United States General Accounting Office

GAO Report to the Attorney General

May 1997 ALIEN APPLICATIONS

Processing Differences

Exist Among INS Field

Units

GAO/GGD-97-47

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-275114 

May 20, 1997

The Honorable Janet Reno

The Attorney General

 of the United States

Dear Madam Attorney General:

The Immigration and Naturalization Service (INS) collects fees for

processing aliens’ applications (and petitions) for such immigration

benefits as naturalization and adjustment of status (to become permanent

residents).1

 Eighteen percent ($566 million) of INS’ fiscal year 1997 budget

of $3.09 billion is allocated for processing applications.

The number of applications received by INS has been growing and there are

indications that some INS field units are faster than others at application

processing. In fiscal year 1996, INS received almost 5.4 million new

applications and completed about 5.6 million total applications, which is

about a 115 percent increase over the number of applications received and

completed in fiscal year 1989. At the end of fiscal year 1996, INS had a

pending caseload inventory of about 1.7 million applications to be

processed. This represented an increase of about 2.5 times the pending

caseload at the end of fiscal year 1989. A recent INS report2

 indicated

differences in application production rates and projected processing times

among its district offices.

Because of the large volume of applications and indications of differences

in processing times across INS field units, we initiated a review under our

basic legislative authority to determine if significant differences in

production rates and processing times existed among field units in

1

Until recently, INS was to deposit the revenue from all of these fees into the Immigration Examination

Fee Account. The 1989 Department of Justice Appropriation Act established the account to be used to

reimburse any appropriation for expenses in providing immigration and naturalization services. P.L.

100-459, 102 Stat. 2186, 2203 (1988). In the fall of 1996, the Illegal Immigration Reform and Immigrant

Responsibility Act established a new account, the Immigration Detention Account, into which certain

additional fees for adjustment of status are now deposited. P.L. 104-208, 110 Stat. 3009, 3009-648,

3009-649 (1996).

2

INS Benefits Division Production Report, Fiscal Years 1996-1997.

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application processing.3 Because we found differences, we also asked

officials at the nine district offices and two service centers that we visited

what factors they believed could have caused the differences. We did not

attempt to do the more detailed analyses that would be necessary to

determine actual causes. This report presents the results of our work.

Results in Brief Our analyses of INS data for the 25-month period of June 1994 through

June 1996 showed that statistically significant differences existed in the

production rates for the five predominant types of applications processed

by INS’ district offices and the three predominant types of applications

processed by its service centers. For example, the district offices’ average

production rates for naturalization applications for that period ranged

from 0.35 completions per hour to 1.83 completions per hour. The service

centers’ average production rates for employment authorization

applications ranged from 3.11 completions per hour to 5.79 completions

per hour.

Large differences also existed in the projected processing times for the

two types of applications for which these data were readily available. The

data showed that INS district offices’ projected processing times ranged

from 112 to 678 days to process naturalization applications and from 36 to

799 days to process adjustment-of-status applications. We found no

significant statistical relationship between production rates and projected

processing times among the district offices.

While we did not determine directly what caused the differences, the wide

range in rates and times suggests that opportunities may exist to improve

the production and timeliness of some of the INS field units. To that end,

we asked INS officials what factors they believed could potentially have

caused the differences in the production rates and processing times. They

suggested a number of potential factors, including the following:

• differences in the way the field units reported the data we used to

calculate the production rates and processing times;

3

We analyzed the production rates and projected average processing times for each of 25 months in 33

INS districts. We did a Pearson correlation coefficient analysis to determine if statistical relationships

between production rates and projected average processing times existed (e.g., was an increase in

production rates statistically related to an increase in projected average processing times). We

calculated “production rates” as the number of completed applications divided by the productive

processing staff hours for each field unit (district office and service center). We calculated monthly

projected average processing times by dividing the number of applications pending at month’s end by

the number of applications completed for the month and multiplying this product by the number of

calendar days in the month.

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• assistance provided by community-based service organizations in some

districts to aliens when filling out their applications;

• the use of outside agencies for conducting naturalization testing by some

district offices;

• the authorization of increased overtime for some districts’ employees;

• the varying experience levels and degrees of specialization of district

office and service center adjudications officers; and

• differences in the staffing levels among some district offices (e.g., some

offices were staffed above their authorized levels, while other offices

temporarily lost staff to larger offices).

We did not attempt to determine whether or to what degree the factors

suggested by the officials may have affected the individual field units’

production rates and processing times. We note, however, that differences

in processing times mean that aliens in different INS districts have had to

wait disparate amounts of time for their applications to be processed.

Thus, the need to treat applicants fairly and use government resources

efficiently makes both determining the causes of the production and

timing differences and, if feasible, improving production and timeliness,

important goals for INS.

Background INS processes applications for aliens seeking immigration benefits—such

as naturalization and adjustment of status—within its 33 district offices’

jurisdictions and 4 service centers located in cities throughout the United

States.

INS collects fees for processing applications. The fees are generally set on

the basis of the approximate cost that INS determines it incurs to process

the type of application filed.4

 The revenue from the fees is to be used for

expenses incurred in (1) processing applications and (2) collecting,

safeguarding, and accounting for the fees. In general, INS processes

applications that require aliens to be interviewed (i.e., those for

naturalization and adjustment of status) at its district offices. However, at

four of its largest district offices, the service centers perform preliminary

processing of applications that require aliens to be interviewed.

Applications that do not require aliens to be interviewed (e.g., those for

4

An exception is the adjustment-of-status application fee, which is set by statute at $1,000 for certain

aliens.

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employment authorization) are processed at its service centers and district

offices.5

Increased Volume of

Applications

While experiencing some fluctuations, the overall number of applications

received, completed, and remaining in INS’ ending inventory significantly

increased between fiscal years 1989 and 1996, as shown in table 1.

Table 1: Number of Applications

Received, Completed, and Remaining

in Inventory, Fiscal Years 1989

Through 1996

Applications

Fiscal year Received Completed

Fiscal year ending

inventory

1989 2,510,015 2,585,478 658,399

1990 2,963,428 2,971,300 540,830

1991 3,359,869 3,379,383 568,189

1992 4,234,980 4,207,968 656,067

1993 4,498,208 4,288,643 679,982

1994 4,137,660 3,911,697 987,485

1995 4,976,716 4,265,463 1,765,999

1996 5,393,501 5,557,102 1,673,163

Source: INS budget data for fiscal years 1989 to 1991 and INS G-22.2 and G-22.3 reports for

fiscal years 1992 to 1996, dated January 1997.

