United States General Accounting Office

GAO Report to Congressional Requesters

July 1998 IMMIGRATION

STATISTICS

Guidance on Producing

Information on the U.S.

Resident Foreign-Born

GAO/GGD-98-155

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-278387 

July 22, 1998

The Honorable Stephen Horn, Chairman

The Honorable Dennis J. Kucinich,

 Ranking Minority Member

Subcommittee on Government

 Management, Information and Technology

Committee on Government Reform and Oversight

House of Representatives

The Honorable Carolyn B. Maloney

House of Representatives

The makeup of the foreign-born population residing in the United States

continues to interest policymakers as they debate immigration issues.

These policymakers have expressed concerns that the information

necessary to make informed decisions on public policy regarding

immigration either has not been available or has not been adequate.

Accordingly, you requested that we review the federal immigration

statistics function. You asked us to (1) follow up on two reports of the

National Academy of Sciences (NAS)1

 that contain recommendations

designed to streamline and strengthen the collection, analysis, and

dissemination of immigration statistics; (2) assess the quality of current

federal demographic information on the foreign-born population; and

(3) identify the federal guidance on the production of demographic

information on foreign-born residents and provide information on

agencies’ status relative to that guidance.

This report responds to the third objective of your request. Objectives 1

and 2 are addressed in separate reports.2

Specifically, this report

• identifies the federal guidance available to the agencies responsible for

collecting, analyzing, and disseminating information on the foreign-born

and

• provides information that compares the agencies to federal guidance on

(1) independence, (2) capacity to produce information, and (3) efforts to

1

NAS is a private, nonprofit society of scholars established by Congress in 1863 to advise the federal

government on scientific and technical matters.

2

Immigration Statistics: Status of the Implementation of National Academy of Sciences’

Recommendations (GAO/GGD-98-119, June 9, 1998) and a companion report that will be issued

shortly.

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coordinate the production of information, which includes statistical data

on the foreign-born.

To determine which agencies were responsible for producing the majority

of the statistics on the foreign-born, we synthesized literature reviews,

agency documents, and testimonial evidence from agency officials and

knowledgeable experts and identified the principal agencies that

generated statistical information on the foreign-born: Immigration and

Naturalization Service (INS)3

 and the U.S. Bureau of the Census.4 We then

verified our selection with officials from the Office of Management and

Budget (OMB) and from the agencies we had tentatively selected. Three

other agencies that collect specialized information on the foreign-born are

(1) the Office of Refugee Resettlement of the Department of Health and

Human Services (HHS); (2) the Immigrant Visa Control and Reporting

Division of the Department of State; and (3) the Population, Refugees, and

Migration Bureau of the Department of State.

In developing the information for this report, we interviewed—and

analyzed relevant documents provided by—officials from OMB and the two

principal agencies as well as experts in the area of federal statistical

information in general and on the foreign-born population. We also drew

upon our current and prior work on statistical information on foreign-born

residents. To identify the federal guidance affecting the production of

statistics on the foreign-born, we talked to officials from OMB, Census, and

INS and experts on immigration issues. To provide information on the two

agencies’ independence, capacity to produce statistical information, and

interagency coordination efforts, we developed indicators using applicable

criteria from current federal guidance on how statistical agencies should

operate. We examined the two agencies’ statistical activities in relation to

the indicators we derived from NAS guidance to make our comparisons

regarding the elements of independence, capacity to produce statistical

information, and interagency coordination.

We requested comments on a draft of this report from the Director of OMB,

the Attorney General, and the Secretary of Commerce. OMB and the

Attorney General provided oral comments, which we discuss near the end

of this report. The Department of Commerce had no comments on the

report. We did our work in Washington, D.C., between October 1997 and

3

Within INS, our work involved reviewing the efforts of the Statistics Branch, which produces

information on the foreign-born.

4

Within the Census Bureau, we focused on the Population Division’s efforts because Census’

information on the foreign-born is produced by staff in that division.

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July 1998 in accordance with generally accepted government auditing

standards.5

Results in Brief Standards and guidance covering the production of all federal statistical

information, including statistics on the foreign-born, have been issued by

two sources. First, governmentwide guidance has been issued by OMB,

which is legislatively charged with ensuring that agencies’ statistical

activities follow federal statistical standards. OMB’s guidance includes

uniform standards for the compilation and release of all federal statistical

data.

Second is NAS’ report, Principles and Practices for a Federal Statistical

Agency, which provides guidance to executive branch agencies on how to

compile and release statistical information and suggests practices for

achieving independence, the capacity to produce information, and

coordination.6

 According to OMB and NAS, the existing federal guidance

provides statements of best practices, which are intended as suggestions,

not prescriptions.

The Bureau of the Census and INS differed from each other in their

structure and mission, and thus their independence, capacity, and

coordination varied. For example, according to Census Population

Division officials, the Census Bureau, structured as a statistical agency

with a primary mission of collecting and disseminating statistical

information, has incorporated the elements of the NAS guidance in

generating information on the foreign-born. Specifically, Census has

procedures in place to protect its independence, it has the capacity to

produce information, and it coordinates with other statistical agencies.

In contrast, INS’ Statistics Branch, a self-described data collection and

analysis unit, has incorporated some, but not all, of the elements of

independence and many of the elements of capacity and coordination. For

example, it was not established by statute as an independent entity.

