by several means,24

including: 

• Detailed, form-specific standard operating and quality review 

procedures; 

• An automated processing system (CLAIMS 4) that prohibits 

adjudicators from approving cases until certain security checks are 

complete; 

• Monthly quality assurance reviews, including correction of errors 

discovered and analysis of error trends; and 

• Recurrent training for staff on processing standards and changes. 

But the management controls for other forms vary, and in some cases, they are 

far less comprehensive. We identified several types of controls that USCIS 

could use more fully to limit errors. We acknowledge that varying levels of 

control can reflect management judgment about the risk involved in granting a 

specific benefit to a mala fide or unqualified alien and the costs of 

implementing stricter controls. Not all of the following controls are high-cost, 

however.

First, USCIS needs to improve how it documents and disseminates the 

policies and procedures for security checks. Communication of procedures is 

a longstanding issue for immigration services; in 1997 and 2001, GAO 

reported, “[P]oor communication was a problem, especially between 

headquarters and field units. For example, field and policy manuals were out 

of date and there was not one place that program staff could go for 

direction.”25 

 

No SOP summarizes the current security check requirements for all forms. 

Revisions to the outdated Chapter 16 of the Adjudicators Field Manual, 

“Fingerprinting and Other Agency Background Checks,” have been in draft 

for months. USCIS plans but has not begun to update the November 2002 

SOP for IBIS name checks. In addition, although district office staff has had 

difficulty submitting and retrieving FBI name checks, they have no manual 

clarifying those procedures. In some cases, form-specific national SOPs 

consolidate security check guidance. Eight of the 12 forms discussed here 

 

24 In tandem with a critical report in 2000 from the DOJ OIG,USCIS (then part of the Immigration and Naturalization 

Service) reengineered the processing of the N-400 to limit errors. (An Investigation of the Immigration and 

Naturalization Service’s Citizenship USA Initiative, July 31, 2000). 25 Immigration and Naturalization Service: Overview of Recurring Management Challenges, GAO-02-168T, p. 5, 

October 17, 2001; INS Management: Follow-up on Selected Problems, GAO/GGD-97-132, July 22, 1997. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 21 

have SOPs. The four that do not–the I-129, I-192, I-730, and I-821–were the 

ones that showed missing or untimely security checks. Most other forms do 

not have specific national SOPs either. 

Additional security check requirements are reflected in a patchwork of 

memoranda and manuals. For example, USCIS issued at least seven

memoranda altering security check procedures in March and April 2005. 

Staff at seven of 11 processing sites we visited expressed frustration with the 

quantity or insufficient clarity of changes to security check procedures. At 

three sites, staff maintains local guidelines to consolidate and clarify security 

check requirements. 

Second, for some but not most forms, USCIS implemented automated controls 

on check completion. Naturalization forms processed in CLAIMS 4 and 

asylum forms processed in the Refugee Asylum and Parole System (RAPS) 

have automated, rule-based support that requires security checks to be 

complete before the adjudicator can approve the case. The Department of 

State has had similar controls in place for visa approvals since 1996. When 

checks result in positive hits, adjudicators must override them, which prevents 

overlooking hits. 

Our sample included two forms processed in RAPS (the I-589 and I-881) and 

all security checks processed through RAPS were complete. However, 

USCIS processes the majority of forms in CLAIMS 3, which does not have 

these automated controls. All the forms in our sample with missing or 

untimely checks were processed in CLAIMS 3. Furthermore, some forms 

filed at the district offices are not supported by any of these national 

automated systems. USCIS staff reported that adding automated controls for 

forms processed in CLAIMS 3 or manually will be difficult until USCIS has a 

new automated case management system, planned since 2001 but not 

expected until 2007. However, even before fielding a new case management 

system, USCIS may better leverage automated controls on check completion. 

For example, automated controls ensured that IBIS checks were complete for 

the I-90s in our sample that were processed in CLAIMS 3 under Systems 

Qualified Adjudication rules. 

Third, USCIS lacks a complete record of checks performed. USCIS needs the 

records to conduct quality assurance and supervisory reviews and to enable 

staff to refer to previous, current checks rather than duplicate them. When 

USCIS began IBIS name checks, guidelines required paper documentation of 

all checks: “The record will be updated to reflect the results of every IBIS 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 22 

query ... When batch checks are conducted, confirmation that the check was 

performed must be placed in the file.”26 The IBIS SOP supports full paper 

documentation. However, senior officials disputed whether all security 

checks must be documented in paper files, when automated systems also 

contain records of checks. 

In our estimation, neither method currently provides adequate control because 

both are incomplete; and paper records in particular are vulnerable to error. 

Almost half of the security check errors discovered during our sampling (60 of 

129, or 46.5 percent) involved paper documentation lapses. Some 

adjudicators continue to document IBIS checks by stamping applications. 

While quick, stamps in our sample were sometimes accompanied by illegible 

dates, results, and conductor initials, and stamps do not indicate which names 

were checked. The more detailed Record of IBIS Query, which the IBIS SOP 

requires, does record which names staff check. However, among over 300 

forms in our sample where applicants listed more than one name, staff did not 

complete a Record of IBIS Query for 125. The paper records do not indicate 

whether staff performed IBIS checks on the aliases as required. 

Automated records do not fully capture alias information, either. 

Furthermore, they do not reflect other important processing steps that are still 

performed manually: individual IBIS queries, adjudicator review of hits, and 

hit resolution. As a result, USCIS’ security check records are fragmentary. 

Incomplete records hinder staff in monitoring check completion and result in 

processing inefficiencies. Several managers and staff told us adjudicators 

routinely conduct new checks rather than rely on the file record. Additionally, 

incomplete automated records compel staff to conduct quality assurance 

manually.27 

Fourth, USCIS should reexamine its controls for reviewing check completion. 