According to INS officials, the significant increase in the number of

applications INS has received since fiscal year 1989 can be attributed to

(1) aliens’ reactions to proposed changes in state and federal laws that

would have denied aliens benefits (e.g., proposals to prohibit children of

illegal aliens from attending public schools); (2) aliens having to replace

their alien registration receipt cards; and (3) legal aliens becoming eligible

to become naturalized and having an incentive to do so because of the

benefits that could be derived from their status as citizens. INS officials

said that naturalization and adjustment-of-status applications reached

record levels in fiscal year 1996. For example, naturalization applications

rose from about 423,000 in fiscal year 1989 to over 1.2 million in fiscal year

1996. The officials also said that the level of applications is expected to

remain high.

According to INS officials, the waiting time needed to process an

application in fiscal year 1995 had increased. For example, the projected

5

In addition, INS processes applications for asylum at eight offices nationwide. Because such

applications are not processed at the district offices or the service centers, we excluded them from our

review.

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processing time for naturalization applications exceeded 2 years in several

of INS’ largest districts. INS added that this increase in processing time was

due to (1) the tremendous growth in application receipts, combined with

the speed at which the increase occurred; and (2) the lag time to obtain

additional resources through the reprogramming process.

Changes in Application

Processing

In 1986, INS began requiring that some applications, other than those

requiring interviews (e.g., those for naturalization and adjustment of

status), be mailed directly to service centers for processing, rather than to

the district offices.6 INS called this the “Direct Mail Program.” Under a

change to the Direct Mail Program, which was effective February 1996,

aliens who would have mailed their naturalization applications to one of

INS’ four largest district offices (Chicago, Los Angeles, Miami, and New

York) are required to mail their naturalization applications directly to a

designated service center. The service centers are to perform the

preliminary processing of the applications in support of these four district

offices.7

 The district offices are to complete the processing of these

applications by doing additional work (e.g., interviewing the aliens).

According to INS officials, INS expects to continue with its plan to expand

the Direct Mail Program to include other district offices and application

types. The officials added that the Direct Mail Program has greatly assisted

these district offices in reducing the large pending workload of

naturalization applications.

In addition to expanding its Direct Mail Program, during fiscal year 1996

INS directed more resources to processing naturalization applications. It

concentrated its additional staff and other resources primarily in Los

Angeles, San Francisco, Miami, Chicago, and New York. These district

offices’ workloads together comprised 75 percent of pending

naturalization applications in fiscal year 1995 and, according to INS

officials, this was the reason they were chosen for the Direct Mail

Program.

According to INS officials, as a result of these efforts, the number of

naturalization applications completed increased by about 166 percent

between fiscal years 1995 and 1996, and the pending balance was reduced

6

The applications were to be mailed to designated remote adjudications centers, which have since

been replaced by the four service centers.

7

Under the Direct Mail Program, the California Service Center supports the Los Angeles District Office,

the Nebraska Service Center supports the Chicago District Office, the Texas Service Center supports

the Miami District Office, and the Vermont Service Center supports the New York District Office.

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by about 13 percent over the same time period. The officials said that INS

received more applications but its capacity to handle applications

increased at the same time. However, its pending balance of

adjustment-of-status applications increased by about 37 percent. The

pending balance for all types of applications decreased by 17 percent. (See

table 2.)

Table 2: Changes in Receipts, Completions, and Pending Balances for Adjustment-of-Status, Naturalization, and All

Application Types for Fiscal Years 1995 and 1996

Application type Fiscal year Receipts

Percent

change Completed

Percent

change Pending

Percent

change

Naturalization 1995 1,057,759 505,913 803,062

1996 1,220,517 15.4 1,344,412 165.7 701,487 (12.6)

Adjustment of status 1995 577,759 357,567 320,770

1996 649,792 12.5 541,867 51.5 438,546 36.7

All types 1995 3,341,198 3,401,983 642,167

1996 3,523,192 5.4 3,670,823 7.9 533,130 (17.0)

Source: INS G-22.2 and G-22.3 reports for fiscal years 1995 and 1996, dated January 1997.

INS Application Processing

Goals

INS’ goal is that the application process will be timely, consistent, fair, and

of high quality. In addition, INS officials stated that a quality decision

includes a timely decision. During fiscal year 1996, INS made processing

naturalization and adjustment-of-status applications among its highest

priorities and INS’ Commissioner set 6-month and 4-month goals,

respectively, for processing these two types of applications.8

 According to

INS officials, INS has not established production rate goals.

Scope and

Methodology

To determine the production rates and projected processing times for

selected application types at INS’ district offices and service centers, we

collected and analyzed INS application processing workload summary data

and projected processing time reports by application type and by month

for the 25-month period ending June 1996. We then compared the

production rates and projected processing times for applications among

district offices and the production rates for applications among service

centers. After identifying differences, we attempted to identify possible

reasons for the differences in production rates and processing times. We

did this by asking INS officials in headquarters and 11 selected field units

8

A processing time frame of 90 days for interim employment authorization applications also exists.

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what factors they believed could have caused the differences.9 On the

basis of our analyses of production rates and projected processing times,

we chose the nine district offices and two service centers we visited

because they had a range of production rates, processing times, and

application volumes.10 At these field units and INS headquarters, we

discussed application processing procedures, staffing changes, production

rates, and application processing times for the period of June 1994 through

June 1996. Their comments are not generalizable to other field units. Also,

we reviewed an INS report that showed differences in production rates and

projected processing times among its field units.11

Using INS’ methodology, we calculated “production rates” as the number of

completed applications divided by the productive processing staff hours

for each field unit (district office and service center).12 This is a measure

of how many applications were completed per hour. According to INS

guidance, the projected processing time for a particular month is to be

calculated by dividing the number of applications pending at month’s end

by the number of applications completed for the month and multiplying

this product by the number of calendar days in the month. This is a

projection of how long INS will take to complete action on an application

received on the last day of the month if the current month’s completion

rate is maintained. This is a proxy measure of how long the “wait time”

would be from receipt of an application to the completion of its

processing, per month. INS used this methodology to calculate projected

processing times for selected application types by month over the

25-month period of June 1994 through June 1996.

Since the fall of 1996, reports by us and others and congressional oversight

hearings have provided evidence that INS’ efforts to reduce backlogs in

naturalization application processing resulted in serious internal control

and other weaknesses that led to improper naturalization actions in some

cases.13 Reviews of these problems, by ourselves and others, are currently

9

We met with Assistant District Directors for Examinations and Service Center Directors, except when

they suggested that we speak with someone else on their staff.

