United States General Accounting Office

GAO Report to the Commissioner of the

Immigration and Naturalization Service

July 1997 INS MANAGEMENT

Follow-up on Selected

Problems

GAO/GGD-97-132

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-260846 

July 22, 1997

The Honorable Doris Meissner

Commissioner

Immigration and Naturalization

 Service

Dear Ms. Meissner:

This report discusses the progress that the Immigration and Naturalization Service (INS) has

made toward addressing long-standing management problems. It discusses actions taken by INS

to address management problems and areas that continue to need attention.

This report contains recommendations to you. The head of a federal agency is required by 31

U.S.C. 720 to submit a written statement on actions taken on these recommendations to the

Senate Committee on Governmental Affairs and the House Committee on Government Reform

and Oversight not later than 60 days after the date of the report. A written statement also must

be sent to the House and Senate Committees on Appropriations with the agency’s first request

for appropriations made more than 60 days after the date of the report.

We are sending copies of this report to the Attorney General, the Director of the Office of

Management and Budget, and other interested parties. We will also make copies available to

others on request.

If you or your staff have any questions concerning this report, please contact me at

(202) 512-8777. This report was done under the direction of Evi L. Rezmovic, Assistant Director,

Administration of Justice Issues. Other major contributors are listed in appendix VII.

Sincerely yours,

Norman J. Rabkin

Director, Administration

 of Justice Issues
Executive Summary

Purpose The Immigration and Naturalization Service (INS), an agency of the

Department of Justice, has received considerable public attention in

recent years as immigration, especially illegal immigration, has become a

focus of national attention. From fiscal year 1993 to fiscal year 1997, INS’

budget more than doubled, and its personnel resources increased by about

45 percent to more than 26,000 positions.

In 1991, GAO reported that INS was experiencing severe management

problems in a variety of areas.1

 Specifically, GAO reported that among other

things, INS (1) lacked clearly defined priorities, (2) lacked management

control over regional commissioners, (3) had poor internal

communications and outdated policies and procedures, (4) did not use

workload data to allocate resources and had budget management and

resource allocation problems that perpetuated backlogs in processing

immigrants’ applications for adjustment of status and naturalization, and

(5) had unreliable financial information that resulted in inadequate budget

monitoring.

Because of the history of management problems and the recent dramatic

growth in INS’ resources, GAO initiated this review to determine what

progress INS had made in these areas. Specifically, GAO’s follow-up review

assessed whether INS had (1) developed goals and priorities to guide

planning and resource allocation, (2) revised its organizational structure,

(3) improved internal communications and updated its field and

administrative manuals, (4) improved the process of allocating budgetary

resources, and (5) improved its capability to monitor its financial status.

GAO’s audit work was conducted between March 1995 and February 1997.

The scope of GAO’s follow-up work for this report did not include

evaluating the recent issues that have arisen regarding the effectiveness of

specific program areas or components, such as the naturalization program,

criminal alien removal program, and delays in implementing several major

automation systems. Nonetheless, other GAO work on some of those issues

indicated that they share, at least in part, common causes in terms of some

of the long-standing management weaknesses discussed in this report.

Background INS is responsible for both administering immigration-related services and

enforcing immigration laws and regulations. INS headquarters in

Washington, D.C., administers its functions through a network of 3

1

Immigration Management: Strong Leadership and Management Reforms Needed to Address Serious

Problems (GAO/GGD-91-28, Jan. 23, 1991).

Page 2 GAO/GGD-97-132 INS Management Problems
Executive Summary

regional offices, 33 district offices, and 21 Border Patrol sectors

throughout the United States. Immigration-related services include such

activities as port-of-entry admissions and processing requests for

adjustment of status, naturalization, and work authorization. Enforcement

responsibility includes such activities as border control, apprehension of

illegal residents and workers, and detention and removal of criminal

aliens.

In 1990, Congress created the Commission on Immigration Reform, which

was tasked with reviewing and evaluating the impact and implementation

of U.S. immigration policy. The Commission’s work, still ongoing as of

March 1997, has indicated that implementation of immigration policies is

beset with problems. In 1994, the Commission reported that illegal aliens

were entering the United States too easily, unlawful residents of the

United States were not being removed, and legal immigrants encountered

too much difficulty in gaining entry to the United States. That report

concluded that “[t]he United States can do a more effective job, but only

with additional financial resources and the political will to take action.”

Since 1994, additional laws have been enacted to strengthen immigration

policy and to provide additional resources to INS. For example, the Violent

Crime Control and Law Enforcement Act of 1994 increased penalties for

such offenses as failure to depart, illegal reentry, and document fraud. It

also authorized additional resources for criminal alien deportations and

detention bed space and provided for asylum claims to be processed more

expeditiously.

More recently, Congress passed the Illegal Immigration Reform and

Immigrant Responsibility Act of 1996. This law provides for

(1) improvements in border control through increased resources and

enhanced use of technology, (2) provisions to help facilitate legal entry,

(3) increased resources for investigators to perform interior enforcement

activities, (4) enhanced enforcement and penalties against alien smuggling,

(5) provisions to further deter the use of fraudulent documents, (6) revised

procedures for removal of inadmissible and deportable aliens, (7) pilot

programs for enforcement of restrictions against employment of illegal

aliens, and (8) restrictions on benefits for aliens. In addition, recently

passed welfare reform legislation, the Personal Responsibility and Work

Opportunity Reconciliation Act of 1996, also has implications for

significantly increasing INS’ naturalization applications workload.

Page 3 GAO/GGD-97-132 INS Management Problems
Executive Summary

INS will also be affected by the Government Performance and Results Act

of 1993 (referred to as the Results Act or GPRA), which provides a

statutory framework for achieving more results-oriented management. The

Results Act requires federal agencies to develop strategic plans by

September 30, 1997, that contain mission statements and outcome-related

strategic goals. Once the mission and outcomes are articulated, agencies

are to align their activities, processes, and resources so that they support

their missions and goals.

Amidst these new developments, INS has continued to receive attention

from GAO, the media, and Congress concerning internal management

issues. Such issues are important because how well INS manages its

budgetary and personnel resources has a direct impact on its ability to

efficiently and effectively carry out its mission. In the context of rapid

growth in resources and growing demand for both law enforcement and

provision of services to legal immigrants, INS has undertaken new

initiatives intended to improve how it is managed.

Results in Brief INS has made progress toward addressing some of its management

problems, but much remains to be done and top management attention is

still required. Since the appointment of a new Commissioner in 1993, INS

has developed a strategic plan, implemented a priorities management

process, taken steps to use priorities and workload information to allocate

resources, and implemented a new organizational structure intended to

provide for more direct oversight of field units. Sustained top management

attention and commitment to continuously improve operational

performance will be needed to ensure that these changes have the

intended effect. Less progress has been made on other needed

improvements, such as providing employees with clear guidance on how

to implement the immigration laws by issuing updated policies and

procedures manuals and establishing clear channels of communication

within the new organizational structure. Additionally, INS selected a new

financial management system without focusing first on conducting an

analysis of its business processes—a practice that GAO guidelines for

acquiring information technology endorsed and Congress required in

legislation.

INS issued a strategic plan in 1994 to guide its decisionmaking and

policymaking and to set the stage for the implementation of a priorities

management process. The agency developed annual goals and priorities

and used them in fiscal years 1995 and 1996 to plan and allocate new

Page 4 GAO/GGD-97-132 INS Management Problems
Executive Summary

resources provided by Congress. However, INS, like other government

agencies, is in the early stages of implementing the Results Act’s

requirements. INS recognizes that it has not yet implemented a coordinated

Results Act effort, especially in terms of the measures it has in place.

In addition, in 1994 the Commissioner established a new organizational

structure with four Executive Associate Commissioners (EAC) and regional

directors who report to one of the executive associate commissioners. The

reorganization reportedly has improved oversight of district offices and

Border Patrol sectors but has also created some internal communication

problems. A lack of clear guidance has also hampered internal

communication and may be impeding front-line employees in carrying out

their mission-related activities.

INS implemented several initiatives intended to improve upon its processes

for allocating budgetary resources. INS made improvements in planning

resource allocations to be more consistent with agencywide annual

priorities and workload demands. Furthermore, INS has contracted with a

consultant to develop a software program that is compatible with existing

staffing models. In addition, the consultant is to review and refine the

deployment planning process and the prototype automated software

support. This effort is intended to move INS toward better deployment

planning. INS’ efforts appear to be steps in the right direction, but

continued management support and attention will be required to ensure

that the intended results are achieved.

INS has had long-standing problems with its financial management system

and is in the process of acquiring a new one. INS implemented some

interim strategies to facilitate budget execution monitoring to assist it until

a new financial management system is in place. INS selected a financial

management system in March 1997, even thought it had not defined its

business processes before it selected the new system. GAO guides on

information management2

 and the Clinger-Cohen Act3 discuss the need to

analyze business processes before acquiring a new system. GAO’s 1994

guide stated that information system projects that do not focus on process

2

Executive Guide: Improving Mission Performance Through Strategic Information Management and

Technology; Learning From Leading Organizations (GAO/AIMD-94-115, May 1994); Assessing Risks and

Returns: A Guide for Evaluating Federal Agencies’ IT Investment Decision-making (GAO/AIMD-10.1.13,

February 1997 Version 1); and Business Process Reengineering Assessment Guide (GAO/AIMD-10.1.15,

April 1997 Version 3).

3

The Omnibus Consolidated Appropriations Act of 1997 renames both the Federal Acquisition Reform

Act of 1996 and the Information Technology Management Reform Act of 1996 as the “Clinger-Cohen

Act of 1996.”

Page 5 GAO/GGD-97-132 INS Management Problems
Executive Summary

improvements typically fail or reach only a fraction of their potential. To

mitigate the risks associated with its approach, INS plans to analyze its

business processes during implementation of the new system, finalize a

detailed implementation plan, and develop a risk management plan.

GAO did not determine how successful each individual INS action has been

in addressing management problems. Moreover, GAO recognizes that it is

not reasonable to expect that all problems would be corrected

immediately and that adjustments will be necessary as these and future

changes are fully implemented. However, GAO’s survey of INS managers

conducted in the fall of 1995—a year after the Commissioner’s initial

policy and organizational changes—and subsequent interviews with INS

managers indicated that although many managers perceived that some

initiatives were having a positive effect, communications problems and

other challenges remained. Problems INS has experienced recently in

several key program areas—e.g., naturalization, criminal alien deportation

programs—appear to be, at least in part, caused by some of the

long-standing weaknesses in key management functions addressed in this

report, such as organizational structure, budgeting and financial

management, and management and administrative communications.

Principal Findings

INS Implemented a

Strategic Plan and Priority

Management System

To better focus its attention on key mission and operational priorities, INS

developed and issued a strategic plan in 1994. The INS strategic

plan—Toward INS 2000, Accepting the Challenge—identified eight major

strategic priorities, including such challenges as facilitating compliance

with immigration laws, deterring unlawful migration, and reengineering INS

work processes. Top INS headquarters and field managers participated in

the development of this strategic plan. GAO’s fall 1995 survey confirmed

that INS’ mission and priorities were clear to a majority of INS managers. A

majority of managers who said they had a basis to judge also agreed that

the strategic planning process had aided INS headquarters and regional

planning and decisionmaking. (See pp. 31 through 33 and pp. 37 and 38.)

To facilitate achievement of the strategic priorities identified in the plan,

INS implemented a priorities management process in fiscal year 1995.

Specific annual goals related to strategic priorities were identified for

special management attention, including the establishment of objectives,

Page 6 GAO/GGD-97-132 INS Management Problems
Executive Summary

tasks, time frames, and performance measures. In fiscal year 1996, to

further focus management attention on the most important goals, INS

ranked the annual goals according to their priority. By assigning senior INS

managers specific responsibility for achieving the annual priority goals, INS

intended to establish better organizational and individual accountability.

These steps appear to be consistent with the intent of GPRA. Although INS’

initial steps in developing a strategic plan and management priorities have

been positive, GAO’s past work at INS and at other agencies indicates that to

be successful, such initiatives require sustained top management attention

and commitment to continuously improve program performance. (See pp.

32 through 35 and p. 39.)

INS Reorganized Before 1994, INS’ 33 district directors and 21 Border Patrol chiefs were

supervised by a single senior INS headquarters manager. To reduce this

supervisory span of control and to improve program planning, review, and

integration, the Commissioner reorganized INS in 1994. The reorganization

established EAC positions for (1) policy and planning, (2) program

development, (3) management, and (4) field operations. The EAC for Field

Operations has overall responsibility for managing INS’ operational field

activities through three regional directors, who have been delegated

budget and personnel authority over the district directors and Border

Patrol chiefs in their respective geographic areas. (See pp. 21 through 25.)

GAO found that the reorganization succeeded in shifting some management

authority to officials closer to the field activities, and many INS managers

that GAO interviewed perceived the reorganization as a positive step in

providing oversight of field units. However, the implementation of the

headquarters reorganization also appears to have created some

uncertainty among INS managers and field staff about the relative roles and

responsibilities of the offices of some of the EACs. This uncertainty has

been amplified by internal questions about possible staffing imbalances

among the offices. GAO found that no analysis had been done, for example,

to determine the appropriate number of staff needed for the office of

program development, given the reassignment of some of its

responsibilities to other offices. (See pp. 40 through 43 and p. 48.)

Internal Communications

and Currency of Manuals

Problematic

Managers responding to GAO’s survey in late 1995 indicated that poor

communication, especially between headquarters and field units, was a

problem. The EACs took some steps during 1995 to clarify their roles and

channels of communication, but INS managers and staff told GAO in the

Page 7 GAO/GGD-97-132 INS Management Problems
Executive Summary

spring of 1996 that they still had difficulty determining the proper channels

through which to obtain policy guidance or implement program initiatives.

Communication problems continued to be evident in April 1997, when a

consultant to the Department of Justice reported that three different

versions of guidance on naturalization procedures had been distributed

throughout INS and that some offices were using the wrong version. (See

pp. 43 through 48.)

Lack of up-to-date policies and procedures was a finding of GAO’s 1991

review. Although INS has begun to update its field and administrative

manuals, no updated manuals had been issued as of February 1997.4

According to INS, in the absence of current manuals, managers and staff

needed to seek oral guidance more frequently than would otherwise have

been the case. Confusion over some offices’ roles and responsibilities may

result in further strain on agency communications and could result in

inconsistencies in guidance across locations.

In late 1995, a project officer was appointed to focus responsibility for

completing the field manuals. INS field manuals contain guidance on

program operations, such as how to conduct border inspections or

process alien applications. The project officer told GAO that the updating of

these manuals had been slowed in the past and at the time of GAO’s review

because priority for use of available staff resources was given to

developing regulations to implement new legislation. Part of the

Inspections Field Manual was expected to be issued in May 1997. The

project officer began work on other manuals in the spring of 1996, but

work was halted to develop regulations. A revised version of the

administrative manual, which contains guidance on such matters as

personnel procedures, cash collection, and use of firearms, had been

drafted, but negotiations about changes with the INS employee unions had

slowed finalization of the manual for several years. In the spring of 1996,

steps were taken to set priorities for union review of the administrative

manual segments, but at the time of GAO’s review, no milestone had been

established for the issuance of the manual. (See pp. 51 through 54.)

INS Took Steps to Improve

Processes for Allocating

Resources

Beginning in fiscal year 1995, INS incorporated the Commissioner’s

priorities into decisions about the allocation of new budget resources,

such as those provided by the Violent Crime Control and Law

4

In commenting on a draft of this report, INS officials said that agreement had been reached with INS

unions that 51 of the 295 chapters of the administrative manual needed only minor modifications and

did not affect work practices. INS staff were notified in April 1997 that those chapters were issued in

computerized form.

Page 8 GAO/GGD-97-132 INS Management Problems
Executive Summary

Enforcement Act of 1994. INS also took steps to use workload information

in making decisions on the allocation of resources, as GAO recommended

in 1991. (See pp. 62 through 66.)

The Departments of Commerce, Justice, and State Appropriations Acts

annually require INS and other agencies that receive funding under these

acts to notify the House and Senate Appropriations Committees of

adjustments in funding allocations within an account. This reprogramming

process applies whether funding is from fees or general funds. The

Department of Justice requires that its components wait to implement

reprogrammings until a response from Congress is received. In fiscal year

1994, according to INS officials, the agency experienced a dramatic decline

in applications filed, which resulted in a commensurate decline in revenue

available to fund its operations. Consequently, INS took steps to reduce

spending to ensure that it did not exceed available balances. (See pp. 68

through 70.)

Therefore, in fiscal year 1995, when INS experienced a dramatic increase in

applications filed, it delayed its reprogramming proposal to increase

permanent staff in order to determine whether, and at what level,

workload increases would continue. As a result, INS did not obtain

approval to reallocate funds until late in the fiscal year. Because the late

funding delayed planned hiring to meet the workload demands, it

contributed significantly to a doubling of the delay in processing

immigrants’ applications for adjustment-of-status and naturalization. For

example, the average delay in processing naturalization applications went

from 8.2 months at the end of fiscal year 1994 to 17.3 months at the end of

fiscal year 1995. INS prepared a proposal for additional spending authority

earlier in fiscal year 1996 to address the continuing workload increase.

(See pp. 70 through 75.)

Although INS has incorporated strategic priorities into its budget

decisionmaking and has begun to develop processes to improve the

allocation of resources based on analysis of workloads, use of workload

information varied among INS’ program offices. A May 1996 INS consultant’s

study of how the agency deploys its personnel resources concluded that

INS’ current processes tended to be reactive rather than prospective and

were driven more by resources that were available than by a

determination of workload-driven requirements. The study concluded that

better workload data were needed and that models currently in use

needed to be updated. INS has hired an additional consultant to identify

personnel deployment planning process improvements; that effort, which

Page 9 GAO/GGD-97-132 INS Management Problems
Executive Summary

includes design, installation, implementation and testing of a prototype,

was scheduled to be completed in June 1997. INS intends to contract for

enhancements to the model for other resource needs, such as equipment

and facilities. (See pp. 67 and 68.)

INS Did Not Follow

Fundamental

Practices for

Acquiring a New

Financial Accounting

System

GAO, the Department of Justice’s Inspector General, and the Justice

Management Division have all reported on serious weaknesses with INS’

principal accounting system—the Financial Accounting and Control

System. GAO reported that these problems persisted as recently as 1993

and 1995,5

 and the Justice Management Division assessments of the

system in 1993, 1994, and 1995 revealed that actions had not been taken to

address recommended improvements. Inaccurate financial data; unreliable

and antiquated financial management systems; and insufficient internal

controls over allocation, obligation, and expenditure of funds have made it

difficult for managers in INS headquarters to readily determine the financial

status of INS field units. These problems, in turn, made it difficult for INS to

monitor budget execution and to make sound budgetary decisions. (See

pp. 75 and 76.)

To improve financial management, INS took interim steps, such as

managing some resources at the regional level rather than the local level.

These steps were intended to improve the efficiency of collecting financial

information by reducing the number of reporting units and to facilitate the

collection of surplus6

 funds from the field for reallocation to unfunded

needs. INS has also implemented an independent position tracking system

intended to better manage personnel resources. (See p. 79.)

INS has also taken action toward implementation of a new financial

management system. On March 31, 1997, the agency selected a new

financial management system that is to have a phased implementation. INS

expects to implement some core functions at key financial management

locations at the start of fiscal year 1998. However, INS did not analyze its

financial management processes before selecting its new system. Previous

GAO work highlights the importance of business process analyses prior to

5

Immigration Issues: Making Needed Policy and Management Decisions on Immigration Issues

(GAO/T-GGD-93-18, Mar. 30, 1993); and INS: Update of Management Problems and Program Issues

(GAO/T-GGD-95-82, Feb. 8, 1995).

6

INS uses the term surplus funds to refer to funds that were not used during the fiscal year for

Personal Services and Benefits and therefore become available for other purposes.

Page 10 GAO/GGD-97-132 INS Management Problems
Executive Summary

information system acquisition. Specifically, GAO’s February 1997 guide,7

which provides a structure for evaluating and assessing how well a federal

agency is selecting and managing its information technology resources,

stated that a key hazard in acquiring information technology is that the

new system will automate outmoded, inefficient business processes. Also,

the Clinger-Cohen Act of 1996 requires executive agencies to analyze

processes before making significant investments in information

technology. The act sought to remedy the dilemma of using technology to

correct process problems by insisting that process redesign drive the

acquisition of information technology, and not the other way around.

According to INS, it had an urgent need to replace its system by fiscal year

1998. The agency also believed that due to the urgency, it could not

perform an analysis of its financial management processes before

selecting a new system. To mitigate the risks of its approach, INS plans to

perform business process analyses during implementation and develop a

comprehensive implementation plan and risk management plan. (See pp.

81 through 85.)

Recommendations GAO recommends that the INS Commissioner (1) further clarify the roles

and responsibilities of the EACs and determine whether staffing

adjustments are needed to fully implement the objectives of the

reorganization, (2) establish milestones for issuance of manuals or the

parts of manuals that can stand alone, (3) develop a strategy and schedule

for periodically evaluating the new deployment planning process to ensure

that it is compatible with INS’ key planning processes and provides

information managers need to adequately plan for resource needs and

make resource decisions, and (4) take steps to mitigate the risks

associated with INS’ planned approach for acquiring a new financial

management system. Such steps should include fully implementing plans

to analyze its current financial management processes and determining

future financial management process needs, finalizing a comprehensive

implementation plan, and fully developing and implementing a risk

management plan.

Agency Comments INS reviewed a draft of this report. INS said that it was pleased that GAO had

recognized its progress in developing a strategic plan, initiating an annual

priorities process, improving the resource allocation process, and linking

resource allocations to the Commissioner’s annual priorities. INS said that

7

Assessing Risks and Returns: A Guide for Evaluating Federal Agencies’ IT Investment

Decision-making (GAO/AIMD-10.1.13, February 1997, Version 1).

Page 11 GAO/GGD-97-132 INS Management Problems
Executive Summary

its staff were working on GAO’s recommendations to clarify roles and

responsibilities, establish milestones for issuance of manuals or parts of

manuals, and develop a strategy and schedule for periodically evaluating

the new deployment planning process. INS presented additional

information for actions that it is performing or plans to perform to mitigate

the risks associated with having selected a new financial management

system without first performing process analysis. GAO agrees that these

actions, if carried out effectively, are more consistent with the approach

that GAO’s work has indicated would mitigate risk, and the

recommendation on this issue was revised accordingly.

Page 12 GAO/GGD-97-132 INS Management Problems
Page 13 GAO/GGD-97-132 INS Management Problems
Contents

Executive Summary 2

Chapter 1 

Introduction

18

A New Era for INS 18

Past Management Problems 26

Objective, Scope, and Methodology 28

Chapter 2 

INS Made Progress

Toward Some

Management Goals of

the Reorganization,

but Others Continue

to Be Problematic

29

INS’ Strategic Plan and Annual Priorities Provided Direction 31

Reorganization Restored Regional Directors to Manage Field

Units

39

Reorganization Not Fully Implemented 40

Field and Policy Manuals Still Have Not Been Updated 51

Survey Results on Gains Made as a Result of Reorganization Were

Mixed

54

Conclusions 58

Recommendations 60

Agency Comments 60

Chapter 3 

Improvements Made

to Management of

Budget Resources, but

Problems Persist

62

INS Made Improvements in Planning Resource Allocations 62

Process for Notifying Congress of Need for Additional Funds

From Fee Account Contributed to Application Backlogs

68

Monitoring of Budget Resources Suffered From Inadequate Data 75

INS Contracted for Assistance to Strengthen Its Budget Process

and Improve Its Financial Management System

80

Conclusions 82

Recommendations 83

Agency Comments and Our Evaluation 84

Appendixes Appendix I: Roles and Responsibilities for the Offices of the

Executive Associate Commissioners and Regional Directors for

Field Operations

86

Appendix II: Objective, Scope, and Methodology 89

Appendix III: Survey Methodology 92

Appendix IV: GAO Survey on INS Management Issues 95

Appendix V: INS’ Fiscal Years 1995 and 1996 Priorities 119

Appendix VI: Comments From the Commissioner of the

Immigration and Naturalization Service

122

Appendix VII: Major Contributors to This Report 126

Page 14 GAO/GGD-97-132 INS Management Problems
Contents

Tables Table 2.1: Goals INS Established for the 1994 Reorganization 30

Table 2.2: Survey Responses Indicate Communication and

Coordination Problems

46

Table 2.3: Managers’ Responses to the Question: Generally, How

Successful or Unsuccessful Do You Think the Reorganization Has

Been in Achieving the Following Goals?