USCIS has set national standards for formal quality assurance and supervisory 

review, but these reviews cover a small proportion of completed applications. 

As mentioned, national and Service Center Operations quality assurance 

samples up to a third of USCIS’ completed applications each month. National 

supervisory review of security checks occurs through the resolution 

memorandum for all IBIS name checks with confirmed hits, which are about 

two percent of IBIS checks. Additionally, supervisors in asylum offices use a 

checklist to review all security checks. 

 

26 “Interagency Border Inspection System Records Check,” July 2, 2002. 27 USCIS does not have a process for auditing IBIS checks by reviewing the source records retained by CBP. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Beyond these reviews, processing offices provide a variety of supervisory and 

quality assurance checks. Four processing sites we visited, two of which were 

asylum offices, provided 100 percent supervisory review of security checks. 

Other offices review a percentage of applications completed, approved, or 

denied, sometimes based on form type or adjudicator tenure. Our concerns 

with this approach are twofold: 1) providing supervisory review based on 

form type can result in certain forms receiving no review; and 2) reviewing 

application denials is of lesser benefit to security because any mala fide 

benefit recipients are among the approvals. Quality assurance also varied 

among offices. Two processing sites we visited provided routine quality 

assurance for all forms; two, for all IBIS checks; and two were considering 

adding quality assurance for all IBIS checks. Other quality assurance staff 

with whom we met supplemented the national program with ad hoc reviews. 

A number of forms are not subject to quality assurance. This is a missed 

opportunity for USCIS: staff reported that quality assurance reviews have 

helped to extinguish incorrect processing behaviors and provided a retraining 

opportunity. USCIS does not require refresher training on how to conduct 

security checks or procedural updates. An additional concern regarding 

quality assurance is that USCIS designated an acceptable quality level (for 

example, the one percent critical error rate) for only a few forms. USCIS 

should establish measures for the remaining forms or apply this one. It will be 

important for USCIS to continue to review security check performance and 

provide management with information to adjust management controls to 

ensure performance goals are met. 

Incomplete security checks and weaknesses in USCIS management controls 

must be considered in context. Many USCIS applicants are bona fide. As 

GAO wrote in 1995, “While INS recognizes that even a relatively small 

number of aliens should not inappropriately receive benefits, it did not want to 

give the false impression that a criminal or terrorist receives a benefit every 

time a fingerprint check is not properly conducted.”28 We agree that this 

holds true for any type of USCIS security check. For the files in our sample 

with missing or untimely IBIS checks, USCIS ran new queries and reported 

no derogatory information on all people checked. Three offices we visited 

reported similar experiences with correcting erroneous IBIS and FBI name 

checks. But whether USCIS’ incomplete security checks involve bona fide or 

 

28 INS Fingerprinting of Aliens: Efforts to Ensure Authenticity of Aliens’ Fingerprints, GAO/GGD 95-40, p. 4, December 

22, 1994. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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mala fide applicants is a matter of chance. In 2002, incomplete screening led 

a USCIS adjudicator to approve naturalization for a member of a terrorist 

group.29 Though there are few reports of USCIS approving benefits for the 

mala fide, incomplete checks present a security vulnerability that USCIS 

should address through targeted improvements to management controls on 

check completion. 

USCIS is implementing solutions to complete stalled cases 

USCIS has an established structure for handling cases with security check hits 

and addressing national security, public safety, and fraud concerns. However, 

for a fraction of cases, slow, inconclusive, or legally inapplicable security 

check results can cause application processing to stall for months or even 

years. These delays can interfere with USCIS’ concluding national security 

and public safety hits with timely denials or referrals to law enforcement. In 

addition, stalled cases decrease operational efficiency by reducing 

productivity and contributing to hundreds of lawsuits against USCIS. USCIS 

is pursuing several solutions to mitigate these effects and close stalled cases. 

Staff described four primary ways that security checks could stall processing 

on a case: 

• Pending FBI name checks. Unlike other USCIS checks that return 

results within a few days at most, the FBI name check takes more than 

a month to complete for six percent of submissions. For one percent, 

the FBI takes more than six months to compile the hit information and 

verify that the initial hit matches the identity of the applicant. In 

December 2002, USCIS (then INS) resubmitted 2.4 million applicant 

names for expanded checks,30 almost double the number USCIS 

typically submits in a year’s time. As of February 2005, USCIS 

reported 171,428 FBI name checks pending, including approximately 

8,500 remaining from the December 2002 rerun. USCIS may pay the 

FBI double to “expedite” up to a few hundred FBI name checks per 

month. USCIS restricts these requests to certain cases, such as when 

the alien is about to become ineligible due to age, the applicant files 

writ of mandamus lawsuits to compel USCIS to complete adjudication, 

 

29 Review of the Circumstances Surrounding the Naturalization of an Alien Known to be an Associate of a Terrorist 

Organization, INS Office of Internal Audit, December 13, 2002. 30 Ibid. In response to an incident that involved processing benefits for a member of a terrorist group, INS added 

searches of the FBI’s reference file to searches of the main investigation file. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 25 

or other humanitarian factors. The “expedite” requests are insufficient 

to clear the backlog of FBI name checks. 

• Open cases referred to ICE for investigation. When USCIS refers 

an open case to ICE for investigation, staff said long delays often 

occur before they receive clearance to complete the adjudication or 

another definitive response. In 2004, FDNS reviewed the IBIS 

national security/terrorism-related hit referral process and found that 

ICE was capable of resolving only about a quarter of the USCIS 

referrals in a timely manner. We observed rows of files USCIS staff 

shelved, pending a response from ICE. 8 C.F.R. § 103.2(b)(18) allows 

USCIS to place cases in formal abeyance and withhold adjudication 

when there is an ongoing investigation relating to the petitioner’s 

eligibility and disclosure to the petitioner would jeopardize the 

investigation. 