10See app. I for a list of locations we visited.

11The data source for this report was the same source that we used for our analysis. INS’ report

excluded data on returned applications, while we included these data.

12Productive processing staff hours do not include staff time spent on any administrative functions

(e.g., training, travel, supervision, and record keeping).

13Naturalization of Aliens: Assessment of the Extent to Which Aliens Were Improperly Naturalized

(GAO/T-GGD-95-51, Mar. 5, 1997); KPMG Peat Marwick LLP. Naturalization Quality Procedures

Implementation Review (Washington, D.C.: Apr. 17, 1997); Naturalization of Aliens: INS Internal

Controls (GAO/T-GGD-97-57, Apr. 30, 1997); Naturalization of Aliens: INS Internal Controls

(GAO/T-GGD-97-98, May 1, 1997).

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ongoing. The scope of the work that was undertaken to address our

objectives for this report—to determine whether significant differences in

production rates and processing times existed among INS’ field units—did

not include an assessment of whether INS’ naturalization processes were

being carried out in accordance with INS’ policies and procedures.

We conducted our review from March 1996 to April 1997 in accordance

with generally accepted government auditing standards. We provided the

Attorney General and the INS Commissioner with a draft of this report for

their review and comment. The Commissioner provided written comments

for the Attorney General, which are discussed and evaluated at the end of

this letter. The INS comment letter is reprinted in appendix III. Appendix I

provides a more detailed description of our objectives, scope, and

methodology. INS also provided separately some technical comments. We

discussed these comments with INS officials and agreed on appropriate

changes.

Variances in

Production Rates

Our analyses of INS monthly workload summary data for the period of

June 1994 through June 1996 showed that statistically significant

differences existed in production rates for each of the five predominant

types of applications among INS district offices and service centers. This is

consistent with the INS report that also showed differences in production

rates among its district offices and among its services centers for fiscal

years 1994, 1995, and 1996. In discussing our analyses with INS officials,

they pointed out that anomalies in some district offices explain some of

the differences. However, INS did not provide any examples of these

anomalies.

Production Rates Differed

Significantly

Our analyses of the production data for district offices and service centers

showed that statistically significant differences existed in average

production rates by application type (as measured by applications

completed per productive hour) for the 25-month period ending June 1996.

(See table 3.) See appendix II for a schedule by field unit and application

type.14

14In our analyses, we compared monthly production rates (completed applications divided by

productive hours) by application type for each district office and service center. In this report, we used

the 25-month average by application type for each unit. This was done for presentation purposes

because of the complexity of the data for 33 district offices and 4 service centers by month, for 25

months, for 5 separate application types.

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Table 3: Range of Average Per Hour

Production Rates for INS District

Offices and Service Centers for Five

Application Types, June 1994 Through

June 1996

District offices’ range Service centers’ range

Application type Low High Low High

I-90 0.04 3.94 3.17 6.69

I-130 0.32 1.26 2.85 4.20

I-485 0.32 1.28 a a

I-765 0.76 4.55 3.11 5.79

N-400 0.35 1.83 a a

Legend:

I-90 = replacement of alien registration card

I-130 = immigrant visa for alien relative

I-485 = registration for permanent residency or adjustment of status

I-765 = employment authorization

N-400 = naturalization

aGenerally, the service centers do not adjudicate the I-485 and N-400 applications.

Source: GAO analyses of INS data.

In comparing production rates among district offices for the five

application types, some district offices tended to be more productive for

all application types, others were comparatively less productive for all

application types, while other district offices’ production rates varied by

application type. For example, one district office had one of the highest

production rates for one application type but the lowest production rate

for two other application types. Another district office had one of the

highest production rates for two application types but the next to lowest

rate for another application type.

We also analyzed the production data to determine if either the proportion

of naturalization applications and adjustment-of-status applications or the

volume of naturalization and adjustment-of-status applications completed

by district offices was related to their production rates for these two

application types.15 We did not find a statistically significant relationship.

We did find, however, a statistically significant, positive relationship

between the production rate for naturalization applications and the

production rate for adjustment-of-status applications.16 That is, district

offices with high production rates for naturalization applications also

tended to have high production rates for adjustment-of-status applications.

15Naturalization and adjustment-of-status applications accounted for about one-half of all completed

applications in fiscal year 1996.

16For the average production rate for the 33 districts, the Pearson correlation coefficient between the

two application types was 0.58 (the probability that the relationship was due to chance was less than

5 percent).

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In other words, we found a tendency for some district offices to have more

completions per hour than others for these two application types.

INS’ Report Containing

Production Data Also

Showed Variances

According to the INS Benefits Division Production Report, average

production rates agencywide for all application types decreased from 1.67

completions per hour in fiscal year 1995 to 1.45 in fiscal year 1996. Across

INS, during the same time period, average naturalization application

completions increased from 0.66 to 0.84 per hour, while completions of

adjustment-of-status applications decreased from 0.74 to 0.70 per hour.

The report further stated that, in fiscal year 1996, field units’ average

production rates ranged from 0.42 to 2.11 completions per hour for all

application types combined, from 0.21 to 2.30 completions per hour for

naturalization applications, and from 0.30 to 1.88 completions per hour for

adjustment-of-status applications. The INS report did not include a

statistical analysis of the differences in production rates.

We compared the results of our analyses with the data in INS’ report and

found that our results were similar to INS’ results. Differences in how we

aggregated data for analyses caused our figures to differ somewhat from

INS’ figures, but the overall pattern of differences across district offices is

evident in both analyses.17 INS excluded returned applications, while our

analyses of the data included returned applications. According to INS

officials, this inclusion would not significantly affect our analyses.

According to INS officials, although INS had not compared the reasons or

studied the causes for differing production rates, it has been working to

address differences in processing times.

Variation in Projected

Processing Times

Our analyses of INS workload summary and projected processing time data

for the 25-month period ending June 1996 showed that differences existed

among district offices concerning projected processing times for the two

predominant types of applications.18 Furthermore, INS’ report also showed

variances in projected processing times among its district offices.

17INS’ report provided data from 65 units, including district offices and suboffices within the district

offices. Naturalization data for two units were zero. The data were for fiscal years 1994, 1995, and

1996. For fiscal years 1995 and 1996, INS also reported the data by quarters. Our analyses were done by

month for the 25-month period ending June 1996 for the same two application types as well as for the

other three major application types.

18As with production rates, we used the 25-month average for projected processing times for

naturalization and adjustment-of-status applications. This was done for presentation purposes because

of the complexity of displaying the data for 33 district offices by month for the 25 months for 2

application types.