Officials said the branch has been working to improve its capacity and

coordination by hiring qualified professional staff and by coordinating its

statistical activities with other agencies that produce data on the

foreign-born.

5

App. I describes in detail the scope and methodology of our work.

6

Principles and Practices for a Federal Statistical Agency (Washington, D.C.: National Academy Press,

1992).

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Background For this report, we define the following terms:

• “Foreign-born” refers to all persons who were born abroad to parents who

were not U.S. citizens, and who now either (1) are in a permanent legal

status (naturalized citizen, legal permanent resident, refugee, person

granted asylum) or (2) are in a temporary legal status (tourists, business

people, and students) or in the United States illegally but who remain here

for over a year.

• “Independence” is derived from elements of NAS’ guidance intended to

provide an agency with freedom from influence by others in the

production of its statistical products.

• “Capacity to produce statistics” refers to elements that we derived from

NAS’ guidance that provide for a clearly defined and well-accepted mission

and commitment to quality and professional standards. This definition also

includes an ability to comply with legal and administrative responsibilities,

such as congressional reporting requirements or contractual arrangements

with other agencies.

• “Coordination” refers to elements that we derived from NAS’ guidance that

suggest cooperation with data users and coordination with other statistical

agencies.

NAS defines a federal statistical agency as a unit of the federal government

whose principal function is the compilation and analysis of data and the

dissemination of information for statistical purposes. NAS further states,

“The unit must be generally recognized as a distinct entity.”

NAS’ Committee on National Statistics is comprised of professionals in the

statistical field who have no direct relationship with the federal

government. Since its founding, the Committee on National Statistics has

concentrated on reviewing selected federal statistics. It also prepares

reports on special studies it carries out—independently or under

contract—that are intended to improve the effectiveness of the federal

statistical system.

The activities, budgets, and staffing of INS’ Statistics Branch and the

Census Bureau, as well as their principal products related to the

foreign-born, are as follows.7

INS’ Statistics Branch INS’ Statistics Branch is responsible for preparing reports on operational

and demographic statistics, monitoring the information system’s

7

App. II provides more detail.

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reliability, and advising other INS offices on sampling and other statistical

applications. Some of the branch’s reports are used for internal

programmatic purposes, and others are used by Congress, federal

agencies, and others interested in information on the foreign-born. The

branch is located within the Office of Policy and Planning, which was

created in a major INS reorganization in 1994 to reinforce Servicewide

planning and provide attention to macro-level immigration policy. The

branch’s fiscal year 1998 budget was $1.4 million, and in March 1998, the

branch had a staff of 24 full-time-equivalent positions, 22 of which were

filled. The branch is responsible for INS’ primary statistical publication, the

annual Statistical Yearbook of the Immigration and Naturalization Service.

Although the Yearbook has been published since 1892, the Immigration

Act of 1990 (P.L. 101-649, section 142, codified at 8 U.S.C. 1103(d)8

)

specified the selected reporting requirements. Also published annually are

the Commissioner’s Fact Book and Immigration Advance Reports.

Census Bureau’s

Population Division

The Population Division’s fiscal year 1998 budget was $31 million. The

division has two full-time demographers who specialize in information on

the foreign-born. These demographers, supported by other Census staff,

collect and analyze information on the foreign-born and implement an

interagency agreement with INS for providing this type of information. Two

Census Bureau products represent a source of immigration information:

(1) estimates and projections, which are published in Census’ Current

Population Reports, are based on data from INS and the decennial census

and (2) the Current Population Survey (CPS). Customers for this

information include Congress, federal agencies, state and local

governments, the private sector, the academic community, research

organizations, libraries, and individuals.

Two Sources Guide

the Production of

Federal Statistical

Information

As required by the Paperwork Reduction Act, official guidance covering

the production of all federal statistical information, including statistics on

the foreign-born, is to be issued by OMB. NAS has also issued guidance for

agencies that produce statistical information. Governmentwide statistical

guidance has been issued by OMB, in its Statistical Policy Handbook and

subsequent statistical policy directives. The other source of guidance is

NAS’ 1992 report, Principles and Practices for a Federal Statistical Agency,

which provides guidance to executive branch agencies on how to compile

and release statistical information, specifies best practices that may be

8

This report was not intended to be a comprehensive analysis of all statutes relating to statistical

information on the foreign-born. Accordingly, this report focuses on 8 U.S.C. 1103(d).

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used to achieve independence, the capacity to produce information, and

coordination with data users and other agencies. The NAS guidance has

been used by us and NAS to carry out studies of statistical agencies.9

 We

used the guidance in our current work to gather and present information

on aspects of independence, capacity, and coordination in the production

of information on the foreign-born.

OMB’s Guidance OMB’s guidance is aimed at federal statistical agencies. The need for strong

oversight and coordination of the decentralized federal statistical system

was recognized in law by the enactment of the Paperwork Reduction Act

of 1980, codified at 44 U.S.C. 3501.10 The act created the Office of

Information and Regulatory Affairs (OIRA) in OMB and assigned the Director

of OMB and the Administrator of OIRA the responsibility for overseeing the

federal statistical system and coordinating its activities. OIRA’s Statistical

Policy Branch functions include

• developing and implementing governmentwide policies, principles,

standards, and guidance concerning data sources, data collection

procedures and methods, and data dissemination and

• evaluating statistical program performance and agency compliance with

governmentwide policies, principles, standards, and guidance.