56

Table 3.1 INS’ Use of WAMs and Workload Data in Planning

Fiscal Year 1995 and 1996 Resource Allocations

65

Table 3.2: Average Projected Wait Times for INS Processing of

I-485 Adjustment-of-Status and N-400 Naturalization Applications

at the Start and End of Fiscal Year 1995

73

Table III.1: Survey Response Rates 93

Table V.1: INS’ Fiscal Year 1995 Priorities 119

Table V.2: INS’ Fiscal Year 1996 Priorities 121

Figures Figure 1.1: INS’ Organizational Structure, 1991 22

Figure 1.2: INS’ Organizational Structure, November 1994, With

Revisions as of March 1997

24

Figure 1.3: Key Events in the 1994 Reorganization 26

Figure 2.1: A Majority of INS Managers Responded That INS’

Mission and Priorities Are Clear

33

Figure 2.2: General Structure of the INS Priority Management

Program

35

Figure 2.3: Many INS Managers Perceived That the Fiscal Year

1995 Strategic Planning Process That Identified Nine Priorities

Aided Headquarters, Regional, and Budget Execution Planning

and Decisionmaking

38

Figure 3.1 Timeline of Key Activities for INS’ Fiscal Year 1995

Reprogramming

71

Page 15 GAO/GGD-97-132 INS Management Problems
Contents

Abbreviations

EAC Executive Associate Commissioner

FACS Financial Accounting and Control System

HITS Hiring Tracking System

INS Immigration and Naturalization Service

IRCA Immigration Reform and Control Act

JMD Justice Management Division

NAPA National Academy of Public Administration

OMB Office of Management and Budget

POSTS Position Tracking System

PS&B Personal Services and Benefits

VCRTF Violent Crime Reduction Trust Fund

WAM Workload Analysis Model

Page 16 GAO/GGD-97-132 INS Management Problems
Page 17 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

During the 1990s, heightened anxieties about legal and illegal immigration

have placed the Immigration and Naturalization Service (INS) in the

forefront of public attention. Congress has significantly increased the

agency’s resources to primarily enhance INS’ enforcement of immigration

policy and laws. INS has promoted naturalization and increased

enforcement activities to deter illegal immigration. At the same time, INS

has undergone a significant reorganization to address management

problems that have troubled it for years.

A New Era for INS Since 1993, INS has had a change in leadership, its budget has increased by

over 100 percent, and it has experienced an unprecedented increase in

naturalization applications. INS has also been under increased pressure

from Congress, states, and citizens to reduce illegal immigration. In 1993,

within the framework of the administration’s multiyear immigration

initiative, INS announced plans to more aggressively enforce immigration

laws to prevent illegal immigration. The multiyear plan is intended to

protect U.S. borders, reduce work incentives for illegal immigrants,

expeditiously remove criminal aliens, stop asylum abuse, reinvent and

revitalize INS, and encourage legal immigrants to become naturalized

citizens. In addition, INS reorganized to improve its oversight of field

operations and enhance its management capabilities.

INS Has New Leadership

and More Resources to

Implement Immigration

Laws

In November 1993, INS’ current Commissioner was sworn in. In

March 1995, she testified before the House Committee on Appropriations

that when she took office in 1993, “[I]mmigration was a backburner issue.

Its budget was insufficient because it failed to keep pace with INS’

complicated and growing responsibilities.”1

Since 1993, with congressional and presidential support, INS’ budget has

been increased dramatically to enable the agency to better implement and

enforce immigration laws. INS anticipates that at the end of fiscal year 1997

its budget appropriation will be $3.2 billion, which represents an increase

of 113 percent over the fiscal year 1993 level of $1.5 billion, and an

increase of 23 percent over the fiscal year 1996 level of $2.6 billion.

1

Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations for

1996: Hearings before a Subcommittee of the House Committee on Appropriations, 104th Cong., lst

Sess. pt.7, at 613 (1995) (statement of Doris Meissner, Commissioner, INS).

Page 18 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

At the end of fiscal year 1996, INS’ estimated on-board strength of full-time

permanent employees was about 23,000.2

 This represents about a

28-percent increase over the fiscal year 1993 level of about 18,000

employees. INS’ fiscal year 1997 appropriation provided for more than

26,000 positions, about a 44-percent increase over 1993.

More Aliens Applying for

Naturalization and Other

Status Changes

As debates in Congress and in state legislatures focus on burdens created

by both illegal and legal immigrants, an increasing number of legal

permanent residents across the country are seeking U.S. citizenship, often

years after they first became eligible to apply. In fiscal year 1995, INS

experienced unprecedented increases in naturalization applications, which

grew from approximately 600,000 in fiscal year 1994 to over 1.2 million in

fiscal year 1996.

Federal and state actions have prompted legal aliens to apply for

naturalization. For example, welfare proposals that were considered in

Congress during 1995 to deny federal assistance to legal immigrants who

were not citizens contributed to a spurt in naturalization applications.

Subsequent passage of the Personal Responsibility and Work Opportunity

Reconciliation Act of 19963

 made changes in the eligibility of noncitizens

for federal, state, and local benefits that according to an INS official,

contributed to more applications for naturalization. INS could also see a

significant increase in naturalization applications as aliens who qualified

for legal status under amnesty provisions in the 1986 Immigration Reform

and Control Act (IRCA) became eligible to apply for naturalization. In

addition, the Commissioner’s fiscal year 1995 annual priorities for INS

included promoting naturalization through public education programs.

Furthermore, Proposition 187, which passed in California in

November 1994,4

 may have motivated some legal aliens to apply for

naturalization because of its general anti-immigrant sentiment. This

legislation is intended to bar illegal immigrants from obtaining

educational, social, and nonemergency medical services.

2

INS also has about 3,000 part-time employees who have a role in adjudicating applications and

inspecting travelers.

3

P.L. 104-193, August 22, 1996.

4

Proposition 187 was a California ballot initiative to deny most public services to illegal immigrants. It

was adopted in November 1994 but was promptly challenged in court as unconstitutional. A federal

judge put a hold on the state’s implementation of the initiative, pending resolution of the court

challenges.

Page 19 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

INS also had a surge in applications during fiscal year 1995 from aliens who

sought to adjust their status. This surge resulted from the amendment

adding subsection 245(i) to the Immigration and Nationality Act of 1952.

Subsection 245(i) permits aliens within certain categories (e.g., entered

without inspection, worked illegally, or overstayed their visas) to apply for

permanent residence if physically present in the United States and eligible

to receive immigrant visas in their own countries.5

 Initially, these aliens

paid a sum of five times the standard filing fee in addition to the standard

filing fee.6

 During fiscal year 1996 and the first quarter of fiscal year 1997,

INS continued to receive a high level of new applications.

INS Is Placing More

Emphasis on

Strengthening Border

Control, Enforcing

Employer Sanctions, and

Removing Criminal Aliens

Most of INS’ fiscal year 1996 increased resources were to go toward

strengthening border control and, to a lesser extent, to stronger workplace

enforcement to reduce the lure of jobs to illegal immigrants and expedited

deportation of criminal aliens. INS’ strategy for controlling illegal entry

across U.S. borders between ports of entry includes adding border patrol

agents; placing fencing and lighting strategically; and using all-terrain

vehicles, infrared scopes, and other new equipment.

Although IRCA mandated that employers verify job applicants’ employment

eligibility,7

 according to the U.S. Commission on Immigration Reform, the

law has not been effectively enforced.8 INS has received funding to increase

enforcement of employer sanctions, and in fiscal year 1996 it received

authorization to hire 384 new investigators and support staff to conduct

and assist in workplace inspections. The agency is also taking steps to

issue work authorization documents that are designed to be

fraud-resistant, tamper-proof, and cost-effective, and to pilot-test other

methods of verification.

The removal of criminal aliens from the United States is another key

component of INS’ comprehensive strategy to prevent and deter illegal

migration. A focus of the criminal alien removal initiative has been more

5

Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies 1995

Appropriations and 1994 Supplemental Appropriations, P.L. 103-317, 8 U.S.C. 1255(i). See INS:

Information on Aliens Applying for Permanent Resident Status (GAO/GGD-95-162FS, June 8, 1995).

6

The filing fee was changed, however, by an amendment in the recently enacted Illegal Immigration

Reform and Immigrant Responsibility Act of 1996. The amendment to 245(i) set the amount of this fee

at $1,000, effective at the end of December 1996. P.L. 104-208 (1996), 8 U.S.C. 1255(i).

7

8 U.S.C. 1324a.

8

U.S. Immigration Policy: Restoring Credibility, A Report to Congress, U.S. Commission on

Immigration Reform, Sept. 1994.

Page 20 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

expeditious removal of aliens incarcerated in federal and state prisons and

local correctional facilities. INS’ stated strategy includes deporting more

criminal aliens by increasing detention capacity; streamlining

administrative procedures for deportation; and expanding its Institutional

Hearing Program, which is designed to place criminal aliens in deportation

hearings so they can be readily deported upon their release from prison.

INS Reorganized One of the first tasks the new Commissioner undertook in 1993 was to

reorganize INS. The reorganization was designed to address a span of

control problem that INS had identified as an unintended consequence of a

1991 reorganization and to alleviate other management problems

identified by others, such as the National Academy of Public

Administration (NAPA) and Congress.

The 1991 reorganization had centralized oversight of district offices and

Border Patrol sectors under one manager in headquarters. INS’

Commissioner at that time gave the program managers in headquarters

increased budget authority to allocate funding for personnel within their

programs in the second quarter of fiscal year 1990. Politically appointed

regional commissioners were replaced with career managers, who were

called regional administrators. These regional administrators provided

administrative support to field offices but did not exercise authority over

field operations. Figure 1.1 depicts INS’ structure as a result of the 1991

reorganization.

Page 21 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

Figure 1.1: INS’ Organizational Structure, 1991

Commissioner

Deputy Commissioner

Security

Internal Audit

Field Support

International Affairs

and Outreach

Associate

Commissioner

IRM

Data

Systems

Project

Integration

Records

Executive Associate Commissioner

for Management

Congressional and

Public Affairs General Counsel

Budget

Accounting

and

Financial

Management

Associate

Commissioner

Finance

Associate Commissioner

Human Resources and

Administration

Personnel

and

Career

Development

General

Administration

EEO

Regional Offices

Associate

Commissioner

Enforcement

Detention

and

Deportation

Investigations

Associate

Commissioner

Examinations

Adjudication

and

Nationality

Inspections

Intelligence Border

Patrol

Legalization and

Administrative

Appeals

District Offices Border Patrol Sectors

Executive Associate Commissioner

for Operations

Strategic Planning

Legend

Reporting relationship for administrative functions.

Source: Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies

Appropriations for 1994, Hearings before a Subcommittee of the House Committee on

Appropriations, 103rd Cong., 1st Sess. pt. 2B, at 3(1993).

Page 22 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

The 1994 reorganization sought to remedy at least two problems with the

1991 structure. First, the Commissioner thought the agency’s field

performance was uneven and poorly coordinated. In particular, the

headquarters operations office had an unrealistically large span of control

because of its responsibility for overseeing the operations of 33 district

offices and 21 Border Patrol sectors. Second, the Commissioner believed

that program planning, review, and integration had suffered because the

operations office was preoccupied with matters that should have been

handled by field managers and therefore could not focus on program

planning. To address these and other problems, the new structure

(1) established a new Office of the Executive Associate Commissioner

(EAC) for Field Operations to oversee field operations; (2) redesignated the

previous EAC for Operations as the EAC for the Office of Programs to

develop and disseminate policies, procedures, and other appropriate

guidelines required for program execution servicewide and to provide

analytical and evaluative support related to specific program operations;

(3) established an Office of Policy and Planning under an EAC to replace

the previous Office of Strategic Planning; and (4) established the EAC for

Management with many of the same management functions as it had under

the previous organizational structure, plus some new ones. The purpose of

establishing the Office of Policy and Planning at an executive level was to

reinforce the importance of servicewide planning on an annual and

long-term basis and to provide appropriate attention to macrolevel

immigration policy development and issue analysis. Figure 1.2 depicts INS’

organizational structure after the reorganization and at the time of our

review.

Page 23 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

Figure 1.2: INS’ Organizational Structure, November 1994, With Revisions as of March 1997

Commissioner

Deputy Commissioner

General Counsel

Public Affairs

Congressional

Relations

Internal Audit

Office of

Planning

Office of

Policy

Administrative

Centers

Finance

Information

Resources

Management

Systems

Integration

Data

Systems

Human

Resources and

Administration

Administration

Human

Resources

and

Development

Financial

Management

Budget

Security

Files and

Forms

Management

Equal

Employment

Opportunity

Office of

Regional

Director

Central

Region

Office of

Regional

Director

Western

Region

Districts/

Sectors

Districts/

Sectors

International

Affairs

Office of

Regional

Director

Eastern

Region

Districts/

Sectors

Foreign

Districts

Enforcement

Investigations

Detention

and

Deportation

Intelligence

Asset

Forfeiture

Border

Patrol

Administrative

Appeals

Records

Service

Center

Operations

Inspections

Adjudications

and

Nationality

Examinations

Executive Associate Commissioner

for Management

Executive Associate Commissioner

for Policy and Planning

Executive Associate Commissioner

for Field Operations

Executive Associate Commissioner

for Programs

Program planning Policy planning

Oversight of field operations Administrative support

Legend:

b b

a

b

aFunction detailed to Office of Field Operations in June 1995.

Page 24 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

bIncorporated into revised 1995 organizational chart.

Source: 8 C.F.R. 100.2, 1996 and INS.

Figure 1.2 shows that the regional offices now report to the Office of Field

Operations and have line authority over the district offices and Border

Patrol sectors. The regional offices are managed by regional directors

rather than regional administrators. The district offices and sectors are to

provide direct service to applicants for benefits and carry out statutory

enforcement responsibilities in their respective geographical areas.

Support and services are to be delivered to field offices through four

administrative centers.

All of the EACs are to serve as principal advisors to the Commissioner and

Deputy Commissioner, who is the Chief Operating Officer for INS. The EACs

also are to participate in the budget formulation and execution processes

as do the regional directors. Further information on the specific roles and

responsibilities for the offices of the EACs and the regional directors is

presented in appendix I.

Implementation of the current organization began in July 1994 and was

officially in place in October 1994. Some of the EACs were acting in their

positions prior to their official appointments to the new posts. Figure 1.3

shows some of the key events related to the 1994 reorganization.

Page 25 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

Figure 1.3: Key Events in the 1994

Reorganization

1993

1994

Year Month Event

November

January

February

July

July

September

October

November

December

October

Commissioner tasked a management group to develop and recommend

options for a new organizational structure.

Attorney General approved INS reorganization plan.

Commissioner outlined in a memo to all employees the plan to reorganize

and return to a decentralized structure. The new structure (1) established

four executive associate commissioners (EACs) and (2) provided for

career regional directors to have authority to oversee field units and

manage field units' budgets.

EACs for Field Operations, Programs, and Management offices

appointed to positions.

Regional director for Central Regional Office appointed.

Regional directors for Eastern and Western Regional Offices appointed.

Effective date for new organizational structure.

EAC for Policy and Planning appointed.

Final rule for INS reorganization printed in the Federal Register.

Regional directors assumed responsibility for controlling allocation of

personnel, salaries, and benefits funds to field units.

1995

Source: INS.

Past Management

Problems

Several of our past reports identified significant management problems

that have troubled INS for years.9

 Our Immigration Management report

identified many management problems related to INS leadership, service

delivery, the budget process, the financial management system, and the

organizational structure. Major problems cited in the reports included the

following:

• INS lacked clearly defined priorities and goals.

• INS’ organization was fragmented both programmatically and

geographically. In our report we attributed part of the fragmentation to the

inability of INS’ leadership to control the politically appointed regional

9

Immigration Management: Strong Leadership and Management Reforms Needed to Address Serious

Problems (GAO/GGD-91-28, Jan. 23, 1991); Financial Management: INS Lacks Accountability and

Controls Over Its Resources (GAO/AFMD-91-20, Jan. 24, 1991); and Information Management:

Immigration and Naturalization Service Lacks Ready Access to Essential Data (GAO/IMTEC-90-75,

Sept. 27, 1990).

Page 26 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

commissioners, who routinely used their authority to thwart headquarters’

efforts to allocate resources and manage programs.

• INS’ leadership had not adequately defined the roles of the two key

enforcement divisions, Border Patrol and Investigations, which resulted in

overlapping responsibilities, inconsistent program implementation, and

ineffective use of resources.

• Poor communications led to weaknesses in INS’ formulation of some

policies and procedures, and policy information was outdated.

• Budget management and resource allocation problems perpetuated

backlogs for processing aliens’ applications.

• Budgets were not based on agencywide priorities, and the budget process

did not adequately use workload to allocate staff.

• Unreliable financial information resulted in inadequate budget monitoring.

In response to management problems that were documented by an

internal Department of Justice audit in December 1988 and our 1990 and

1991 management reports, in 1990, Justice requested that NAPA provide INS

and Justice with a strategy to assist in the determination of the critical

management problems that needed to be addressed and courses of action

available to address them. The team preparing the NAPA report did not

conduct its own management review but instead relied on our studies,

audits and inspections by the Department of Justice’s Inspector General

and Justice Management Division, other INS and Justice documents, and

interviews with various officials. The NAPA report focused on providing

another perspective on the management problems and recommendations

to resolve them. NAPA’s findings generally agreed with our management

review findings but offered some different recommendations to resolve

the problems.10

INS management problems have continued, as indicated in testimony by

the Department of Justice Inspector General before the House

Appropriations Committee in February 1997. The Inspector General

reported that INS failed to conduct criminal history checks before granting

applications for citizenship, INS managers in Miami and the Eastern

Regional Office intentionally misled a congressional delegation, and some

major systems in INS’ automation initiatives were behind schedule.

10Managerial Options for the Immigration and Naturalization Service, A Report for the U.S. Department

of Justice, National Academy of Public Administration, Feb. 1991.

Page 27 GAO/GGD-97-132 INS Management Problems
Chapter 1 

Introduction

Objective, Scope, and

Methodology

The objective of this review was to follow up on our past INS management

report to determine whether steps had been taken to correct some of the

most significant management problems identified. Specifically, we

determined whether INS had

• developed goals and priorities to guide planning and resource allocation,

• revised its organizational structure,

• improved internal communications and updated its field and

administrative manuals,

• improved the process of allocating budgetary resources,

• improved its capability to monitor its financial status.

We used a variety of techniques to determine whether INS had taken steps

to address management problems. We reviewed past management studies

of INS; sent a survey in September 1995 to 3,676 career and appointed INS

managers and senior staff agencywide; and conducted interviews with

managers in headquarters, the regional offices, and certain district and

sector offices. We also reviewed agency documents on the reorganization

and budget execution. We began our audit work during the first fiscal year

that the reorganization was implemented. Therefore, our findings

represent INS’ progress in accomplishing its goals as of the time of our

review. The scope of this review cut across various INS program areas (e.g.,

employment verification and naturalization); components (e.g., Border

Patrol and Office of Investigations); and field offices (e.g., districts and

sectors); however, we did not evaluate the effectiveness of specific

program areas, components, or field offices. Furthermore, we did not

review management issues identified more recently, such as delays in

implementing several major automation systems. Appendix II provides a

more detailed description of our objectives, scope, and methodology.

Further details of the survey methodology are presented in appendix III.

We did our work between March 1995 and February 1997 in accordance

with generally accepted government auditing standards. We requested

comments on a draft of this product from the Commissioner of the

Immigration and Naturalization Service, and her comments are presented

and evaluated in chapters 2 and 3.

Page 28 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

The purpose of INS’ reorganization in 1994 was to address a broad

spectrum of management problems. The INS Commissioner wanted to

reduce headquarters’ span of control over field units to help improve field

supervision. In addition, the reorganization sought to improve servicewide

planning and policy development, strengthen operational program

planning, and enhance communications. We identified these management

areas as problems in our past studies. Table 2.1 lists INS’ management goals

for the reorganization, the intent of the goals, and the structural or role

change made to facilitate accomplishment of the management goals.

Page 29 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

Table 2.1: Goals INS Established for

the 1994 Reorganization Goal Intent Structure/role change

Goal 1

Develop a capability and

commitment to plan for the

future, set customer service

standards, and establish

quantitative performance

measures to enable INS to

evaluate its programs and

service delivery

To provide long-range

program and priority

planning

Establishment of the Office

of Policy and Planning

Goal 2

Decentralize

decisionmaking and

delegate authority to

persons geographically

closer to the locations

where work is being done

To decentralize the INS

management structure

Regional directors were to

supervise the district

directors and Border Patrol

chiefs. Regional directors

were also given authority to

manage personnel and

funds for the districts and

sectors.

Goal 3

Empower field operational

units to improve the

delivery of services to

customers

To directly involve regional

directors in field activities to

provide consistency in field

operations

Regional directors were to

oversee district directors

and Border Patrol chiefs.

Goal 4

Create a clearer sense of

mission by knitting together

INS’ major functions and

programs

To combine major functions

and place them in separate

offices, such as program

planning, policy planning,

and field operations

Establishment of the Office

of Programs, the Office of

Policy and Planning, and

the Office of Field

Operations

Goal 5

Reengineer major

processes, such as those

that develop and

disseminate organizational

policy and guidelines, and

that are outdated

approaches to handling

records and information

To establish planning

across INS rather than have

each headquarters program

office planning for its own

program without

considering agencywide

needs

Establishment of the Office

of Policy and Planning

Source: Federal Register, Vol. 59, No. 224, p. 60066, Nov. 22, 1994, and interviews with INS

officials tasked with recommending a revised organization structure.

Consistent with these goals and with alleviating a problem identified in our

1991 management report, INS developed a strategic plan and has set annual

priorities. A majority of INS’ managers who responded to our survey in the

fall of 1995 and expressed an opinion indicated that the annual priorities

aided planning and decisionmaking. Also, managers whom we interviewed

told us that they perceived that oversight of field operations had improved

Page 30 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

under the reorganization. In addition, INS decentralized its management

structure by restoring regional directors to manage field units, which is

intended to help improve field supervision.

Although some progress was made toward addressing past management

problems through INS’ reorganization, the implementation of the

reorganization has yet to address others and created some new problems.

INS’ implementation of the reorganization did not clearly delineate the

responsibilities and authority of the Office of Field Operations and the

Office of Programs, causing confusion for some managers. Also, poor

communication continued as a problem that was exacerbated by the

reorganization and the lack of up-to-date field and policy manuals.

INS’ Strategic Plan

and Annual Priorities

Provided Direction

In our 1991 management review, we reported that INS lacked a strategic

plan and that past priority management processes were not successful. We

also stated that past efforts to implement agencywide planning systems

lacked sustained top management support, managers were not held

accountable for achieving goals and objectives, and priorities were not

used in planning for decisionmaking. INS’ current leadership developed a

strategic long-term plan and established annual goals and objectives.

Annual priorities were used to plan and make resource decisions in fiscal

years 1995, 1996, and 1997. Top managers were major participants in the

annual priorities management process, and INS’ objectives had

performance measures.

INS Developed a Strategic

Plan

In 1993, INS began an 18 month strategic planning process that included all

top INS headquarters and field managers, as well as external stakeholders

interested in and affected by INS’ mission, to brainstorm issues facing the

agency over the next decade. A strategic planning work group comprising

a cross-section of INS program representatives and managers was

established to guide the development of INS’ strategic plan. Subsequently,

teams were formed to develop goals, objectives, and alternative strategies

for each key area. In the spring of 1994, the team leaders presented their

recommendations to the INS executive staff. In November 1994, INS

formally issued Strategic Plan: Toward INS 2000, Accepting the Challenge.

The INS Strategic Plan presented a blueprint intended to take INS into the

next century. The plan included the Commissioner’s vision for INS and a

mission statement. Eight major strategic directions, which were to guide

decision- and policymaking within INS, emerged from the planning process.

Page 31 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

The eight strategic directions were: (1) facilitate compliance with

immigration laws, (2) deter unlawful migration, (3) reinvent INS work

processes, (4) build partnerships to manage the immigration system,

(5) promote professionalism, (6) carefully collect and communicate

immigration information, (7) concentrate resources, and (8) measure

effectiveness. These strategic directions were to be the guiding operating

principles for development of more specific issue area program goals and

objectives.

INS’ strategic planning effort was undertaken at about the same time that

Congress passed the Government Performance and Results Act of 19931

(the Results Act). Also referred to as GPRA, the Results Act provided a

statutory framework for achieving more results-oriented management and

requires federal agencies to develop strategic plans by September 30, 1997,

that contain mission statements and outcome-related strategic goals.