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Projected Application

Processing Times Differed

Significantly Among INS

District Offices

Our analyses of projected processing time data for adjustment-of-status

and naturalization applications showed that significant differences existed

among INS district offices.19 For example, the projected average processing

time for adjustment-of-status applications from June 1994 to June 1996

was 357 days for all district offices combined, with a low of 36 days and a

high of 799 days20 (see table 4).

Table 4: Average Projected Processing

Times for Adjustment-of-Status

Applications at 32 District Offices,

June 1994 Through June 1996

INS district office Number of days

St. Paul, MN 36

Portland, ME 69

Buffalo, NY 102

Cleveland, OH 107

Honolulu, HI 110

Denver, CO 141

Anchorage, AK 147

Baltimore, MD 151

Helena, MT 163

Philadelphia, PA 180

Detroit, MI 197

Dallas, TX 208

Boston, MA 209

Miami, FL 221

Seattle, WA 228

New Orleans, LA 237

Kansas City, MO 244

Atlanta, GA 273

San Antonio, TX 311

Portland, OR 316

Newark, NJ 347

Omaha, NE 348

San Francisco, CA 353

Washington, D.C. 359

Chicago, IL 424

(continued)

19Because staff at INS service centers generally did not adjudicate naturalization and

adjustment-of-status applications, we did not analyze the processing times for INS’ four service

centers. Also, data on processing times for other types of applications were not readily available.

Therefore, we only analyzed naturalization and adjustment-of-status applications.

20We eliminated the Harlingen District Office (Texas) from our computation of INS’ average because

its reported projected processing time appeared to be an anomaly. Doing further analyses to determine

whether the time reported was an anomaly or an error was not practical.

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INS district office Number of days

New York, NY 456

San Diego, CA 504

San Juan, PR 521

Phoenix, AZ 608

El Paso, TX 669

Los Angeles, CA 770

Houston, TX 799

INS average 357

Note: According to INS officials, as part of a pilot of the Direct Mail Program, the Vermont Service

Center has been performing the preliminary processing of adjustment-of-status applications in

support of the Baltimore District Office. The officials added that this initiative could affect the

district office’s projected processing times and production rates for this application type.

Source: GAO analyses of INS data.

For naturalization applications, the average projected processing time

from June 1994 to June 1996 was 373 days across all district offices, with a

low of 112 days and a high of 678 days. (See table 5.)

Table 5: Average Projected Processing

Times for Naturalization Applications

at 32 District Offices, June 1994

Through June 1996

INS district office Number of days

Portland, ME 112

Buffalo, NY 130

Baltimore, MD 138

Washington, D.C. 140

Anchorage, AK 159

Cleveland, OH 167

St. Paul, MN 170

Helena, MT 171

Kansas City, MO 185

Philadelphia, PA 188

San Antonio, TX 196

Portland, OR 196

Honolulu, HI 218

New Orleans, LA 259

New York, NY 261

Atlanta, GA 265

Omaha, NE 265

Boston, MA 274

Denver, CO 287

(continued)

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INS district office Number of days

San Diego, CA 294

El Paso, TX 295

Harlingen, TX 308

Newark, NJ 331

San Juan, PR 339

Seattle, WAa 344

Los Angeles, CA 369

Detroit, MI 379

Dallas, TX 455

Chicago, IL 526

San Francisco, CA 552

Miami, FL 578

Houston, TX 615

Phoenix, AZ 678

INS average 373

aAn official in the Seattle District Office said that its processing time for naturalization applications

did not exceed 196 days. According to the official, the difference between the average data INS

and we used and its data resulted from the fact that INS and we used a formula (which is a proxy

on the basis of the aggregate flow of applications) to calculate average projected processing

times, whereas the Seattle District Office used the actual processing times spent to complete

individual naturalization applications each month. We did not verify Seattle’s calculation.

Source: GAO analyses of INS data.

To determine whether a statistical relationship existed between

production rates and projected processing times, we analyzed data for

adjustment-of-status and naturalization applications for all district offices

that completed at least 100 of either type of application per month during

the 25-month period ending June 1996.21 We found no significant

relationship between production rates and projected processing times

among the district offices.22

21To detect a possible relationship between the two application types, we needed a sufficient number

of completed applications. On the basis of our review of the data, 100 completed applications per

month were adequate for our purpose—29 and 30 district offices had completed an average of 100

naturalization and 100 adjustment-of-status applications per month, respectively. At the time of our

review, data from the New York District Office were not available. Because of data problems, we

excluded the Harlingen District Office (Texas).

22The Pearson correlation coefficient was less than 0.1 (with a probability greater than 0.8).

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INS’ Report Containing

Timeliness Data Showed

Variances

According to the INS Benefits Division Production Report, during fiscal

year 1996, the average projected processing times of reporting field units

for completing all types of applications ranged from 45 days to 296 days.

The average projected processing time for naturalization applications

ranged from 22 days to 383 days. According to the INS report, 53 percent of

its reporting field units had average projected processing times for their

naturalization applications of less than or equal to 183 days (6 months),

which was INS’ processing goal. The projected processing times for the

field units to complete adjustment-of-status applications ranged from 38

days to 998 days. Twenty-eight percent of the field units completed

processing of adjustment-of-status applications within 122 days (4

months), which was INS’ processing goal. As in the case of INS’ production

data, its projected processing time data were consistent with our

analyses.23

Possible Reasons for

Differences in

Production Rates and

Processing Times

To identify factors that may have contributed to the differences in

production rates and processing times, we met with officials at INS

headquarters, nine district offices, and two service centers.24 Generally,

these officials’ comments focused on the data used to compare the field

units’ rates and times, as well as on other factors that may have affected

the units’ production and timeliness. With the exception of comparability

of data issues, we were not able to gain insight into the extent to which

these factors actually affected the production rates and processing times.

Such an assessment would require a more thorough review and analysis of

the field units’ procedures and practices for processing applications than

we could complete within a reasonable period of time.

In our discussions about factors that the officials said could have affected

differences in production rates and processing times, the issues they

identified tended to be interrelated. Therefore, in the following discussion,

we do not separate production rate and processing time issues.

Data May Affect

Comparisons of Field Units

INS officials in certain field units said that our comparisons of field units’

production rates and projected processing times could be affected by two

data-related factors.

23The same previously discussed reasons explain the differences between INS’ report and our analyses.

24Before meeting with these officials, we provided them with our analyses of production rates and

projected processing times.