OMB established governmentwide uniform statistical standards and

guidance for the collection and compilation of statistical data and for the

release and publication of federal statistics. According to OMB, the

standards and guidance are intended to result in several benefits, including

greater efficiency in the design and conduct of statistical surveys,

reduction in reporting burdens on respondents, greater uniformity and

comparability among statistical series and studies, and improved accuracy

and timeliness of statistical data. OMB also encourages the use of NAS’

Committee on National Statistics as an independent adviser and reviewer

of federal statistical activities.

NAS’ Guidance NAS’ Committee on National Statistics developed guidance that it believes

comprises “fundamental characteristics that define a statistical agency and

its operations.” The guidance is contained in NAS’ 1992 report, which the

9

Statistical Agencies: Adherence to Guidelines and Coordination of Budgets (GAO/GGD-95-65, Aug. 9,

1995) and The Bureau of Transportation Statistics: Priorities for the Future (Washington, D.C.:

National Academy Press, 1997).

10In addition, the Budget and Accounting Procedures Act of 1950 and the Paperwork Reduction Act of

1995 granted OMB general statutory responsibility for developing statistical standards and definitions.

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committee prepared partially in response to requests from congressional

and executive branch officials for advice on what constituted an effective

federal statistical agency. The committee also prepared the report because

it was concerned that federal statistical agencies sometimes might not

meet what it considered to be acceptable professional standards.

According to NAS, the guidance contains principles and practices,

consistent with current laws and statistical theory, that are statements of

“best practices,” rather than legal requirements or scientific rules. In its

report, NAS also provided guidance that it considered important for the

proper functioning of a statistical agency.11 This guidance includes a

strong measure of independence, the capacity to produce statistics, and

coordination with statistical agencies and data users.

Independence The guidance included suggestions for ensuring that a statistical agency

have a strong measure of independence, noting that the circumstances of

different agencies may govern the exact form that independence takes and

that not all aspects of independence are required.

Specifically, the agency should

• be generally recognized as a distinct entity that may be located within a

cabinet department or an independent agency;

• have independence mandated in organic legislation or encouraged by

organizational structure;

• be headed by a presidential appointee for a specific term not coincident

with that of the administration;

• be distinct from the enforcement and policy-making activities carried out

by the department in which it is located;

• have broad authority over the scope, content, and frequency of data

collected, compiled, or published;

• have primary authority over the selection and promotion of its

professional staff; and

• be recognized by policy officials outside the unit for its authority to

release statistical information without prior clearance.

The NAS guidance discusses the importance of each of the above elements

of independence. For example, the guidance suggests that “A statistical

agency must be in a position to provide credible information that may be

used to evaluate the program and policies of its own department or the

11According to NAS, “Although focused on federal statistical agencies, many of the principles and

practices presented [in its report] also apply to statistical activities elsewhere.”

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government as a whole. The basic independence of a statistical agency is

essential.”

Although recognizing that some limitations on independence are common,

the guidance further says, “. . . the effectiveness of an agency depends on

its maintaining a reputation for impartiality; thus, an agency must be

continually alert to possible infringements on its credibility and be

prepared to argue strenuously against such infringements.” NAS also

suggests that the independence of the unit head be understood and that

the unit head be recognized as professionally qualified and have direct

access to the secretary of the department in which the unit is located.

The guidance cites as an example the independence of agencies such as

the Census Bureau, where the head of the agency is appointed by the

president and confirmed by the Senate. The guidance suggests that the

unit head and qualified unit staff be able to speak on the unit’s statistical

program before Congress. The guidance also suggests that a clear

distinction be made between the statistical information the unit releases

and the policy interpretations of such statements by the secretary of the

department, the president, or others. This suggestion reflects practices

long followed by many of the principal statistical agencies.

Capacity The NAS guidance also included the suggestions that a statistical agency

have a commitment to professional standards and to a clearly defined and

well-accepted mission, which we consider to be components of a capacity

to produce statistics.

Specifically, the agency should

• have a clearly defined and well-accepted mission;12

• develop strong staff expertise in the disciplines relevant to its mission as

well as in the theory and practice of statistics;

• develop an understanding of the validity and accuracy of its data and

convey the resulting measures of uncertainty to users;

• use modern statistical theory and sound statistical practice in all technical

work; and

• follow accepted standards in reports and other releases of data on

definitions, documentation, descriptions of data collection methodology,

measures of uncertainty, and discussions of possible sources of error.

12We interpret this element as also having the ability to comply with legal or administrative

requirements.

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According to the NAS guidance, “The best guarantee of high-quality results

is a strong professional staff . . . . Managers . . . should charge

professionals with responsibility and authority for developing and

promulgating statistical standards.” The guidance further says

“An effective statistical agency keeps up to date on developments in statistical theory or

practice that might be relevant to its program. It must also be alert to changes in the

economy or in society that may call for changes in the concepts or methods used in

particular data sets.”

