Department of Homeland Security
 

U.S. Citizenship and Immigration 


Services’ Progress in Transformation 


OIG-12-12 November 2011
 
 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528

 November 23, 2011 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

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

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the Department. 

This report addresses the strengths and weaknesses of the U.S. Citizenship and 

Immigration Services’ Office of Transformation Coordination and Office of Information 

Technology. It is based on interviews with employees and officials of relevant agencies 

and institutions, direct observations, and a review of applicable documents. 

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

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

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

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

Assistant Inspector General 

Information Technology Audits 

Frank Deffer 
Executive Summary.............................................................................................................1
 

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

Results of Audit ...................................................................................................................6
 

Progress Made, But Transformation Implementation Delayed...................................... 6
 

Other Factors Limit Transformation Progress ............................................................. 10
 

USCIS Has Taken Steps To Address Challenges ........................................................ 13
 

Recommendations........................................................................................................ 15
 

Management Comments and OIG Analysis................................................................. 15
 

Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................17
 

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

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

Appendix D: Report Distribution ..............................................................................23
 

Table of Contents/Abbreviations 

Abbreviations 

CIO Chief Information Officer 

CLAIMS Computer Linked Application Information Management System 

DHS Department of Homeland Security 

FY Fiscal Year 

IT information technology 

OIG Office of Inspector General 

OIT Office of Information Technology 

OTC Office of Transformation Coordination 

PIPT Program Integrated Product Team 

TLT Transformation Leadership Team 

USCIS United States Citizenship and Immigration Services 

WIPT Working Integrated Product Team 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

In 2005, the United States Citizenship and Immigration Services 

(USCIS) embarked on an enterprise-wide program to transform its 

fragmented, paper-based business processes to a flexible and 

efficient process supported by an integrated technical environment. 

In July 2009, we reported that USCIS established a structure to 

manage transformation initiatives and implemented pilot programs; 

however, pilot success was restricted by ineffective planning, 

business process reengineering efforts were incomplete, and 

stakeholder participation levels fluctuated. We recommended that 

USCIS communicate an updated transformation approach, include 

stakeholder participation in defining requirements, and assess pilot 

program results. 

We conducted a follow-up audit to determine USCIS’ progress in 

implementing its business and information technology 

transformation. Since our 2009 report, USCIS has completed a 

number of activities to prepare for its first transformation 

deployment and improved its coordination and communication 

with stakeholders. However, implementation of the transformation 

program has been delayed because of changes in the deployment 

strategy and insufficiently defined system requirements. Other 

challenges, such as governance and staffing problems, further 

delayed the program. As a result, USCIS continues to rely on 

paper-based processes to support its mission, which makes it 

difficult for USCIS to process immigration benefits efficiently, 

combat identity fraud, and provide other government agencies with 

the information required to identify criminals and possible 

terrorists quickly. 

USCIS has taken steps to address these challenges by moving to a 

more agile transformation approach, improving its program 

monitoring and governance, and focusing on staffing issues. We 

recommend that USCIS ensure that process documentation 

provides sufficient detail, develop and implement a governance 

structure to enable streamlined decision making, and ensure that 

staff with the necessary skills are in place. 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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Background 

The USCIS mission is to secure America’s promise as a nation of 

immigrants by providing accurate and useful information to its 

customers, granting immigration and citizenship benefits, 

promoting an awareness and understanding of citizenship, and 

ensuring the integrity of the immigration system. To accomplish 

its mission, USCIS has more than 18,000 government employees 

and contractors working at 250 offices worldwide. USCIS 

provides its services through a structure that consists of its 

headquarters office in Washington, D.C., four service centers, 33 

district offices, 133 application support centers, three regional 

offices, three overseas district offices, eight asylum offices, six 

telephone centers, the National Records Center, and the National 

Benefits Center. USCIS receives approximately 6 million 

immigration applications and petitions for legal review and 

adjudication each year. On any given day, USCIS’ federal and 

contract employees process 30,000 applications for immigration 

benefits, issue 6,000 permanent resident cards, adjudicate 200 

refugee applications and 230 asylum applications, and naturalize 

3,000 new citizens. 

USCIS provides nearly all of its services using paper forms. 

Customers submit paper application forms that USCIS staff sort, 

check for errors, electronically scan into images or copy, and 

manually verify and enter the data into several systems, one of 

which is the Computer Linked Application Information 

Management System (CLAIMS), for processing. Through 

CLAIMS, USCIS provides automated support to process 

applications, determine the status of pending applications, and 

track fees collected. Other paper documents used to verify a 

customer’s identity, such as birth certificates and drivers’ licenses, 

are collected, electronically scanned into images or copied, filed, 

and manually correlated to the number assigned to each 

application. 