• Inconclusive results from checks and referrals. Senior officials and 

staff said that security checks and supplementary information from 

FBI, ICE, or other record owners can sometimes be vague, 

inconclusive, or difficult to relate to the case adjudication. At one 

district office, staff said they shelved cases with complete, positive 

FBI name check responses for months, pending guidance on how to 

adjudicate them. 

• Legally inapplicable security check results. In a 2003 audit, the 

DOJ OIG reported that INS could not deny the petition of an alien 

otherwise eligible for temporary worker benefits based on an IBIS 

hit.31 Unlike the adjudicative standards in the Immigration and 

Nationality Act for most benefits, the standards for adjudicating 

employment- and family-based petitions require USCIS to evaluate 

only the authenticity of the employment offer or family relationship,

without regard to whether the person evokes security concerns. These 

employment- and family-based petitions serve simply to document the 

relationship, but they enable approved aliens to apply for other 

benefits such as legal permanent residence and visas from the 

Department of State. Nevertheless, USCIS would prefer not to 

approve any petition when security concerns have been identified. 

USCIS sometimes withholds adjudication through an informal 

 

31 Immigration and Naturalization Service’s Premium Processing Program, DOJ OIG Report No. 03-14, February 2003. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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abeyance; 8 C.F.R. § 103.2(b)(18) does not apply unless the 

investigation relates to the pending application. 

Previous options that USCIS had for completing these four types of cases in a 

timely manner were insufficient. Given their partially automated systems, 

staffing level, and number of customers other than USCIS, the FBI’s National 

Name Check Program officials said they could not complete USCIS’ routine 

cases more quickly. The American Immigration Lawyers Association said 

that lawyers have begun to recognize that filing mandamus lawsuits helps to 

expedite FBI name check results. The USCIS Office of Chief Counsel 

estimated there were 1,000 cases filed in the federal courts last year naming 

USCIS as a party, of which 80 to 90 percent relate to security checks.32 This 

“solution” may assist applicants, but the volume of cases consumes USCIS 

time and resources that could be used elsewhere. Regardless, there are not 

enough “expedite” slots for all pending FBI name checks. 

For the relationship-based petitions, USCIS options include withholding 

adjudication through an ongoing, informal abeyance; requesting that 

applicants withdraw the petitions; or approving the petitions in the expectation 

that applicants will be denied at another point in the process. However, delays 

from informal abeyance are also vulnerable to legal challenge. Furthermore, 

applicants can refuse to withdraw petitions, and the transfer of derogatory 

information to support later denial is not fail-safe. For some cases, USCIS 

relies on the Department of State to deny the alien a visa. USCIS forwards 

petitions stamped “admissibility concerns identified” to visa processing 

centers. Because information-sharing protocols prevent USCIS from 

revealing derogatory information it received from third parties, visa staff must 

attempt to recreate USCIS’ hit. A Department of State manager said that they 

were not always able to do so. 

Long-delayed cases increase USCIS’ workload other ways, as well. IBIS and 

FBI fingerprint checks can expire, requiring new checks and repeated 

fingerprinting. In addition, adjudicators run queries on a regular basis for 

each case with a pending FBI name check, to learn whether FBI name checks 

cleared. 

 

32 This figure is exclusive of litigation relating to the commercial and administrative law division. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Solutions USCIS is pursuing

USCIS has begun to address cases delayed with ICE and the FBI by assigning 

USCIS staff to work off the backlogs. In order to keep ICE’s backlog from 

growing, FDNS ceased referring IBIS national security hits to ICE in 

November 2004, instead resolving them in house. In May 2005, FDNS 

assumed responsibility for the backlog of approximately 600 national security 

hit cases that had remained with ICE. In March 2005, USCIS detailed five 

personnel to the FBI National Name Check Program for up to a year to assist 

with the pending FBI name checks. 

Additionally, USCIS has been pursuing regulatory and statutory options to 

expand authority to withhold adjudication and to deny benefits due to national 

security concerns. USCIS described the suggested statutory change as 

providing the legal basis “to deny any benefit to aliens described in any of the 

national security related provisions of inadmissibility or deportability in the 

Immigration and Nationality Act (INA), who are the subject of a pending 

investigation or case that is material to eligibility for a benefit, or for whom 

law enforcement checks have not been conducted and resolved.”33 However, 

USCIS has been pursuing similar changes for several years, and staff has no 

indication that their approval is imminent. 

Meanwhile, USCIS is developing two specialist staff units to help conclude 

cases with complex adjudication and security check issues. In March 2005, 

USCIS created a unit called FOCUS within the Office of Field Operations to 

assist in the adjudication of selected cases with identified national security or 

public safety concerns. Both field offices and FDNS may refer cases to 

FOCUS for adjudication guidance. FOCUS’s initial workload is 100 cases. 

USCIS has also proposed developing a Background Check Analysis Unit 

within FDNS to resolve the more complex and sensitive hits, receive and 

review all national security notifications to observe trends, provide direction 

and oversight to the field, and coordinate issues with other USCIS 

components including the Office of Chief Counsel. FDNS estimates the unit 

will resolve at least 500 complex and sensitive security checks per year. The 

reprogramming request to fund seven personnel to staff the unit was in the 

preliminary approval process as of April 2005. 

 

33 USCIS draft amendment adding a new Section 362 of the Immigration and Nationality Act, “Denial of Immigration 

Benefits to Terrorists and Criminals.” 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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USCIS can administer security checks more efficiently 

USCIS can strengthen the efficiency of its security check program. First, 

USCIS automation does not provide many of the efficiencies that existing IT 

solutions offer. USCIS needs improved automation to reduce duplicative, 

paper-based security check processes. USCIS has two systems in 

development that could streamline how USCIS runs, documents, and monitors 

checks. Second, more than a year after the creation of FDNS, many USCIS 

parties are still responsible for aspects of the security check program. While 

there are justifications for the diffused responsibility, clarifying accountability 

could better enable USCIS to address program weaknesses including the lack 

of an integrated, risk-based plan for which checks to conduct, lack of 

comprehensive program management data, and delays in disseminating 

uniform policies and standards. 