Annual Priority Process

Initiated

During fiscal year 1995, INS also started to implement an annual priorities

management process. Annual priorities, referred to as the Commissioner’s

Priorities Program, include a statement of annual goals in support of INS’

strategic plan. According to INS, annual priorities seek to address both the

key current operational imperatives for the fiscal year and, to the extent

possible, the strategic goals and objectives previously identified. INS

defined a priority goal as that part of the INS mission, strategic direction, or

area of activity that the Commissioner has identified for special

management attention. Priority goals are defined as change-oriented

initiatives that address areas of high visibility, a new or renewed interest

that would not otherwise have received adequate attention, or special

needs that the Commissioner deems compelling. A particular goal may be

included in the Commissioner’s annual priorities for 1 or more years. Each

goal has several objectives that contribute to accomplishment of the goal,

and objectives within a priority are intended to be accomplished in 1 year.

Objectives are to have specific tasks, time frames for accomplishing tasks,

and performance measures.

During fiscal year 1995, INS had nine priority goals. According to the EAC

for Policy and Planning, the 1995 priority goals were not ranked in their

order of importance. For fiscal year 1996, INS had six annual priority goals,

which were ranked in their order of importance. See appendix V for more

information on the annual priority goals for fiscal years 1995 and 1996.

1

P.L. 103-62, August 3, 1993.

Page 32 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

The Commissioner communicated her commitment to the 1995 priority

goals at the annual Commissioner’s conference held in November 1995.

We found that INS’ mission and priorities were clear to a majority of INS’

managers. Figure 2.1 shows that 66 percent of the managers who

responded to our 1995 survey thought that INS’ overall mission was

somewhat clearly or very clearly communicated. Similarly, 61 percent of

the managers who responded to our 1995 survey believed that INS’

priorities have been somewhat clearly or very clearly communicated.2

Figure 2.1: A Majority of INS Managers

Responded That INS’ Mission and

Priorities Are Clear

0

20

40

60

80

66

61

34

39

Percentage of INS managers responding

Overall mission Priorities

Somewhat or very clear

Somewhat or very unclear

Source: Analysis of GAO 1995 survey responses.

2

This particular question has a 4-point scale rather than the 5-point scale that is generally used.

Page 33 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

INS Managers Are Charged

With Implementing the

Commissioner’s Priority

Program

The Commissioner emphasized the importance of priority management by

assigning responsibility for its implementation to key members of the

executive staff. In fact, in the new organizational structure, priority

management planning and implementation are primary responsibilities of

the EAC for Policy and Planning. As shown in figure 1.2, the EAC for Policy

and Planning function is at the same organizational level as executives

responsible for field operations, management, and program planning.

The EACs, General Counsel, assistant commissioners, and regional

directors are responsible for accomplishing goals and objectives.

Specifically, each of the EACs and the General Counsel, who report to the

Commissioner and Deputy Commissioner, are lead officials responsible

for the oversight and accomplishment of one or more of the priority goals.

Lead officials are to take “ownership” of a priority and be responsible for

directing, coordinating, and integrating the activities of cross-cutting

programs in order to achieve the priority. Assistant commissioners or

regional directors are generally the action officers responsible for

accomplishing the objectives within a priority. For example, the EAC for

Programs was the lead official for the 1995 goal to reduce incentives for

unlawful migration. This goal had several objectives, one of which was to

analyze and reinvent employer sanctions.3

 The action officers for this

objective were the regional directors for the eastern and western regions

and the Assistant Commissioner for Investigations at headquarters. Figure

2.2 illustrates the general structure for the priority management process

and the responsible officials, using one of the 1995 priority goals as an

example.

3

INS is responsible for enforcing the employer sanctions provision of IRCA. IRCA requires employers

to verify the employment eligibility of workers and imposes civil and criminal penalties, e.g., sanctions

against employers who knowingly hire unauthorized workers.

Page 34 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

Figure 2.2: General Structure of the INS Priority Management Program

Priority goal Objectives Action officers Lead official

EAC Office of Programs

Reduce incentives for

unlawful migration

Engage in increased employment

compliance and enforcement efforts

Assistant Commissioner for

 Investigations

Special Assistant to the Executive

 Associate Commissioner for the

 Office of Field Operations

Assistant Commissioner for

 Adjudications and Nationality

Associate Commissioner for 

 Information Resources 

 Management

Executive Associate Commissioner

 for the Office of Programs

Assistant Commissioner for

 Investigations

Regional Director Eastern

 Regional Office

Regional Director Western

 Regional Office

Analyze and develop recommendations for major systemic change and

pilot activities to test new approaches

Expand INS' employer assistance by

providing supporting information and 

direction to both employers and 

employees through revised publications, informational advertisement

campaigns, and selected personal

appearances

Simplify the status/eligibility verification process by reducing the 

numberof documents used and by 

improving the security and timeliness of INS-issued documents 

Assistant Commissioner for

 Investigations

Special Assistant to the Executive

 Associate Commissioner for the

 Office of Field Operations

Acting Director of the Office of

 Employer and Labor Relations

Source: INS implementation plan for its 1995 annual priorities.

According to INS guidance on the annual priorities management program,

the program provides a means by which organizational and individual

accountability can be established. Furthermore, quarterly reviews provide

for periodic evaluation of progress toward achieving the objectives.

Although we did not evaluate whether INS had achieved its priorities, we

note that in our 1991 management report we said that various planning

Page 35 GAO/GGD-97-132 INS Management Problems
Chapter 2 

INS Made Progress Toward Some

Management Goals of the Reorganization,

but Others Continue to Be Problematic

systems INS had used since 1980 fell into disuse after top management

support for them faded. Thus, we believe that the ultimate success of the

annual priorities management system will be dependent on the sustained

commitment of top management.

Three Stages of Priority

Process Coincide With

Budget Planning and

Monitoring

INS guidance states that there must be a correlation between priority

planning and budget formulation and between priority implementation and

budget execution. According to INS guidance, the Commissioner’s

Priorities Program has three principal stages: (1) priority identification,

(2) implementation planning, and (3) assessment and reporting. Priority

identification is to take place between April and June each year so that the

Commissioner can approve and issue priority statements for the next

fiscal year by July 1. Implementation planning is to occur between July

and mid-September so that approval of the annual priorities can coincide

with the beginning of the fiscal year. According to an INS official, since the

start of the fiscal year 1996 priorities cycle, INS has also combined the

annual priorities reporting and assessment reviews and budget execution

financial reviews so that the annual priorities are an integral part of the

budget monitoring process.

Fiscal year 1995 was the first year that the Commissioner issued annual

priorities. Because the annual priorities were identified in the fall of 1994

and implementation plans were not formally issued until January 1995,

they were not used in budget formulation for fiscal year 1996, which would

have begun in the spring of 1994. However, according to INS officials,

priorities were used in budget execution planning for new initiatives in

fiscal years 1995 and 1996. Also, during the fiscal year 1995 quarterly

reviews, the assessment of the annual priorities implementation was

conducted concurrently with the budget financial review. We discuss the

link between the annual priorities and the budget process further in

chapter 3.

For fiscal year 1996, INS identified its annual priorities in August 1995.

According to INS officials and INS budget guidance, the emphasis for fiscal

year 1996 was to allocate new budget resources to support the

Commissioner’s 1996 priorities. According to an INS official, new resources

for fiscal year 1997 were used to support the 1997 priorities. INS was also

examining ways that it could estimate obligations to specific annual

priorities.

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Similar to many other government agencies, INS’ fiscal year 1996 budget

was subject to several continuing resolutions, and the agency experienced

periods of employee furloughs. For fiscal year 1996, prescribed time

frames for establishing performance measures and assessment of the

annual priorities were not followed. According to a memorandum

prepared by the EAC for Policy and Planning, management of the 1996

annual priorities was an iterative process, and implementation plans were

revised as needed to address changes caused by the furloughs and the

delay in receiving a final budget from Congress.

According to an INS official, INS needs to link the fiscal year priorities,

which are to be finalized in the two quarters preceding the beginning of

the new fiscal year, and INS’ budget formulation, which occurs 2 years

before the actual fiscal year involved. To that end, in December 1996, INS

engaged in a process for obtaining headquarters and field manager input to

identify priorities that should be addressed for fiscal year 1999. This

activity reportedly led to initial identification of fiscal year 1999 priorities,

which are serving as the backdrop for the development of the fiscal year

1999 spring budget plan.

Survey Results Indicated

Many Managers Believed

Annual Priorities Aided

Planning and

Decisionmaking

In our survey, we asked INS managers their opinions on the extent to which

the strategic planning process, which identified nine priorities for fiscal

year 1995, had aided INS. Thirty-eight to 54 percent of the managers

responded that they had no basis to judge. However, of those who had an

opinion, a majority of managers responded positively. Figure 2.3 shows

that INS managers who had an opinion perceived that the strategic

planning process aided INS headquarters and regional planning and

decisionmaking from “some extent” to “ a very great extent.” Seventy-nine

percent of the managers who expressed an opinion said that the process

aided headquarters planning, and 81 percent of the managers who

expressed an opinion responded that the process aided regional planning.

Seventy-four percent of the managers who expressed an opinion said that

the process aided headquarters decisionmaking, and 79 percent of the

managers who expressed an opinion said that the process aided regional

decisionmaking. A majority of survey respondents who expressed an

opinion also perceived that the priorities process aided budget execution.

Sixty-eight percent of the managers who expressed an opinion said that

the process aided budget execution planning, and 67 percent of the

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managers who expressed an opinion said that the process aided budget

execution decisions.4

Figure 2.3: Many INS Managers

Perceived That the Fiscal Year 1995

Strategic Planning Process That

Identified Nine Priorities Aided

Headquarters, Regional, and Budget

Execution Planning and

Decisionmaking

0

20

40

60

80

100

Region

 n = 1052

Headquarters

 

 n = 1240

Planning Decisions

Planning

 n = 1398

Decisions

 

 n = 1382

Headquarters

 n = 1202

Region

 n = 1081

Some, moderate, great, very great extent 

Little or no extent

Extent aided (as a percent)

Budget execution

Source: Analysis of GAO 1995 survey responses.

These responses showed that progress had been made toward using

annual priorities to plan and make decisions. However, 19 to 33 percent of

4

For survey responses on whether the priorities had aided INS, we have deviated from the usual

presentation by combining the response scales “to some extent” through “to a very great extent” and

kept the response scale “to little or no extent” separate. We did this to measure whether the strategic

planning process has had an impact, not to measure the degree of the impact. Figure 2.2 shows the

extent to which priorities were perceived to be helpful. We did not include respondents who answered

“no basis to judge” in our analysis.

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the INS managers responded that priorities had marginally, i.e. to little or

no extent, aided planning and decisionmaking. This indicated that some

managers believed that more could be done in this area.

INS Priority Management

Process Included Some

Tasks Required for

Implementation of the

Government Performance

and Results Act

The Results Act was passed in 1993 to, among other things, improve the

effectiveness and efficiency of federal programs by establishing a system

to set performance goals and measure results. The Act is to improve the

performance of governmental programs through a set of integrated

activities that include strategic planning, setting annual performance

targets, measuring progress toward reaching those targets, and reporting

on results. INS took some early steps consistent with the goals of the Act’s

requirements with the establishment of its strategic plan in 1994 and the

implementation of the Commissioner’s Annual Priorities Program in fiscal

year 1995. INS officials told us that during the development of the fiscal

years 1996 and 1997 implementation plans, increased attention was given

to establishing and tracking performance measures that would align with

the Results Act. INS officials said that they recognized that additional

efforts are still required to fine-tune performance measurement, reporting,

and coverage of appropriate program activities. In April 1997, INS officials

told us that both the Office of Planning and the Office of Budget were

combining efforts to review the Act’s measures. GAO’s past work at INS and

at other agencies indicates that to be successful, such initiatives require

continued top management attention and commitment to continuously

improve program performance.

Reorganization

Restored Regional

Directors to Manage

Field Units

The 1994 reorganization restored regional directors into the chain of

command to supervise district directors and Border Patrol chiefs. As a

result, according to some managers, district directors and Border Patrol

chiefs received more supervision. Prior to the 1994 organization, the EAC

for Operations was responsible for directly supervising 33 district

directors and 21 Border Patrol chiefs. Some managers told us that district

directors and Border Patrol chiefs were often able to operate

independently of headquarters direction. The current Commissioner

considered this span of control too large and supervision too far removed.

Under the current organization, the EAC for Field Operations is to provide

headquarters direction to the field by supervising the three regional

directors. Each regional director in turn is to supervise an average of 18

district directors and Border Patrol chiefs. According to INS managers,

with the smaller span of control, regional directors can be more

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but Others Continue to Be Problematic

responsive to field needs and provide more oversight than the EAC for

Operations could under the previous structure. According to a

headquarters Field Operations manager, an assistant district director, and

a deputy regional director, the strength of the regional structure lies in the

direct, personal contact between regions and districts. This is reportedly

better than the former structure, because headquarters does not have the

resources to respond to all the districts and sectors and is too far removed

from the field to know the problems that the field is having.

In addition to reestablishing a regional structure with oversight

responsibility for field units, INS’ reorganization delegated resource

allocation authority to regional directors to provide consistency in field

operations and improve the delivery of services. According to regional

directors, they had gradually begun to exercise their new authorities. For

example, one regional director told us of having taken the unprecedented

act of moving a couple of positions from one district to another.

Furthermore, regional offices began to manage personal services and

benefits (PS&B) funds for district offices and Border Patrol sectors

beginning in fiscal year 1996. PS&B funds are payroll costs and represent

the majority of INS’ budget. The allocation and management of PS&B funds

were being maintained at the district and sector levels during fiscal year

1995. Two regional directors told us that the district directors were no

longer able to act independently.

Managers responding to our survey were divided in their perceptions of

the success of the reorganization. Generally, 35 to 40 percent of managers

responding to our survey believed that the reorganization was somewhat

or very unsuccessful in clarifying lines of authority, delegating authority to

persons geographically closer to locations where work was being done,

and decentralizing decisionmaking. About 20 percent of the managers

responding believed that the reorganization had been very or somewhat

successful in achieving these goals.5

 More information on the survey

results and our interpretation of them is presented later in this chapter.

Probing the reasons behind these survey responses was beyond the scope

of our study.

Reorganization Not

Fully Implemented

At the time of our review, INS had not fully defined the responsibilities and

authorities of the offices of Field Operations and Programs, nor had it

determined staffing levels for these offices on the basis of their new

5

This survey question listed 11 goals and had 8 response categories. For more details, see appendix IV,

question 34.

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but Others Continue to Be Problematic

responsibilities. Also, INS had not improved communications and

coordination among offices or updated field manuals and the policy

manual, as we previously recommended. We recognize that the

Commissioner did not expect the reorganization to correct all problems

immediately and that adjustments are needed as a new organizational

structure is implemented. However, we believe that fully implementing the

reorganization as soon as possible would help INS work more efficiently

and help achieve the goals of the reorganization.

Our survey and interviews with managers indicated that headquarters and

field managers were confused and frustrated because INS’ implementation

of its new organizational structure left unclear the differences in

responsibility and authority between the Office of Field Operations and

the Office of Programs. Also, INS did not determine the staffing levels that

would be needed for the Office of Field Operations to carry out its new

functions, did not determine the staffing levels for the Office of Programs

to meet its changed responsibilities, and did not move all operational

activities to the Office of Field Operations. Some INS managers told us that

they were having difficulty determining whom to coordinate with, when to

coordinate, and how to communicate with each other because they were

unclear about headquarters offices’ responsibilities and authority. Some

managers also said that they believed resources in the Office of Field

Operations were insufficient to meet field needs.

Responsibilities and

Authority of the Office of

Field Operations and

Office of Programs Were

Unclear

In December 1994 INS published an organizational chart and general

description of the roles and responsibilities of the Office of Field

Operations and the Office of Programs in the Federal Register (see ch. 1).

However, we were told by headquarters and field managers that INS had

not clearly delineated the respective roles and responsibilities of these two

offices. As stated by an INS field manager, “Neither [office] seems to know

the limits of its responsibilities nor the parameters of its authority.” INS

managers whom we interviewed also said that because the authority of the

EACs was not clear, decisions that should have been made at the EAC level

often had to go to the Deputy Commissioner for resolution.

In our interviews with INS managers and in comments written on our

survey, some managers indicated that they felt frustrated by a lack of clear

understanding of responsibilities and authority at headquarters. As one INS

manager stated on our survey:

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but Others Continue to Be Problematic

“With respect to the whole reorganization of 1994, there seemed to be little thought given

to its implementation and actual practical working[s] beyond just an organizational chart.

Overnight the [re]organization was implemented with virtually no transition, leaving . . .

each office [to] themselves to figure out what to do. Rather than plan for this organization

in some detail, it was left to personal ideas of the top management who gained the new

positions in the new structures to determine what would happen.”

INS managers whom we interviewed provided examples to demonstrate the

lack of clear delineation of responsibility between the Office of Field

Operations and the Office of Programs. One example related to the

development of the deployment plan for interior enforcement for fiscal

year 1996. The Office of Programs drafted the deployment plan because it

does the program planning for allocating resources to meet the

Commissioner’s priorities. It sought input from the field units and

subsequently provided a draft to the other EACs. When the EAC for Field

Operations received the Program Office’s subsequent draft, he determined

that the revised draft did not adequately consider or incorporate field

concerns. The EAC for Field Operations sent his own draft proposal for a

deployment plan to the field units with assumptions different from those

in the plan prepared by the Office of Programs. The field units provided

input to the second draft proposed by the Office of Field Operations.

Subsequently, the Deputy Commissioner intervened and instructed the

two EACs to develop a single proposal that they could agree upon.

Another example provided to us involved the selection of employees from

the field to train as instructors for firearms courses. A district manager

said that headquarters Field Operations staff asked the region to provide a

list of employees to attend instructor training for new firearms that were

being issued. The district manager provided a list to headquarters of

employees that the district wanted to recommend for instructor training.

The headquarters Field Operations staff selected employees from the list

to attend the training.

Subsequently, the headquarters Programs office staff asked the district

manager to provide a list of employees to be trained as instructors for the

firearms training. The district manager provided the Office of Programs

the same list of employees recommended for instructor training, and the

staff in the Programs office selected from it. The Office of Programs and

the Office of Field Operations selected different employees from the lists

provided. It was initially unclear to the district manager who was

responsible and had the authority to select employees for instructor

training. The Office of Programs ultimately made the decision on who

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but Others Continue to Be Problematic

would take the instructor training but, according to the district manager

who provided this example, field staff were confused and frustrated by the

situation.

Some headquarters and field managers whom we interviewed told us that

it is difficult to separate program planning activities and operational

activities. For example, some headquarters managers said it is clear that

the Office of Programs is responsible for such things as planning where

resources should be allocated and that the Office of Field Operations is

then responsible for implementing the use of resources as planned. But, as

stated by an INS official, it is unclear where planning ends and

implementation begins. This had implications for where responsibilities

and authorities should begin and end and where coordination is needed.

An example that illustrates the difficulty in separating program planning

and implementation was the development of a new automated system for

allowing people to enter the United States at remote locations along the

northern border.6

 According to INS officials, the headquarters program

office was working with staff in the district office in Montana to test the

use of new systems for the northern border. The headquarters Program

Office manager and the staff in Montana proceeded to develop the new

systems without including the region or the Office of Field Operations

until they needed staff for the project. The region did not know that it

would have to provide a staff position to the Montana office in order to

implement the new technology until the Program Office contacted the

Field Operations office when the resource was needed. The region was not

involved in the program planning for this initiative but was eventually

responsible for providing the district resources to support it. This started

out as a planning activity but became an operational one.

Communication Processes

Within the New Structure

Had Not Been Clearly

Defined and

Communicated

In a February 1994 memo to INS employees, the Commissioner stated that

the new organizational structure would build communication capabilities.

As one of its new responsibilities, the Office of Programs was to develop

communication capabilities. However, under the reorganization, it had

difficulty developing new communication paths with the rest of the

agency. Managers in the Investigations Office of Programs told us they

initially thought that their chain of command for communicating with the

districts was through the Office of Field Operations. This reportedly

6

At selected remote ports-of-entry that are not open 24 hours, local residents on both sides of the

border are to be able to apply for a permit allowing them to cross the border during the hours when

the port is closed using new technology for identification. Montana piloted the use of computerized

voice recognition and video conference by inspectors located at the nearest 24-hour port-of-entry.

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but Others Continue to Be Problematic

became too burdensome over time. Consequently, according to these

headquarters program managers, the EAC for Field Operations provided

oral guidance to the field units on when it was appropriate for the

headquarters Programs Office to contact the field directly and when the

Programs Office should go through the Office of Field Operations.

However, headquarters program managers told us that in practice, some

headquarters Field Operations staff continued to require that all

communications go through their office. Also, field units continued to

consider their appropriate channel of communication to be through the

regions and the Office of Field Operations. At the time of our review, INS

had not provided any written guidance on what needs to be communicated

and coordinated and when it should happen.

In March 1996 we met with the Commissioner and Deputy Commissioner

to obtain their perspectives on particular problems that managers in the

agency had described to us. During this meeting they told us that it would

be appropriate for field managers to communicate with headquarters

program managers without going through the Office of Field Operations

when program managers are seeking information or getting the field’s

input. The Commissioner told us that headquarters program managers

need to talk with the field to develop policies and assess the effectiveness

of policies. According to the Deputy Commissioner, the headquarters

program managers should go through the Office of Field Operations and

regional directors when they are tasking the field to do something that will

involve consumption of operational resources.

Nonetheless, according to headquarters program managers, some staff in

the Office of Field Operations continued to require program staff to go

through their office before contacting the field. This was reportedly the

case regardless of the purpose of the contact. Some headquarters program

managers reported that they have received mixed messages from the

Office of Field Operations on the circumstances under which they can

communicate directly to the field.

Another example of problems with the channels of communication

pertained to who had responsibility for a priority and the lack of

coordination between offices. We were told by some INS managers that

communication problems had occurred between the Office of Policy and

Planning and the Office of Programs. Headquarters program managers in

the investigations program area believed that the Office of Policy and

Planning had developed a priority objective for antismuggling but had not

consulted with the headquarters investigation managers even though the

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

headquarters investigations program area has an antismuggling branch

that has a role in planning for the area. The investigations program

managers responsible for antismuggling activities said they would have

liked to have been involved. According to one official, it was unclear

whether the Office of Policy and Planning did not see a need for their

involvement or if there were not enough people in the Office of Policy and

Planning to coordinate the sharing of products. However, according to an

Office of Policy and Planning official, the EAC for Field Operations—not

Policy Planning—was the lead official for a priority that included this

objective. The official said that the Office of Field Operations did not

include the Office of Programs Investigations Division staff in the process

and, thus, was not employing the proper approach to priority management

by involving appropriate offices.

Survey Responses

Reflected Problems With

Communication and

Coordination

INS managers responding to several questions in our September 1995

survey indicated that there were problems coordinating and

communicating, particularly between headquarters and field units.

Sixty-three percent of the managers indicated that poor communications

was a problem to a great and very great extent.7

 Ninety-two percent of the

managers responded that headquarters should consult more with the field

when developing policy. Seventy-three percent of the managers responded

that headquarters was not in touch with events, problems, and concerns of

the field. Fifty-nine percent of the managers responded that coordination

and cooperation among INS units needed improvement to a great or very

great extent. Although field managers were more likely to respond that

headquarters should consult the field more and that headquarters was not

in touch with events and concerns of the field, a majority of both

headquarters and field managers responded that there was a problem.

Table 2.2 presents these survey results for all managers combined and for

headquarters managers and field managers separately.

7

The analysis of survey data in this paragraph does not include respondents who answered “no basis to

judge.”

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Table 2.2: Survey Responses Indicate Communication and Coordination Problems

Percent of

Question Statement Response category

All

managers

Headquarters

managers

Field

managers

Thinking about the

implementation of INS

internal policy, would you

agree or disagree with the

following statements as they

apply servicewide?

Headquarters should

consult more with the field

when developing policy.

Agree or strongly agree 92 83 95

Do you agree or disagree

with the following statements

concerning INS as an

organization?

Headquarters is in touch

with events, problems, and

concerns in the field.

Disagree or strongly

disagree

73 64 76

In your opinion, to what

extent, if at all, do you feel

the following areas need

improvements servicewide?

Coordination and

cooperation among INS

units.

To a great or very great

extent

59 70 56

Source: Analysis of GAO 1995 survey.

The following written comments from INS managers in our survey further

illustrated the perceived problems with communication and coordination

in the fall of 1995:

• “The Commissioner’s reorganization has created so many layers of

oversight that it delays all communications to the field. Even on routine

program or operational matters, all communications must go through the

EAC for Field Operations.”

• “Since the reorganization, the lines of authority and communication

between Programs and Field Operations have become more complex. We

need better understanding and cooperation among all INS functions.”

• “The reorganization has created lots of confusion in our office. Many areas

do not know if they report to the regional office or headquarters . . . .

There is no clear definition of who reports where.”