USCIS adjudications officers determine whether an applicant is 

eligible for benefits by reviewing the paper documentation 

submitted, performing background checks, and in some cases 

interviewing and obtaining biometric information from the 

applicant. USCIS staff use automated and manual methods to 

conduct background checks on applicants through systems such as 

the Interagency Border Information System, which is managed by 

U.S. Customs and Border Protection. To schedule appointments 

for interviews and to collect biometric information, USCIS staff 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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use the Scheduling Notification for Applicant Processing System, a 

fingerprint scheduling program that extracts information from 

CLAIMS. Customers use the InfoPass scheduling system on the 

USCIS website or mail in forms to schedule appointments with 

local information officers. 

USCIS issues paper evidence of benefits, such as permanent 

resident cards, and stores the information about the status of 

applicants both electronically and in applicants’ paper files. 

Document production of benefits has mostly been centralized 

through the Integrated Card Production System. USCIS maintains 

a paper set of documents on individuals to document their 

immigration status and citizenship. USCIS staff can locate these 

records through the National File Tracking System. In addition, 

the Central Index System, a department-wide index, maintains 

immigrant and non-immigrant status information on individuals, 

and tracks the location of applicants’ paper files. 

USCIS’ paper-based processes require that USCIS obtain, ship, 

process, and store a significant number of documents. The annual 

cost of shipping, storing, and handling these paper files is 

approximately $314 million. The volume of documents stored is 

illustrated in figure 1, a photograph of the file room in USCIS’ 

National Benefits Center, just one location where documents are 

stored. 

Figure 1: National Benefits Center File Room 

Recognizing that dependence on paper files makes it difficult to 

process immigration benefits efficiently, USCIS embarked on an 

enterprise-wide transformation program in 2005 to transition the 

agency from a fragmented, paper-based operational environment to 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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Increment Line of Business Functions Timeframe 

One Citizenship Fiscal Year (FY) 

Naturalization, Military Naturalization, and 

International Adoptions 2009 

Two Immigrant FY 2010 – 

Permanent Residence FY 2011 

Three Humanitarian FY 2012 

Refugee, Asylum, Parole, Temporary 

Protected Status 

Four Non-Immigrant FY 2013 

Non-immigrant Workers 

Figure 2: Transformation Implementation Timeframes, March 2008 

a centralized and consolidated account-based environment using 

electronic adjudication. USCIS’ strategy involved digitizing 

applicant filings, either by scanning in the hard copy documents 

received or by providing electronic filing capability; obtaining 

modern case management software to enable electronic 

adjudication of all cases; and modernizing the USCIS website and 

its supporting information technology (IT) to provide useful web 

services for its customers. 

In 2007, USCIS developed a multi-year strategy for deploying the 

capabilities needed to achieve its transformation goals. The 

strategy called for creating and implementing new business 

processes and IT systems incrementally over a 6-year period. 

USCIS planned to implement the reengineered business processes 

in four increments that correlated with USCIS’ major lines of 

business: (1) Citizenship, (2) Immigrant, (3) Humanitarian, and 

(4) Non-Immigrant. Figure 2 shows the transformation phases and 

their implementation timeframes as of March 2008. 

USCIS’ Office of Transformation Coordination (OTC) is 

responsible for coordinating transformation initiatives across 

USCIS, including managing and overseeing efforts to move the 

agency from a paper-based business to a more efficient electronic 

environment. OTC’s mission is to lead, manage, and facilitate a 

comprehensive transformation of people, processes, and 

technologies that will enhance national security, promote 

operational excellence, and provide superior customer service to 

those seeking immigration benefits. 

Because the transformation efforts rely on IT modernization, OTC 

and the Office of Information Technology (OIT) maintain an 

ongoing partnership to accomplish transformation goals. OIT’s 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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mission is to provide the information services, strategic vision, 

leadership, technical expertise, and capabilities necessary to enable 

USCIS to deliver effective, efficient, economical, and secure 

immigration services. OIT leads USCIS in the design, 

development, delivery, and deployment of IT services and 

solutions. Figure 3 shows OTC and OIT within the USCIS 

organization. 

Figure 3: USCIS Simplified Organization Chart 

In November 2008, USCIS awarded a contract to International 

Business Machines Corporation to serve as the solution architect. 

The contract called for the solution architect to provide services, 

including planning, requirements gathering, design, and 

development, to modernize and transform USCIS business 

processes, beginning with the Citizenship line of business. USCIS 

has obligated more than $500 million for the transformation 

program since FY 2008. 

In July 2009, we reported that USCIS had established a structure to 

manage its transformation initiatives and an approach to deploy 

new business and IT capabilities.1 The success of pilot programs 

to test the new IT capabilities, however, had been restricted by 

ineffective planning and limited implementation reviews. In 

addition, the business process reengineering efforts needed to 

support the transformation were incomplete, and stakeholder 

understanding and participation in the transformation program had 

1 U.S. Citizenship and Immigration Services' Progress in Modernizing Information Technology (OIG-09­

90), July 2009. 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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been limited. We recommended that the Acting Deputy Director, 

USCIS: 

 Develop an updated transformation approach, strategy, or 

plan to communicate end-state business processes and IT 

solutions to stakeholders. 