Closely related to a discussion of an agency’s capacity to produce data is

NAS’ suggestion that an agency have a clearly defined and well-accepted

mission. In its guidance, NAS explains that some agencies’ missions are

spelled out in legislation, while other agencies lack a specified mission and

instead have only general legislative authority. The guidance further

explains that, occasionally, specific requirements may be set in legislation,

and when this is the case, NAS’ guidance suggests that meeting these

legislative requirements is a measure of an agency’s capacity to produce

statistics. Further, the guidance suggests that a statistical agency recruit

and retain a professional staff of statisticians and analysts in fields

relevant to the unit’s mission and develop relationships with appropriate

professional statistical organizations to review the agency’s statistical

program, priorities, methods, and data products.

Coordination In addition, the NAS guidance included the suggestions that a statistical

agency coordinate with other statistical agencies and cooperate with data

users. Specifically, the agency should

• coordinate with other statistical agencies;

• seek advice on data concepts, methods, and products;

• seek advice on its statistical programs, priorities, and methodologies;

• meet access and confidentiality needs; and

• make data accessible to all potential users.

The guidance also suggests working with interagency committees and

engaging “wholeheartedly in coordinating activities.” The guidance

provides that

“Statistical agencies do not conduct their activities in isolation. They must be alert not only

to exterior needs for their data, but also to potential exterior sources of data and of

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improved methods. An effective statistical agency will also be alert to occasions in which it

can provide technical assistance to others.”

The guidance further suggests the use of “joint arrangements”—one

agency contracting with another to conduct a survey, compile special

tabulations, or develop models. The NAS guidance calling for cooperation

with data users is closely related to the guidance on coordination because

of the interagency dependence on one another’s data on the foreign-born.

Independence,

Capacity, and

Coordination of

Statistical Efforts

Varied

According to agency officials and experts with whom we spoke, the two

agencies’ independence, capacity to produce information, and

coordination with statistical agencies and data users varied depending on

the nature of the agency—its mission, structure, and output—and whether

it was considered to be a statistical agency. OMB has identified and

categorized the federal agencies that produce statistical information.13

According to OMB’s characterization, the Census Bureau is the largest of

the 10 “principal” statistical agencies whose sole mission is to collect and

disseminate statistical information. INS’ Statistics Branch is part of a

grouping of about 60 agencies that are not considered to be principal

statistical agencies.

The Census Bureau’s organizational structure was established by statute.

Further, the Bureau’s director is appointed by the president and confirmed

by the Senate. The Census Bureau’s adherence to the NAS guidance was

documented in our 1995 report on statistical agencies.14 In that report, we

said Census is well-recognized as the largest multipurpose agency in the

federal statistical system. In contrast, INS’ Statistics Branch is a

self-described data compilation and analysis unit that primarily provides

program support for INS operations.15 The Statistics Branch was not

established by statute as an independent entity, and it is headed by a

career civil servant. The branch is working to develop the capacity of its

demographic statistics section in order to provide for more policy-related

information, and it is continuing to coordinate with other agencies that

13OMB’s annual report, Statistical Programs of the United States Government, lists about 70 units, each

of which spends over $500,000 annually on statistical activities. Ten of these are recognized by OMB as

“principal statistical agencies” because they collect, analyze, and produce statistics as their primary

mission.

14GAO/GGD-95-65, Aug. 9, 1995.

15Although INS tried to establish a Bureau of Immigration Statistics in its fiscal year 1996 budget, the

request for 10 additional positions and $10 million for salaries and expenses was eliminated in

committee without comment.

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develop information on the foreign-born, as discussed in the following

sections.

Three other organizations produce statistical information on the

foreign-born, but they are primarily program support units that produce

specialized statistical information (e.g., numbers of refugees and visa

applications) for the agencies in which they are located. These three

organizations—HHS’ Office of Refugee Resettlement and State’s Immigrant

Visa Control and Reporting Division and State’s Population, Refugees, and

Migration Bureau—are not considered to be statistical agencies.

Independence Although INS’ Statistics Branch does exhibit some elements of

independence—it has authority over the scope of the data it collects,

authority over its staff, and tries to maintain a distinction between its data

and the policy interpretation by others—it is not independent as NAS

defines the term. The branch was not established by statute as a separate

entity, is headed by a career civil servant, cannot release data without

approval from its Office of Policy and Planning, and has no predetermined

schedules for releasing data. Further, the branch’s chief has not served as

a witness at congressional hearings.

In contrast, Census’ legislative mandates and organizational placement

within the Department of Commerce afford the bureau a higher degree of

independence.16 Census is organizationally distinct from its department’s

enforcement and policy-making activities. Census’ director is appointed by

the president and confirmed by the Senate.

Congress is a major user of the statistics produced by the Census Bureau.

The director testifies before congressional committees about the results of

statistical activities and to outline the agency’s budget requests. The

director also appears regularly at user conferences, which have been

attended by Members of Congress and congressional staff, to discuss

aspects of statistical programs.

As the NAS guidance on independence indicates, one of the ways in which a

federal statistical agency can guard against the perception of political

interference is by carefully controlling the release of important statistical

data. As an example, the release of economic statistical data produced by

Census is governed by OMB Statistical Policy Directive No. 3, which

16As noted by NAS, most statistical agencies have broad authority over their programs, but that

authority can be limited by budgetary constraints, departmental interests, OMB review, and

congressional mandates.