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but Others Continue to Be Problematic

INS Attempted to Clarify

Responsibilities and

Communication Processes,

but Problems Had Not Yet

Been Resolved

INS has taken actions to try to solve some of the concerns about roles,

responsibilities, and communications. In April 1995, the EAC for Field

Operations sent an electronic mail message to the western region

requesting feedback on the reorganization and suggestions for

communication mechanisms. The Western Regional Director forwarded

the request to the districts and sectors under his jurisdiction and then

provided their comments to the Office of Field Operations. Several district

directors and Border Patrol chiefs reported many of the same

coordination and communication problems that were reported to us from

the cross-section of managers whom we interviewed. We could not

determine whether a message had been sent to the other regional offices,

but the regional managers for the eastern and central region told us that

they did not remember such a request.

In August 1995, the EACs and staff from the headquarters Field Operations

and Programs offices met and discussed their roles, responsibilities, and

communication issues. The EAC for Field Operations summarized the

results of the meeting and communicated them to the regional and

international affairs directors. The summary defined the roles of each of

the offices.

The summary said that Field Operations was looking to the Office of

Programs to develop plans, conduct analysis, and devise tools for tracking

progress in the field. In addition, according to the EAC’s summary, the

group agreed that the Office of Programs would conduct an inventory of

reports that it prepares that could be shared with the Office of Field

Operations. The summary also stated that the group agreed there would be

more active sharing of information between the two offices.

The EAC’s summary listed actions to be taken by the Office of Field

Operations and the Office of Programs. These included developing

mechanisms for Field Operations to provide input to the Office of

Programs and clarifying Field Operations organizational structure for

liaison purposes. The summary also recommended that the Office of

Programs and the Office of Field Operations set up regular meetings at the

assistant commissioner level with structured agendas. Furthermore, the

summary presented other ideas that the group discussed, such as

(1) having an 800 number for the reporting of problems and incidents,

(2) including managers from the Office of Management in a later meeting,

and (3) discussing at a later meeting where the Office of Policy and

Planning fits in.

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According to an INS official in the Office of Field Operations, the summary

was provided to the regional directors but was not shared with the Office

of Programs. The Office of Programs did not prepare a summary of the

meeting, according to officials in that office.

In the spring of 1996, we interviewed several headquarters investigations

and detention and deportation program managers about problems

between headquarters and field managers. We also recontacted some field

managers in the central and western regions about problems described to

us earlier in the review. According to several headquarters program

managers, some improvements had occurred, but communication

problems continued. The weekly meetings between the managers in the

individual program offices and the Office of Field Operations provided a

mechanism for sharing some information on routine operations, but the

participating officials did not have the authority to make major decisions.

Several field managers that we recontacted told us that there was still

confusion in the field regarding responsibilities and communication. A

recent example of continuing communication problems was reported by a

consultant to the Justice Department who was reviewing INS’

naturalization procedures. The consultant reported that three different

versions of guidance on naturalization procedures had been distributed

throughout INS and that some offices were using the wrong version. One

version was a copy of the memorandum signed by the Commissioner,

another was an unsigned electronic version of the memorandum with

different attachments, and the third was an early version drafted for the

Deputy Commissioner’s signature.

Staffing Level for the

Office of Field Operations

Was Perceived to Be

Insufficient

Several managers whom we interviewed stated that the Office of Field

Operations had not been sufficiently staffed to accomplish its function and

duties. According to the EAC for Field Operations, the initial plan for the

reorganization intended that the Office of Field Operations have a

relatively small staff and that the regional office staff be an extension of

the headquarters office. The expectation was that regional offices would

be more involved with the districts and sectors and would respond to their

needs. However, as the reorganization evolved, the headquarters office

found that it needed more staff at headquarters to accomplish its

functions. A June 1994 organization chart provided for 29 positions in the

Office of Field Operations. According to an INS official in the Office of

Field Operations, as of March 1996, the Office of Field Operations had 41

authorized positions, of which 32 were filled. No analysis had been done to

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determine what the staffing levels should be in relation to the

responsibilities of the headquarters Office of Field Operations.

Headquarters investigations managers in the Office of Programs provided

an example of the problem of insufficient staffing level in the Office of

Field Operations. Within the Field Operations office, three people handled

field issues for investigation activities; and in each of the three regions,

three or four staff were dedicated to investigations work. According to the

headquarters program managers in investigations, the investigations staff

in the Field Operations Office were overwhelmed because there were

about 2,000 investigators in the field units seeking assistance from the few

staff in the regional office and headquarters Field Operations. Several

managers told us in interviews and through written comments on our

September 1995 survey that the headquarters field operations office was

not sufficiently staffed to handle the workload.

Some Office of Programs managers told us that they felt that they had to

respond to field inquiries and assist the Office of Field Operations because

that office was unable to handle the numerous calls and accompanying

heavy workload. According to these headquarters program officials, field

managers called them for assistance because they were unable to reach

headquarters Field Operations staff. However, some staff in the

headquarters Office of Field Operations perceived that headquarters

program officials were unwilling to relinquish the authority they formerly

had over field operations.

Staffing Level for the

Office of Programs Had

Reportedly Not Been

Reassessed After

Responsibilities Changed

According to managers in headquarters, the regional offices, and field

units, staffing levels for the Office of Programs were not changed as a

result of the reorganization even though the responsibilities of the office

had changed.

Some managers outside of the Office of Programs perceived that there was

an imbalance between resources in the Office of Programs and the Office

of Field Operations, and some survey respondents commented that the

personnel resources of the Office of Programs remained the same despite

the change in its role and responsibilities. For example, at headquarters,

the Office of Programs had 531 authorized positions compared to the 41

authorized positions in the Office of Field Operations in March 1996.

Further, the investigations program in the Office of Programs had 46 staff

and, as mentioned previously, the Office of Field Operations’

investigations staff consisted of 3 people, according to INS officials. It

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would seem logical that with changed responsibilities, INS would need to

reassess its staffing of this office.

Leaving Operational

Activities in the Office of

Programs Caused Some

Confusion

One of the objectives of the reorganization was to separate program

planning and operational activities so that headquarters program

managers could focus on program planning and not be involved in the

day-to-day operations. However, INS management decided that some

operational activities should remain in the Office of Programs. According

to the headquarters program managers whom we interviewed in the

Investigations and Detention and Deportation Offices, some operational

activities were left in the headquarters Office of Programs because the

workload needed to be done at headquarters and was too large for the

Office of Field Operations to take over. These program managers also told

us that another reason operational activities were left in the headquarters

Programs office was that the staff had particular expertise in a particular

program area that was relevant to both planning and operations.

According to the Commissioner and Deputy Commissioner, INS needed the

mix in expertise of staff left in the Programs Office to do the program

planning functions. However, headquarters program managers told us that

because they continued to do operational activities, they did not feel that

they were able to devote enough time to planning activities.

We did not identify all the operational activities that continued to be the

responsibility of the Office of Programs, but through interviews we were

able to identify a sample of the kinds of operational activities that

remained there. Management of the Mariel Cubans8

 and juveniles in

detention facilities are two activities that were left in the Office of

Programs. According to INS officials, the caseload for processing Mariel

Cubans was too large for the newly created Office of Field Operations to

handle. In the case of juveniles, headquarters program managers told us

that they had the expertise to contract for juvenile bed space. Until the

reorganization, the Office of Programs’ detention and deportation staff

handled both the planning and operational aspects of detaining juveniles.

Since they had the experience, INS management decided to have the staff

in Programs continue handling both planning and operations for juveniles.

Other operational activities that remained in the Office of Programs

included processing of applications for immigrant benefits through INS’

four service centers, oversight of the witness security program, and review

and approval of requests for authority to conduct undercover operations.

8

Mariel Cubans are Cuban nationals who were allowed to enter the United States as refugees in 1980.

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but Others Continue to Be Problematic

We found no evidence that field units were unable to accomplish their

missions because some operational functions remained in the Office of

Programs. However, several headquarters and regional managers told us

that having operational functions remain in the Office of Programs

contributed to the confusion regarding when and how to coordinate with

the Office of Field Operations.

Field and Policy

Manuals Still Have

Not Been Updated

Through the reorganization, INS sought to create a structure that would

enable it to reengineer major processes, such as those that develop and

disseminate organizational policy and guidelines. We reported in 1991 that

policy information was outdated, and we found in this review that policy

information still has not been updated. INS was in the process of updating

manuals in some program areas but not in others. Sections of the manuals

are to be issued as they are completed, but no revised manuals or sections

of manuals had been issued as of February 1997.9

INS Was Beginning to

Update Field Manuals

Six program areas10 are to have field manuals containing policies and

procedures on how to implement the immigration laws. These field

manuals are basic reference tools for managers. For example, INS

managers rely on the inspector’s field manual to explain the procedures

for inspecting cruise ships and cargo vessels and the necessary forms for

each of these inspections. If a stowaway is found, the field manual also

explains the procedures INS employees are expected to follow.

According to an INS official, until 1995, no work had been done on the

manuals for about 5 years. To help alleviate this problem, in November

1995, INS assigned a project officer specifically responsible for updating

manuals.11 The project officer told us that in the past and at the time of our

review, completion of field manuals had been delayed because staff

assigned to develop them had been sidetracked to develop regulations to

implement legislation. In a briefing report used in March 1996, INS stated

that the lack of updated field manuals had created a burden for employees

because they had to search out too many sources of information on

9

In commenting on a draft of this report, INS officials said that agreement had been reached with INS

unions that 51 of the 295 chapters of the administrative manual needed only minor modifications and

did not affect work practices. INS staff were notified in April 1997 that those chapters were issued in

computerized form.

10The six program areas are inspections, adjudications and nationality, detention and deportation,

investigations, Border Patrol, and intelligence.

11This excludes the Border Patrol manual, which is being updated by the Border Patrol Program Office.

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

immigration laws or regulations. This had reportedly made it difficult for

employees to follow INS procedures because they received conflicting

information on procedures. The briefing report said that the lack of

current manuals also led to field officers creating policy locally, and this

compounded the confusion and the difficulties in coordination.

INS was in the process of updating the Inspections Field Manual and

expected that parts of the revised manual would be issued in May 1997. INS

began updating the Adjudications and Nationality Field Manual in March

1996. The project officer said that in the spring of 1996 he had also held

preliminary meetings with the detention and deportation and

investigations program area officials to discuss updating their manuals.

However, according to the project officer, as of February 1997, nothing

more had been accomplished on these manuals because he had to respond

to a higher priority to develop legislatively mandated regulations. The

intelligence program area is to have a chapter in each of the other five

program area field manuals in addition to having its own general manual

on procedures to follow for reporting intelligence information. The

Intelligence Program Office is to develop the general Intelligence Field

Manual.

INS Had Drafted a Revised

Administrative Manual but

Was Not Sure When It

Would Be Issued

INS staff rely on the administrative manual to provide information on

internal technical policies that are not related to immigration law. The

administrative manual includes information on procedures, such as cash

collection, disciplinary actions, firearms, uniforms, personnel issues, and

financial management. INS took about 2 years to revise the manual, and

several additional years have passed as changes were being negotiated

with the employee unions.

According to an INS official, as part of the partnership agreement that INS

has with its employee unions, the unions can review changes to the

administrative manual and field manuals. When INS completed a draft of

the administrative manual in 1993, the two unions were given the draft to

review. According to INS’ labor relations manager and a union president,

the changes made to the administrative manual were voluminous, and the

unions were unable to review it expeditiously. As a result, negotiations

with the unions on the changes have gone on for more than 3 years. In the

spring of 1996, INS management and the unions agreed on a list of sections

in the draft manual that needed to be reviewed with the unions and have

prioritized the list to expedite the process. The section on use and storage

of firearms is the first item on the priority list.

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

Due to the negotiations between INS and the unions, INS had not yet

established a timeline for completing the revised administrative manual as

of February 1997. According to the INS official directing the field manuals

project, sections of the administrative manual may be issued when they

are finalized with the unions. To avoid similar delays with the field

manuals, INS management was seeking agreement with the unions on small

sections of each manual as they are approved by INS management. This

was done with the draft section of the Inspections Manual and worked

well, according to the project officer.

The following written comments by respondents to our survey illustrate

INS’ problems communicating policies and procedures in the fall of 1995:

• “The Administrative Manual is extremely out-of-date. There have been

numerous times that I have researched an issue and arrived at a

conclusion, only to be told by [the] Region that, ‘That’s so old; we don’t

follow that anymore.’ If it’s still ‘on the books’ then I should be able to use

it as a tool for completing my work. Of course, the alleged current policy

or procedure is rarely validated by a written issuance.”

• “With regard to . . . policy implementation, field personnel all do their own

thing. There is not one place an officer can go for direction. The . . .

operating instructions are out of date and policy wires often don’t make it

to the field.”

• “The reorganization was recent, and it is understandable that policies and

procedures may still be in the process of being developed, but

headquarters should at least communicate that guidance is in process and

provide interim guidance. As an example, legislation effective October 1,

1995 calls for charging fees for some services at the land border. No policy

guidance for collecting the fees has been issued. Over $50,000 was

collected in San Diego the first week. Apparently, there was a disconnect

between the Office of Programs and the Office of Field Operations about

who is responsible for implementing the program. It should be a

coordinated effort. Even if headquarters is still in the process of

developing the policies and procedures, interim guidelines, such as ‘follow

the district’s cash collection procedures’ would have been fine.

Headquarters does not see the urgency. They do not see the people lining

up with applications.”

• “I was recently told by a regional staff employee that it was not the policy

to put things out in writing. How are employees suppose[d] to know what

to do if they are not told. I believe the word is ‘chaos.’ (confusion)

[Headquarters] needs to know [and] understand the needs of district [and]

sectors. [Headquarters] needs to establish written policies in a multitude

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but Others Continue to Be Problematic

of areas using input from field office personnel. [Headquarters] must

communicate with regional personnel as well as field offices when

establishing procedures.”

• “Dissemination of policies in my unit is sometimes through hearing instead

of in writing . . . execution of policies differ greatly . . .”

Survey Results on

Gains Made as a

Result of

Reorganization Were

Mixed

INS identified goals for the reorganization to help it manage better. We

asked a question on our survey about the success of the reorganization in

accomplishing INS’ goals, and respondents to the survey had mixed

opinions. Concerning the reorganization’s success in clarifying lines of

authority, for example, 20 percent of the managers responded that the

reorganization was very successful or somewhat successful, 21 percent

responded that the reorganization was as successful as unsuccessful, and

41 percent responded that the reorganization had been somewhat or very

unsuccessful. Another 15 percent of the managers responded that they had

no basis to judge. Table 2.3 presents the question that we asked managers

and responses by INS’ managers on the success of the reorganization in

achieving some of the goals. A complete list of the goals and managers’

responses can be found in appendix IV.

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Page 55 GAO/GGD-97-132 INS Management Problems
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Management Goals of the Reorganization,

but Others Continue to Be Problematic

Table 2.3: Managers’ Responses to the

Question: Generally, How Successful

or Unsuccessful Do You Think the

Reorganization Has Been in Achieving

the Following Goals? Goals

Clarifying lines of authority

Delegating authority to persons geographically closer to locations where work is being

done

Decentralizing decisionmaking authority

Improving processes to develop and disseminate organizational policy and guidelines

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

Managers responding

Very or

somewhat

successful

As successful as

unsuccessful

Somewhat or very

unsuccessful

Goal achieved prior to

reorganization

Too early to

say

No basis to

judge

20% 21% 41% 2% 3% 15%

22 18 36 1 4 20

22 18 35 1 5 20

17 21 44 1 4 13

Note: Percentages may not add to 100 percent due to rounding.

Source: Analysis of GAO 1995 survey.

There were several possible reasons cited by various INS managers as to

why the percentage of managers who thought the reorganization had been

unsuccessful in achieving certain goals was roughly twice as great as the

percentage who thought the reorganization had been successful. First,

they said overlaps in the roles and responsibilities of the Offices of

Programs and Field Operations may have led managers to believe that

lines of authority were unclear. Second, we were told that regional

directors did not assume all of their new authority immediately, and the

agency was going through a transition phase the first year. Thus, some

managers could have perceived that the reorganization had not

accomplished its goal for delegating authority closer to where the work is

performed or decentralizing authority. A third reason given was that not

enough time had passed for significant changes to occur. For example,

some of the goals of the reorganization, such as developing planning

capability, improving the delivery of services, and establishing quantitative

performance measures, could take several years to accomplish.

Furthermore, INS had not begun to implement some of the strategies to

achieve its goals. For example, in March 1996, the Commissioner told us

that the agency has not formalized processes to disseminate information

and procedures.

In April 1996, INS’ Office of Policy and Planning began a review of the 1994

reorganization. According to an INS official, the review was an ongoing

effort, and, as the need for organizational changes or refinements are

identified, changes can be included in future INS plans and budgets.

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

Conclusions INS has taken some steps to address long-standing management problems.

INS developed a strategic plan and initiated an annual priorities

management process—initial steps in the Results Act process. We believe

that such efforts are important components of effective planning and

decisionmaking. The priorities process had top management support, had

been linked with planning and decisions for resource allocations, and had

been clearly communicated throughout the organization. The long-term

impact is yet to be determined and will require that top management

persist in its commitment to using priority management for planning and

decisionmaking.

INS achieved some of its management goals for the reorganization, but, as

can be expected in the first years of implementing a new structure, not all

management goals were achieved. INS reestablished a regional structure

with oversight responsibility of district directors and Border Patrol chiefs;

and regional directors have been delegated authority to manage the field

resources, which places responsibility closer to where the work is

performed. It is too soon to determine whether the organizational changes

will improve customer services and enforcement activities.

According to many managers we interviewed, the lack of delineation of

responsibilities and authority between the Office of Programs and the

Office of Field Operations had caused confusion for headquarters and field

managers. For example, separate requests to a field manager from each of

the offices to identify trainers resulted in a duplication of effort and in

different employees being selected as potential trainers from the same list.

Furthermore, headquarters and field managers perceived that too many

decisions that should be resolved at the EAC levels had to go to the Deputy

Commissioner for resolution because lines of responsibility and authority

were not clear. The agency had not clearly defined the responsibilities and

authority of the Office of Field Operations and the Office of Programs in

relation to each other and to other INS units and had not clearly defined

how and when these offices should coordinate with each other.

INS’ new structure and the Commissioner’s Priority Program had created

new ways of communicating. Managers reported to us that they were

confused and frustrated about when and how to communicate with each

other. INS’ new structure and the Commissioner’s Priority Program

required that communication and coordination cut across the agency. The

EAC for Field Operations had reportedly provided oral guidance on

communications between the Office of Programs and the field units and

had taken some actions to address communication problems. However,

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

these efforts did not appear to have provided a clear understanding of

what communication is needed and when it should occur. INS had not

provided any written guidance on what needs to be communicated and

coordinated and when it should happen for this new way of working.

The agency reorganized in 1994 and created a new Office of Field

Operations, created new Regional Director offices, and changed the role of

the previous EAC for Operations to EAC for Programs. However, the agency

did not determine what resources would be needed for these offices to

carry out their new responsibilities. One of INS’ goals for the reorganization

was to enhance program planning capabilities by relieving headquarters

program managers of responsibility for day-to-day operations. Yet, some

operational activities remained with the Office of Programs. According to

headquarters program managers, they did not have any more time for

program planning as a result of the reorganization. Although INS provided

reasons for some activities remaining in the Office of Programs, this may

be counterproductive to accomplishing an intended goal of the

reorganization to create a clearer sense of mission by separating policy

planning, program planning, and field operations.

INS’ field and administrative manuals had not been updated since we

reported the lack of policies and procedures as a problem in 1991. One of

the goals of the reorganization was to improve the processes for

dissemination of organizational policy and guidelines. The lack of current

manuals made it difficult for employees to carry out their mission-related

activities and led to field officers creating policy locally. The agency was in

the process of revising some of the field manuals and finalizing approval of

the revised administrative manual. In the past and at the time of our

review, completion of field manuals had been delayed because staff

assigned to develop them had been sidetracked to develop regulations to

implement legislation. The administrative manual had not been issued

because of negotiations between INS and its two unions. INS had not

established milestones for issuing manuals or parts of manuals. Having

milestones could help INS management to recognize when slippage occurs

and focus the need to remain vigilant with respect to issuing current

guidance.

Overall, we found that the reorganization had addressed some of the

management problems identified in past reports, but the reorganization

had not been fully implemented. INS was beginning to evaluate the 1994

reorganization as we concluded our review.

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Management Goals of the Reorganization,

but Others Continue to Be Problematic

Recommendations We recommend that the INS Commissioner take the following actions to

help achieve the reorganization goals:

• provide written guidance to all INS managers on the responsibilities and

authority of the EACs for Field Operations and Programs in relation to each

other;

• provide written guidance on the appropriate coordination and

communication methods and channels between offices to include

(1) when and how Field Operations and Programs should coordinate and

communicate with each other, (2) when and how the Office of Programs

should coordinate and communicate with the regional offices and the

districts and sectors, and (3) when and how the Office of Policy and

Planning should coordinate and communicate with the other offices;

• determine whether staffing levels need to be adjusted for Programs, Field

Operations, and regional offices to accomplish their prescribed roles and

responsibilities consistent with the respective mission and workloads for

each office;

• establish milestones for issuance of manuals or parts of manuals that can

stand alone; and

• incorporate into INS’ current evaluation of the reorganization the issues

raised in this report so that they can be addressed as INS attempts to fully

achieve the goals of the reorganization.

Agency Comments INS provided written comments on a draft of this report, which are printed

in full in appendix VI. INS said that it agreed with our assessment that some

objectives of the reorganization had not been achieved and stated that it

has proposed changes to improve lines of responsibility that address many

of the concerns raised in the report.

INS provided technical comments separately, which we incorporated

where appropriate. INS also provided updated information on the

administrative manual. According to INS officials, INS and the unions

reviewed 85 of the 295 chapters of the administrative manual to identify

ones that needed only minor modifications and did not constitute changes

in working conditions. Following this review, 51 chapters were issued in a

computerized format in December 1996, and the EAC for Management sent

a memo to field offices in April 1997 to inform staff that these new

chapters were available for their use. We added this information to our

report. INS was to meet with union representatives again in June to review

another group of 70 to 80 chapters to identify ones that require minor

modifications and do not constitute changes in working conditions so that

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but Others Continue to Be Problematic

more chapters can be issued. Chapters that need further negotiation are to

be handled at a later date.

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Improvements Made to Management of

Budget Resources, but Problems Persist

In 1991, we reported that INS’ budget allocations had not been based on

agencywide priorities, INS had not adequately used workload information

as a factor in making budget allocations, and budget management and

resource allocation problems perpetuated backlogs for processing aliens’

applications for naturalization and adjustment of status. We also reported

that INS’ primary accounting system was outmoded and had weak internal

controls, and the use of unreliable financial information had resulted in INS

inadequately monitoring its budgetary resources.

During our review of INS’ fiscal year 1995 budget execution process, we

found that INS (1) had improved its management of budget resources by

using annual priorities to help make budget allocation decisions and using

workload information for planning to some extent in four of its six

program areas,1

 and (2) was seeking to improve its capability to use

workload information in each of its program areas. However, problems

persisted because INS continued to (1) experience resource allocation

problems that caused field offices to have backlogs in processing alien

applications and (2) lack accurate, complete, and consistent data to

efficiently monitor budgetary resources.

INS has been taking steps intended to improve workload analysis, improve

the data it uses to monitor the budget, and implement a new financial

management system. Although these steps, if fully implemented, should

move INS in a positive direction toward resolution of the problems we

identified, continued top management attention to monitoring progress

and reducing the risks associated with these initiatives will be necessary.

INS Made

Improvements in

Planning Resource

Allocations

For several years, INS acknowledged the need to make better use of the

agency’s financial resources. Accordingly, INS took several steps intended

to improve its allocation of budgetary resources. INS sought to find ways to

better match resources to workload demands and performance at each

field location and to more strongly link program activities to strategic

planning. As discussed in chapter 2, INS initiated a strategic planning

process that tied annual priorities and performance measures to resource

allocation. In addition, steps were taken to improve the use of workload

data in deciding how to allocate resources in the six major INS program

1

Adjudications and nationality, Border Patrol, detention and deportation, inspections, intelligence, and

investigations are the six major INS program areas.

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areas. Also, for the first time, INS developed a table of organization2 to

assist the various field and program units in planning and managing

personnel resources. In addition, deployment plans were being used in

fiscal year 1996 to allocate new resources. Finally, INS developed a

long-range growth management plan to assist the agency in accomplishing

its resource allocation goals of directing the additional resources provided

by Congress to priorities and workload demands.