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• The first factor was the possibility of inaccuracies in the data reported by

other field units. For example, officials in two field units were concerned

that other field units may not have accurately reported their production

data. However, none of the field units we visited identified problems

associated with its own production data. Furthermore, many of the

officials told us that they reviewed and corrected their units’ production

data before sending the data to their respective regional offices or INS

headquarters.

• The second factor, which was cited by several district offices at the time of

our visit, was inconsistency in defining the point when approved

naturalization applications were considered completed. For example, five

of the nine district offices we visited considered an approved

naturalization application completed after the naturalization interview,

and at that point, the district offices would approve the application. The

other four district offices considered an approved naturalization

application completed only after the alien was sworn in as a naturalized

citizen.25 We agree with INS that the differences in production rates and

processing times could be partly attributed to this inconsistent definition.

However, as shown in table 6, our analyses indicated that differences

existed in the production rates of the four districts that considered the

naturalization ceremony the point of completion, as well as among the five

district offices that considered the interview the point of completion.

Table 6: Ranges of Average

Production Rates and Projected

Processing Times for the Nine INS

District Offices Broken Out by When in

the Process Naturalization

Applications Were Considered

Completed, June 1994 Through

June 1996

Per hour production

rate

Projected

processing time in

days

Naturalization complete High Low High Low

After ceremony 1.34 0.82 615 185

After interview 1.83 0.56 455 130

Source: GAO analyses of INS data.

As shown in table 7, wide variances also existed among these district

offices’ per hour production rates for the four types of applications, other

than those for naturalization.

25According to INS officials, INS now requires its field units to consider a naturalization application

completed after the naturalization ceremony. The five district office officials said that they are now

following this requirement.

Page 15 GAO/GGD-97-47 INS Processing of Alien Applications
B-275114 

Table 7: Range of Average Per Hour

Production Rates for the Nine INS

District Offices for Four Application

Types, June 1994 Through June 1996

District offices’ range

Application type Low High

I-90 0.10 3.94

I-130 0.32 1.26

I-485 0.37 1.28

I-765 0.76 3.78

Legend:

I-90 = replacement of alien registration card

I-130 = immigrant visa for alien relative

I-485 = registration for permanent residency or adjustment of status

I-765 = employment authorization

Source: GAO analyses of INS data.

Regarding the nine district offices’ projected processing times, data were

readily available for adjustment-of-status applications but not for other

application types. The nine district offices’ projected processing times for

adjustment-of-status applications also varied widely, ranging from 102

days to 799 days.

INS headquarters officials were aware of concerns that field units had

about the data we used for our analyses. However, they pointed out that

the data were the best available and were used by INS for budgeting and

management purposes, such as in INS’ previously mentioned Benefits

Division Production Report. In addition, INS uses the same data for its

report to Congress on the status of adjudications and naturalization

processing.

Other Factors That May

Affect Production Rates

and Processing Times

During our visits to field units, INS officials identified several factors that

they believed may affect production rates and processing times. They

pointed out that, in any such work process, an interrelationship exists

among many factors that may affect both production rates and processing

times. We agree and generally did not verify whether or to what extent the

following factors actually affected production rates or processing times.

• An official from one district office said that it must rely on the courts to

conduct naturalization ceremonies, which can delay the naturalization

dates and, therefore, increase the time spent to complete applications. An

official from another district office said that his office conducted the

naturalization ceremony on the same day the application was approved,

thereby shortening processing times.

Page 16 GAO/GGD-97-47 INS Processing of Alien Applications
B-275114 

• According to officials in two district offices, aliens’ naturalization

applications tended to be more accurately completed when aliens received

assistance from community-based service organizations. As a result,

according to these officials, INS officers were able to process these

applications more quickly.

• According to eight field unit officials, district offices have varying degrees

of automation. For example, one district office developed a computerized

tracking system to enhance the recording and processing of

adjustment-of-status applications. According to officials in this district,

other districts have requested and started to use this system to enhance

their adjustment-of-status application processing.26

• According to district office officials, in four district offices, adjudications

staff specialized in certain application types, while in the other five district

offices, adjudications staff performed as generalists, processing all types

of applications.

• According to INS officials at one field unit, the mix of applications (i.e., the

proportion of application types) that field units receive affects their

processing times. These officials added that, if a field unit receives a larger

percentage of applications that take longer to process, its average

processing times for all types of applications would be longer relative to

other field units.

• According to INS officials we visited, staffing at the district offices has

varied. While some district offices have been staffed at or above their

authorized levels, other offices have lost staff on a temporary basis to

larger offices. These officials added that the experience level of the

adjudication staff differs across INS. They said INS had recently hired new

staff, and the new hires are generally not as efficient as the more

experienced staff.

• According to officials we visited, some INS district offices rely on outside

testing agencies to conduct naturalization examinations, while other

offices conduct their own examinations. According to the officials, the use

of outside testing agencies may improve timeliness.

• According to officials in three district offices, authorized increases in

overtime hours above their budget enabled their offices to reduce

processing times.

Conclusions Our analyses showed that the production rates among the district offices

and among service centers varied significantly for the five application

types we analyzed. We did not find a relationship between production

rates and the mix of applications received or the volume of completed

26At the time of our review, this system was not being used agencywide.

Page 17 GAO/GGD-97-47 INS Processing of Alien Applications
B-275114 

applications. Furthermore, the projected processing times of

naturalization and adjustment-of-status applications differed among the

district offices. We found no significant relationship between production

rates and projected processing times among the district offices. An INS

report covering approximately the same time period also showed

variations in projected production rates and projected processing times

among its district offices. INS has not identified reasons for these

variations.

We did not attempt to assess the extent to which specific practices or

circumstances caused the differences in production rates and processing

times among field units. However, our analyses of production rates and

projected processing times for the nine district offices we visited, along

with the fact that the field officials also provided other reasons, seem to

indicate that factors other than data quality problems, at least in part, may

have contributed to the variation. Data quality, specifically definitional

issues, however, could have contributed to differences across field units.

The production rates of district offices and service centers are important

because of the significant growth in the number of applications that INS

has received over the past several years. This growth has placed greater

demands on INS as it attempts to process these applications within

reasonable time frames. Our comparisons among field units show that

significant differences exist in their production rates; thus, opportunities

may exist to improve the production rates of some of the units.

Aliens pay the same fees for the various applications at all INS offices;

however, the length of time that aliens wait for their applications to be

completed has varied widely from field unit to field unit. This raises a

fairness issue in that the length of time aliens have to wait for their

applications to be processed varies according to the INS office at which

they apply.