Automated systems provide inadequate support for processing security checks 

USCIS does not have a centralized, automated case management system or 

security checks system. A large portion of the security check process is 

completed and documented by hand or with homegrown systems. Compared 

to the Department of State’s, USCIS’ systems have limited ability to reduce 

duplication and processing steps, control approvals, document checks for 

audit purposes, and create adequate program management information. As a 

result, the process is labor-intensive, vulnerable to human error, and 

inefficient. 

Several previous OIG and GAO reports have noted that USCIS does not have 

information systems adequate to support efficient processing of benefits and 

security checks.34 Cases are not managed or tracked centrally: staff processes 

applications in CLAIMS 3, CLAIMS 4, RAPS, the Integrated Case 

Management System, the Marriage Fraud Amendment System, homegrown 

systems such as the Buffalo Examination Tracking System, and in some cases, 

no automated system. Furthermore, even cases that have automated records 

have paper records as well, which staff must create, track, update, and retrieve 

manually. Although staff initiates security checks electronically, they remain 

 

34 Audit Report: Fingerprint and Biographical Check Services Provided by the Federal Bureau of Investigation to the 

Immigration and Naturalization Service, DOJ OIG, Report No. 99-13, March 1999; Immigration Benefits: Several 

Factors Impede Timeliness of Application Processing, GAO-01-488, May 4, 2001; Immigration Benefit Fraud: Focused 

Approach is Needed to Address Problems, GAO-02-66, January 31, 2002. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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largely a paper process. Staff and contractors review paper applications to 

find and screen applicants’ aliases. Checks are documented and reviewed 

manually with IBIS stamps, handwritten Records of IBIS Query, Interim IBIS 

printouts, printed FBI Rap sheets, printed FBI name check results, and 

handwritten hit resolution documents. 

The existing paper and automated systems have limited ability to: 

• Prevent duplication of work. USCIS’ automated systems do not store 

complete security check information in order to permit staff to review 

it electronically regardless of location. While national case 

management systems such as CLAIMS 3 and RAPS store security 

check dates and results, more detailed information such as hit content 

and resolution is available only in paper files and, in some cases, local 

systems. Therefore, when staff does not have the paper record to 

review–for example, an immigration information officer assisting a 

walk-in applicant–staff re-runs and resolves IBIS checks even if they 

are current. USCIS also does not have an automated system to store 

fingerprints. When fingerprints age past 15 months, which USCIS’ 

backlog and slow FBI name checks can cause, applicants must return 

to application support centers to submit their fingerprints again. 

• Automatically update screening results. The screening databases 

USCIS uses do not provide “wrap-back” updates that push updated 

records to USCIS when information on applicants whom USCIS has 

already screened changes. Instead, USCIS staff re-runs all IBIS name 

checks more than 90 days old before adjudication to see if any of the 

records have changed. Although USCIS studied and selected the 90-

day expiration period to reduce the possibility of missing significant 

record updates, the potential exists. Like the IBIS check, USCIS 

repeats the FBI fingerprint check for updates on a 15-month expiration 

schedule. USCIS has not set an expiration period for the FBI name 

check, but the FBI considers a name check to be current for 120 days. 

However, updating FBI name checks also consumes labor as staff 

checks repeatedly whether pending name checks have finalized. 

Asylum Branch’s IDENT checks are refreshed when applicants return 

to the asylum offices. Asylum staff has begun to receive some wrapback information through US-VISIT, though headquarters staff must 

manually redirect it to local offices. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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• Assist in verifying applicants’ identity with biometric identifiers. 

Although USCIS collects fingerprints and photographs from many of 

its applicants, in most cases these are used for card production and 

criminal history record checks, not for automated, biometric 

verification of the applicant’s identity. Visual inspection of biometric 

data to establish the applicant’s identity is slower and less reliable than 

automated checks. Only the fingerprints that are stored in IDENTAsylum are used for automated identity verification. However, this 

biometric check has limitations as well. US-VISIT does not 

crosscheck IDENT-Asylum files with its visa and entry-exit records, 

and asylum staff conducts manual, name-based searches of this 

information until US-VISIT improves cross-check capability. 

• Consolidate checks. The May 2003 Security Matrix Project 

Recommendations Report advised USCIS to develop “multiple system 

search capacity,” the ability to enter and review applicant information 

in a single system for checks conducted in several others. USCIS staff 

must log in to separate systems to initiate and review most IBIS, FBI, 

IDENT, and administrative checks. A March 2005 study indicated 

that derogatory information provided by FBI name checks was not 

consistently available via IBIS name checks, even though the IBIS 

check contains FBI information from the National Crime Information 

Center and Terrorist Screening Database. Therefore, for many 

applications, USCIS continues to run two security name checks, 

biometric checks, and administrative checks. 

• Generate national program management information. The systems 

USCIS uses do not track the resources used to process security checks, 

and none except RAPS tracks the check results. For example, national 

systems do not supply records of the number of IBIS checks 

conducted, the amount of time staff spends resolving hits, the number 

and types of IBIS hits received, and the adjudication results of cases 

with IBIS hits. USCIS has developed estimates of some figures based 

on data provided by individual service centers, which have more 

extensive automated support than district offices. Further information 

comes from ad hoc studies; other manually compiled reports; and the 

Performance Analysis System, the reliability of which DOJ OIG 

criticized.35

 

35 Accuracy of Adjudications and Naturalization Data in the Performance Analysis System of the U.S. Immigration and 

Naturalization Service, DOJ OIG Report No. 99-03, February 1999. In FY 2004, independent auditors reported internal 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Improved automated systems that include these features would assist USCIS 

in eliminating duplication of work, increasing productivity, reducing 

opportunities for human error, and maintaining management controls. The 

Department of State developed systems that include some of these features. 