Resource Allocations

Linked to Priorities

As discussed in chapter 2, in 1995 INS began implementing a priorities

management process to establish annual priorities in support of, among

other things, its strategic plan. The purpose of these priorities was to

provide a means of monitoring crosscutting program initiatives important

to the agency’s mission. They provided a mechanism to tie agency

resources to annual priority activities. Under this approach, senior INS

executives were required to make recommendations to the Commissioner

on priorities for budget formulation, allocations for budget execution, and

other resource issues that have an agencywide effect. The goal was to

ensure that allocation of budgetary resources supports the

Commissioner’s annual priorities.

INS receives funding through the appropriations process from several

sources. These sources include: (1) general revenues, (2) the Violent

Crime Reduction Trust Fund3

 (VCRTF), and (3) various fees paid by users of

immigration services. INS linked its allocation of additional resources from

these funds to program initiatives and annual priorities. At the beginning

of fiscal year 1995, INS instituted a priorities implementation review

process that established connections among the strategic plan, priorities,

budget initiatives, and program requirements. Extending this effort, INS

then linked the priorities implementation review sessions to its quarterly

financial review process. The quarterly financial reviews helped identify

needs for additional funding and the availability of resources that had not

been obligated and that could be reallocated to other priorities or agency

needs. The intended outcome of the linkage was to ensure that resource

allocation decisions were consistent with the agency’s annual priorities.

2

A table of organization is a document prepared by INS’ Office of Budget in conjunction with the

various field and program units. It provides detailed information to unit managers on authorized

funded staffing levels.

3

A separate account in the Treasury, the Violent Crime Reduction Trust Fund was created by the

Violent Crime Control and Law Enforcement Act of 1994 (P.L. 103-322, 42 U.S.C. 14211). Amounts in

the Fund are to be used for the purposes authorized in that act.

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Steps Taken to Better

Incorporate the Use of

Workload Information

INS has taken steps to better use and incorporate workload

models—referred to in INS as workload analysis models (WAMs)—into its

budget allocation decisions. The purpose of WAMs is to help determine the

distribution of current personnel resources and to base projected future

staffing needs on operational priorities and cross-cutting programmatic

needs. WAMs were designed as a management tool to assist INS officials in

basing program resource allocation decisions on workload distribution

while maintaining flexibility to respond to changing events, circumstances,

and emerging priorities. Under the reorganized management structure

created in 1994, the role of INS’ program offices was to shift away from

managing field resources. The new focus of these offices was to be on

program development and integration that anticipate growing workloads

and demands on the agency. Program offices were to be primarily

responsible for developing, maintaining, and utilizing WAMs that provide INS

managers with information to enable them to respond to changes in

workload demands. Much of the information included in the workload

models relies on workload data from the various INS field and service

units.

We interviewed cognizant officials and found that the type and use of

workload information varied among the six major INS program areas. As

table 3.1 shows, during fiscal years 1995 and 1996, four of the six program

areas used workload data to some extent for planning and allocation

purposes. Inspections used a WAM; adjudications used WAMs for service

centers, but not for district offices; investigations had a WAM in place, but it

was not used; intelligence had no model but utilized workload

information; and neither Border Patrol nor detention and deportation had

WAMs or used workload data to project how to allocate budgetary

resources.

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Table 3.1 INS’ Use of WAMs and Workload Data in Planning Fiscal Year 1995 and 1996 Resource Allocations

WAM in place? Workload data used?

INS Program Yes No Yes No Brief description of situation

Adjudications and

Nationality

—Service Centers

—District Offices

• 

•

•

•

WAM was used to recommend allocation of resources

among adjudication service centers.

No evidence that WAM was used for planning and

projecting allocation of resources in district offices.

Border Patrol • • According to an INS official, allocation of resources in this

program area in fiscal year 1995 was decided primarily

by program initiatives and agency and congressional

priorities, which continued into fiscal year 1996.

Detention and Deportation • • INS had entered into a contract to develop a WAM for this

program area. No evidence of the use of workload data in

planning and projecting resource allocations.

Inspections • • Detailed WAM and automated workload data collection

system were in place and were used in planning and

projecting resource allocations.

Intelligence • • No WAM existed. An INS official said that INS utilized

workload information in making resource allocation

decisions in fiscal years 1995 and 1996.

Investigations • • Detailed WAM was in place. However, it had not been

used in planning and projecting resource allocations

since 1992. Workload information was considered in

making some of the resource allocation decisions in fiscal

years 1995 and 1996.

Source: INS documents and interviews with cognizant officials.

Inspections, investigations, and the adjudications service centers had

mathematical workload analysis models. Inspections’ model seemed to be

the most sophisticated because it took baseline information from ports of

entry and did computer simulations to estimate personnel resource needs

under different scenarios and changing priorities. The investigations

workload model used data to estimate a weighted workload based on the

relative size of work among districts and the priority of the work area, e.g.,

removal of criminal aliens and proactive investigations of major alien

smuggling organizations to project future workload allocations. The

adjudications service centers’ workload information was based on

incoming receipts and the productivity per employee, among other things,

to project resources needed to meet workload demands.

Despite not having WAMs, the adjudications district offices and intelligence

used workload information to decide how to allocate resources in fiscal

years 1995 and 1996. Border Patrol resource allocations were based on

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priorities and program initiatives that among other things, sought to

increase the number of agents on the border to deter illegal entry into the

United States. The detention and deportation program area has a contract

with a firm to develop mathematical workload analysis models that are

intended to identify the most effective distribution of current personnel

resources and to project future staffing needs.

We did not attempt to evaluate how effectively the units were using WAMs

or workload data to help them allocate resources. We also did not attempt

to verify the quality of the workload data being utilized by the INS

programs. However, INS’ efforts to improve workload information and the

use of models to make resource decisions are steps in the right direction.

Other Steps Taken in

Fiscal Year 1996 to

Improve Resource

Allocation

INS has taken further steps intended to improve the linkage between

workload and the way it allocates and tracks the deployment of its

resources. In fiscal year 1996, INS began providing tables of organization to

its various resource managers, developed deployment plans to manage the

allocation of additional resources that were being provided by Congress,

and developed a long-range plan for growth management.

Tables of Organization Tables of organization are a management tool intended to assist managers

with resource allocation planning. The information in the tables of

organization allows INS managers to compare the existing staff distribution

to funded personnel levels. According to INS headquarters officials, INS

tries to ensure that the tables of organization are updated quarterly to

reflect changes in authorized funded staffing levels. Prior to the use of the

tables of organization, INS resource managers did not have information

readily available on authorized funding levels to use in making hiring plans

and resource allocation decisions.

To alleviate this problem, INS began drafting tables of organization with its

resource managers starting with the fourth quarter of fiscal year 1995. The

first table of organization drafted was for the Border Patrol Program. In

April 1996, INS provided a draft consolidated table of organization to all

headquarters and field locations for review. The final version was

distributed in July 1996. The tables of organization are intended to help INS

manage staffing for the various INS units, including regional offices, Border

Patrol sectors, adjudications service centers, and district offices.

Deployment Plans In fiscal year 1996, INS formalized the use of deployment plans with the

intent of ensuring that additional resources received during the year were

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Improvements Made to Management of

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allocated in a way that was consistent with priorities, program initiatives,

and identified workload needs. Deployment plans are management tools

intended to specify when and where to distribute new positions. These

deployment plans had generally been developed through an iterative

process that included statistical analysis and field input. For example, an

INS official responsible for managing the development of the deployment

plan for the interior border enforcement initiative said that WAMs and the

table of organization have served as a base of information for developing

deployment plans. INS’ Interior Enforcement Deployment Plan outlines

specific steps to be taken in fiscal year 1996 for the deployment of new

resources to key geographic locations in support of established priorities,

program initiatives, and workloads for fiscal year 1996.

Growth Management Plan INS also took steps in fiscal year 1996 to implement a growth management

plan that included long-range deployment planning and a management

process that tied into budget formulation and priorities planning,

incorporated congressional requirements, and projected general plans for

growth, by location. As part of this effort, INS had developed a long-range

plan that was intended to assist the agency in managing planned growth in

the size of its officer workforce and support staff through fiscal year 1998.

The growth management plan called for INS to implement its deployment

plans by building sound multiyear staffing models and to redesign its

deployment plans to incorporate projected growth. The growth

management plan outlined goals for recruiting, hiring, and training officers

and support staff and for ensuring field readiness to absorb planned

growth. INS intended to monitor these plans to ensure that any required

adjustments could be made in a timely manner.

Independent Study In April 1996, INS hired a consultant to do an independent analysis of how

INS deploys its personnel resources, including an assessment of the

strengths and weaknesses of WAMs and deployment planning processes.

The results of the May 1996 independent study indicated that INS’

processes tended to be reactive rather than prospective and were driven

more by resources that were available than by a determination of actual

requirements. The consultant concluded in part that (1) workload was not

adequately captured and reflected in the processes that were intended to

recommend staff allocations and (2) WAMs currently in use needed to be

updated to better serve as forecasting tools. Among other things, the

consultant recommended that INS develop a minimum 5-year, rolling

strategic planning process; develop an INS-wide requirements-based model

to assist planners at all levels that builds on the strengths of existing

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stand-alone tools, such as WAMs; and conduct further analyses to formulate

a more integrated INS deployment planning process.

In response to these recommendations, INS hired another consultant to

identify deployment planning process improvements that were needed;

assess INS’ deployment planning requirements; develop a stand-alone,

automated deployment planning tool for INS, which included design,

installation, implementation, and testing of a prototype software program;

and train selected INS personnel on the implementation of the software

program. The prototype software program is to initially help plan for

deploying personnel resources by service locations and is to be capable of

expanding to include planning for training, equipment, and facilities. The

prototype is also to be compatible with existing automated staffing

models. The contractor was to accomplish its tasks by June 1997. INS

intends to contract for enhancements to the model for other resource

needs, such as equipment and facilities.

Process for Notifying

Congress of Need for

Additional Funds

From Fee Account

Contributed to

Application Backlogs

Approximately one-third of INS’ funds in fiscal year 1995 were derived from

fees, with the Immigration Examinations Fee Account being the largest.

The demand for examinations fee services, and therefore funding levels,

fluctuates more than for other INS fee activities. Consequently,

examination fee levels are more likely to require adjustments after the

current year budget has been enacted. If INS anticipates a need for a

change in funding authority as a result of higher or lower-than-expected

fee collections, then INS is to prepare a reprogramming proposal for

transmittal by the Department of Justice to the Office of Management and

Budget (OMB) and, subsequently, to the appropriation subcommittees with

jurisdiction over the Department of Justice.

INS started fiscal year 1995 with a higher-than-expected adjudications

workload. An amendment adding subsection 245(i) to the Immigration and

Nationality Act of 1952 and California’s Proposition 187, passed in

November 1994, led to a dramatic surge in the demand for adjudication

benefits in 1995. INS also experienced a tremendous growth in its

examinations fee account receipts because of (1) a new

adjustment-of-status application process under the 245(i) amendment and

increased fees from that provision, and (2) increases in the number of

naturalization applications received. When INS determined that the

increase in the number of applications was likely to persist and that it

needed to respond to the additional demand for services, it took steps to

notify Congress of the need to use additional funds from the Immigration

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Examinations Fee Account.4 A proposal for additional spending authority

was submitted to Congress in the third quarter of the fiscal year.

According to INS officials, INS wanted to determine the extent to which the

number of applications would rise after the passage of the 245(i)

amendment and whether the growth would continue. Therefore, it

monitored data on application rates for the first 3 months of fiscal year

1995. After INS determined that there was a need for additional funding, the

internal and external processes for planning, preparing, and reviewing the

proposal for reprogramming of funds consumed another 4 months before

the proposal could go to Congress. As a result, backlogs and average wait

times for processing applications continued to grow in the field units.

INS Reprogramming During most of fiscal year 1994, INS experienced a lower-than-normal level

of receipts. Consequently, INS proposed several reprogrammings to

decrease spending for activities funded by the Examinations Fee Account.

However, INS experienced a surge in applications in the final 2 months of

fiscal year 1994 and had a large pending workload going into fiscal year

1995. This workload was compounded by a further increase in the

applications filed during the first quarter of fiscal year 1995. As a result, INS

determined that it needed additional funding to hire people to process the

applications. According to an INS budget official, other fee accounts are

more predictable, which enables INS to project revenues more reliably.

Because the Examinations Fee Account has “peaks and valleys,”

reprogrammings are used to address the uncertainty of the workload in

this program area. But, according to INS officials, the reprogramming

process does not respond quickly enough to the need for additional funds.

As part of the 1995 congressional action, INS’ spending level authority for

the Examinations Fee Account was $291.1 million. In establishing this

funding level, the Conference Report acknowledged that it might not cover

INS’ full cost of inflation increases. The report directed that if INS realized

examination fee receipts in fiscal year 1995 that were higher than the

current estimate, INS should use those funds for base inflation costs, as

necessary, and to the extent possible, to provide additional resources for

the processing of naturalization applications. The conferees stated that

they expected to be notified of changes in spending plans as delineated by

4

INS’ Examinations Fee Account derives revenue from fees collected for processing 59 types of

applications, petitions, hearings, and appeals forms for immigration benefits, such as naturalization

and permanent resident status. INS collects fees and processes applications at 4 regional service

centers and 33 district offices.

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the reprogramming requirements of the appropriation bill.5 Under these

requirements, which are found in section 605 of the Appropriation Act,

notification to the Appropriation Committees of both Houses of Congress

must be provided 15 days in advance of reprogramming of funds.

In accordance with section 605 of the 1995 Appropriation Act and section

8 of the Department of Justice Appropriation Authorization Act, 1980, P. L.

96-132, the Department of Justice notified the House and Senate

Committees on Appropriations and the Judiciary of proposed

reprogramming actions for INS’ Examinations Fee Account, the

Legalization account, and the VCRTF in April 1995. The reprogramming

provided additional spending authority of $76.6 million.

Process for Proposing

Reprogramming Actions

The Department of Justice requires INS and its other department

components to prepare and submit a report containing a justification for

the reprogramming proposal. Justice also requires INS and its other

components to obtain congressional response to the reprogramming

action before expending any of the additional funds being sought. Several

internal and external layers of review and approval were required before a

reprogramming proposal could be forwarded to Congress. These layers

contributed to the time it took to process a reprogramming proposal.

INS officials said that before proceeding with a reprogramming proposal in

fiscal year 1995, INS managers decided that they needed data on the

aftermath of the 245(i) and proposition 187 legislation. INS officials said

that the agency decided to wait until 3 months of trend data on

applications were available before reacting to any increases in workload

demands. INS officials said that they took this approach because they

wanted to be certain that the increases in workload trends were not a

temporary surge in response to the passage of the new legislation.

Examinations fees collected in the first 2 months of fiscal year 1995

increased substantially and exceeded expectations. INS officials said they

assumed this increase was a temporary reaction in response to the new

legislation and not a trend that would continue. However, after the results

from the third month in the first quarter showed a continuing increase in

fees, INS officials determined it was not a short-term rush but a growing

demand that would require additional resources. Once a decision was

made to proceed in January 1995, officials said that internal discussions

5

Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies 1995

Appropriations and 1994 Supplemental Appropriations, P.L. 103-317; H.R. Rep. No. 103-708, 103d

Cong., 2d Sess at 35 (1994).

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were held to decide whether additional resources should be for permanent

or temporary personnel, given that the 245(i) amendment would expire in

October 1997. This discussion and development of the resource needs,

along with other internal reviews of reprogramming documents by INS

budget officials, EACs and their staffs, the Office of the General Counsel,

the Deputy Commissioner, and the Commissioner, took about 2 months.

External layers of review and approval also contributed to the amount of

time it took to obtain congressional response to the reprogramming

proposal. Justice and OMB reviewed the proposal before it was submitted

to Congress. Because INS waited 3 months before starting to draft the

reprogramming proposal and then the internal development and external

reviews took another 4 months, a reprogramming proposal was not

submitted to Congress until April 1995. Figure 3.1 shows the timeline of

key activities for INS’ reprogramming of funds in fiscal year 1995 to

respond to increasing adjudication workload demands.

Figure 3.1 Timeline of Key Activities

for INS’ Fiscal Year 1995

Reprogramming 1994

1995

Year Month Activity

October 1-

December 31

December

JanuaryMarch

March 3

March 3-28

March 28

March 28-

April 11

April 13

April 13-

June 6

June 7

INS collected information on receipts from applications to adjust status

and naturalization petitions.

An INS fee analysis group met to decide what to do in response to

increasing workload demands and to make projections of future

revenue receipts.

Documentation requesting additional spending authority was prepared

and reviewed internally.

Request for additional spending authority was forwarded to Justice for

approval.

Justice added an $11 million request for Community Relations Services

to carry out Operation Safe Haven to assist Cubans and Haitians.

Justice forwarded the request to Office of Management and Budget.

Office of Management and Budget reviewed, approved, and returned

request to Justice.

Justice forwarded request to Congress for House and

Senate review.

Congressional review period and communication with INS about use

of additional funds.

Congress responded in writing with formal approval and a few

modifications.

(Figure notes on next page)

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Source: Justice, INS, and OMB officials.

Average Wait Times for

Adjudication Applications

Grew During Fiscal Year

1995

The time spent in the preparation and review of the fiscal year 1995

reprogramming proposal contributed to an increase in average projected

waiting times for processing certain adjudication applications. For fiscal

year 1995, INS’ self-designated acceptable time for processing all I-485

adjustment-of-status and N-400 naturalization applications was 4 months.6

Our analysis of applicant waiting times revealed that the average projected

agencywide waiting time for processing adjustment-of-status applications

during fiscal year 1995 grew from about 5 months as of September 30,

1994, to about 10 months as of September 30, 1995. The average projected

waiting time for the processing of naturalization applications grew from

about 8 months to about 17 months.

At the beginning of fiscal year 1995, 8 of the 33 INS districts exceeded INS’

acceptable processing time of 4 months by 1 month or more for

adjustment-of-status applications. At the end of fiscal year 1995, 18 of the

33 INS districts exceeded INS’ acceptable processing time of 6 months by 1

month or more. Twenty-one of the 33 INS districts exceeded the acceptable

processing time for processing naturalization applications by 1 month or

more at the beginning of the fiscal year compared to 26 of the 33 INS

districts at the end of the fiscal year.

During fiscal year 1995, average projected wait times for

adjustment-of-status applications more than doubled in 19 of the 33 INS

districts, as shown in table 3.2. In the Harlingen, Texas, District Office,

average projected wait times increased from an average of 27 months to an

average of 53 months.7

 Average projected wait times for naturalization

applications more than doubled in 11 of the 33 districts. The average

projected wait time for naturalization in the Chicago District Office

increased from an average of 8 months to an average of 40 months and in

Miami from an average of 9 months to an average of 49 months.

6

INS set a priority for fiscal year 1996 to complete the processing of naturalization applications within

6 months and, in September 1996, revised the adjustment-of-status goal to 5 months.

7

The average projected wait times for adjustment-of-status applications for the Harlingen district

appear anomalous. We do not know if these wait times are correct or are due to an error.

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Table 3.2: Average Projected Wait Times for INS Processing of I-485 Adjustment-of-Status and N-400 Naturalization

Applications at the Start and End of Fiscal Year 1995

Average projected 

wait time (in months)

Average projected

wait time (in months)

I-485 Applications to adjust status N-400 Naturalization applications

INS District Offices

As of

September 30, 1994

As of

September 30, 1995

As of

September 30, 1994

As of

September 30, 1995

Servicewide 4.5 9.5 8.2 17.3

Eastern region districts

Atlanta 1.6 5.1 5.1 7.7

Baltimore 9.7 1.6 3.9 6.8

Boston 2.2 7.6 2.8 7.9

Buffalo 2.3 2.2 5.6 4.5

Cleveland 1.2 4.3 3.7 9.9

Detroit 1.8 3.5 5.7 13.0

Miami 6.7 9.0 8.6 48.6

Newark 5.6 19.6 2.5 8.9

New Orleans 2.2 9.7 7.5 4.0

New York City 8.6 18.5 4.8 23.7

Philadelphia 1.7 4.7 6.1 5.4

Portland, Maine 2.1 1.6 10.3 1.5

San Juan, Puerto Rico 2.7 9.6 6.2 16.6

Washington, D.C. 4.1 7.9 3.5 6.5

Central region districts

Chicago 3.3 2.7 7.9 39.7

Dallas 2.4 4.2 12.7 11.0

Denver 2.2 3.6 3.9 5.2

El Paso 1.7 9.3 6.6 9.4

Harlingen, Texasa 26.5 52.8 11.9 11.2

Helena 6.8 3.8 5.6 3.9

Houston 4.7 16.8 8.6 16.0

Kansas City, Missouri 3.0 2.0 5.1 4.2

Omaha 1.8 7.3 1.5 10.2

San Antonio 3.5 11.8 4.6 5.4

St. Paul .1 .6 2.6 3.8

Western region districts

Anchorage 4.9 3.7 3.2 4.8

Honolulu 4.0 4.3 5.7 7.3

Los Angeles 9.7 19.6 12.6 26.3

Phoenix 6.1 12.9 9.7 10.5

(continued)

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Average projected 

wait time (in months)

Average projected

wait time (in months)

I-485 Applications to adjust status N-400 Naturalization applications

INS District Offices

As of

September 30, 1994

As of

September 30, 1995

As of

September 30, 1994

As of

September 30, 1995

Portland, Oregon 0.5 10.1 4.1 9.5

San Diego 3.2 12.6 13.7 7.5

San Francisco 2.8 10.2 18.2 21.5

Seattle 2.0 4.4 9.2 7.4

Note: INS computed the processing wait times by dividing the number of applications pending at

month’s end by the number of applications completed for the month and multiplying by the

number of calendar days in the month. This method computes how long it would take to complete

all cases pending at the end of the month if the rate of completions remained constant.

aThe average projected wait times for adjustment-of-status applications for the Harlingen district

appear anomalous. We do not know if these wait times are correct or are due to an error.

Source: INS data.

INS officials attributed delays in the processing of adjudication applications

to the lack of authority to spend funds to hire additional personnel to

address increased workload demands.

INS Submitted Fiscal Year

1996 Reprogramming

Proposal to Congress

Earlier in the Fiscal Year

For fiscal year 1996, INS began drafting a reprogramming proposal in

August 1995. The reprogramming proposal was submitted to the Justice

Department in September 1995, to OMB in October 1995, and to Congress in

November 1995. Congress responded in January 1996. The reprogramming

provided additional spending authority for the Examinations Fee Account

to expedite the processing of naturalization applications and 245(i)

applications and to expand direct mail services and cover mandatory

expenses. An INS budget official said that this reprogramming action was

less complex than that of fiscal year 1995.

The fiscal year 1995 reprogramming was more complex because it

included several proposed actions within different sources of funds. INS’

fiscal year 1995 reprogramming proposed actions within its Examinations

Fee Account, Legalization Account, and VCRTF. It sought increased

resources for processing naturalization applications and

adjustment-of-status applications under the section 245(i) amendment;

disseminating information on the naturalization process; staffing and

contract support for Ask Immigration, which is INS’ public information

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system; supplementing operational and support components; and

increasing positions for the Institutional Hearing Program.

Monitoring of Budget

Resources Suffered

From Inadequate Data

INS continued to experience problems in fiscal year 1995 with monitoring

its budgetary resources because of inaccurate and incomplete data in its

financial management system and inconsistencies in data available to and

provided by headquarters and field units. For example, INS experienced

problems monitoring its resources because the Budget Office did not have

the information it needed on commitments made by field units, staff

attrition, and hiring plans.

Long-standing Problems

With INS’ Financial

Management System

A financial management system is to integrate accounting, budget,

personnel, and procurement systems, as well as other information

systems.8

 Inaccurate financial data; an unreliable and antiquated financial

management system; and insufficient internal controls over allocation,

obligation, and expenditure of funds have made it difficult for managers in

INS headquarters to readily determine the financial status of INS’ field units.

These serious financial management problems are not new at INS. They

have long affected INS’ ability to effectively manage and accurately report

the results of its program and administrative operations. The Department

of Justice’s Office of the Inspector General and Justice Management

Division (JMD) and we have issued several reports on the serious

weaknesses in INS’ internal controls and accounting system.

In 1991, we reported that INS’ primary accounting system —Financial

Accounting and Control System (FACS) —was outmoded and had weak

internal controls.9

 These 1991 reports stated that weaknesses had existed

for many years and would require a commitment by INS leadership across

succeeding administrations to correct. We reported again in 1993 and 1995

about these problems.10

Furthermore, JMD assessments of problems identified with FACS in fiscal

years 1993, 1994, and 1995 revealed that actions had not been taken to

8

Framework for Federal Financial Management Systems, Joint Financial Management Improvement

Program (FFMSR-O, Jan. 1995).

9

Financial Management: INS Lacks Accountability and Controls Over Its Resources (GAO/AFMD-91-20,

Jan. 24, 1991); and Immigration Management: Strong Leadership and Management Reforms Needed to

Address Serious Problems (GAO/GGD-91-28, Jan. 23, 1991).