Determining the reasons for the differences in, or methods for improving,

production or timeliness were outside the scope of this review. Because

INS has in-depth knowledge of its field operations and its application

processing procedures, it is in the best position to pursue the causal

factors that may be contributing to higher production in some field units.

The identification of these factors can be important because they may

relate to opportunities for improved efficiencies at all field units.

Page 18 GAO/GGD-97-47 INS Processing of Alien Applications
B-275114 

Recommendations to

the Attorney General

We recommend that you direct the INS Commissioner to periodically

determine and assess the production rates and processing times in the INS

field units. The Commissioner should first ensure that the field units are

consistently reporting the data used to calculate the rates and times. After

ensuring that data are consistently reported, including using the same

definitions, the Commissioner should (1) analyze the production rates and

processing times for each field unit by application type, (2) identify factors

that contribute to making the field units more or less productive and

timely, (3) determine whether and what changes could be made to make

individual field units more productive and timely, and (4) follow up with

the field units to ensure that appropriate changes are implemented.

Agency Comments

and Our Evaluation

In an April 22, 1997, letter, the INS Commissioner provided comments on a

draft of this report (see app. III). Although not specifically commenting on

our recommendations in its letter, INS officials, including the Associate

Commissioner for Examinations, in a meeting on March 18, 1997, said that

they agreed with our recommendations.27 However, the Commissioner

said that our draft led the reader to believe that our overall conclusions

were based on scientific analyses when, in her view, they were based

simply on unvalidated testimonial and anecdotal information.

We disagree with INS that our analyses and conclusions were not

scientifically based. We analyzed the production rates using standard

statistical techniques to determine if the differences between field units by

application type were significant. Our analyses showed that significant

differences existed. We then examined other factors that might be related

to the differences in the production rates such as processing times, mix of

application types, and volume of application types. However, we

recognized as a result of INS’ comment that additional information about

our methodology would be beneficial to a reader. Accordingly, we added

additional information to this report to clarify the statistical analyses we

performed.

INS also said that the data in our draft were suggestive and not conclusive

and that the report provided very little information to help it better

understand the problem. Therefore, INS believes that our work further

demonstrates the need for it to continue its efforts to improve data

integrity. INS added that one of its priorities is to revise its workload

27At this meeting, INS provided technical comments, which were incorporated in this report where

appropriate.

Page 19 GAO/GGD-97-47 INS Processing of Alien Applications
B-275114 

reporting process, including standardizing the definitions and methods of

data collection.

As discussed in this report, we agree that the data we analyzed do not

provide conclusive reasons for the differences in production rates and

processing times within the nine field offices. Our objectives for this

review did not include determining actual causes for the differences.

This report contains recommendations to you. As you know, 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 Chairmen and Ranking

Minority Members of interested congressional committees; the INS

Commissioner; the Director, Office of Management and Budget; and other

interested parties. Copies will also be made available to others upon

request.

Major contributors to this report are listed in appendix IV. If you have any

questions about this report, please contact me on (202) 512-8777.

Sincerely yours,

Norman J. Rabkin, Director

 Administration of Justice Issues

Page 20 GAO/GGD-97-47 INS Processing of Alien Applications
Page 21 GAO/GGD-97-47 INS Processing of Alien Applications
Contents

Letter 1

Appendix I 

Objectives, Scope,

and Methodology

24

Appendix II 

INS Field Units’

Average Production

Rates and Average

Completions by

Application Type for

the 25-Month Period

Ending June 1996

28

Appendix III 

Comments From the

Commissioner,

Immigration and

Naturalization Service

31

GAO’s Comments 33

Appendix IV 

Major Contributors to

This Report

34

Tables Table 1: Number of Applications Received, Completed, and

Remaining in Inventory, Fiscal Years 1989 Through 1996

4

Table 2: Changes in Receipts, Completions, and Pending Balances

for Adjustment-of-Status, Naturalization, and All Application

Types for Fiscal Years 1995 and 1996

6

Table 3: Range of Average Per Hour Production Rates for INS

District Offices and Service Centers for Five Application Types,

June 1994 Through June 1996

9

Page 22 GAO/GGD-97-47 INS Processing of Alien Applications
Contents

Table 4: Average Projected Processing Times for

Adjustment-of-Status Applications at 32 District Offices,

June 1994 Through June 1996

11

Table 5: Average Projected Processing Times for Naturalization

Applications at 32 District Offices, June 1994 Through June 1996

12

Table 6: Ranges of Average Production Rates and Projected

Processing Times for the Nine INS District Offices Broken Out by

When in the Process Naturalization Applications Were

Considered Completed, June 1994 Through June 1996

15

Table 7: Range of Average Per Hour Production Rates for the

Nine INS District Offices for Four Application Types, June 1994

Through June 1996

16

Table II.1: INS District Office Average Per Hour Production Rates

and Average Monthly Completions by Application Type for the

25-Month Period Ending June 1996

28

Table II.2: INS Service Center Average Per Hour Production

Rates and Average Monthly Completions by Application Type for

the 25-Month Period Ending June 1996

30

Abbreviations

INS Immigration and Naturalization Service

Page 23 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I 

Objectives, Scope, and Methodology

Because of the large volume of applications and indications of differences

in processing times across INS field units, we initiated a review under our

basic legislative authority to determine if significant differences in

production rates and processing times existed among INS’ field units in

application processing. Because we found differences, we also asked

officials at the nine district offices and two service centers that we visited

what factors they believed could have caused the differences. We did not

attempt to do the more detailed analyses that would be necessary to

determine actual causes.

To determine the production rates for each type of application in the INS

district offices and service centers, we obtained the monthly adjudications

workload summary reports (G-22.2 and G-22.3 reports, dated January 31,

1997) from INS headquarters covering the 25-month period from June 1994

through June 1996. These monthly reports provided information, by

district office and application type, on (1) the number of applications

received and completed, as well as the ending (pending) balances; and

(2) the productive hours of the adjudications staff. For each office, we

then calculated average monthly production rates for each application

type by dividing the applications completed by the productive hours spent

on adjudications.

The reports do not include contractor hours for processing applications

and records management at the field units. During our discussions with

field unit officials, they did not mention contractor hours as a factor

affecting the differences in production rates or processing times. Since the

INS reports did not contain contractor hours, we could not analyze the

effect that contractor hours may have had on production rates or

processing times.