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provides guidance to federal statistical agencies on the compilation,

release, and evaluation of principal federal economic indicators. The

directive establishes the authority of affected agencies to release

economic statistical information without prior clearance or policy

interpretations. Procedures established by this directive were designed to

ensure that key economic data that are the basis for government and

private sector actions and plans are released promptly and on a regular

schedule, that no one benefits from “inside” access to the data before they

are available to the public, and that the public has confidence in the

integrity of the data. Also, the directive does not limit the authority of the

agencies over the scope, content, and frequency of economic data

collected, compiled, or published.

Another important element of independence, according to NAS, is

adherence to predetermined schedules in public release of important data,

an element intended to prevent manipulation of release dates for political

purposes. INS officials said they are working on developing such

predetermined schedules. Census follows procedures outlined in OMB’s

guidance for developing approaches to releasing information. For

example, Census develops release schedules annually and provides them

to OMB, and the schedules are available on the Internet.

Capacity Regarding the capacity of INS’ Statistics Branch to produce statistical

information, INS officials said the branch meets aspects of the NAS

guidance, such as strong staff expertise, a relationship within the

profession (e.g., membership in professional organizations), and accepted

standards in reports and data releases. From our interviews with branch

statisticians, it appears that the branch has made progress in increasing its

capacity in recent years. Experts on immigration statistics also credit the

branch for making improvements in its capacity to produce statistical

information. However, as mentioned earlier, NAS guidance suggests that

when specific requirements for statistical information are called for in law,

meeting these requirements is a measure of an agency’s capacity to

produce statistics.

INS’ capacity is limited because it does not report on all of the data

elements called for in 8 U.S.C. 1103(d). The act requires the Commissioner

of INS to “provide for a system for collection and dissemination, to

Congress and the public, of information . . . useful in evaluating the social,

economic, environmental, and demographic impact of immigration laws.”

The law also specifies that the information system provide for the

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collection and dissemination of information not less often than annually.17

Table 1 lists the data elements and identifies those that INS officials said

have and have not been reported annually.

Table 1: INS’ Annual Reporting

Requirements Under 8 U.S.C. 1103(d) Does INS report?

Data element Yes No

The alien population in the United States X

Rates of naturalization of resident aliens X

Rates of emigration of resident aliens X

Aliens who have been

Admitted X

Paroled X

Granted asylum X

Nonimmigrants in the United States, information on their

Occupation X

Basis for admission X

Duration of stay X

Aliens who have not been admitted to the United States X

Aliens who have been removed from the United States X

The number of applications filed for cancellation of removal X

The number of applications granted for cancellation of removal X

The number of aliens estimated to be present unlawfully in the

United States in each fiscal year

Xa

Applications for naturalization, number and rate of

administratively denied by

INS district office X

National origin X

Total 9 7

aThis data element is revised periodically. It was reported for three points in time—October 1988,

October 1992, and October 1996.

Source: INS officials.

As previously noted, the ability to comply with legislative mandates is part

of the mission requirements for a statistical organization and relates to the

organization’s capacity to produce statistical information. However, INS

has provided reasons—which we did not analyze—for not complying with

some of the requirements. For example, officials said the agency does not

report the alien population of the United States because the term “alien

17INS is also responsible for providing information under other laws requiring data on the foreign-born,

as discussed in a companion report on immigration statistics to be issued shortly.

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population” is not clear. They explained that INS has internal estimates of

foreign-born entrants and the legal resident population. Other elements,

such as rates of emigration of resident aliens, are difficult to develop, the

officials said. Another rationale for not complying with the 1990 law was

contained in INS’ 1996 and 1998 budget submissions, which said, “. . . INS

will be unable to meet its reporting mandates as stipulated in the

[law] . . .” unless the agency’s funding is increased.

INS, as well as other organizations and experts, has recognized concerns

about the quality of immigration statistics. In 1985 and 1996, NAS issued

reports that recommended improvements in the quality of immigration

statistics. INS has started implementing over half of the recommendations

directed to it. In our report responding to the first objective of your

request, we provided the implementation status of these

recommendations.18 Of eight major recommendations directed to INS, five

were substantially or partially implemented. Further, we assessed the

quality of current federal demographic information on the foreign-born

population, which is discussed in a separate report to be issued shortly.

Although INS’ Statistical Branch officials said they are improving their

unit’s commitment to quality and professional standards, they recognized

that they could make further improvements, including

• undertaking ongoing quality assurance programs to improve (1) data

validity and reliability and (2) the processes of gathering, compiling,

editing, and analyzing data; and

• publishing statistical standards for modern statistical theory and sound

statistical practice to guide the technical work of professionals in the

agency as well as external users.

Further, as noted on page 10 of our June 1998 report, NAS recommended

that INS increase its capacity, saying

“INS should establish an advisory committee composed of experts in the use and production

of immigration-related data, to advise the associate commissioner and the proposed

Division of Immigration Statistics of needs for new or different types of data; to review

existing data and data collection methodology; and to provide the Service with independent

evaluation of its statistical products, plans, and performance.”

18GAO/GGD-98-119, June 9, 1998. 

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In that report, we noted that

“the Statistics Branch does not have a standing advisory committee but has brought in

advisers several times to review existing data systems and to comment on current products

. . . . Groups of outside experts have also provided comments on current methodologies,

such as the estimates of the illegal immigrant population. INS plans to continue to use

outside experts on an ad hoc basis rather than through a standing committee [which it

believes] will better address the variety of data specialties and methodologies used to make

estimates.”