For example, an entry in the Department of State’s Non-Immigrant Visa 

Processing System permits staff to initiate and review security check 

information in IDENT, the Consular Consolidated Database, Security 

Advisory Opinions, and the Consular Lookout and Support System. Consular 

officers can more quickly review the consolidated information, including 

historical records, without logging in and out to search different systems. The 

Non-Immigrant Visa Processing System also automatically checks applicant 

aliases, runs fingerprint and facial recognition biometric checks, and compares 

biographic data during checks to flag potential identity mismatches. 

Furthermore, the system incorporates management controls including rules 

that prevent approvals without security checks, complete historical records of 

security check information reviewed, and several means of reviewing case 

decisions. 

Without these features, USCIS’ security check processes are more labor 

intensive, vulnerable to human error, and difficult to monitor. For example, 

we estimated that refreshing IBIS checks to ensure they are current within 90 

days at adjudication resulted in a minimum of 4.3 million additional IBIS 

checks in FY 2004. Conducting checks without automated controls on 

completion and renewal permits staff errors like those found during USCIS 

quality assurance and OIG sampling. And the lack of centralized, automated 

records for analysis causes USCIS to rely on less-definitive estimates and 

anecdotes for decisions. For example, USCIS has no record of how many 

relationship-based petitions staff was obliged to approve despite derogatory 

security check results. There is no estimate of the scale of the problem to help 

indicate whether the statutory change being pursued is the only viable 

solution. 

USCIS has been planning to improve automated support for the security check 

process for several years. In December 2001, USCIS (then INS) issued an IT 

modernization plan36 with goals to integrate the disparate case management 

systems; transition to a paperless system; and incorporate automated, 

 control weaknesses in USCIS’ Performance Analysis System. (U.S. Department of Homeland Security Performance and 

Accountability Report, Excerpts of Financial Information Part II, Seven Months Ended September 30, 2003, KPMG 

LLP.) 

36 Immigration Services IT Strategic Plan, 2002-2012, December 2001. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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biometric identification. USCIS does not expect to field a consolidated, 

automated case management system until 2007. However, other advances 

have been made. In 2004 and 2005, the National Benefits Center and lockbox 

application receipt operations began to enter data and pre-process applications 

for all district offices, partially automating this work, which includes initial 

name checks and fingerprint scheduling. 

Furthermore, USCIS conceived two new software systems to support the 

background check process. The Background Check System (BCS), which 

USCIS began testing in spring 2005, will centralize check records, helping to 

reduce duplication of checks and supporting check reviews. Also in spring 

2005, USCIS contracted to begin building the BSS, which will retain 

fingerprints, photographs, and signatures for screening. Once fielded, these 

systems should do much to reduce duplication and manual effort, and to 

improve USCIS’ ability to monitor processing. USCIS’ May 2005 strategic 

plan discusses integrating these systems with its case management systems 

and pursuing wrap-back updates from the agencies that supply check 

information. 

USCIS has suffered delays in implementing its plans to modernize and 

automate its background check systems. Staff said that the BCS software 

were in development when Immigration Services split from the other offices 

of INS in March 2003. Under the DHS realignment, Immigration Services 

lost direct IT support, instead receiving it from ICE under a shared service 

agreement. USCIS recently reformed its IT infrastructure, integrating 

authority under the Chief Information Officer (CIO) in May 2005, and that 

office assisted in advancing BCS and BSS development.37 USCIS succeeded 

in obtaining access to a test environment for testing BCS in spring 2005, and a 

contract to develop BSS followed. Continued progress will be necessary to 

eliminate obstacles to processing efficiency. 

USCIS should continue reorganization of security check management

In previous sections, we discussed several improvements USCIS should pursue, 

including a risk-based plan to enhance the scope of security checks, more 

comprehensive program management information, and stronger management 

controls. FDNS has begun to provide some of this support for security checks. 

However, it shares responsibility for these areas with adjudicative and policy 

 

37 For further discussion of USCIS IT modernization and infrastructure, see U.S. Citizenship and Immigration Services Is 

Not Effectively Managing Information Technology to Meet Mission Requirements, DHS OIG (forthcoming). 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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offices including Service Center Operations, Field Operations, and the Office of 

Quality Assurance and Production Management. It also shares responsibility 

with the Asylum Branch and the CIO, which are outside the domestic 

operations organization where FDNS sits. Coordinating some of these parties 

has delayed at least one significant SOP change. In order to ensure aggressive 

progress in security check management, USCIS needs to establish 

accountability and timelines for developing security check plans, policies, and 

program information. 

Announcing the official formation of FDNS in May 2004, the USCIS director 

defined its mission to: 

• Oversee and enhance policies and procedures pertaining to 

the performance of law enforcement (background) checks on 

applicants and petitioners 

• Identify and evaluate vulnerabilities in the various policies, 

practices, and procedures which threaten the integrity of the 

legal immigration process 

• Recommend solutions and internal controls to address these 

vulnerabilities.38 

Since that time, FDNS reengineered procedures for resolving security check 

hits involving national security and developed new policies to support law 

enforcement and intelligence agencies interacting with benefit applicants. In 

February 2005, FDNS initiated its Benefits Fraud Assessment to statistically 

assess for the first time the percentage and type of fraud in six higher risk 

applications. The information from this study should enable FDNS to evaluate 

vulnerabilities, as will the information developed with FDNS’s new automated 

Fraud Tracking System and planned Background Check Analysis Unit. 