 Develop and implement a plan to achieve sufficient and 

consistent stakeholder participation in process 

reengineering and requirements definition activities. 

 Complete evaluations to document the results and lessons 

learned from the pilot and proof-of-concept programs. 

In response, USCIS updated its Transformation Strategic Plan, 

Concept of Operations, and Transformation Program 

Communications Plan. In addition, USCIS developed a 

Stakeholder Management Plan and completed lessons learned 

documentation. Based on USCIS’ actions, we closed these

recommendations. As part of this audit, we revisited these areas in 

assessing USCIS’ progress in implementing its transformation

program.

Results of Audit 

Progress Made, But Transformation Implementation Delayed 

USCIS has made progress toward transformation since our 2009 report. 

Specifically, USCIS has completed a number of activities to prepare for its

first IT system deployment in December 2011. In addition, USCIS has 

improved its coordination and communication with internal and external 

stakeholders. 

Although USCIS has made progress, implementation of the transformation 

has been delayed. Specifically, USCIS has extended the timeline for its 

initial deployment of electronic capabilities from 2009 to 2011 and has 

reduced the scope of the deployment. 

Progress Made 

USCIS has completed a number of IT system development 

activities to prepare for its first IT deployment in December 2011. 

USCIS has also improved the coordination between OTC and OIT, 

provided information to and obtained feedback from USCIS staff, 

and increased communication with external stakeholders. 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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Activities Completed for First IT Deployment 

USCIS has completed steps in preparation for a planned 

deployment of capabilities in December 2011. Specifically, 

USCIS has gathered requirements, created the high-level design, 

and has begun testing the first development cycle and phase of the 

first release of the new system. 

The first release will include delivering core capabilities such as 

online accounts, case management, and electronic filing for one 

benefit type. In this planned release, a customer will be able to set 

up an account, make payments, provide supporting evidence, and 

check the status of his or her application electronically. An 

adjudicator will be able to receive evidence electronically, perform 

background checks, assess risk and fraud, and issue notices and 

proof of benefit. 

At the time of our fieldwork, USCIS had completed the 

development of processes for nine forms for the Non-Immigrant 

line of business and ten forms for the Citizenship line of business. 

Further, as of May 2011, the transformation program had 

documented and reengineered more than 170 Non-Immigrant 

processes for users. In addition, USCIS had completed initial 

interface requirements documents with all federal partners with 

interfaces in the first system release. 

According to senior IT and program officials, USCIS expects to 

meet the December 2011 scheduled date for this release. 

Coordination and Communication 

USCIS has improved its coordination and communication with 

internal and external stakeholders. In June 2010, both OTC and 

OIT brought in new leaders, who have worked to improve 

coordination between the offices. OTC created and staffed the 

position of transformation IT project manager, who has made 

changes to improve coordination. For example, the manager has 

positioned OIT staff in transformation working groups. One-third 

of OIT staff now work on the transformation program in some 

capacity. Further, OIT is coordinating with OTC to ensure a 

successful transition from the legacy IT environment to the 

transformed environment. For example, to help ensure that the 

agency’s IT infrastructure is ready for transformation, OIT has 

provided additional workstations for testing and deployment sites 

and purchased sufficient software licenses. 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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In addition, USCIS has increased its outreach and engagement with 

other internal stakeholders. For example, USCIS staff who 

perform immigration processing serve as members of the 

transformation working groups and as subject matter experts to 

ensure that the requirements for the new technology reflect their 

business needs. In May and June 2010, transformation program 

staff conducted surveys, focus groups, and interviews to gather 

feedback from USCIS leaders and staff about the transformation 

program. USCIS created the Transformation Liaison Program in 

June 2010 to communicate to the agency’s workforce. In February 

and March 2011, the transformation liaisons and OTC staff 

demonstrated how customer accounts will be established and cases 

will be managed electronically. Approximately 5,000 USCIS staff 

participated in these demonstrations. The liaisons and OTC staff 

responded to feedback provided by participants at each session. 

USCIS also has increased its coordination with external 

stakeholders. USCIS holds frequent meetings with external 

stakeholders, including other federal agencies, customers, and 

other organizations. Specifically, it meets quarterly with federal 

stakeholders such as U.S. Customs and Border Protection, U.S. 

Immigration and Customs Enforcement, the Department of State, 

and the Department of Justice to develop the agreements and 

interfaces necessary to share information. USCIS conducted 

customer and advocate information sessions nationwide to 

incorporate immigration applicant feedback into the transformation 

program. Further, USCIS gathered feedback from more than 230 

other organizations, including law firms, nonprofit organizations, 

software developers, trade associations, and universities. 

Transformation Implementation Delayed 

Although USCIS has made progress, implementation of the 

transformation program has been delayed. Specifically, USCIS 

extended its timeline for its first deployment because of a change 

in its deployment strategy. In addition, the lack of sufficiently 

defined requirements prior to selecting the IT system solution led 

to a reduction in the scope of the first deployment. 