INS considers that it has partially implemented this recommendation. We

reported that, “[i]n our opinion, using advisers on an ad hoc basis is not a

substitute for a standing advisory committee.”

In its operations, the Census Bureau incorporated more of the guidance’s

elements of capacity than INS did. Census has authority over the scope,

content, and frequency of data collection, compilation, or publication.

However, this authority is limited by budgetary constraints and federal

laws, such as those intended to reduce paperwork burdens on businesses

and individuals. The Census Director also has primary authority for

selection and promotion of professional staff. In addition, as discussed in

the following section, Population Division officials said that in fiscal years

1996 and 1997, they carried out Census’ contractual obligations to INS

regarding the provision of information on the foreign-born. However, as

we note in our forthcoming report on data quality, questions have been

raised regarding the quality of this information. In that report, we note that

Census said it has no current plans or initiatives to improve its data on the

foreign-born because its budget and mission do not support such work.

Coordination INS officials told us that their primary coordination mechanism is through

the INS-sponsored Federal Interagency Working Group on Immigration

Statistics. This group’s quarterly meetings were initiated in 1991 in

response to several evaluations of immigration data needs—including one

by NAS19—that concluded that the knowledge base in this area was

deficient in providing the data needed to support agency operations and to

serve in formulating and evaluating immigration policy. The meetings were

also initiated as a response to the provisions of the Immigration Act of

1990, which required that the Commissioner of INS provide for a statistical

information system useful in evaluating the impact of immigration laws.

19Immigration Statistics: A Story of Neglect (Washington, D.C.: National Academy Press, 1985).

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B-278387 

The interagency working group has been attended by researchers and

statisticians from other statistical agencies, NAS, the Commission on

Immigration Reform, legislative branch offices, and others interested in

immigration issues. This group identified the need for “country of birth” to

be added to the monthly CPS, and as a result, beginning in 1994, several of

the working group agencies provided funds to Census to collect country of

birth data. The group also evaluated existing longitudinal studies involving

significant immigrant populations, and participant agencies helped fund

the New Immigrant Survey pilot test, which was designed to provide

accurate data on immigrants and their families’ economic, social, and

political adaptation to living in the United States.

The need for coordination among agencies that collect information on the

foreign-born has been a long-standing issue, as discussed in our report on

the two NAS reports that contain recommendations designed to streamline

and strengthen the collection, analysis, and dissemination of immigration

statistics.20 In that report, we noted that while the interagency working

group has resulted in improved coordination, NAS’ recommendations to INS

have not been fully implemented. For example, NAS recommended that not

only federal but state agencies also should participate in INS’ liaison

efforts. We noted that although INS has established a liaison with federal

agencies, no corresponding liaisons exist with state agencies. In its 1985

report, NAS noted that state and local governments are also involved in the

collection and analysis of immigration- and emigration-related data that

could be useful for INS’ statistical purposes.

Regarding Census’ coordination efforts, we noted in our prior work that

(1) coordination with other federal agencies is particularly important for

Census because of its role in collecting statistical data for agencies and

(2) Census cooperates with data users in a variety of ways.21 For example,

a Census representative is a member of the INS-sponsored interagency

coordinating group. Further, the NAS guidance on coordination indicates

that the most important aspect of coordination among federal agencies is

the sharing of data. Census and other statistical agencies have been active

in recommending and supporting efforts to enhance data sharing. For

example, the Statistics 2000 task force—composed of members from

Census and the other major statistical agencies—worked with OMB and

20GAO/GGD-98-119, June 9, 1998.

21GAO/GGD-95-65, Aug. 9, 1995.

Page 16 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
B-278387 

Congress in developing proposals for enhanced data sharing.22 However, it

appears that the sharing of data on the foreign-born among federal

agencies was limited by the provisions designed to protect the

confidentiality of individual data providers. For example, one of the

products of the INS-sponsored interagency working group addressed

expanding the immigration database by using more administrative records.

The group proposed linking information from various agencies to a

specific individual by social security number. The group’s paper noted the

problems associated with access to such information because of privacy

or confidentiality provisions.

The NAS guidance also suggests that federal agencies should, when

possible and appropriate, cooperate with state, local, and international

statistical agencies. Census officials said the agency had cooperated with

other governments to the extent necessary to obtain the data on the

foreign-born that was needed.

Census and INS have worked collaboratively on a wide variety of projects

for a number of years, sharing data on the foreign-born. Currently, INS is

providing part of the financial support for the monthly collection of

nativity data in the CPS, a project that began in January 1994. INS decided in

1996 to expand the use, analysis, and dissemination of these data and

requested the continued assistance of the Census Bureau in this expansion

effort. Under this agreement, INS provides the specifications for the data

files needed and collaborates with Census to support the work. Census’

responsibilities under the agreement include providing the data, producing

and publishing an annual report on the foreign-born, providing

subject-matter consultants for special projects, and meeting with INS

officials regarding issues and concerns about the foreign-born.

As we have said in an earlier report,23 coordination is important because in

its absence, it is unlikely that programs will efficiently supplement each

other to meet both program improvement and policy-making information

needs.

22Statistical Agencies: Proposed Consolidation and Data Sharing Legislation (GAO/T-GGD-98-91,

Mar. 26, 1998).

23Program Evaluation: Agencies Challenged by New Demand for Information on Program Results

(GAO/GGD-98-53, Apr. 24, 1998).