Several responsibilities related to policy, procedures, and controls for security 

checks are assigned outside FDNS. FDNS officials told us that the 

responsibility for planning the types of security checks to conduct belongs with 

the adjudicative offices such as the Asylum Branch, Service Center Operations, 

and Field Operations. Supporting this statement, the Asylum Branch and 

Service Center Operations initiated recent changes regarding how USCIS 

screens applicant aliases. 

 

38 “Introducing the Office of Fraud Detection and National Security (FDNS)”, May 2004. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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For writing the policy defining user access to IBIS, or which type of records 

users at different security clearance levels can view, the Office of the CIO has 

responsibility. For the management control of quality assurance procedures and 

testing, the Office of Quality Assurance and Production Management, Service 

Center Operations, and selected field offices have been driving changes. Much 

of USCIS’ quality assurance assesses performance other than security checks, 

but field offices are discussing plans to develop a quality assurance test solely 

for security checks. Offices other than FDNS also manage another control, 

security checks training. We observed several opportunities for making 

training more complete and uniform. Most field offices we visited lack 

recurrent training on changing security check policies and procedures, and staff 

requested more security checks training, such as on IBIS features. 

In sum, security check administration is still somewhat decentralized within 

USCIS. While this is management’s prerogative, we note that USCIS formed 

FDNS partially in response to a 2003 study that recommended USCIS 

centralize management of security checks. The centralization was intended to 

improve the efficiency and effectiveness of the security check process and 

eliminate “variability of background check requirements ... inconsistent 

administration of background check information ... [and] poor use of 

resources.”39 

Although USCIS continues to refine its security check process, we did not 

observe efforts to unify the process under a plan with performance goals and 

measures, clearly defined accountability, and timelines for implementing 

changes. However, these steps are necessary to balance available resources, 

decentralized office responsibilities, and desired program outcomes. The 

Office of Management and Budget directs: “[R]esults-oriented managers must 

ask themselves if the programs they administer are achieving the desired result 

at an acceptable cost. If the answer is ‘no’ or ‘we don’t know,’ they must do 

something about it, such as clearly define the desired outcomes, determine the 

causes of unsatisfactory performance, construct plans to remedy any problems, 

develop aggressive timeframes for taking action, and ensure that actions are 

implemented.”40 

Without clear plans, accountability, and timelines, USCIS will have difficulty 

coordinating its offices to implement needed improvements on an aggressive 

 

39 BCIS Background Checks: Identifying the Need for a centralized Background Check Unit (BCU), Booz Allen 

Hamilton, May 14, 2003. 

40 The Federal Government is Results-Oriented: A Report to Federal Employees, Office of Management and Budget, p. 

1, August 2004. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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schedule. For example, when our review began in October 2004, FDNS 

planned to revise the outdated 2002 SOP for IBIS. By the conclusion of our 

fieldwork in March 2005, FDNS and Service Center Operations had begun 

discussions on IBIS roles and responsibilities and potential SOP changes, to be 

followed by discussions with Field Operations and other IBIS users on an 

indefinite timeline. It is unclear when the revision will be complete, and as we 

noted on page 21, field offices have begun compiling local guidelines in the 

absence of a current IBIS SOP. The risk of this alternative is that local offices 

will develop guidelines that do not fully comply with the official SOP, which 

was the case at one office we visited. 

Recommendations 

We recommend that U.S. Citizenship and Immigration Services: 

Recommendation 1: Expand the use of biometric identification in security 

checks, as consistent with risk assessment. 

Recommendation 2: Establish a comprehensive, risk-based plan for the 

selection and completion of security checks. 

Recommendation 3: Set measurable objectives for the conduct and 

completion of all security checks and reorganize management controls to 

ensure objectives are met. 

Recommendation 4: Implement the Background Check Analysis Unit in the 

Office of Fraud Detection and National Security.

Recommendation 5: Implement an automated system that stores applicants’ 

biometric information and supports its use in security checks. 

Recommendation 6: Implement an automated system that supports running, 

documenting, reviewing, and monitoring security checks. 

Recommendation 7: Define accountability and timelines for implementing 

changes to the security check process that include the development of the plan 

for completion of security checks, check completion objectives, and 

reorganized management controls. 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 36 

Management Comments and OIG Evaluation 

We evaluated USCIS’ written comments and made changes to the report 

where deemed appropriate. Below is a summary of USCIS’ written responses 

to our recommendations and our analysis of the response. A copy of USCIS’ 

response in its entirety can be found in Appendix B. 

USCIS agreed that its security check process requires improvements including 

consolidated management, clarified procedures, and increased monitoring. 

USCIS added that better automated tools, which are in development, are 

fundamental to process improvements. In addition, USCIS stated that it will 

continue to pursue access to automatic updates for changing security check 

information, i.e. wrap-back. We agree the wrap-back feature could play a vital 

role in improving both the security and efficiency of USCIS checks. 

Recommendation 1: Expand the use of biometric identification in security 

checks, as consistent with risk assessment. 

USCIS Response: USCIS acknowledged that only applications related to 

asylum currently use biometrics to validate identity. USCIS intends to work 

with DHS to establish a biometric and biographic data collection standard that 

will be common to USCIS, the Department of State, CBP, and ICE. 

Separately, USCIS is in the preliminary stages of plans to collect biometrics 

from customers when they first apply for a benefit and to use the biometrics to 

verify identity during subsequent processes. USCIS anticipates using this 

model for the Temporary Worker Program. 

OIG Evaluation: We concur with USCIS’ action and regard the 

recommendation as resolved and open. In its action plan, USCIS should 

explain which benefits will be included as biometric collection is expanded 

and note the results of its preliminary planning. Coordination with DHS to 

ensure the compatibility and interconnectivity of USCIS, CBP, ICE, and 

Department of State biometric identity systems is a critical part of managing 

the entry and exit of immigrants and non-immigrants to the United States. 