Deployment Timeline 

USCIS has extended its timeline for deploying a new IT system. 

USCIS’ March 2008 transformation plans called for deploying the 

technology to support reengineered processes for its Citizenship 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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line of business in 2009. This deployment was to include webbased account setup and customer electronic filing of 20 different 

Citizenship forms. In addition, USCIS planned to deploy the 

technology supporting the electronic completion of 21 forms for its 

Immigrant line of business by the end of FY 2011. However, 

USCIS had not deployed the new technology for either line of 

business as of May 2011. 

USCIS did not meet its original deployment goals because it 

revised its deployment strategy in December 2009. Specifically, 

USCIS reversed the order in which it planned to reengineer 

processes and implement electronic capabilities for each line of 

business, as shown in figure 4. 

Figure 4: Revised Transformation Implementation Timeframes 

USCIS initially planned to begin its transformation with the 

Citizenship line of business, which is generally the last step in the 

immigration process. USCIS’ rationale for deploying Citizenship 

first was to eliminate the need for applicants who began their 

interactions with USCIS by completing forms electronically to 

transition back to paper forms for subsequent processes. In the 

transformed environment, applicants would file Citizenship forms 

electronically, and the paper documents that they had filed during 

earlier steps in the process would be digitized. 

After beginning the transformation of the Citizenship line of 

business, transformation program leadership determined that the 

costs of digitizing the previously received paper forms for 

Citizenship applicants would be higher than originally estimated. 

Reversing the order of the deployment to begin with the NonImmigrant line of business and end with the Citizenship line of 

business would reduce the immediate costs of the transformation 

by reducing the amount of paper forms that would need to be 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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digitized. In addition, a USCIS analysis of deployment 

alternatives indicated that beginning deployment with the NonImmigrant line of business would enable USCIS to establish 

customer accounts and perform electronic adjudication earlier. 

However, the change also resulted in USCIS extending the 

timeline for its first deployment from FY 2009 to FY 2011. 

Deployment Scope 

USCIS also has reduced the scope of its initial transformation 

deployment. In March 2010, USCIS planned to deploy the first 

release of capabilities for the Non-Immigrant line of business by 

the third quarter of FY 2011. This release was to provide end-toend electronic case management for approximately 17 NonImmigrant benefit types or forms. USCIS customers filed 

approximately 2.3 million of these forms in FY 2008. As of May 

2011, the approved plan for the first Non-Immigrant release 

included delivering capabilities for one of the 17 forms, the 

Application to Extend/Change Nonimmigrant Status, by December 

2011. USCIS received approximately 191,000 of these 

applications in FY 2008. 

The reduction in scope for the first release was necessary because 

USCIS had not sufficiently defined its requirements before the IT 

system solution was selected. Based on its initial understanding of 

the processes and requirements, the solution architect concluded 

that an out-of-the-box system would provide the capabilities 

needed to enable customers to complete forms electronically and 

USCIS adjudicators to review the forms electronically. However, 

the USCIS working groups that identified system requirements did 

not limit the requirements to the constraints of the out-of-the-box 

system. USCIS envisioned that the new system would fully 

automate the entire benefits process, such as automatically 

assigning work to USCIS employees and automatically checking 

for potential criminal and fraudulent activity. In September 2010 

and again in January 2011, the solution architect informed USCIS 

that it would have to reduce the scope of the deployment to include 

the additional requirements and meet the December 2011 deadline 

for deployment. 

Other Factors Limit Transformation Progress 

Other factors have contributed to delays in USCIS realizing its 

transformation goals. Specifically, USCIS’ transformation governance 

structure, as implemented, did not promote timely and effective decision 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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making. In addition, USCIS has faced challenges in staffing its 

transformation effort. 

Governance Structure 

According to federal guidance, agencies are required to implement

IT governance structures and to ensure effective acquisition of IT 

resources.2 USCIS has appropriately established a governance 

structure for the transformation program but still faces a number of 

challenges. The structure is made up of three primary groups: the 

Transformation Leadership Team (TLT), the Program Integrated

Product Team (PIPT), and Working Integrated Product Teams 

(WIPTs).

 TLT—The TLT is comprised of USCIS executive-level

management and provides strategic direction for the 

transformation program. The USCIS director and senior 

leadership from this team meet each week to discuss 

program direction, policy decisions, investment strategy, 

program scope, and acquisition strategy. 

 PIPT—The PIPT, comprised of senior USCIS managers, 

was established by the TLT to serve as the transformation

program’s executive board. The board oversees the 

management of the program schedule, cost, and

performance; oversees the WIPTs; and reports status and

escalates issues to the TLT when not able to reach

decisions at the PIPT level. This executive board meets 

three times a week.