Page 17 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
B-278387 

Agency Comments OMB and INS provided oral comments on a draft of this report. Their

comments were of a technical nature, or to clarify points. We considered

all of their comments and have incorporated them where appropriate. The

Department of Commerce had no comments on the report.

As agreed with your staffs, unless you publicly announce its contents

earlier, we plan no further distribution of this report until 30 days from its

issue date. At that time, we will send copies to the Chairmen and Ranking

Minority Members of other committees with jurisdiction over immigration

issues; the Attorney General; the Secretaries of Commerce, HHS, and State;

and other interested parties. We will also make copies available to others

upon request.

If you have questions concerning this report, please telephone me at

(202) 512-7997. Major contributors to this report are listed in appendix III.

Susan S. Westin

Associate Director

Advanced Studies and Evaluation

 Methodology Group

Page 18 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Page 19 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Contents

Letter 1

Appendix I 

Scope and

Methodology

22

Appendix II 

Profiles of the Two

Principal Agencies

That Produce

Statistics on

Foreign-Born

Residents

23

Appendix III 

Major Contributors to

This Report

27

Related GAO Products 28

Tables Table 1: INS’ Annual Reporting Requirements Under 8 U.S.C.

1103(d)

13

Table II.1 INS’ Statistics Branch Budget and Staffing 23

Table II.2: Population Division Budget 26

Abbreviations

CPS Current Population Survey

FTE Full-time equivalent

HHS Department of Health and Human Services

INS Immigration and Naturalization Service

NAS National Academy of Sciences

OIRA Office of Information and Regulatory Affairs

OMB Office of Management and Budget

PAS Performance Analysis System

Page 20 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Page 21 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Appendix I 

Scope and Methodology

To identify the federal guidance affecting the production of statistics on

foreign-born residents and the principal agencies involved in the

collection, analysis, and dissemination of statistics on the foreign-born, we

talked to officials from OMB and INS and experts on immigration issues. On

the basis of those discussions, we gathered information on relevant

guidance by reviewing pertinent literature, laws, NAS reports on

immigration, and NAS and OMB guidance for federal statistical agencies.

To determine the primary agencies responsible for producing statistics on

the foreign-born, we synthesized literature reviews, agency documents,

and testimonial evidence from agency officials and knowledgeable experts

and identified the agencies that seemed to generate the statistical

information germane to the request. We then verified this information with

officials from OMB and from the agencies we selected: INS’ Statistics Branch

and the Census Bureau’s Population Division.

These agencies are considered to be primary sources of demographic data

on the foreign-born. In addition, we interviewed officials and reviewed

relevant documents from HHS’ Office of Refugee Resettlement, State

Department’s Immigrant Visa Control and Reporting Division, and State

Department’s Population, Refugees, and Migration Bureau, who collect

program-specific information on the foreign-born. We also drew on other

work being done in response to the first and second objectives of the

request. Other agencies that did not engage in any primary data collection

or analysis activities but only disseminated information on the

foreign-born were not included in our work.

To provide information on the agencies’ positions on independence,

capacity to produce statistical information, and interagency coordination

efforts, we compiled criteria for each of these areas from our review of

federal guidance on how statistical agencies should operate. Using these

criteria, we derived a set of indicators by which to compare the agencies’

statistical operations against the elements in the NAS guidance regarding

independence, capacity to produce statistical information, and interagency

coordination.

Page 22 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Appendix II 

Profiles of the Two Principal Agencies That

Produce Statistics on Foreign-Born

Residents

INS’ Statistics Branch INS’ Statistics Branch is the largest producer of statistics on the

foreign-born and currently has a staff of 24 full-time-equivalent positions.

The branch is located within the Office of Policy and Planning, which was

created in a major INS reorganization in 1994 to reinforce Servicewide

planning and provide attention to macro-level immigration policy. As an

executive-level office, Policy and Planning reports directly to the INS

Commissioner. Its mission is to

• support INS leadership in policy development, strategic planning, program

evaluation, and statistical analysis and reporting;

• act as a central clearinghouse for collecting, interpreting, and

disseminating information about immigration policy; and

• act as a liaison between INS and nongovernmental organizations and

interest groups that have a stake in national immigration policy.

The fiscal years 1994 through 1998 Statistics Branch budget allocations are

shown in table II.1.

Table II.1 INS’ Statistics Branch

Budget and Staffing

Fiscal year

Dollars in

millions FTE’sa

1994 1.2 24.1

1995 1.3 22.9

1996 1.3 22.5

1997 1.4 24.2

1998 1.4b 24.0b

aFull-time-equivalent positions.

bINS estimates.

Source: INS.

The Statistics Branch consists of two sections—Operational and

Demographic. The two sections are responsible for preparing reports on

operational and demographic statistics, respectively; monitoring the

information system’s reliability; and advising other INS offices on sampling

and other statistical applications.