10Immigration Issues: Making Needed Policy and Management Decisions on Immigration Issues

(GAO/T-GGD-93-18, Mar. 30, 1993); and INS: Update of Management Problems and Program Issues

(GAO/T-GGD-95-82, Feb. 8, 1995).

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address recommended improvements. Specifically, the JMD audits

concluded that FACS (1) lacked reliable information, (2) failed to comply

with administrative policies and procedures in regard to funds control, and

(3) contained significant weaknesses in internal controls over payments

and obligations. Managers within INS also perceived the need for

improvements in financial management. Seventy-two percent of the

respondents to our 1995 survey on INS management issues said that

servicewide improvements were needed to a great or very great extent in

INS’ financial management. The INS Commissioner told us that in the past,

INS was required to use Justice’s financial management information system

because Justice wanted all of its components on the same system. She said

that INS has always maintained that the Justice system would not meet INS’

management needs. In the spring of 1994, Justice reached an agreement

with INS that enabled the agency to develop its own financial management

system. However, INS did not receive funding to pursue a new financial

system until May 1995.

Since fiscal year 1992, quarterly financial reports have generally been

prepared for INS nationwide, encompassing every program and field office.

INS quarterly reports are intended to enable INS managers to better monitor

expenditures and availability of funds, make accurate end-of-year financial

projections of obligations, and allow for the timely preparation of requests

for changes in spending authority. Further, these quarterly reports are to

provide managers with the information that INS believes is necessary to

detect and address potential problems in a timely manner by comparing

budget allocations with obligations and projected spending. In addition, in

November 1994, INS appointed the EAC for Management as its Chief

Financial Officer, responsible for overseeing all of INS’ financial

management activities. The Chief Financial Officer’s responsibilities

include, among other things, overseeing the integration of budgeting and

accounting information; the preparation of financial statements; and the

production of complete, reliable, timely, and consistent financial

information.

Data From INS’ Financial

Accounting and Control

System Continued to Be

Inadequate

During our review of INS’ fiscal year 1995 budget execution process, we

found that adequate financial information was neither readily available nor

being maintained in INS’ FACS. Consequently, INS budget officials and

managers did not have the requisite information in FACS to determine the

amount of funds available in specific INS units or to prepare accurate

financial status reports. Consistent with what we found in 1991, INS’

financial accounting system in fiscal year 1995 still failed to provide INS

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managers with the financial management information they needed to

adequately control funds and evaluate program operations in an efficient

manner.

The information in FACS did not provide management with accurate and

complete financial information on its program and administrative

operations. Also, because much of the financial information that FACS

produced was not a correct reflection of the financial status of INS field

units, it was unreliable. In addition, INS’ financial management system did

not adequately integrate information that INS managers needed, such as

information on commitment of funds, attrition of staff, and hiring plans in

the field. For example, FACS had generally maintained data on commitment

of funds only at the INS headquarters level, which did not provide

headquarters or regional managers with detailed information on the

commitment of funds at specific INS field units. Commitments had

generally been tracked directly by the individual INS field locations.

INS Did Not Have

Complete Financial and

Personnel Information

Needed to Manage Its

Budget Execution

FACS was not able to provide accurate data to INS managers on the financial

status of each field unit. Also, the Office of Budget in headquarters did not

have ready access to personnel data that would have enabled it to identify

current and planned staffing levels in INS field units. To obtain the

necessary accounting and personnel information for an accurate picture of

the financial status of its field units, managers in INS headquarters had to

rely on information obtained from each of INS’ 33 districts and 21 sectors.

For example, the Office of Field Operations, which is responsible for

managing resources in INS field units, had to obtain information on, among

other things, attrition of personnel, commitment of funds, and hiring plans

from INS’ 33 districts and 21 sectors to be able to project what funds would

be available for reallocation during quarterly financial reviews for fiscal

year 1995. In fiscal year 1995, the allocation and management of PS&B

funds, including information on financial commitments and vacant

positions associated with these funds, were being maintained at the

district and sector levels. Accurate information on spending in PS&B funds

in INS field units was not consistently available to managers at INS

headquarters or being readily maintained in INS’ financial accounting

system.

Inconsistencies Existed in

the Data Provided by INS

Resource Managers

Inconsistencies in the financial data being used by INS managers in

headquarters and in the field resulted in very different projections of the

financial status of the various INS units. During fiscal year 1995, field unit

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projections of funds expected to be used and funds available to reallocate

differed significantly from initial projections that the Office of Budget had

developed from data in INS’ financial accounting system.

For example, relying on FACS data as of March 31, 1995, the Office of

Budget projected that the field would have about $115 million in surplus

funds through the end of the fiscal year.11 This was a baseline projection

that the Office of Budget used as a starting point to obtain input from the

field offices on the status of finances as part of the normal financial review

process. Subsequently, the Office of Field Operations, relying on data

provided by the INS regional offices and the 33 districts and 21 sectors,

projected that the INS field units would experience a $5 million shortfall in

funding for the remainder of fiscal year 1995.

Managers in INS headquarters and field units said that they spent a great

deal of time attempting to reconcile the $120 million difference in fiscal

year 1995 projections. Ultimately, the Office of Budget based and revised

its initial mid-year estimate on data provided by INS field units. After

incorporating field data on attrition of staff, commitment of funds, and

hiring plans, and reconciling other differences, the Office of Budget

indicated in its Prospective Financial Status report for the period ending

March 31, 1995, that about $25 million in surplus funds would be available

to Field Operations through the remainder of the fiscal year. This was

about $90 million less than the Office of Budget’s initial estimate of

$115 million in surplus funds.

Office of Budget officials said that the process of determining the financial

status of INS units was impeded by several factors. These officials said that

the following factors contributed to the problems:

• various officials responsible for collecting information to be used in the

financial reports used different data sources,

• various officials responsible for reporting financial data did not

consistently use formats that the budget office provided, and

• data provided by the field had errors.

11INS uses the term surplus funds to refer to funds that were not used during the fiscal year for PS&B

and therefore become available for other purposes.

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INS Has Taken Interim

Steps Until New

Accounting System Is

Available

INS has acknowledged that FACS is old and labor-intensive and has had

difficulty accounting for and controlling its resources in an accurate and

timely manner. To work toward having more complete, accurate, and

useful information, in October 1996, INS decided to use a competitive

selection process to acquire a new financial management system through

an interagency agreement with a federal agency that could best meet its

user needs. The Office of Management and Budget endorses the use of

cross-servicing with other federal agencies as a cost effective and efficient

way to obtain services. In January 1997, a letter of interest and a

solicitation to acquire a system were sent to the Treasury Department, the

Commerce Department, and the Department of the Interior’s U.S.

Geological Survey. INS had identified these agencies as having the potential

for meeting its needs. Proposals were to be provided to INS by January 31,

1997; however, as of the beginning of February 1997, INS had one proposal

that it was evaluating and was negotiating an extension for proposals from

another agency. INS evaluated the proposals during February and

March 1997 and selected a vendor on March 31. INS’ solicitation for a

financial management system specified that the agency expected to have a

core financial management system implemented by October 1, 1997, to

meet the deadline agreed upon with the Department of Justice.

In the meantime, INS officials said that starting with the first quarter of

fiscal year 1996, PS&B resources were allocated and managed at the

regional level instead of at the district and sector levels. This change was

undertaken to alleviate, among other things, the need to collect

information from the 33 districts and 21 sectors. As previously presented,

INS developed a table of organization, which provided information to field

units and headquarters’ managers on authorized funded staffing levels.

This document was intended to help INS managers better monitor and

control personnel resources in the various INS units. According to an INS

official, the tables of organization data were manually compared to

on-board staffing level data to derive vacancy levels by office and major

occupations. This manual reconciliation process is a temporary measure,

which is to be eventually automated through implementation of a new

Position Tracking System (POSTS).

INS’ implementation of the new Position Tracking System is to address the

lack of information on current staffing levels, staff attrition, vacancies, and

hiring plans. POSTS is to contain both the tables of organization control data

and data on occupied positions. When fully operational, POSTS is to provide

INS managers with an up-to-date summary of filled and vacant positions.

Additionally, POSTS is to interface with the new Hiring Tracking System

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Budget Resources, but Problems Persist

(HITS) to provide INS managers with, among other things, an account by

location of all vacancies in INS. Neither of these systems was sufficiently

implemented as of April 1997 to provide useful data to support the

activities of the Office of Budget, but INS expects the systems to be

available throughout the agency by the end of fiscal year 1997.

Concerning inconsistencies in the data provided by the various INS units,

little was done to correct the problem until the beginning of fiscal year

1996. At that time, INS officials in the Office of Budget, Office of Field

Operations, and other INS units began working together to establish

mutually agreed-upon data sources and time frames and to develop

consistent and reliable reporting mechanisms to be used for the first

quarterly financial review of fiscal year 1996. On the basis of lessons

learned from prior financial reviews, a revised financial review process

and policy was developed with the intent to, among other things:

• ensure that all organizational components are using the same financial

data for review, projections, and adjustments;

• guarantee that all organizational components utilize the same automated

tools, algorithms, and methodologies to perform analyses and adjustments

to projections, thereby providing consistency and confidence in the

results, particularly the determination of available surplus funds; and

• maximize the effectiveness of planning the use of resources by utilizing

not only actual to-date surplus funds, but also projected surplus.

INS Contracted for

Assistance to

Strengthen Its Budget

Process and Improve

Its Financial

Management System

In April 1996, INS contracted with the National Academy of Public

Administration (NAPA) to assist it with developing a framework to change

its budget and financial management process and execution. INS stated in

the contract that it had taken steps to address problems in the budget and

financial management areas, but it believed it needed to further clarify and

strengthen the budget process at all levels of the organization. NAPA’s

January 1997 report12 made 40 recommendations related to such issues as

budget account structure, budget formulation, budget execution, and

organizational issues affecting budgeting. In addition, as part of the

process of developing recommendations to clarify and strengthen the INS

budget process at all levels of the organization, the NAPA project included

an analysis of how the INS budget process connected to the financial

management system and agency efforts to develop a new core financial

management information system.

12Report by a Panel of the National Academy of Public Administration for the Immigration and

Naturalization Service, Budgeting for Performance: Strategy, Flexibility, and Accountability to Meet a

Demanding Mission, January 1997.

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Budget Resources, but Problems Persist

The NAPA report raised concerns regarding (1) the quality of systems

requirements that INS developed; (2) the need to analyze and document

current “as is” business processes and develop targeted “to be” processes;

and (3) the need for systems integration analyses, among other things.

According to the NAPA report, INS’ acquisition of a new core financial

management information system will not resolve the long-standing

deficiencies in the agency’s financial management system because the root

cause of its problems lies in the domain of INS’ business processes and

procedures. The report stated that although a new financial information

system is needed, improvements in agency processes and procedures must

come first. NAPA also reported that various offices within INS were engaged

in activities that could be construed as process analysis activities, but

these activities were independent and were not part of an overall

systematic process improvement strategy, plan, and program. In a briefing

to the Justice Department in January 1997 on NAPA’s findings and

recommendations, INS recognized the need to address major process

problems and provided information on activities that it had undertaken

through its contract with a financial management consultant to identify

requirements and begin prioritizing options for business process

reengineering. However, NAPA questioned the quality of INS’ planning

efforts and was concerned about INS’ expectation to implement a new

financial system by October 1, 1997. According to an INS official, as of

January 1997, the agency was committed to implementing a new system by

October 1, 1997, because it wanted to meet the agreed-upon deadline

established with the Justice Department and because problems have been

long-standing, and the agency wanted to show that it is making progress

toward addressing them.

In July 1996, INS contracted with a financial management consultant to

(1) assist it with reviewing and revising processes and procedures in

anticipation of converting to a new financial system and (2) review

requirements for selected functional areas of the system to optimize

process improvements to be derived from the new system. INS’ financial

management consultant also suggested to INS that it should first define

business processes and clarify functional requirements before selecting a

new system. Specifically, the consultant stated that its experience and best

practices model incorporated the concept of defining and improving

business processes as an antecedent to the selection and use of

technology and software. The consultant made several recommendations,

one of which was for INS to establish a risk management plan to allow for

timely management action so that quality, schedule, and cost objectives

are achieved. Both NAPA and INS’ consultant raised concerns about the

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Improvements Made to Management of

Budget Resources, but Problems Persist

adequacy of INS’ planning efforts to acquire its new system and the

feasibility of implementing a core financial management system by

October 1, 1997.

Our previous and current work highlights how important it is for INS to

address the issues raised by NAPA and the consultant. Our May 1994 guide,13

which identified information and technology management best practices,

described how information systems initiatives must be focused on process

improvement and guided by an organizational architecture.14 The guide

also stated that information systems projects that do not focus on process

improvement typically fail or reach only a fraction of their potential. Our

February 1997 guide,15 which provides a structure for evaluating and

assessing how well a federal agency is selecting and managing its

information technology resources, stated that a key hazard in acquiring

information technology is that the new system will automate outmoded,

inefficient business processes. Another guide that we issued in April 199716

stated that technology is an enabler of process reengineering, not a

substitute for it. This guide also stated that acquiring technology in the

belief that its mere presence will somehow lead to process innovation is a

root cause of bad investments in information systems. The Clinger-Cohen

Act of 199617 requires executive agencies to conduct analyses of work

processes before making significant investments in information

technology. The act sought to remedy the dilemma of using technology to

correct process problems by insisting that process redesign drive the

acquisition of information technology, and not the other way around.

Thus, an assessment of current processes (process mapping, baselining,

benchmarking) should be completed before a decision is made about

acquiring technology.

Conclusions Since fiscal year 1995, some, but not all, program areas used WAMs and

workload information in deciding how to deploy resources. INS contracted

13Executive Guide: Improving Mission Performance Through Strategic Information Management and

Technology; Learning From Leading Organizations (GAO/AIMD-94-115, May 1994).

14Architectures explicitly define common standards and rules for both data and technology, as well as

mapping key processes and information flows.

15Assessing Risks and Returns: A Guide for Evaluating Federal Agencies’ IT Investment

Decision-making (GAO/AIMD-10.1.13, February 1997 Version 1).

16Business Process Reengineering Assessment Guide (GAO/AIMD-10.1.15, April 1997 Version 3).

17The Omnibus Consolidated Appropriations Act of 1997 renames both the Federal Acquisition Reform

Act of 1996 and the Information Technology Management Reform Act of 1996 as the “Clinger-Cohen

Act of 1996.”

Page 82 GAO/GGD-97-132 INS Management Problems
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Improvements Made to Management of

Budget Resources, but Problems Persist

with a consultant to develop a software program that would be compatible

with existing staffing models and that is intended to move INS toward

better deployment planning. In general, we believe that the use of WAMs

can help INS make resource allocation decisions, because INS will be able to

consider different factors and changing scenarios. Thus, we support INS’

initiative to develop WAMs and use models to improve resource allocation

planning.

INS has been taking steps to address the weaknesses in its financial

management system that have adversely affected financial reporting and

management at all levels and that hampered INS’ ability to prepare accurate

quarterly financial management reports in fiscal year 1995. The

improvements made during fiscal year 1996 address some of the

weaknesses associated with INS not having consistent and readily available

data but will not remedy the problems. INS selected a new financial

management system. Ultimately, the new system is intended to provide

consistent and reliable data, integrate information from other systems, and

produce accurate and complete information on commitment of funds,

attrition of staff, and hiring plans in the field. However, NAPA and INS’

financial consultant recommended that INS define its current business

processes and define its desired business processes before acquiring a

new system. Our guides on information management and the

Clinger-Cohen Act also endorse these practices. Problems with the

accuracy, completeness, and consistency of data that we identify in this

chapter are process issues, not technology issues. INS did not perform a

comprehensive analysis of its financial management processes before

selecting a new financial management system; therefore, the new financial

management system may not address process problems. As a result, INS

has incurred a risk that the system may not meet its financial management

requirements.

Recommendations We recommend that the Commissioner of INS take the following actions:

• Develop a strategy and schedule for periodically evaluating the new

deployment planning process to help ensure that it is compatible with INS’

key planning processes and provides information needed by managers to

adequately plan for resource needs and make resource decisions.

• Take steps to mitigate the risks associated with INS’ planned approach for

acquiring a new financial management system. Such steps should include

fully implementing plans to analyze its current financial management

processes and determining future financial management process needs,

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Improvements Made to Management of

Budget Resources, but Problems Persist

finalizing a comprehensive implementation plan, and fully developing and

implementing a risk management plan.

Agency Comments

and Our Evaluation

INS provided written comments on a draft of this report, which are printed

in full in appendix VI. INS also provided technical comments separately,

which we incorporated where appropriate. INS agreed with our

recommendation that it should evaluate its improvements to the

deployment planning process to help ensure that the agency’s information

needs are being met.

On the issue of INS’ plans for implementing a new financial management

system, INS stated that we failed to recognize its urgent need for a

replacement financial system. To the contrary, we have long recognized

this need. We believe our report and many past reports by us and others

fully recognize the problems in INS’ financial management systems and the

need to replace them. Thus, our primary focus in this report was on

expressing our concerns about INS’ plans for implementing a new system.

In this regard, INS disagreed with a recommendation in our draft report

that it analyze financial management processes prior to acquiring a new

financial management system and stated that it thought we relied too

much on the NAPA findings and did not follow up appropriately with

additional field work on the steps INS had taken after the NAPA report was

issued. We disagree that we relied primarily on the NAPA findings. Although

our report discusses the NAPA findings as they related to INS’ efforts to

acquire a new system, our recommendation was based in addition on our

analysis of agency documents, INS consultant reports, and our long history

of work on the implementation of major new information technology

systems. For example, our May 1994 guide, which we used in assessing INS’

approach, stated that information systems projects that do not focus on

process improvements typically fail or reach only a fraction of their

potential. To better clarify the basis for our observations, we have added

some information to the report about our previous work in this area.

Although we continued to discuss these and other matters in this report

with INS as the report was being developed and reviewed, we wanted to be

sure that we had fully considered all of the most recent developments in

its plans for a new financial system that were raised by INS in its comment

letter. Accordingly, we met with the Assistant Commissioner for the Office

of Financial Management and other finance officials in May 1997 to

discuss actions that INS plans to take to mitigate the risks associated with

Page 84 GAO/GGD-97-132 INS Management Problems
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Improvements Made to Management of

Budget Resources, but Problems Persist

implementing its new financial management system. In addition to

establishing an Executive Steering Committee and obtaining the

contractual support described in INS’ comments, these officials told us that

they were working with or preparing to work with consultants on

(1) analyzing INS’ financial management processes, (2) developing a

comprehensive implementation plan that would include how the system is

to be evaluated, and (3) developing a risk management plan. They also

stated that the entire system will not be in place by October 1, 1997, as

originally intended; rather, core functions will be implemented and tested

at some, but not all, locations.

In the time since our audit work was largely completed, INS’ strategy for

implementing a new financial management system has evolved further,

and INS is currently taking steps to plan for a phased implementation and

other actions that should help to mitigate the risks we observed. These

actions, if carried out effectively, are more consistent with the approach

that our work in this area has indicated would mitigate risk. For that

reason, we have revised our recommendation to focus more on actions the

Commissioner needs to take to fully develop and implement the plans that

were discussed with us in concept.

Page 85 GAO/GGD-97-132 INS Management Problems
Appendix I 

Roles and Responsibilities for the Offices of

the Executive Associate Commissioners and

Regional Directors for Field Operations

Executive Associate

Commissioner, Office

of Policy and Planning

• Serve as principal advisor to the Commissioner and Deputy Commissioner

on matters of policy and planning.

• Formulate, review, integrate, codify, and disseminate national INS policy.

• Serve as a clearinghouse for the coordination and dissemination of

program-specific policy, regulations, guidelines, and directives.

• Develop strategic plans, annual priorities, and statistical data.

• Research and develop cross-program initiatives.

• Establish an administration position on broader-than-INS immigration

policy questions and examine broad policy questions.

• Analyze new legislative proposals and regulatory and procedural changes.

• Perform organizational analysis to assist in the allocation of resources,

identify structural deficiencies, and avoid duplication of functions.

• Implement governmentwide initiatives, such as quality management and

the Vice President’s National Performance Review.

• Provide high-quality agencywide statistical information for use in

decisionmaking.

• Improve and expand technology assessment and research.

• Participate with the Executive Staff in the budget formulation and

execution processes.

Executive Associate

Commissioner, Office

of Field Operations

• Serve as principal advisor to the Commissioner and the Deputy

Commissioner on field operations.

• Plan, direct, and manage field operations through the three regional

directors and the Director, International Affairs.

• Provide general guidance and supervision to the regional directors and the

Director, International Affairs.

• Ensure that the annual operating plans of the regional directors and the

Director, International Affairs, are developed in accordance with the

Commissioner’s priorities.

• Allocate resources to the regional directors and the Director, International

Affairs.

• Authorize the transfer of resources that cross regional boundaries.

• Monitor the implementation of approved plans by the regional directors

and the Director, International Affairs.

• Recommend INS policies in areas related to field operations.

• Respond to field office needs and provide a single point of contact at

headquarters for field issues.

• Ensure policy consistency and program effectiveness in the work of the

districts and sectors.

Page 86 GAO/GGD-97-132 INS Management Problems
Appendix I 

Roles and Responsibilities for the Offices of

the Executive Associate Commissioners and

Regional Directors for Field Operations

• Represent the Commissioner with other agencies, Members of Congress,

interest groups, law enforcement officials, and the general public in

matters related to field operations.

• Serve as action officer on projects or special activities requiring executive

direction and high-profile leadership.

• Participate with the Executive Staff in the budget formulation and

execution processes.

Executive Associate

Commissioner, Office

of Programs

• Serve as the principal advisor to the Commissioner, Deputy

Commissioner, and the Executive Associate Commissioner for Field

Operations on enforcement and examinations program resources.

• Strengthen INS policy and planning capabilities by providing a cohesive

framework for enforcement and examinations to function as integrated

elements of INS.

• Establish a programmatic structure that will empower program managers

to develop program plans that anticipate demands on the agency, build

communications capabilities, and concentrate on program integration.

• Develop INS program policy and ensure policy consistency and program

effectiveness in the work of INS’ districts and sectors.

• Provide general guidance and supervision to the Associate Commissioners

for Enforcement and Examinations.

• Ensure that program objectives are developed in accordance with the

Commissioner’s priorities.

• Represent the Commissioner and Deputy Commissioner with other

agencies, Members of Congress, interest groups, law enforcement officials,

and the general public in matters related to INS program policy.

• Participate with the Executive Staff in the budget formulation and

execution processes.

Executive Associate

Commissioner, Office

of Management

• Serve as the principal advisor to the Commissioner and INS management

on financial, human resources, administrative, and information resource

management issues.

• Manage all INS management support services at headquarters, regions, and

field locations.

• Develop policies related to all administrative functions.

• Serve as action officer on projects or special activities requiring executive

direction and high-profile leadership.

• Direct personnel management, facilities development, procurement, and

other administrative functions through the Associate Commissioner,

Human Resources and Administration.

Page 87 GAO/GGD-97-132 INS Management Problems
Appendix I 

Roles and Responsibilities for the Offices of

the Executive Associate Commissioners and

Regional Directors for Field Operations

• Direct the affirmative employment and discrimination complaints

programs through the Director, Equal Employment Opportunity.

• Direct budget, finance, and resource management through the Associate

Commissioner, Financial Management.

• Direct data systems and systems integration through the Associate

Commissioner, Information Resource Management.

• Direct regional management and administrative activities through the

regional administrators.

• Direct all security and suitability activities through the Director, Security.

• Develop policies for the records program and Freedom of Information Act

through the Director, Files and Forms Management.

Regional Director,

Regional Offices for

Field Operations

• Plan, direct, and manage field operations in their respective regional areas.

• Provide general guidance and supervision to district directors and Border

Patrol’s chief Patrol agents.

• Develop and recommend annual operating plans for the region.

• Allocate and manage resources within the region.

• Monitor the districts’ and sectors’ implementation of approved plans.

• Serve as the Commissioner’s spokesperson in the geographic area.

• Participate in the budget formulation and execution processes for the

region.

Note: These are INS’ definitions of the roles and responsibilities.

Page 88 GAO/GGD-97-132 INS Management Problems
Appendix II 

Objective, Scope, and Methodology

The objective of this review was to follow up on our past INS management

report to determine whether INS had taken steps to correct some of the

most significant management problems identified. Specifically, we

reviewed whether INS had

• developed goals and priorities to guide planning and resource allocation;

• revised its organizational structure;

• improved internal communications and updated its field and

administrative manuals;

• improved the process of allocating budgetary resources;

• improved its capability to monitor its financial status; and

• generated accurate, complete, and consistent data to monitor budget

execution.