Recommendation 2: Establish a comprehensive, risk-based plan for the 

selection and completion of security checks. 

USCIS Response: FDNS will prepare a plan to outline how, when, and for 

what benefits expansion of biometric checks should occur. They will base this 
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 37 

analysis on risk assessments and assign responsibilities, timelines, and 

milestones for the implementation. 

OIG Evaluation: We concur with USCIS’ action and regard the 

recommendation as resolved and open. In its action plan, USCIS should 

include documentation of the plan’s progress. 

Recommendation 3: Set measurable objectives for the conduct and 

completion of all security checks and reorganize management controls to 

ensure objectives are met. 

USCIS Response: FDNS, in coordination with the Production Management 

Division, will work to establish acceptable quality levels. These two offices 

will use information in the Background Check System to measure compliance 

with the quality levels. USCIS commented that management controls 

embedded in automated systems are the most effective for ensuring security 

check completion. Future USCIS systems will include these controls. In 

addition, FDNS will review and consolidate all USCIS guidance on security 

checks. USCIS will also explore ways to improve program management 

information by tracking adjudication decisions in relation to security check 

results. 

OIG Evaluation: USCIS’ proposed actions, including establishing acceptable 

quality levels for all forms and improving management controls such as policy 

documentation, are responsive to the recommendation. The recommendation 

is resolved and open. 

Recommendation 4: Implement the Background Check Analysis Unit in the 

Office of Fraud Detection and National Security.

USCIS Response: USCIS noted that FDNS has resolved all national-securityrelated IBIS hits since March 2005. FDNS’s Background Check Analysis Unit 

reviews, tracks, analyzes, and resolves all name-vetted hits related to rational 

security. 

OIG Evaluation: This recommendation is resolved and open. In its action 

plan, USCIS should discuss the organizational and staffing changes made in 

FDNS to support the additional mission of analyzing and resolving national 

security hits.
A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Recommendation 5: Implement an automated system that stores applicants’ 

biometric information and supports its use in security checks. 

Recommendation 6: Implement an automated system that supports running, 

documenting, reviewing, and monitoring security checks. 

USCIS Response: USCIS will deploy the Biometric Storage System in the 

fourth quarter of FY 2006 and the Background Check System in the third 

quarter of FY 2006. 

OIG Evaluation: USCIS’ proposed actions are responsive to the 

recommendations, which are resolved and open. 

Recommendation 7: Define accountability and timelines for implementing 

changes to the security check process that include the development of the plan 

for completion of security checks, check completion objectives, and 

reorganized management controls. 

USCIS Response: As of September 19, 2005, USCIS designated FDNS as the 

lead on all security check-related activities. As discussed in recommendations 

2, FDNS will develop the plan for security check completion. 

OIG Evaluation: This recommendation is resolved and open. In its action 

plan, USCIS should note the timeline for completion of changes to the 

security check process discussed in its response to this report. 
Appendix A 

Purpose, Scope and Methodology 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 39 

We evaluated the adequacy and efficiency of the security checks that USCIS 

conducts to help identify unqualified alien beneficiaries, particularly terrorists 

and criminal aliens, and to deny their applications for immigration benefits. 

We examined the security check processes and procedures USCIS uses to 

detect fraud and identify mala fide applicants. We assessed the scope and 

depth of the security checks that USCIS performs to identify whether there are 

gaps in coverage and opportunities for increasing coverage. We reviewed 

USCIS’ implementation of the security checks to learn whether checks are 

completed, properly conducted, and concluded with timely denials and law 

enforcement/fraud referrals when appropriate. Finally, we examined the 

efficiency of USCIS’ implementation of the security checks, including 

frequency of duplicate checks and resources required for processing. 

We analyzed laws and regulations related to immigration benefits and security 

checks; USCIS documentation, including guidance, directives, SOPs, 

manuals, policy memoranda, training materials, quality assurance reports, and 

Internet websites; various reports from the GAO and DOJ and DHS OIG on 

immigration benefits processing, fraud and security checks, and the 

management of immigration programs; and other related reports and articles. 

During our review we conducted over 125 interviews and teleconferences. 

The majority of the interviews took place during our site visits to three USCIS 

service centers, four district offices, two asylum offices, two application 

support centers, and two file storage facilities. We spoke with senior officials 

at USCIS headquarters and at the Department of State, FBI, the Directorate of 

Border and Transportation Security, ICE, EOIR, and US-VISIT. 

As part of our data analysis, we sampled over 600 immigration and asylum 

files for evidence of security check completion. Focusing on applications 

USCIS approved in FY 2004, we selected a random sample of eight different 

form types for which USCIS does not provide monthly, national quality 

assurance checks. These included two asylum-related forms that receive 100 

percent supervisory review of security check completion. Based on inspector 

judgment, we sampled approximately 300 forms at each of two sites: the 

National Records Center (five form types) and the Harrisonburg storage 

facility (three form types). 

Our fieldwork was conducted from October 2004 to March 2005. The review 

was conducted under the authority of the Inspector General Act of 1978, as 

amended, and according to the Quality Standards for Inspections issued by the 

President’s Council on Integrity and Efficiency. 
Appendix B 

Management Response to Draft Report 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

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Appendix B 

Management Response to Draft Report 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 41 
Appendix B 

Management Response to Draft Report 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 42 
Appendix C 

Security Checks for USCIS Immigration Forms 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 43 