 WIPTs—The WIPTs work directly with the solution 

architect to define the transformed business processes and 

help design the operational aspects of the technology to

meet those needs. These teams make recommendations to 

the PIPT regarding operational, regulatory, policy, cost, 

and schedule impacts. 

Although USCIS established a transformation governance 

structure, the structure has weaknesses that have contributed to 

transformation delays. Transformation leadership told us the

governance structure was too complex and unwieldy, with too 

2 The Clinger-Cohen Act of 1996; Office of Management and Budget Circular A-130, Management of

Federal Information Resources; and Office of Management and Budget Circular A-11, Part 7, Planning,

Budgeting, Acquisition and Management of Capital Assets, provide regulations and guidance for 

investment review and capital planning activities.

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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many stakeholders and boards involved in making decisions. 

Specifically, the transformation chief, transformation program 

manager, transformation IT project manager, and the USCIS Chief 

Information Officer (CIO) expressed concerns with the length of 

time it has taken to make a decision. In addition, IT officials noted 

the volume of decisions that have been escalated to the PIPT or 

TLT levels. 

Many subject matter experts in the field, as well as headquarters 

staff, voiced similar concerns with the governance structure’s 

decision-making processes. Specifically, staff described 

frustration over program leadership’s reversal of, or revisiting, 

major program decisions. For example, program leadership 

initially decided that electronic filing would not be mandatory and 

later proposed to reverse that decision. Leadership has also 

changed its decision on which capabilities would be included in the 

first release for the Non-Immigrant line of business. After 

reviewing the transformation program, the DHS CIO concluded 

that the program had an overly complex governance structure that 

required too many formal meetings and checkpoints for review, 

consensus building, and decision making. The DHS CIO 

recommended that the agency develop a more streamlined 

governance structure to improve the decision-making process. 

Staffing Challenges 

The transformation program has also faced staffing challenges. 

OTC had 98 authorized positions as of May 2011. However, from 

July 2010 to May 2011, the number of vacancies in OTC ranged 

from 30% to 45% of its authorized positions. For example, at the 

time of our fieldwork, 6 of 15 positions were vacant in the 

increment and release management division, which is responsible 

for integration management and release delivery and deployment. 

In addition, 9 of 24 positions were vacant in the business 

integration division, which is responsible for working group 

support, strategic business analysis, and business architecture. 

Further, OTC experienced staff turnover, including the departure 

of two division directors. According to the DHS CIO, the large 

amount of internal turnover in the program’s staffing was a risk. 

After reviewing the transformation program, the DHS CIO 

concluded that USCIS did not have enough experienced program 

staff to support a more effective, agile transformation approach. 

The transformation program has had difficulty hiring staff because 

the skills required are very specific. According to OTC officials, 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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they need people with the right program management skills, 

experience, and competencies to contribute to the program 

effectively. For example, program staff told us they had difficulty 

finding people with the skills required to develop schedules and 

cost estimates and perform engineering activities. 

The solution architect has also experienced staffing shortages. The 

solution architect could not meet the schedule for a design milestone 

for the new system due to a shortage of 12 to 15 people with the 

necessary skills to staff the design team. The solution architect 

also experienced high turnover, with more than 200 personnel 

departing the project between November 2008 and March 2011. In 

addition, the solution architect had challenges filling positions to 

work on designing, building, and testing the new system. 

USCIS Has Taken Steps To Address Challenges 

USCIS has recognized its challenges and has taken steps to address them. 

Specifically, USCIS has moved to a more agile transformation approach 

and strengthened program monitoring to help identify and address problems 

that can lead to further implementation delays. USCIS has also adjusted 

its governance structure to facilitate decision making and taken steps to 

address its staffing shortages. 

Transformation Approach and Monitoring 

In response to recommendations from the DHS CIO, USCIS made 

its transformation program approach more agile. Specifically, the 

DHS CIO recommended that USCIS deploy releases incrementally 

in 6-month cycles instead of following the original plan, which 

called for fewer, larger releases. According to the DHS CIO, 

smaller releases of capabilities are beneficial because there is less 

risk to ongoing operations. The DHS CIO recommended that 

USCIS identify core functionality and begin development before 

the completion of the system design in order to identify and 

understand underlying problems more quickly. As discussed 

previously, USCIS plans to deploy core capabilities and one form 

type in the first Non-Immigrant release, and will deploy additional 

capabilities and form types in 6-month intervals thereafter. 

USCIS has also strengthened its methods for monitoring 

transformation progress. For example, transformation program 

staff developed a critical task schedule in August 2010 to ensure 

that each USCIS office is aware of planned activities and 

milestones. As of March 2011, program staff were restructuring 

the critical task schedule to align better with stakeholder 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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requirements and provide increased traceability of tasks. In 

addition, transformation program management had improved 

coordination with the solution architect. For example, USCIS 

employees have been embedded in teams with the solution 

architect, which has increased the visibility of potential problems. 

In February 2011, USCIS began requiring the solution architect to 

report any newly identified risks immediately. Further, OTC holds 

daily “escalation” meetings at which the solution architect 

identifies and discusses threats to meeting the program schedule. 