To better understand how production compared across INS field units, we

analyzed the production rates for the five major types of applications

separately. According to INS data, the five application types that were

processed most frequently were the replacement of alien registration card

(I-90), immigrant visa for alien relative (I-130), registration for permanent

residency or adjustment of status (I-485), employment authorization

(I-765), and naturalization (N-400). These five application types accounted

for about 97 percent of all completed applications for June 1996. We

compared the rates for each application type only with those for the same

type of field unit. For example, the production rates for employment

authorization applications at district offices were compared with those at

other district offices but not with those at service centers. According to

Page 24 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I 

Objectives, Scope, and Methodology

INS, the application review processes are different in the two types of field

units.

To determine whether a relationship existed between production rates and

projected processing times, we analyzed data for adjustment-of-status and

naturalization applications for all district offices that completed at least

100 of either type of application per month during the 25-month period

ending June 1996. To determine whether a relationship existed between

the two application types, we needed a sufficient number of completed

applications. On the basis of our review of the data, 100 completed

applications per month was adequate for our purpose. We also analyzed

the production data to determine whether the mix of naturalization and

adjustment-of-status applications received (i.e., proportion of application

types at a district office) or the volume of naturalization and

adjustment-of-status applications completed by district offices, was

related to their production rates.1

 Specifically, we performed three

statistical analyses.

• Our analysis of the variation in monthly production rates showed a

statistically significant difference (probability that the relationship was

due to chance was less than 5 percent) between district office average

production rates. We analyzed data from June 1994 through June 1996 for

the 33 districts for the 5 predominant types of applications processed by

the district offices and 3 types for service centers. This result led to several

other analyses to attempt to determine what factors might be related to

production rates.

• We compared production rates and projected average processing times to

see if a statistically meaningful relationship existed between the two. That

is, we wanted to know if districts with high production rates also generally

had shorter projected average processing times than districts with lower

production rates, or whether the inverse was true. We analyzed data for

adjustment-of-status and naturalization applications for all district offices

that completed an average of at least 100 applications per month during

the 25-month period. We did not find a significant relationship (the

Pearson correlation coefficient was less than 0.1 with a probability due to

chance greater than 80 percent).

• We also analyzed adjustment-of-status and naturalization applications to

see if either the volume of applications processed or the mix of

applications processed was related to the production rate. Volume was

measured by the average number of completions per month for the two

1

Naturalization and adjustment-of-status applications accounted for about one-half of all completed

applications in fiscal year 1996.

Page 25 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I 

Objectives, Scope, and Methodology

application types, and mix was measured by the ratio of applications

completed for one application type divided by applications completed for

all other application types. We did not find a statistically meaningful

relationship among these factors. We did, however, find a statistically

significant, positive relationship between the production rate for

naturalization applications and the production rate for

adjustment-of-status applications (Pearson correlation coefficient equaled

0.58, with a probability that the relationships was due to chance of less

than 5 percent). That is, districts with high production rates for one

application type tended to have high production rates for the other

application type.

Finally, while we did not verify the accuracy of the adjudications data

received from INS, we obtained the comments of INS officials in field units

and headquarters on how data for the monthly adjudications workload

summary reports and productive hours are accumulated, as well as what

checks are performed to ensure the quality and accuracy of the data.

These officials raised questions about the reporting of productive hours

and the definition of naturalization application completions. Accordingly,

we performed additional analyses of the data in an effort to determine

their validity.

To analyze applications’ processing times, we gathered processing time

reports (also called “aging reports”) from INS headquarters covering each

district office for the same 25-month period—June 1994 through

June 1996. Processing time data were not readily available for the service

centers. We focused our analyses on the naturalization and

adjustment-of-status applications because these were the only applications

for which INS collects timeliness data. Further, INS has made these

application types its highest priority for adjudication and the INS

Commissioner has set specific processing time goals for these two types of

applications. As with the production rate data, at each INS office we visited

we also obtained the comments of INS field and headquarters officials on

the accuracy of the processing time data and what factors affect the

usefulness of the data.

To determine the reasons for the differences in production rates and

projected processing times, we selected and visited 9 of INS’ 33 district

offices and 2 of its 4 service centers. On the basis of our analyses of the

production data provided by INS, we selected five of the relatively more

productive district offices—Dallas, TX; El Paso, TX; Houston, TX; Omaha,

NE; and Seattle, WA—and four of the relatively less productive district

Page 26 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I 

Objectives, Scope, and Methodology

offices—Baltimore, MD; Buffalo, NY; Kansas City, MO; and Los Angeles,

CA—to visit. In addition, as part of our selection criteria, we factored in

the relative volume of applications received and applications’ projected

processing times. The service centers we visited were the California

Service Center (Laguna Niguel, CA) and the Texas Service Center (Irving,

TX). These two service centers were chosen primarily on the basis of their

proximity to the selected district offices we visited.

At each field unit, we gathered data on how production and processing

time data were collected and what checks were in place to ensure the

data’s accuracy. Generally, we met with Assistant District Directors for

Examinations and Service Center Directors, except when they suggested

that we meet with someone else on their staff. We discussed the unique

characteristics of the various field units we visited and what role these

characteristics may have played in affecting production rates and the

timeliness of adjudications. Finally, we discussed the policies and

procedures used by the field units we visited. Their comments are not

generalizable to other field units.

INS processes asylum applications at eight offices nationwide. Because

they are not processed at the district offices and service centers, we

excluded these applications from our review.

In the report, we present average processing and timeliness data for the

25-month period. This was done for presentation purposes. Our analyses

were done for each application type, by unit, and by month. We did the

analyses by month because using averages over 25 months could hide

differences. We performed our work between March 1996 and April 1997

in accordance with generally accepted government auditing standards.