Because this review was limited in its scope, we did not investigate

whether INS had better defined the roles of the two key enforcement

divisions—Border Patrol and Investigations. Also, we did not examine

how much progress INS had made in addressing all the goals and objectives

of the reorganization or whether all the newly created offices had

accomplished their new missions. With respect to the process for notifying

Congress of the need for additional spending authority, we reviewed only

the Examinations Fee Account. This is the largest of the fee accounts, and

we wanted to determine if INS’ reprogramming process enabled it to

provide timely services to aliens applying for benefits such as

naturalization and adjustment-of-status.

We used a variety of techniques to determine whether INS had taken steps

to address management problems. To obtain an understanding of INS

management issues, we reviewed our prior management studies, INS

management studies by the Committee on Government Operations and the

National Academy of Public Administration, agency documents, budget

materials, congressional testimonies, and transcripts of congressional

hearings. The reorganization structure was put in place at the beginning of

fiscal year 1995, and our review was conducted during fiscal years 1995

and 1996. Information in this report is on the first year and a half of the

reorganization.

To obtain the perceptions of current INS management, we sent a survey to

3,676 career and appointed INS managers and senior staff. Survey

recipients included all INS managers and senior staff at or above the grade

13 level, as well as all other individuals designated as managers or

supervisors by INS at grades 11 and 12. All organizational units within INS

Page 89 GAO/GGD-97-132 INS Management Problems
Appendix II 

Objective, Scope, and Methodology

were represented in our survey. The response rate for our targeted

population was 69 percent.1

 Further details of the survey are presented in

appendix III.

We conducted interviews with the four Executive Associate

Commissioners (EACs); the three regional directors; assistant regional

directors, district office program managers, and Border Patrol chiefs in

Los Angeles, California; El Paso, Texas; and Buffalo, New York, locations

judgmentally selected with one from each of the regions; and other

headquarters and regional managers responsible for budget activities,

program planning, and operational activities to obtain more detailed

information than was obtained through the survey regarding the new

structure and the budget execution process during fiscal year 1995. We

also interviewed budget officials at the Justice Department and the Office

of Management and Budget (OMB) to obtain information on INS’ procedures

for proposing the reprogramming of funds from the Examinations Fee

Account. In addition, we conducted a joint interview with the INS

Commissioner and Deputy Commissioner to discuss management issues

related to the new organizational structure and budget execution during

fiscal year 1995.

To determine whether INS had developed goals and priorities, we reviewed

INS documents to determine whether INS had a mission statement, priority

goals, strategies to attain the goals, and performance measures. We also

used information from interviews and the survey data to ascertain

management support for and use of the priority goals. To determine

whether INS’ current organizational structure achieved its major

management goals, we reviewed INS documents articulating the purpose

and goals of the latest reorganization; and we interviewed top

headquarters officials, regional directors, and headquarters and field

managers concerning their perceptions of the reorganization. We also

obtained information on the reorganization through the survey. To

determine whether INS had updated its policy handbooks and manuals, we

interviewed managers at headquarters and in the field offices and used

survey data on managers’ perceptions of these and other communication

issues. We also reviewed policy documents and interviewed managers on

the status of efforts to update written communication through guidance

materials.

1

See appendix III sections “Problems with INS Mailing List” and “Survey Response Rate” for

clarification of this response rate.

Page 90 GAO/GGD-97-132 INS Management Problems
Appendix II 

Objective, Scope, and Methodology

To determine whether INS had taken steps to improve its resource

allocation process, we collected and analyzed information on INS’ budget

development, budget execution, and financial review processes for fiscal

years 1994 through 1996. We also collected copies of workload models and

resource allocation plans that INS developed and used to assist in its

decisionmaking process. Our examination of INS’ use of workload

information was limited to determining which program areas had

workload analysis models or used workload information in planning

resource allocation needs and which ones did not. For program areas that

had workload models, we relied on interviews with program and budget

officials to determine if they used the information to allocate resources. To

assess the relationship between INS’ resource allocation process and its

management of alien applications, we examined INS’ process for obtaining

congressional approval for increased funding authority from the

Examinations Fee Account and how well the process worked during fiscal

years 1995 and 1996. To determine whether INS had complete and

consistent data to monitor budget execution, we reviewed budget

documents and financial status reports and interviewed resource

managers and budget officials.

Page 91 GAO/GGD-97-132 INS Management Problems
Appendix III 

Survey Methodology

Overview In an effort to obtain a broad spectrum of views on INS management issues,

we developed and pretested a survey that included questions on the

relationship between headquarters and the field, organization changes,

communication, budget execution, and other management-related areas.

Our target population was all INS managers. For our survey, we defined a

“manager” as any INS employee at grade GS-13 or above as well as persons

designated by INS as managers or supervisors at grades GS-11 and 12. INS

provided us a list of employees who met our definition of manager.

To obtain managers’ candid opinions and insights about INS’ management,

we promised anonymity to the survey recipients. To ensure anonymity, no

identification numbers were included on the survey. A postcard containing

an identification number was included in the package sent to our target

population. The postcard was to be mailed back to us separately from the

survey. Receipt of the postcard allowed us to remove names from our

follow-up mailing list. In September 1995, we mailed the survey to 3,676 INS

employees whom INS told us were managers. In late October 1995, we sent

out a follow-up mailing containing another survey and postcard to those

who did not respond to our first mailing.

Problems With INS’

Mailing List

During the course of the survey, a number of INS employees who were

mailed surveys called or wrote to us indicating that they were not

managers. This led us to ask INS whether the list of managers that it

provided us may have included persons who should not have been in our

target population. The results of this follow-up inquiry showed that we

sent surveys to 714 INS employees who were in grades GS-11 and 12 but

were not designated by INS as managers or supervisors. These individuals

should not have been sent surveys to complete.

In the course of our investigation, we also found that our mailing list did

not include a number of INS employees who should have been included in

our target population. We found that approximately 400 employees at

grade GS-13 and above who should have received surveys did not because

INS did not include them on the mailing list it provided us. One reason that

we were concerned about this omission is that if these employees were

located in one or a few locations, this could introduce a systematic bias

into our results. However, we were able to determine that these particular

employees were located throughout INS.

Page 92 GAO/GGD-97-132 INS Management Problems
Appendix III 

Survey Methodology

Survey Response

Rates

Because we inadvertently mailed surveys to 714 grade GS-11 and 12

nonmanagers, our survey response rate was adversely affected. This is

because individuals receiving our management survey who were not

managers were much less likely to return the survey than were managers.

Because of this, we are providing two separate response rates for our

survey, one response rate for the managers who correctly received our

survey and another for the nonmanagers who incorrectly received our

survey. These response rates are shown in table III.1.

Table III.1: Survey Response Rates

Number of

Percent

INS employees

receiving surveys

Postcards returned

indicating that a survey

was returned

Response

rate

INS managers

(correct target population) 2,962 2,034 69%

Grade 11 and 12 nonmanagers

(should not have received surveys) 714 295 41

Total 3,676 2,329a

a We actually received 2,321 completed surveys. This discrepancy may be due to the lack of a

perfect match between those who returned the survey and those who returned the postcard.

Source: GAO analysis.

From the postcards we received, the survey results used in this report

contain data from approximately 295 grade GS-11 and 12 nonmanagers

who completed and returned our survey. Therefore, responses received

from INS employees who should not have been in our survey population

represent about 13 percent of the data used throughout the report. We

were not able to remove these data from our database because the surveys

were anonymous and, therefore, did not contain any identifying

information about the respondents.

Reporting Survey

Results

Throughout this report, the percentages presented do not include

respondents who skipped a question. For some questions the percentages

presented do not include respondents who answered “no basis to judge.”

When this occurs, we indicated this in a footnote.

In general, when we report responses to five-point scales, we report the

combination of the percentages of respondents selecting the top two

response categories and the combination of the percentages of

Page 93 GAO/GGD-97-132 INS Management Problems
Appendix III 

Survey Methodology

respondents selecting the bottom two response categories. Occasionally,

we deviate from this practice. When this occurs, we indicate this in a

footnote.

Respondents to our survey provided numerous written comments dealing

with management issues. We did not analyze all of the written comments

in a systematic manner. We used a number of these comments in our

report to illustrate some of the management issues discussed in the report.

Nonsampling Errors The practical difficulties of conducting any survey may introduce errors,

commonly referred to as nonsampling errors. For example, differences in

how a particular question is interpreted, in the sources of information that

were available to respondents, or in the types of people who did not

respond can introduce unwanted variability into the survey results. We

included steps in the development of the survey, the data collection, and

the data analysis for minimizing such nonsampling errors. These steps

include practices, such as extensive pretesting of the survey, procedures

to ensure that respondents remain anonymous, and the inclusion of

various edit checks in the analysis program.

Page 94 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

Page 95 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

I. Background Information

1. To which of the following are you

currently assigned? (Check one.)

n=2,275

25% 1. Headquarters

25% 2. Eastern Region

24% 3. Central Region

27% 4. Western Region

2. Please indicate if you are assigned to any

of the following offices. (Check one.)

n=2,274

24% 1. Border Patrol Sector

26% 2. District Office

3% 3. Service Center

3% 4. Administrative Center

5% 5. International Affairs/Asylum

Offices/Foreign Offices

39% 6. None of the above

3. How long have you been at this physical location?

Mean = 9 years

_____ Years _____ Months

4. How long have you worked at INS?

Mean = 16 years

_____ Years _____ Months

5. What position do you currently hold at INS?

(Include acting positions.) (Check one.)

n = 2,300

0.9% 1. Commissioner, Deputy

Commissioner, Executive

Associate Commissioner, or their

immediate staffs

2.3% 2. Regional Director, Deputy

Regional Director, or their

immediate staffs

2.5% 3. District Director, Deputy District

Director, or their immediate staffs

2.3% 4. Chief Patrol Agent, Deputy Chief

Patrol Agent, or their immediate

staffs

1.2% 5. General, Regional, or District

Counsel

0.1% 6. Associate Commissioner

0.7% 7. Assistant Commissioner

3.1% 8. Assistant District Director

2.3% 9. Assistant Chief Patrol Agent

14.7% 10. Second line supervisor (Port

Director, officer-in-charge, etc.)

43.4% 11. First line supervisor

16.7% 12. Non-supervisory staff

9.7% 13. Other - Please specify:

_________________

2

Page 96 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

Page 97 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

Strongly

agree

(1)

Agree

(2)

Neither

agree nor

disagree

(3)

Disagree

(4)

Strongly

disagree

(5)

No basis

to judge

(6)

a. My unit can recruit qualified employees

n=2,292 17% 38% 12% 16% 9% 8%

b. My unit can fill vacancies in a timely fashion

n=2,296 5% 16% 10% 30% 32% 8%

c. My unit can retain quality employees

n=2,265 9% 34% 15% 25% 13% 3%

d. My unit currently has adequate staff to 

do its work n=2,290 3% 16% 6% 33% 42% 0.5%

e. Adequate funding for training is available for

my unit n=2,294 3% 22% 15% 31% 25% 4%

f. Adequate time for training is allocated for 

those in my unit n=2,299 4% 25% 14% 32% 23% 1%

g. Staff in my work unit are provided the types

of training courses they need n=2,296 3% 24% 19% 34% 19% 1%

h. I am provided with the types of training

courses I need n=2,293 4% 28% 17% 33% 17% 0.7%

i. My unit plans for its future staffing needs

n=2,291 6% 32% 17% 22% 17% 6%

j. The staff in my unit have the needed skills to

do their jobs well n=2,301 10% 49% 18% 17% 6% 1%

k. My unit currently has adequate clerical staff

to do its work n=2,301 3% 18% 8% 30% 40% 2%

8. In general, how clear or unclear to you are the following? (Check one box in each row.)

Very

clear

(1)

Somewhat

clear

(2)

Somewhat

unclear

(3)

Very

unclear

(4)

a. Your current duties and responsibilities

n=2,303 59% 28% 8% 4%

b. Your unit's goals and objectives

n=2,304 47% 32% 14% 7%

c. INS' priorities

n=2,306 26% 35% 24% 15%

d. INS' overall mission

n=2,306 31% 35% 20% 14%

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9. In your opinion, how positive or negative an impact, if any, have the following factors had on morale at INS?

(Check one box in each row.)

Very 

positive

(1)

Positive

(2)

No

impact

(3)

Negative

(4)

Very

negative

(5)

No basis

to judge

(6)

a. Leadership provided by top management at INS

n=2,297 3% 19% 16% 35% 26% 2%

b. Operational/program funding levels n=2,296 2% 20% 11% 37% 23% 7%

c. Communications between Headquarters 

and the regions n=2,305 1% 10% 15% 27% 14% 34%

d. Communications between Headquarters and

administrative centers n=2,307 0.3% 6% 14% 15% 8% 56%

e. Communications between the regional offices 

and the administrative centers n=2,307 1% 8% 15% 12% 6% 59%

f. Communications between regional offices 

and the districts/sectors n=2,307 3% 23% 16% 19% 7% 33%

g. Level of cooperation among units at INS

n=2,293 3% 29% 13% 37% 15% 3%

h. Availability of training/development opportunities

n=2,302 2% 21% 16% 43% 14% 4%

i. Physical work environment (office space,

facilities, outdoor work, etc.) n=2,312 6% 29% 14% 32% 19% 1%

j. Availability/quality of equipment 

(computers, cars, etc.) n=2,308 6% 36% 8% 33% 17% 1%

k. Amount of time required for duties 

unrelated to primary work n=2,302 1% 12% 27% 39% 17% 4%

l. Staffing level n=2,292 2% 14% 12% 41% 29% 3%

m. Anything else - Please specify: _____________

n=537 2% 2% 2% 21% 70% 5%

 10. Currently, how would you characterize the general level of morale in your unit? (Check one.)

n=2,238

 1. Very high 3%

 2. Fairly high 21%

 3. Neither high nor low 25%

 4. Fairly low 31%

 5. Very low 19%

 ------------------

 6. No basis to judge 0%

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III. Budget

11. Thinking about the budgeting and financial management process in INS as a whole and in your unit, would you

agree or disagree with the following statements? (Check one box in each row.)

Strongly 

agree

(1)

Agree

(2)

Neither 

agree nor

disagree

(3)

Disagree

(4)

Strongly

disagree

(5)

No basis

to judge

(6)

Budget Process in INS 

a. The INS budget directs resources to 

where they are most needed n=2,314 1% 11% 13% 41% 24% 10%

b. The distribution of funding among INS 

programs is appropriate n=2,313 1% 7% 13% 41% 24% 14%

c. The distribution of personnel among 

INS programs is appropriate n=2,314 0% 9% 13% 42% 25% 11%

d. The distribution of funding among 

geographic areas is appropriate n=2,313 0% 8% 18% 26% 17% 31%

e. The distribution of personnel among 

geographic areas is appropriate n=2,312 0% 11% 17% 28% 18% 26%

f. Decisions about how to allocate funds in 

INS are made by the right people n=2,315 1% 4% 13% 27% 34% 21%

Budget Process in Your Unit

g. My unit has financial problems that affect 

its ability to carry out its mission n=2,313 22% 32% 15% 21% 5% 6%

h. My unit receives its fair share of 

financial resources n=2,314 2% 23% 19% 33% 16% 8%

i. My unit receives the financial resources 

it needs to operate in a timely fashion n=2,316 3% 21% 16% 35% 19% 6%

j. My unit uses the financial resources 

it receives efficiently n=2,315 22% 46% 12% 9% 5% 6%

k. My unit has the necessary number of people 

on board to carry out its mission n=2,317 3% 15% 6% 38% 38% 1%

l. My unit has the necessary equipment to meet 

its goals, objectives, and mission n=2,318 4% 26% 11% 34% 24% 1%

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IV. Management Information

12. In your opinion, how adequate or inadequate is management information provided to you for the following? 

(Check one box in each row.)

More

than

adequate

(1)

Generally

adequate

(2)

Neither

adequate

nor

inadequate

(3)

Generally

inadequate

(4)

Very

inadequate

(5)

No basis

to judge

(6)

a. Information on personnel and staffing

allocation n=2,306 2% 25% 16% 31% 19% 9%

b. Information on budget and financial

management n=2,307 1% 18% 16% 30% 23% 11%

c. Measures of workload (e.g., number of 

arrests, etc.) n=2,303 4% 36% 19% 19% 12% 9%

d. Measures of productivity (e.g., number of cases

adjudicated per work hour, etc.) n=2,302 4% 31% 21% 20% 14% 11%

e. Information on policies and procedures

n=2,297 3% 37% 14% 25% 17% 3%

If you checked box 4 or 5 for any item in question 12 → Continue with Question 13.

If you checked box 1, 2, 3, or 6 for all items in question 12 → Skip to Question 15.

13. For which of the following reasons, if any, do you have inadequate management information? 

(Check all that apply.)

n=699 1. Information systems (automated or manual) are not providing reliable management information

n=841 2. Information systems (automated or manual) are not providing timely management information

n=866 3. Information systems (automated or manual) are not providing complete management information

n=770 4. Most of the information I need to manage my unit is not readily available in electronic format

n=437 5. Other - Please describe: ________________________________________________

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14. Which of the following describes how this

inadequate management information impacts your

unit? (Check all that apply.)

n=851 1. Impedes the accomplishment of my

program's goals and objectives

n=803 2. Makes it necessary to keep

supplemental records

n=535 3. Hinders my ability to adequately

measure performance

n=762 4. Hinders my ability to make wellthought-out decisions

n=520 5. Prevents holding employees

accountable

n=1,025 6. Results in wasting scarce resources

(e.g., people, time, or money)

n=175 7. Other - Please describe: 

_____________________________

V. Priority Setting and Planning

15. To what extent, if at all, are INS-wide goals and

objectives clear enough to assist you in carrying

out your planning responsibilities? (Check one.)

n=2,281

 4% 1. To a very great extent

15% 2. To a great extent

33% 3. To a moderate extent

26% 4. To some extent

22% 5. To little or no extent

16. Given the following options, how would you

characterize the current setting of priorities at INS

between enforcement and service functions? 

(Check one.)

n=2,297

13% 1. Much heavier emphasis on

enforcement than on service

14% 2. Somewhat heavier emphasis on

enforcement than on service

21% 3. About equal priority

19% 4. Somewhat heavier emphasis on

service than on enforcement

26% 5. Much heavier emphasis on service

than on enforcement

-------------------------

 8% 6. No basis to judge

17. In your opinion, how should enforcement vs.

service priorities be set at INS? (Check one.)

n=2,285

25% 1. Should be much heavier emphasis

on enforcement than on service

25% 2. Should be somewhat heavier

emphasis on enforcement than on

service

43% 3. Should have about equal priority

 2% 4. Should be somewhat heavier

emphasis on service than on

enforcement

 1% 5. Should be much heavier emphasis

on service than on enforcement

-------------------------

 4% 6. No basis to judge

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 The following question refers to the Commissioner's strategic planning process.

 This includes the following priorities:

 · Strengthen Border Protection

 · Expedite Removal of Criminal Aliens

 · Reduce Incentives for Unlawful Migration

 · Implement Asylum Reform Regulations

 · Improve Customer Service

 · Promote and Streamline Naturalization

 · Improve Professionalism

 · Provide Innovative Immigration Policy Leadership

 · Broaden and Integrate INS Systems Infrastructure

 

18. In your opinion, to what extent, if at all, has the strategic planning process, which identifies nine priorities, aided

INS in the following areas? (Check one box in each row.)

 

To little

or no

extent

(1)

To 

some

extent

(2)

To a

moderate

extent

(3)

To a

great

extent

(4)

To a very

great

extent

(5)

No basis

to judge

(6)

a. Headquarters planning n=2,272 11% 17% 13% 9% 3% 47%

b. Regional planning n=2,273 9% 15% 14% 7% 2% 54%

c. Headquarters decision-making n=2,267 14% 16% 13% 9% 3% 45%

d. Regional decision-making n=2,262 10% 15% 15% 6% 2% 52%

e. Unit planning n=2,255 24% 25% 23% 11% 4% 14%

f. District or sector ability to carry 

out their missions n=2,262 18% 23% 20% 8% 2% 30%

g. Budget execution planning n=2,269 20% 19% 14% 7% 2% 38%

h. Budget execution decisions n=2,269 20% 18% 14% 7% 2% 39%

i. Personnel planning n=2,270 23% 21% 16% 9% 3% 27%

j. Personnel decisions n=2,264 25% 21% 17% 7% 2% 28%

k. Immigration policy planning n=2,268 17% 19% 15% 9% 3% 37%

l. Providing agency-wide perspective 

on programs n=2,265 20% 20% 18% 8% 3% 31%

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VI. Client Service

19. Is your unit (See Glossary on page 1) directly involved with adjudications and nationality; legalization; refugees,

asylum; outreach; or information services (i.e., does it deal directly with the public)? (Check one.)

n=2,255

38% 1. Yes → Continue with Question 20.

62% 2. No → Skip to Question 22.

20. How would you rate your unit's performance in the following areas? (Check one box in each row.)

Excellent

(1)

Very

good

(2)

Fair

(3)

Poor

(4)

Very

poor

(5)

No

basis

to judge

(6)

a. Quality of service provided to the public

n=892 24% 42% 24% 7 % 2 % 0 %

b. Timeliness of service provided to the public

n=892 18% 37% 27% 12% 6 % 1 %

c. Efficiency of service provided to the public

n=893 17% 40% 29% 10% 3 % 1 %

d. Quantity/volume of service provided 

to the public n=892 26% 38% 25% 7 % 4 % 1 %

21. In your opinion, to what degree does INS commit the necessary resources for quality service? 

(Check one.)

n=891

 4% 1. Very high commitment

14% 2. High commitment

37% 3. Moderate commitment

26% 4. Low commitment

16% 5. Very low commitment

---------------------------

 3% 6. No basis to judge

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VII. Organizational/Accountability Issues

22. In general, over the past 5 years, would you say that the quality of leadership in the following INS top

management positions has improved, stayed about the same, or has gotten worse? (Check one box in each row.)

Improved

greatly

(1)

Improved

somewhat

(2)

Stayed 

about 

the same

(3)

Gotten

somewhat

worse

(4)

Gotten

much 

worse

(5)

No

basis 

to judge

(6)

a. Top Headquarters management positions

(Commissioner, Deputy Commissioner,

Executive Associate Commissioners) n=2,308 11% 22% 26% 16% 17% 9%

b. Top regional office management positions

(Regional Director, Deputy Director) n=2,302 10% 22% 32% 11% 8% 17%

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23. Do you agree or disagree with the following statements concerning INS as an organization? 

(Check one box in each row.)

Strongly 

agree

(1)

Agree

(2)

Neither 

agree nor

disagree

(3)

Disagree

(4)

Strongly

disagree

(5)

No basis

to judge

(6)

a. Overall, the current organizational structure of

INS works well n=2,298 2% 18% 17% 35% 26% 2%

b. Headquarters should have more control over INS'

field operations n=2,308 8% 15% 14% 33% 27% 4%

c. INS' regional offices should have more input into

national policy setting n=2,309 14% 48% 15% 11% 4% 9%

d. Districts/sectors should have more input into

national policy setting n=2,309 29% 48% 10% 6% 2% 6%

e. The regional offices should have greater input

into how their districts/sectors are managed

n=2,302 13% 35% 20% 19% 7% 7%

f. Regional offices should have more autonomy

n=2,297 8% 27% 26% 24% 8% 8%

g. Districts/sectors should have more autonomy

n=2,293 14% 31% 20% 22% 7% 5%

h. There should be more coordination among INS

regions and the districts/sectors under their

jurisdiction n=2,309 32% 48% 11% 2% 1% 6%

i. Headquarters is in touch with events/

problems/concerns in the field n=2,311 2% 11% 13% 33% 37% 5%

j. The regional offices are in touch with

events/problems/concerns in the districts/sectors

n=2,309 4% 27% 21% 23% 13% 13%

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24. Listed below are problems which may occur in an organization. In your opinion, to what extent, if at all, are

these problems present at INS? (Check one box in each row.)

Extent these may be problems at INS

To little

or no

extent

(1)

To some

extent

(2)

To a

moderate

extent

(3)

To a

great

extent

(4)

To a very

great

extent

(5)

No basis

to judge

(6)

a. Unclear lines of authority n=2,302 24% 24% 19% 14% 18% 2%

b. Chain-of-command is not followed n=2,307 24% 22% 19% 15% 16% 3%

c. Unclear lines of accountability n=2,302 15% 19% 20% 20% 23% 3%

d. Lack of central decision-making authority

n=2,279 23% 20% 18% 14% 16% 9%

e. Too much central decision-making authority

n2,260 27% 20% 17% 13% 13% 11%

f. Unclear decision-making authority at

the local level n=2,293 28% 22% 17% 13% 11% 9%

g. Duplication of effort n-2,302 10% 20% 18% 23% 25% 4%

h. Poor communications n=2,311 4% 16% 17% 24% 38% 1%

i. Poor dissemination of information n=2,311 5% 16% 18% 22% 37% 1%

25. Given your experiences, would you say that at

least some of the work performed in your unit is

duplicated by some other office in INS (e.g., a

Border Patrol unit working the same or related

case as an Investigations unit)? (Check one.)

n=2,307

48% 1. Yes → Continue with Question

26.