The OTC Chief said that this process has allowed potential 

problems to be addressed as they arise. 

Governance 

USCIS has taken steps to improve transformation decision making. 

For example, in February 2011, transformation program 

management determined that the current decision structure did not 

enable rapid and timely support for design, development, and 

testing decisions for the IT system release, and proposed the 

addition of internal decision-making bodies. To facilitate rapid 

decision making, USCIS created a release integration team and a 

design and construction support team. The release integration 

team manages and makes decisions for the design and construction 

of an overall release. The design and construction support team 

oversees the design and construction of release components and 

supports rapid decision making on issues that require escalation. 

Staffing Improvements 

USCIS has taken action to address staffing challenges. OTC 

developed a staffing plan to track specific responsibilities, 

occupation information, job location, and whether the position can 

be sourced from within USCIS for each of its vacancies. OTC 

monitors the status of vacancy announcements, including which 

office is responsible for the next step in the hiring and onboarding 

process for each position. Further, the OTC Chief reviews every 

resume to ensure that OTC is getting the right people. Despite 

these actions, a USCIS program official familiar with the 

program’s staffing needs said that OTC still faces difficulty in 

recruiting people with highly specialized skills, such as systems 

engineering, risk management, cost analysis, program control, and 

communication. 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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Recommendations 

We recommend that the Chief, Office of Transformation 

Coordination: 

Recommendation #1: Complete business and technology process 

documentation to provide the detail necessary to implement the 

transformation program effectively. 

Recommendation #2: Revise its current governance structure to 

enable more streamlined program decision making. 

Recommendation #3: Ensure that transformation program staff 

possess the necessary skills to implement the transformation 

program. 

Management Comments and OIG Analysis 

We obtained written comments on a draft of this report from the 

Chief of Staff, Office of the Director, USCIS. The Chief of Staff 

concurred with our recommendations and provided details on steps 

being taken to address specific findings and recommendations in 

the report. We have included a copy of the comments in their 

entirety in appendix B. 

In response to recommendation 1, the Chief of Staff stated that 

OTC is working toward the use of a modified agile development 

approach, where new functionality is released every 6 months after 

an integrated requirements/development phase. The Chief of Staff 

stated that this will require a tailored documentation approach, 

which USCIS is exploring with the DHS Office of the Chief 

Information Officer. We look forward to learning about progress 

made toward addressing this recommendation. We consider this 

recommendation to be resolved and open. 

In response to recommendation 2, the Chief of Staff stated that 

USCIS is working on restructuring its governance and decisionmaking process to accommodate the current phase of the project, 

which is focused on the development and deployment of the 

USCIS Electronic Immigration System. Additionally, the Chief of 

Staff said that working with DHS and USCIS senior leadership, 

OTC will streamline the current governance and decision-making 

processes while maintaining transparency and ensuring USCIS 

leadership is actively informed and involved. We are encouraged 

U.S. Citizenship and Immigration Services’ Progress in Transformation 

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by the steps taken to address this recommendation, and look 

forward to learning about progress made in revising the current 

governance structure. We consider this recommendation to be 

resolved and open. 

In response to recommendation 3, the Chief of Staff stated that 

OTC is using all of the recruitment and staffing tools available to 

fill its vacancies. The Chief of Staff said that OTC recently hired 

13 highly qualified individuals and was able to generate a larger 

pool of qualified candidates by including repayment of relocation 

expenses. This technique also has helped USCIS attract highly 

qualified individuals from USCIS and throughout the Department 

who can serve as subject matter experts in key areas such as 

program management, communications, and training and who also 

possess unique understanding of USCIS’ operational and business 

requirements. The Chief of Staff said that OTC has taken 

additional steps to ensure that all divisions and staff members 

possess the necessary skills in project management, scheduling, 

and contract administration, including emphasizing to employees 

that sufficient funding has been allotted to ensure that all 

appropriate training requests can be approved. 

The Chief of Staff also said that OIT has assigned highly qualified 

personnel from its existing pool of resources to support OTC, and 

is working on a staffing campaign to hire individuals with 

enterprise solution architecture, agile development, and IT project 

management skills. We recognize the progress made in this area 

since our audit, and look forward to learning more about continued 

progress. We consider this recommendation to be resolved and 

open. 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 16
 
Appendix A 

Purpose, Scope, and Methodology 

The objective of this audit was to determine USCIS’ progress in 

implementing IT modernization initiatives and addressing our prior 

recommendations. 

We researched and reviewed federal laws and executive guidance 

related to USCIS’ immigration benefits processes and systems. 

We reviewed recent Government Accountability Office and OIG 

reports to identify prior findings and recommendations. In 

addition, we searched the Internet to obtain published reports, 

documents, and news articles regarding USCIS operations and the 

transformation initiative. We evaluated documents that USCIS 

provided in November 2009, March 2010, May 2010, and October 

2010, including updated action plans and milestones, on activities 

to address our July 2009 report recommendations. Using this 

information, we designed a data collection approach, consisting of 

focused meetings and document analysis, to conduct our follow-up 

review. We developed a series of questions and discussion topics 

for our meetings. 