Page 27 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix II 

INS Field Units’ Average Production Rates

and Average Completions by Application

Type for the 25-Month Period Ending June

1996

Table II.1: INS District Office Average

Per Hour Production Rates and

Average Monthly Completions by

Application Type for the 25-Month

Period Ending June 1996

District office I-765 rate

I-765

completions N-400 rate

Anchorage, AK 2.74 20 0.57

Atlanta, GA 4.55 587 0.84

Baltimore, MD 0.76 96 1.09

Boston, MA 4.39 1,358 0.73

Buffalo, NY 2.10 260 0.56

Chicago, IL 3.81 1,541 0.74

Cleveland, OH 1.95 338 0.94

Dallas, TX 3.09 634 0.97

Denver, CO 2.22 351 0.86

Detroit, MI 1.51 289 0.94

El Paso, TX 3.06 337 1.83

Harlingen, TX 3.00 310 0.66

Helena, MT 1.43 67 0.40

Honolulu, HI 1.99 261 0.45

Houston, TX 2.78c 437 1.18

Kansas City, MO 1.96 326 0.82

Los Angeles, CA 2.04 896 1.12

Miami, FL 2.29 4,174 0.88

New Orleans, LA 2.04 354 0.65

New York, NY 2.59 4,385 0.74

Newark, NJ 1.81 1,143 1.59

Omaha, NE 3.23 289 1.10

Philadelphia, PA 2.51 447 0.65

Phoenix, AZ 3.77 740 0.60

Portland, ME 1.34 43 0.35

Portland, OR 1.89 277 0.93

San Antonio, TX 3.24 556 0.78

San Diego, CA 2.06 713 0.74

San Francisco, CA 2.63 2,832 0.57

San Juan, PR 1.80 238 0.37

Seattle, WA 3.78 501 1.34

St. Paul, MN 4.11 294 0.53

Washington, D.C. 3.14 911 0.79

Page 28 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix II 

INS Field Units’ Average Production Rates

and Average Completions by Application

Type for the 25-Month Period Ending June

1996

N-400

completions I-130 rate

I-130

completions I-90 rate

I-90

completions I-485 rate

I-485

completions

Other

forms’ rate a

Other forms’

completions a

85 0.88 26 0.31 b 0.41 36 0.07 3

1,212 0.91 336 1.79 33 0.64 772 0.07 42

1,384 0.32 216 0.28 1 0.37 468 0.05 40

2,086 0.68 517 0.74 7 0.73 1,010 0.04 45

415 1.13 556 0.17 7 0.41 192 0.15 201

3,200 0.74 537 0.24 1 0.74 1,304 0.07 51

537 0.59 158 0.71 9 0.71 320 0.07 23

1,153 0.93 249 1.56 8 1.03 894 0.04 17

565 1.05 210 0.04 1 0.88 506 0.04 15

721 0.54 152 2.17 132 0.79 398 0.02 16

1,277 1.26 79 0.48 2 1.28 341 1.11 1,563

442 0.69 70 0.42 173 0.47 152 0.46 503

67 0.60 140 0.37 2 0.41 72 0.05 29

532 0.83 305 2.04 45 0.32 247 0.08 52

1,383 1.10 186 2.88 31 0.62 630 0.08 31

416 0.37 118 0.10 1 0.49 226 0.04 15

13,750 0.55 966 2.19 2 0.51 2,628 0.05 194

5,048 0.83 1,060 0.25 27 0.47 2,331 0.03 60

631 0.68 170 0.90 39 0.50 375 0.04 21

9,575 0.47 1,390 0.26 4 0.59 3,239 0.11 395

3,086 1.03 429 0.79 40 0.64 1,562 0.04 34

184 0.99 74 3.94 75 1.06 138 0.02 2

869 0.79 283 1.27 4 0.52 518 0.09 30

928 0.71 192 1.51 665 0.47 524 0.39 751

113 0.43 38 0.10 3 0.43 50 0.01 5

349 1.14 108 1.50 b 0.82 236 0.06 9

807 0.65 179 0.74 203 0.84 473 0.63 670

1,495 0.68 101 1.31 356 0.65 343 0.66 1,510

5,730 0.71 740 0.86 167 0.52 1,836 0.03 48

321 0.90 187 0.12 2 0.58 237 0.07 21

1,171 0.79 259 0.42 29 0.85 537 0.06 64

419 1.03 631 0.41 11 0.50 254 0.04 16

1,360 0.74 337 1.48 30 0.50 713 0.14 69

Page 29 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix II 

INS Field Units’ Average Production Rates

and Average Completions by Application

Type for the 25-Month Period Ending June

1996

aThe other application types (“other forms”) represented a small volume of applications, and

therefore we did not analyze them separately or as a group.

bLess than one completion per month on average.

cThe Houston data for March 1996 seemed to contain an error (547 completions per hour). Rather

than attempt to determine the actual number of completions and productive hours for March, we

eliminated the March data. If we had included the March data, Houston’s average production rate

would have been 24.59 completions per hour.

Source: GAO analysis of INS data.

Table II.2: INS Service Center Average Per Hour Production Rates and Average Monthly Completions by Application Type

for the 25-Month Period Ending June 1996

Service center I-765 rate

I-765

completions I-130 rate

I-130

completions I-90 rate

I-90

completions

Other

forms’ ratea

Other forms’

completionsa

California 4.28 15,434 4.20 14,357 5.31 16,009 0.22 1,356

Nebraska 4.02 5,125 2.85 6,349 4.09 5,708 0.41 3,453

Texas 5.79 12,842 4.14 11,218 6.69 10,394 0.72 2,090

Vermont 3.11 14,238 3.07 13,905 3.17 10,697 0.28 2,028

Note: The other application types (“other forms”) represented a small volume of applications, and

therefore we did not analyze them separately or as a group. Generally, the service centers do not

process the N-400 and I-485. The N-400 and I-485 are not included with the other forms.

Source: GAO analysis of INS data.

Page 30 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix III 

Comments From the Commissioner,

Immigration and Naturalization Service

Note: GAO comments

supplementing those in the

report text appear at the

end of this appendix.

See comment 1

Page 31 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix III 

Comments From the Commissioner,

Immigration and Naturalization Service

Page 32 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix III 

Comments From the Commissioner,

Immigration and Naturalization Service

The following are GAO’s comments on the Immigration and Naturalization

Service’s April 22, 1997, letter.

GAO’s Comments 1. INS said that the overall results of our work alluded to problems related

to data. It pointed out that we gathered information on how production

and processing time data were collected and what checks were in place to

ensure data accuracy but added that we provided little information to help

INS understand the problem. To identify what INS believed were the

potential causes for the differences in production rates and processing

times, we asked field unit officials among other things about any steps that

they may have taken regarding the checks that are performed to ensure

the quality and accuracy of data. They pointed out that they had concerns

that other field units may not have accurately reported their production

data, but many of the officials told us they reviewed their unit’s data. We

agree that we did not perform any detailed analysis regarding data

accuracy.

Page 33 GAO/GGD-97-47 INS Processing of Alien Applications
Appendix IV 

Major Contributors to This Report

General Government

Division, Washington,

D.C.

James M. Blume, Assistant Director, Administration of Justice Issues

David P. Alexander, Senior Social Science Analyst

James A. Bell, Assistant Director

James M. Fields, Senior Social Science Analyst

Joanne M. Parker, Senior Social Science Analyst

Bonita J. Vines, Computer Specialist

Michelle D. Wiggins, Issue Area Assistant

Dallas Field Office Christopher H. Conrad, Evaluator-in-Charge

Frederick T. Lyles, Jr., Evaluator

Office of the General

Counsel, Washington,

D.C.

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