43% 2. No

Skip to Question 28.

9% 3. No basis

to judge

26. Consider the work performed in your unit. How

rarely or often would you say that tasks

performed in your unit are duplicated in some

other office? (Check one.)

n=1,114

8% 1. Rarely → Skip to Question 28.

48% 2. Occasionally

10% 3. As often as not Continue with

Question 27.

22% 4. Often

12% 5. Very often

1% 6. No basis to judge →Skip to

Question 28.

13

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27. Which of the following groups in INS

unnecessarily duplicate at least some of the work

that your unit does? (Check all that apply.)

n=26 1. None of the duplication is

unnecessary

n=20 2. Office of the Commissioner or

Office of the Deputy Commissioner

n=73 3. Office of the Executive Associate

Commissioner for Programs

n=82 4. Office of the Executive Associate

Commissioner for Policy and

Planning

n=127 5. Office of the Executive Associate 

Commissioner for Field Operations

n=59 6. Office of the Executive Associate

Commissioner for Management

n=89 7. Office of the Regional Director

n=73 8. Office of the District Director

n=57 9. General Counsel, Regional

Counsel, or District Counsel

n=83 10. Congressional Relations 

n=83 11. Public Affairs 

n=31 12. Asset Forfeiture

n=300 13. Border Patrol

n=436 14. Investigations

n=234 15. Intelligence

n=62 16. International Affairs/Asylum

Offices

n=203 17. Detention and Deportation

n=86 18. Adjudications and Nationality 

n=106 19. Service Center

n=148 20. Inspections

n=88 21. Records

n=12 22. Administrative Appeals

n=39 23. Equal Employment Opportunity,

Security, Files and Forms

Management

n=88 24. Budget and Financial Management

n=84 25. Human Resources and

Administration

n=44 26. Information Resources

Management

n=50 27. Internal Audit

n=99 28. Administrative Centers

n=58 29. Other - Please specify: 

________________________

28. To your knowledge, how often, if ever, does the

field carry-out programs differently than

Headquarters may have originally intended? 

(Check one.)

n=2,293

13% 1. Very often

18% 2. Often

30% 3. Sometimes

12% 4. Rarely

 7% 5. Very rarely, if ever

--------------------

21% 6. No basis to judge

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29. In your opinion, service-wide, how consistent or inconsistent is the actual implementation of policies,

procedures, directives, and regulations by the various offices at INS? (Check one box in each row.)

Very

consistent

(1)

Consistent

(2)

As consistent

as

inconsistent

(3)

Inconsistent

(4)

Very

inconsistent

(5)

No

basis 

to judge

(6)

a. Implementation of policies

n=2,313 4% 24% 27% 27% 11% 9%

b. Implementation of procedures

n=2,313 3% 20% 26% 30% 13% 8%

c. Implementation of directives

n=2,311 4% 24% 27% 26% 10% 9%

d. Implementation of regulations

n=2,312 6% 29% 24% 22% 10% 9%

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VIII. INS Internal Policy Development and Implementation

30. Thinking about the implementation of INS internal policy (e.g., personnel practices, budget processes, etc.), would

you agree or disagree with the following statements as they apply service-wide? (Check one box in each row.)

Strongly 

agree

(1)

Agree

(2)

Neither 

agree nor

disagree

(3)

Disagree

(4)

Strongly

disagree

(5)

No basis

to judge

(6)

a. INS policy is clearly defined by Headquarters

n=2,301 3% 23% 22% 34% 15% 5%

b. Headquarters provides adequate policy guidelines

to the field n=2,301 2% 17% 20% 38% 18% 6%

c. Field offices can voice opposition concerning a

policy to Headquarters if they feel the policy is

misguided or inappropriate n=2,305 3% 24% 13% 27% 19% 15%

d. Headquarters should consult more with the field

when developing policy n=2,305 48% 41% 6% 1% 1% 4%

e. Advice from the field is heeded by Headquarters

when developing policy n=2,303 8% 14% 19% 28% 18% 13%

f. INS policy is clearly communicated by

Headquarters to the field n=2,301 2% 17% 23% 37% 17% 5%

g. Policy is communicated to the field in a formal

(standardized) manner n=2,304 2% 29% 24% 26% 13% 6%

h. Changes in policy are promptly disseminated 

n=2,300 1% 13% 17% 43% 22% 4%

i. Changes in policy are disseminated to everyone

who needs them n=2,300 1% 13% 18% 39% 22% 6%

j. Field offices should have discretion in

implementing INS policy n=2,300 8% 26% 17% 29% 16% 4%

k. Headquarters ensures that policies are

consistently implemented service-wide n=2,298 2% 8% 21% 40% 21% 10%

l. Written policies are kept up-to-date n=2,304 1% 9% 16% 39% 31% 5%

m. Instructions on carrying out policy are complete

n=2,304 1% 10% 20% 39% 26% 5%

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IX. Overall Management Concerns

31. In your opinion, to what extent, if at all, do you feel the following areas need improvement service-wide? 

(Check one box in each row.)

To little

or no

extent

(1)

To some

extent

(2)

To a

moderate

extent

(3)

To a

great

extent

(4)

To a very

great

extent

(5)

No basis

to judge

(6)

a. Financial management n=2,307 2% 10% 13% 24% 40% 12%

b. Budget development/formulation n=2,307 1% 10% 14% 27% 34% 15%

c. Budget execution process n=2,300 1% 9% 14% 26% 35% 16%

d. Distributed Budget Module System (DBM)

(i.e., system used to allocate and move funds)

n=2,303 2% 7% 11% 16% 31% 33%

e. Quality of service to the public n=2,295 10% 23% 23% 18% 17% 9%

f. Quality of information services to the public

n=2,306 9% 19% 20% 21% 21% 10%

g. Record and data management n=2,297 3% 13% 21% 26% 26% 11%

h. Workload/productivity measures n=2,300 7% 17% 25% 22% 21% 7%

i. Employee morale n=2,309 1% 7% 13% 25% 53% 1%

j. Lines of authority n=2,303 12% 20% 24% 19% 23% 2%

k. Coordination and cooperation among INS units

n=2,309 4% 16% 19% 24% 34% 2%

l. Agency-wide planning n=2,300 2% 12% 22% 25% 31% 8%

m. Oversight and evaluation of INS programs

n=2,297 3% 15% 24% 23% 27% 8%

n. Development of managers n=2,306 2% 11% 18% 26% 41% 3%

o. Training of staff n=2,307 3% 12% 22% 27% 33% 2%

p. Quality of staff n=2,307 6% 20% 26% 19% 28% 2%

q. Personnel process n=2,305 3% 12% 19% 24% 37% 6%

r. Quality of INS leadership at Headquarters

n=2,303 5% 14% 19% 17% 37% 8%

s. Quality of INS leadership at the regional offices

n=2,309 8% 19% 22% 14% 20% 16%

t. Quality of leadership in districts/sectors n=2,307 11% 23% 22% 13% 20% 11%

u. Other - Please specify:__________ n=275 1% 2% 2% 16% 72% 7%

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32. In your opinion, how effectively or ineffectively is INS carrying out the following activities? 

(Check one box in each row.)

Very

effectively

(1)

Somewhat

effectively

(2)

Neither

effectively nor ineffectively

(3)

Somewhat

ineffectively

(4)

Very

ineffectively

(5)

No basis

to judge

(6)

a. Timely processing of international travelers

at ports-of-entry n=2,297 15% 24% 4% 8% 3% 46%

b. Screening immigrants at ports-ofentry for admissibility n=2,293 10% 25% 5% 14% 6% 41%

c. Apprehending noncriminal aliens

n=2,283 5% 22% 8% 22% 28% 15%

d. Detaining noncriminal aliens n=2,287 3% 13% 8% 20% 41% 15%

e. Apprehending criminal aliens n=2,288 6% 30% 8% 24% 18% 15%

f. Detaining criminal aliens n=2,283 6% 24% 7% 24% 24% 15%

g. Controlling the border between 

ports-of-entry n=2,293 3% 21% 8% 24% 24% 21%

h. Deporting aliens in a timely manner

n=2,295 2% 10% 6% 21% 43% 18%

i. Adjudicating resident status and

naturalization cases in a timely manner

n=2,293 2% 14% 8% 17% 16% 43%

j. Adjudicating legalization cases in a timely manner n=2,293 2% 10% 9% 13% 16% 50%

k. Adjudicating asylum cases in a timely manner n=2,295 4% 10% 7% 14% 18% 48%

l. Adjudicating other benefit cases in a timely manner n=2,291 2% 14% 11% 16% 10% 48%

m. Adjudicating cases across the country in a

consistent manner n=2,289 1% 8% 8% 19% 16% 48%

n. Identifying fraud n=2,293 3% 19% 10% 25% 26% 17%

o. Enforcing employer verification 

of work eligibility n=2,293 1% 10% 10% 23% 31% 26%

p. Fining employers who hire illegal aliens

n=2,292 1% 10% 8% 23% 33% 26%

q. Collecting breached bonds n=2,288 1% 6% 6% 14% 21% 53%

r. Providing accurate and complete

information to clients and the general public

n=2,293 2% 18% 17% 22% 17% 25%

s. Managing seized assets n=2,292 1% 10% 11% 12% 12% 54%

t. Stopping the flow of illegal narcotics 

into the United States n=2,288 1% 15% 9% 17% 35% 23%

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X. Reviewing the Past Two Years

33. In your opinion, over the past two years, have the following improved, worsened, or stayed about the same

in your unit? (Check one box in each row.)

Improved

greatly

(1)

Improved 

somewhat

(2)

Stayed

about

the same

(3)

Worsened

somewhat

(4)

Worsened 

greatly

(5)

No basis

to judge

(6)

a. Information on personnel and

staffing allocation n=2,301 3% 17% 45% 16% 11% 9%

b. Information on budget and

financial management

n=2,300 2% 12% 42% 18% 14% 13%

c. Measures of workload

 (e.g., number of arrests)

n=2,295 5% 19% 45% 13% 8% 10%

d. Productivity n=2,294 10% 33% 32% 13% 7% 5%

e. Measures of productivity 

(e.g., number of cases adjudicated

per work hour) n=2,296 5% 21% 42% 11% 6% 16%

f. Information on policies and

procedures n=2,297 2% 16% 48% 19% 10% 5%

g. Quality of work n=2,294 6% 31% 38% 14% 8% 3%

Page 113 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

XI. 1994 INS Reorganization

 The following questions refer to the reorganization that began in July 1994.

The reorganization established four Executive Associate Commissioner 

positions, changed the number of regional offices from four to three, and

had administrative centers report to Headquarters rather than to the regions. 

34. Generally, how successful or unsuccessful do you think the reorganization has been in achieving the following

goals? (Check one box in each row. If goal had been achieved prior to the reorganization, check box 1.)

 Goals

Goal achieved

prior to the 

reorganization

(1)

Very

successful

(2)

Somewhat

successful

(3)

As

successful

as

unsuccess-ful

(4)

Somewhat

unsuccess-ful

(5)

Very

unsuccessful

(6)

Too

early

to say

(7)

No

basis

to judge

(8)

a. Creating a clearer sense

of mission by

combining INS' major

functions

n=2,293 2% 3% 18% 20% 17% 18% 7% 16%

b. Decentralizing 

decision-making

authority n=2,292 1% 3% 19% 18% 17% 18% 5% 20%

c. Empowering the field

operational units to

improve the delivery of

services to customers

n=2,292 1% 3% 18% 18% 16% 15% 4% 25%

d. Developing planning

capability n=2,287 1% 3% 16% 20% 16% 17% 5% 23%

e. Setting customer service

standards

n=2,288 1% 3% 19% 19% 12% 12% 4% 30%

f. Establishing quantitative

performance measures

n=2,288 1% 2% 15% 21% 17% 17% 4% 23%

g. Clarifying lines of

authority n=2,289 2% 3% 17% 21% 16% 24% 3% 15%

Question 34 continued on next page.

Page 114 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

Question 34 (Continued)

In your opinion, how successful or unsuccessful has the reorganization been at achieving the following goals?

(Check one box in each row. If goal had been achieved prior to the reorganization, check box 1.) (74-77)

 Goals

Goal achieved

prior to the 

reorganization

(1)

Very

successful

(2)

Somewhat

successful

(3)

As

successful

as

unsuccess-ful

(4)

Somewhat

unsuccess-ful

(5)

Very

unsuccessful

(6)

Too

early

to say

(7)

No

basis

to judge

(8)

h. Focusing on overall

INS effectiveness rather

than individual program

objectives n=2,297 1% 4% 22% 20% 17% 15% 6% 17%

i. Building an atmosphere

of trust between the

field and Headquarters 

n=2,299 1% 2% 11% 15% 22% 34% 3% 13%

j. Improving processes to

develop and disseminate

organizational policy

and guidelines

n=2,298 1% 2% 15% 21% 21% 23% 4% 13%

k. Delegating authority to

persons geographically

closer to locations

where work is being

done n=2,298 1% 3% 19% 18% 17% 19% 4% 20%

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GAO Survey on INS Management Issues

35. In your opinion, has the reorganization improved, worsened, or had no effect on the following in INS? 

(Check one box in each row.)

Improved

greatly

(1)

Improved 

somewhat

(2)

Had no

effect

(3)

Worsened

somewhat

(4)

Worsened 

greatly

(5)

Too

early 

to say

(6)

No basis

to

judge

(7)

a. Quality of leadership provided by

top management n=2,303 3% 18% 33% 16% 17% 4% 9%

b. Level of cooperation among 

INS units n=2,307 1% 17% 43% 17% 10% 3% 9%

c. Communication between 

Headquarters and the regions

n=2,311 1% 13% 17% 12% 9% 2% 46%

d. Communication between

Headquarters and administrative

centers n=2,309 1% 8% 13% 7% 6% 2% 63%

e. Communication between the

regions and the administrative

centers n=2,311 1% 7% 13% 8% 6% 2% 64%

f. Communication between the

regional offices and the

districts/sectors n=2,313 3% 19% 26% 10% 5% 2% 36%

g. Level of effort involved in

obtaining administrative services

n=2,307 1% 10% 25% 18% 14% 2% 29%

h. Quality of decision-making

n=2,300 1% 16% 33% 20% 14% 3% 13%

i. Timeliness of decision-making

n=2,307 1% 14% 31% 21% 18% 2% 13%

j. Consistency of policies among

units/programs n=2,307 1% 14% 36% 20% 13% 3% 14%

k. Timeliness of work n=2,309 1% 15% 41% 18% 11% 3% 11%

l. Efficiency of work n=2,309 1% 16% 40% 18% 11% 3% 11%

m. Review process (layers of

review needed) n=2,305 1% 11% 31% 18% 19% 2% 19%

Page 116 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

36. In your opinion, has the reorganization improved, worsened, or had no effect on the following in your unit? 

(Check one box in each row.)

Improved

greatly

(1)

Improved 

somewhat

(2)

Had no

effect

(3)

Worsened

somewhat

(4)

Worsened 

greatly

(5)

Too

early 

to say

(6)

No basis

to

judge

(7)

a. Effectiveness of program

operations n=2,308 1% 17% 43% 19% 11% 3% 7%

b. Staff morale n=2,313 1% 9% 37% 26% 22% 2% 5%

c. Quality of decision-making 

n=2,309 2% 14% 46% 19% 12% 2% 6%

d. Timeliness of decision-making 

n=2,309 2% 13% 44% 20% 13% 2% 6%

e. Accountability n=2,308 2% 13% 46% 16% 13% 2% 7%

37. In your opinion, what would be the best organization for INS' administrative functions? (Check one.)

n=2,287

16% 1. Current administrative center structure 

(i.e., administrative centers that support regional offices and report to Headquarters)

29% 2. Previous administrative structure

(i.e., administrative offices that supported regional offices and reported to the regional offices)

18% 3. Administrative centers with specialized centers that report to Headquarters 

(i.e., specialized centers located outside of Headquarters, such as finance in one location and

personnel at another location, etc. )

10% 4. Other organization - Please specify: _______________________________________________

28% 5. No opinion

Page 117 GAO/GGD-97-132 INS Management Problems
Appendix IV 

GAO Survey on INS Management Issues

XII. Comments

38. If you have any additional comments regarding any previous question or comments concerning INS' managerial

practices, internal control weaknesses, or specific problems that need to be addressed, please use the space

provided below. If necessary, you may add additional sheets.

974 respondents included written comments.

Thank you for your assistance. 

Please return your questionnaire in the pre-addressed envelope. Also, please return the postcard separately.

GGD-SMK 9/95

Page 118 GAO/GGD-97-132 INS Management Problems
Appendix V 

INS’ Fiscal Years 1995 and 1996 Priorities

Table V.1: INS’ Fiscal Year 1995 Priorities

Prioritya INS statement of priority

1. Strengthen border protection INS will continue to improve border protection by facilitating travel and commerce while

ensuring border integrity. This will be accomplished by employing a strategy of

prevention through deterrence, concentrating resources at key transit and entry points

(foreign and domestic), and employing resource-multiplying technology. Activities will

include continued implementation of a comprehensive Southwest land border strategy,

improvement in the use of lookout systems through better integration of data, and

continued development of automated inspections processes.

2. Expedite removal of criminal aliens INS will broaden its programs to identify and apprehend criminal aliens and expedite

their removal from the United States. Activities will include responding to federal, state,

and local law enforcement officers’ requests on alienage and immigration status;

completing implementation of the five-state Institutional Hearing Program model;

completing development of a national alien transportation plan; expanding the use of

technology, including the use of electronic fingerprinting and teleconferencing; and

completing a comprehensive review of the legal and regulatory processes for removal.

3. Reduce incentives for unlawful migration INS will decrease the “pull factors” for illegal migration and simultaneously support

benefit providers with information on alienage of individuals. Strategies include making it

easier for employers to verify employment eligibility and increasing efforts to educate

employers about their responsibility to comply with the law, focusing enforcement efforts

on industries that have traditionally relied on unauthorized labor and employers who

knowingly violate the law, and increasing the security of employment authorization

documents.

4. Implement asylum reform regulations INS will implement a more timely asylum processing and decision system. New

procedures, coupled with additional resources, will enable the Service to keep up with

incoming applications and begin to handle backlogged cases. This effort will also focus

enforcement on fraudulent applications, reducing incentives for asylum abuse.

5. Improve customer service INS will enhance delivery of services to its customers. This will be accomplished by

improving the current systems being used to obtain and apply customer service

feedback; implementing all components of the Executive Order on “Setting Customer

Service Standards”; and applying benchmarking to programs, where applicable, to

achieve best-in-the-business practices and standards.

6. Promote and streamline naturalization INS will encourage and promote naturalization through public education programs by

establishing cooperative agreements with community-based organizations, ethnic group

networks, and educational institutions to assist in preparation of applications and study

for civics and language tests; and by seeking ways to streamline the naturalization

process.

7. Improve professionalism INS will pursue professionalism at all levels of the agency. This will be accomplished by

maintaining high standards of conduct fostered through proper training and career

development and hiring and promotion practices—as reflected in the Service’s new

Equal Employment Opportunity plan—that result in a workforce that reflects the diversity

of America and our clientele.

8. Provide innovative immigration policy

leadership

INS will inform and shape immigration policy through production of timely, high-quality

information and policy analysis. The Service will take a proactive role in creating a better

understanding of immigration issues and in advancing new initiatives, including

legislation, to improve administration of U. S. immigration law and policy.

9. Broaden and integrate INS’ systems

infrastructure

INS will improve management information systems by developing accurate, timely,

integrated databases that upgrade operational effectiveness and productivity. The INS

“information highway” will lead to paperless work processes and national automated

immigration data repositories for both INS and relevant non-INS users.

(Table notes on next page)

Page 119 GAO/GGD-97-132 INS Management Problems
Appendix V 

INS’ Fiscal Years 1995 and 1996 Priorities

aAccording to INS officials, these priorities were not ranked in their order of importance.

Source: INS.

Page 120 GAO/GGD-97-132 INS Management Problems
Appendix V 

INS’ Fiscal Years 1995 and 1996 Priorities

Table V.2: INS’ Fiscal Year 1996 Priorities

Prioritya INS statement of priority

1. Strengthen the INS workforce INS will rapidly increase the size of its officer workforce and support staff. To accomplish

the goal of hiring over 4,000 new, productive employees, INS will (1) streamline and

target recruitment, (2) expand training, (3) increase retention of experienced employees,

and (4) deploy new employees with proper equipment.

2. Strengthen border enforcement and

facilitation

INS will regulate entry to the United States in a manner that facilitates lawful travel and

commerce while ensuring border integrity against unlawful entry. Efforts in fiscal year

1996 will consolidate and expand progress achieved at and between ports-of-entry in

the primary corridors of illegal immigration. To pursue these strategic targets, INS will (1)

enhance control between ports-of-entry along the Southwest Border, especially in San

Diego, Tucson, McAllen, and El Paso; (2) tighten control at ports-of-entry in anticipation

of the impact from beefed-up Border Patrol activities; (3) facilitate traffic by adding new

inspectors, opening lanes, and redesigning signs; (4) establish a proactive intelligence

program to support field managers in anticipating and responding to shifts in illegal alien

crossing patterns; (5) develop overseas deterrence activities, particularly in Mexico City,

to support border control efforts; and (6) expand antismuggling operations.

3. Increase removal of deportable aliens INS will increase removal of criminal and noncriminal illegal aliens, focusing especially

on aliens convicted of aggravated felonies. To increase removals, INS will (1) increase

criminal alien removals through expanded Institutional Hearing Programs and county jail

projects; (2) expand noncriminal alien removals with final orders of deportation of aliens

who have absconded, been rejected for asylum, or are in the workforce illegally; (3)

improve functioning of primary components of removal system, including the national

transportation system; and (4) enhance cooperative efforts with other law enforcement

agencies.

4. Enhance worksite enforcement and

verification systems

INS will reduce opportunities for illegal employment through enhanced worksite

investigations, document improvements, and automated status verification services. To

increase control at the worksite, INS will (1) target the worst violators of immigration and

employment standards laws and coordinate investigations with the Department of Labor,

(2) increase worksite operations to remove unauthorized workers and make jobs

available for authorized workers, and (3) test and expand pilot programs to assist

employers in complying with the law.

5. Improve immigration services INS will continue to improve services to its various customers, including petitioners for

immigration benefits, other law enforcement agencies, its own front-line employees, and

the local communities within which the Service works. To improve services, INS will (1)

reorganize service delivery to applicants for immigration benefits by improving forms,

reducing waiting periods, and accelerating processing times; (2) increase coordination

with other local law enforcement agencies to improve sharing of information, response

times, and joint operations; and (3) expand outreach to local communities through

citizen advisory groups, coordination with consulates, and participation in public events,

including expanded public affairs activities and communication with local congressional

offices.

6. Implement citizenship U.S.A. INS will respond to the tremendous growth in naturalization applications by reducing

naturalization processing times to 6 months. It will greatly increase the efficiency, quality

control, and convenience of the process and work with a variety of local organizations to

meet the increase in applications while maintaining examination standards.

aAccording to INS officials, these priorities were ranked in their order of importance.

Source: INS.

Page 121 GAO/GGD-97-132 INS Management Problems
Appendix VI 

Comments From the Commissioner of the

Immigration and Naturalization Service

Page 122 GAO/GGD-97-132 INS Management Problems
Appendix VI 

Comments From the Commissioner of the

Immigration and Naturalization Service

Page 123 GAO/GGD-97-132 INS Management Problems
Appendix VI 

Comments From the Commissioner of the

Immigration and Naturalization Service

Page 124 GAO/GGD-97-132 INS Management Problems
Appendix VI 

Comments From the Commissioner of the

Immigration and Naturalization Service

Page 125 GAO/GGD-97-132 INS Management Problems
Appendix VII 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

Evi L. Rezmovic, Assistant Director, Administration of Justice Issues

Linda R. Watson, Evaluator-in-Charge

Charity J. Goodman, Senior Evaluator

Charles Michael Johnson, Senior Evaluator

Stuart M. Kaufman, Senior Social Science Analyst

Katherine M. Wheeler, Publishing Consultant

Pamela V. Williams, Communications Analyst

Office of the General

Counsel, Washington,

D.C.

Ann H. Finley, Senior Attorney

Los Angeles Field

Office

Michael P. Dino, Senior Evaluator

Leah G. Riordan, Senior Evaluator

(183594) Page 126 GAO/GGD-97-132 INS Management Problems
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