Subsequently, we conducted information-gathering meetings at 

USCIS headquarters and field offices and gathered supporting 

documentation to meet our audit objectives. At headquarters, we 

met with senior leaders of the transformation effort, including the 

Chief and Deputy Chief of OTC, and staff involved with the 

transformation to discuss USCIS business and IT transformation. 

We were particularly interested in transformation planning, 

business process reengineering, requirements gathering, and 

transformation program implementation activities. We collected 

numerous documents from these offices about USCIS 

accomplishments, current initiatives, and future plans for 

transformation. 

We met with the USCIS CIO and Deputy CIO to obtain updates on 

coordination with OTC, lessons learned from past pilot programs, 

and the outlook for transformation. We met with OIT personnel to 

learn about coordination in planning and implementing 

transformation, as well as about current and past transformation 

efforts and OIT involvement. To support their comments, these 

officials provided copies of transformation-related documentation. 

In addition, we met with the DHS CIO to discuss transformation 

progress and challenges. 

We conducted audit fieldwork from February to May 2011 at 

USCIS headquarters in Washington, D.C.; USCIS service centers 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 17
 
Appendix A 

Purpose, Scope, and Methodology 

in St. Albans, Vermont; Laguna Niguel, California; and Lincoln, 

Nebraska; and the National Benefits Center in Lee’s Summit, 

Missouri. In addition, we met with USCIS staff in regional offices 

in South Burlington, Vermont, and Los Angeles, California; in 

field offices with some district office representation in Los 

Angeles, California; St. Albans, Vermont; and Kansas City, 

Missouri; and at an asylum office and telephone center in Los 

Angeles, California. 

At USCIS field locations, we toured facilities, observed 

demonstrations of select business processes and systems use, and 

led information-gathering meetings with senior managers, IT 

specialists, immigration service officers, and other employees. We 

discussed recent and past activities regarding the transformation 

program, local IT development practices, and user involvement 

and communications with headquarters concerning the 

transformation. Where possible, we obtained reports and other 

materials to support the information provided during the meetings. 

We conducted this performance audit between February 2011 and 

May 2011 pursuant to the Inspector General Act of 1978, as 

amended, and according to generally accepted government 

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

upon our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

The principal OIG points of contact for this audit are Frank Deffer, 

Assistant Inspector General for Information Technology Audits, 

and Richard Harsche, Director of Information Management. 

Appendix C lists major OIG contributors to the audit. 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 18
 
Appendix B 

Management Comments to the Draft Report 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 19
 

U.s.IkpOl'lmOol ofHon,"",nd Soourlty

U.S. Cilinn$hip • ..:I Jmmii"'lion s.r.;"..

Office ofr~ Dit'c<;Ior (MS 20(0)

WashJniIon, DC 2(1529-2000

U.S. Citizenship and Immigration

Services

OCT 13 lOll

Memorandum

TO: Frank Dcffcr

Assistant Inspector General

~/C7~J. L {~5<.--' FROM: Rebecca Carson ~V~ 1-

ChiefofStaff

SUBJECT: USCIS's Progress in Transfonnation, 010-11-032 Draft Report

Recommendation #1: Complete business and technology process documentation to provide

the detail necessary to implement the tnmsformation program effectively.

USCIS's Response: USCIS concurs with this recommendation. The original Request for

Proposals (RFP) for the Solution Architect (SA) dated October 12, 2007, contained a Statement

of Objectives (SOO) instead ofa Statement ofWork (SOW). The RFP listed the results expected

by USCIS, as the SA contract did not dictate the mechanisms by which a transfonned

environment would be achieved. This approach was approved by the Department ofHomeland

Security (DHS), who manages the SA contract, and by the Office of Management and Budget

(OMB). OMB understood that USCIS had reengineered business processes and requirements that

would be transferred to the SA, an approach which distinguishes the SA from a traditional Lead

Systems Integrator (LSI). The SA was then required to engineer and implement the solution

under direct oversight ofthe Office ofTransfonnation and Coordination (OTC) (e.g. milestone

reviews, incremental acceptance ofservices and capabilities, etc.) and participate in

organilational cbange activities. The requirements for Increment Onc wcre dctailcd in a 424-

page Enterprise Segment Activity Roadmap (ESAR) dated February 29, 2008. Additionally, a

separate 291-page ESAR covering all increments and releases was fmalized on February 20,