Figure 4: Security Checks for USCIS Immigration Forms 

FORM

TITLE

FY 2004 

Application 

Receipts41

FY 2004 

Application 

Completions42

IBIS 

Name 

Check 

FBI 

Fingerprint 

Check 

FBI 

Name

Check

IDENT 

Asylum

I-765

Application for Employment Authorization 1,555,176 1,919,980 yes 

I-90

Application to Replace Permanent Resident Card 624,583 1,111,469 yes yes 

I-130

Petition for Alien Relative 712,320 831,042 yes 

I-485

Application to Register Permanent Residence 

or to Adjust Status 605,505 742,333 yes yes yes 

N-400

Application for Naturalization 662,788 639,377 yes yes yes 

I-131

Application for Travel Document 437,441 557,193 yes 

I-129

Petition for a Nonimmigrant Worker 418,125 433,744 yes43 

I-539

Application to Extend/Change Nonimmigrant Status 

(Supp A also) 251,735 280,687 yes 

I-751

Petition to Remove the Conditions on Residence 175,324 137,875 yes 

I-821

Application for Temporary Protected Status 13,826 126,493 yes yes 

I-589

Application for Asylum and Withholding of Removal 32,85944 110,646 yes yes yes yes 

I-140

Immigrant Petition for Alien Worker 80,348 85,844 yes 

N-600

Application for Certification of Citizenship 57,803 66,513 yes 

I-824

Application for Action on an Approved Application

 or Petition 29,140 37,253 yes 

I-881

Application for Suspension of Deportation or 

Special Rule Cancellation of Removal (NACARA) 12,36845 35,441 yes yes yes yes 

 

41 USCIS Performance Analysis System data. 

42 USCIS Performance Analysis System data. 

43 Unnamed applicants on blanket petitions do not receive IBIS checks. 44 RAPS data. 

45 RAPS data. 
Appendix C 

Security Checks for USCIS Immigration Forms 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 44 

FORM

TITLE

FY 2004 

Application 

Receipts41

FY 2004 

Application 

Completions42

IBIS 

Name 

Check 

FBI 

Fingerprint 

Check 

FBI 

Name

Check

IDENT 

Asylum

I-730

Refugee/Asylee Relative Petition 26,715 33,377 yes 

N-565

Application for Replacement Naturalization/

Citizenship Document

29,405 30,740 yes 

I-600

Petition to Classify Orphan as an Immediate Relative 28,066 29,913 yes yes 

I-102

Application for Replacement/ Initial Nonimmigrant 

Arrival/ Departure Document

20,231 23,343 yes 

I-360

Petition for Amerasian, Widow(er), or Special 

Immigrant

12,600 11,403 yes 

N-336

Request for Hearing on a Decision in Naturalization 

Proceedings under section 336 of the Act

9,659 10,100 yes 

I-817

Application for Family Unity Benefits 6,697 9,584 yes yes 

I-698

Application to Adjust Status From Temporary to 

Permanent Resident (IRCA applicants)

226 944 yes 

N-300

Application to File Declaration of Intention 205 753 yes 

N-470

Application to Preserve Residence for 

Naturalization Purposes 

579 537 yes 

I-914

Application for T Nonimmigrant Status 

(supporting form -B, family form -A)

566 507 yes yes 

I-690

Application for Waiver of Grounds of Excludability 

under sections 245A or 210 of the Immigration and 

Nationality Act

393 316 yes 

I-829

Petition by Entrepreneur to Remove Conditions 123 310 yes 

I-526

Immigrant Petition By Alien Entrepreneur 247 290 yes 

I-694

Notice of Appeal of Decision 155 248 yes 

I-914A

Application for T Nonimmigrant Status (family form -A) 86 117 yes yes 

N-644

Application for Posthumous Citizenship 9 3 yes 
Appendix C 

Security Checks for USCIS Immigration Forms 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 45 

FORM

TITLE

FY 2004 

Application 

Receipts41

FY 2004 

Application 

Completions42

IBIS 

Name 

Check 

FBI 

Fingerprint 

Check 

FBI 

Name

Check

IDENT 

Asylum

I-192

Application for Advance Permission 

to Enter as Nonimmigrant

data not 

available 

data not 

available yes yes yes 

I-212

Application for Permission to Reapply for Admission 

into the U.S. After Deportation or Removal 

data not 

available 

data not 

available yes 

I-600A

Application for Advance Processing of Orphan Petition 

data not 

available 

data not 

available yes yes 

I-601

Application for Waiver of Grounds of Excludability 

data not 

available 

data not 

available yes yes yes 

I-602

Application By Refugee For Waiver of

Grounds of Excludability 

data not 

available 

data not 

available yes 

I-612

Application for Waiver of the 

Foreign Residence Requirement 

data not 

available 

data not 

available yes 

I-94

Arrival-Departure Record

data not 

available 

data not 

available yes 

In addition to security checks performed on people, USCIS may conduct 

security checks on businesses (for example, those submitting an I-129, 

Petition for Nonimmigrant Worker) and schools (for example, those 

submitting an I-17, School Approval).
Appendix D 

Major Contributors to Report 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 46 

Office of Inspections

Douglas Ellice, Chief Inspector 

Randall Bibby, Chief Inspector 

David M. Hiles, Chief Inspector 

Wynne Krause, Inspector 

Kirsten Murray, Inspector 

Melissa Keaster, Inspector 
Appendix E 

Report Distribution 

A Review of U.S. Citizenship and Immigration Services’ Alien Security Checks 

Page 47 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

General Counsel 

Executive Secretariat 

Under Secretary, Border and Transportation Security 

Director, Bureau of Citizenship and Immigration Services 

Assistant Secretary, Public Affairs 

Assistant Secretary, Legislative Affairs 

Assistant Secretary of Policy 

Deputy Chief Security Officer 

OIG Audit Liaison 

CIS Audit Liaison 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Program Examiner 

Congress

Congressional Oversight and Appropriations Committees 
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General 

(OIG) at (202) 254-4100, fax your request to (202) 254-4285, 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 the OIG Hotline at 1-800-323-8603; or write to Department of

Homeland Security, Washington, DC 20528, Attn: Office of Inspector 

General, Investigations Division – Hotline. The OIG seeks to protect the 

identity of each writer and caller.