2008. The.se requirements were provided to the SA, which in tum engineered the solution and

presented a strategy and approach to implementing the solution in accordance with the

requirements ofthe SA contract. USCIS Subject Matter Experts conducted a thorough analysis

ofthe SA's solution and detennined that, while the solution as prescnted was viable, a

resequencing ofthe software 'releases and some refinements to the functionality contained within

each ofthe software releases would Y.ield a more effective almroach to transfonning the agencxx"',,- _

business processes.
Appendix B 

Management Comments to the Draft Report 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 20
 

uscrs's Progress in Transformation, OlG-II"()32 Dnlft Report

Page 2

Cwmltly. OTC exercises lDOl'e oversight over the s~ concract than origioally envisioned by

DHS and OMB. The DHS Acquisition Directive 102 (AD-I02) issued in November of2oo8,

ftllIUires an increased level ofgovemmeut oversight and much greater involvement in

information technology decisions. After the implementation of AD-I 02, OTC, in conjunction

with the SA, produc:ed incremellilevel documents in November 2008 and updated documents.

In addition, AD-I 02 documents were updated and new ones produced fot the Project Planning

Review (PPR) in March 2010 and the Acquisition Decision Review in 2012. arc is currently

working towards Ihe use ofa modified agile development approach, where new fuDctiooality is

released every six months after an integnucd requirements/development phase. 1bis will ftllIUire

atailorul documentatioo approach, which uscrs is exploring with the DHS Office ofthe Olief

Information Officer (OCIO).

Recommendation 112: Revise its enITeDt govemtnee nructurt to tnthle mon streamlined

prognm decision making.

USCIS', Response: uscrs concurs with this recommendation. The USCIS govcrrwlCC

structure that was put in place at the onset ofthis prognun WI! appropriate and necessary to

ensure t complete and thorough vetting ofthe uscrs business processes and the validation of

detailed requimnents for the automation ofthose processes. USClS is currently working on

restnlctUring its governance and decision-making process 10 accommodate the current phase of

the project which is focused on the development and deployment ofthe USClS Elcctronie

Immigration System (EUS). Working with the DHS and USCIS senior h:adership, OTC will

sueamline the c~t governance and decision-making processes while maintaining

transpareoey and ensuring USClS leadership is actively informed and involved

Reeommendation #3: Ensure that transformation pro&ram sttff POSltUe5 the necessary

skills to Implement the transformation program.

USCIS's Response: users concurs with this reeommendation. The OTC is utilizing all ofthe

recruitment and staffing tools available to fill its vacancies. The OTC recently hired 13 highlyqualified individuals. We were able to generate a larger pool of qualified candidates by

announcing vacancies that include repayment ofrelocation expenses. This technique has proven

especiaUy successful in attracting fughly·qualified individuals from USCIS and other DHS

offices across the United States who can serve as subjeet matter experts in key areas such as

program management, oommunications, and training and who also possess unique understanding

ofUSCIS 's operational and business requirements.

OTC has taken additional steps to ensure that all divisions an(! staffmembers possess the

necessary skills in project management, scheduling, and contract administration. OTC leadership

has emphasized in all-hands meetings that every OTC employee is ell:pec!ed to take advantage of

relevant training opportunities as sufficient funding has been allolled 10 ensure lhat all

appropriate training requests can be approved. OTC is strongly encouraging staffto become

--- ---Projeet-Man.agement-Professional-fP-MP~-eertified;-and·is-funding-P-Mp..preparalion,coUl'Ses-and

testing fees.
Appendix B 

Management Comments to the Draft Report 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 21
 

USCIS's Progress in Transfonnation, OIG-ll..()32 Draft Report

Page 3

The uscrs Office oflnfonnation Tcclmology (011) has assigned highly qualified personnel

from its existingpool ofresources to support OTC. Additionally, orr is working on a staffing

campaign to hire individuals with unique qualifications such as Enterprise Solution Architecture,

Agile Development, and lnformatioo Technology (l1) Project Management skills and experience

on large-scale rr projects. orris targeting individuaLs with domain expertise in Middleware,

Application, Business Intelligence, Data Warehouse, and Service Orienwed Architectures..

These DeW hires will provide support 10 lbe USCIS EUS system as well as USCIS legacy

sysltmS to ensure the agency's business functionS are supported tIuough USCIS's rransformed

ope!8ting enviroomeru.

orr provides its stafftraining oppommiries 00 Change, Configun.tion, and Release

Management, Agile Development, Sectioo 508 Complia.nc:e, and Information Security. orr also

eocourages its staffmembers to become PMP. Certified Information Systelll5 Security

Professional (ClSSP). and ScromMasler certified.
Appendix C 

Major Contributors to this Report 

Richard Harsche, Director 

Elizabeth Argeris, Auditor-in-Charge 

Erin Dunham, Auditor 

Sheila Cuevas, Auditor 

BriElle Bryson, Program and Management Clerk 

Beverly Dale, Referencer 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 22
 
Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, Government Accountability Office/OIG Liaison Office 

USCIS, Director 

USCIS, Chief Information Officer 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Director of Local Affairs, Office of Intergovernmental Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

U.S. Citizenship and Immigration Services’ Progress in Transformation
 

Page 23
 
 

 

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