Operational Statistics

Section

The Operational Statistics Section provides information on INS’ operations

(workload and resources) and develops models for estimating revenue to

support budget requests. The staff manages INS’ Performance Analysis

Page 23 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Appendix II 

Profiles of the Two Principal Agencies That

Produce Statistics on Foreign-Born

Residents

System (PAS), which is a workload measurement system; produces reports

of PAS data; responds to requests for information (usually from within INS);

develops models for estimating revenue to support budget requests; and is

to be the principal source of information to meet the requirements of the

Government Performance and Results Act. The data originate from a

variety of sources, including manual reporting systems, reports from

automated mission systems, and electronic vehicle counters at U.S.

borders. INS’ Information Resources Management Office provides

automation support for PAS through a contract with Electronic Data

Systems, for which INS pays $130,000 annually.

Until 1997, the Operational Statistics Section employed two

statisticians—the section chief and a senior statistician. Two additional

statisticians were recently hired, one who concentrates on analyses of

enforcement data, and the other who concentrates on immigration

services information. In March 1998, the section was authorized 13 FTEs,

and 12 of these were filled. The employees’ job titles and grade structure

were as follows:

• 1 Supervisory Statistician, GS-14,

• 3 Statisticians, GS-13,

• 2 Management Analysts, GS-11,

• 2 Management Analysts, GS-9, and

• 4 Statistical Assistants, GS-6.

Demographic Statistics

Section

The Demographic Statistics Section produces reports on the size and

characteristics of various alien populations and analyzes pertinent

information collected by other agencies, such as the Census Bureau and

the Bureau of Justice Statistics. To produce the reports, the section

primarily uses extracts from INS’ mission systems, which are developed

and maintained by the Office of Policy and Planning.

The Demographic Statistics Section issues a number of products, many of

which are available on the Internet. The Statistical Yearbook of the

Immigration and Naturalization Service is published annually and is INS’

primary statistical publication. The Yearbook has been published since

1892. Specific reporting requirements contained in recent Yearbooks are

called for by the Immigration Act of 1990, codified at 8 U.S.C. 1103(d). Also

published annually are the Commissioner’s Fact Book and Immigration

Advance Reports. Other publications include the following.

Page 24 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Appendix II 

Profiles of the Two Principal Agencies That

Produce Statistics on Foreign-Born

Residents

• INS Fact Book (Mar. 1993): A summary of recent immigration data.

• Immigration to the United States in Fiscal Year 1996 (Apr. 1997):

Information on legal immigration to the United States.

• Immigration Fact Sheet (Oct. 1997): A compilation of statistics and

historical data on the national origin and residence of immigrants and the

foreign-born population in the United States.

• Estimates of the Unauthorized Immigrant Population Residing in the

United States: October 1996 (published periodically): Estimates as of

October 1996 for the top 20 countries of origin and states of residence;

includes text describing the estimation procedure, limitations, and

discussion of estimate results.

• State Population Estimates: Legal Permanent Residents and Aliens Eligible

to Apply for Naturalization (single publication): Estimates for each state as

of April 1996; includes brief supporting text.

• Bulletins (on selected topics, published periodically).

In March 1998, the Demographics Statistics Section was allocated 11 FTEs,

one of which was vacant. The staff members’ job titles and grades were as

follows:

• 1 Supervisory Statistician, GS-14,

• 1 Statistician, GS-14,

• 3 Statisticians, GS-13,

• 1 Supervisory Information Specialist, GS-11,

• 2 Management Analysts, GS-11,

• 1 Presidential Management Intern, GS-11, and

• 1 Statistical Analyst, GS-7.

Census Bureau The Census Bureau is responsible for collecting, tabulating, and publishing

a variety of statistical data about the people and the economy of the

United States. Census’ responsibilities include the decennial census of

population and housing; censuses of state and local governments and

domestic industries; special censuses done at the request and expense of

states and localities; and compilations of U.S. foreign trade statistics. Many

other statistical agencies make use of Census’ extensive field structure and

data-gathering operations on a reimbursable basis.

Census’ Population Division is the federal government’s provider of

regularly updated information on the population of the United States,

including the foreign-born, and its demographic, geographic, and social

characteristics. Through its subject-matter expertise, the division oversees

Page 25 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Appendix II 

Profiles of the Two Principal Agencies That

Produce Statistics on Foreign-Born

Residents

the planning, collecting, processing, and distributing of population data

obtained from censuses, surveys, and administrative records. Census has

assigned two full-time demographers to collect and analyze information on

the foreign-born and to implement an interagency agreement with INS for

this type of information.

Two products of the Population Division represent a source of

immigration information: estimates and projections and the Current

Population Survey (CPS). The former provides a component of population

change labeled “net international migration.” This component comprises

(1) legal immigration from abroad, (2) net undocumented immigration,

(3) emigration, and (4) net movement between Puerto Rico and the U.S.

mainland. The CPS provides information on the foreign-born population in

the United States and in selected states. Customers for this information

include Congress, federal agencies, state and local governments, the

private sector, the academic community, research organizations, libraries,

and individuals. In addition, Census has published the 1996 Statistical

Abstract of the United States and We the American Foreign Born, a special

publication issued in September 1993.

Table II.2 shows the Population Division’s budgets for fiscal years 1994

through 1998.

Table II.2: Population Division Budget

Dollars in millions

Fiscal year Budget

INS

reimbursement

1994 $31 0

1995 24 0

1996 27 $0.20

1997 27 0.27

1998 31 0

Source: Census Bureau.

Two professional staff members in the Population Division specialize in

information on the foreign-born population. Both of these staff members

have the job title statistician/demographer. One is a GS-12, and the other is

a GS-9.

Page 26 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Appendix III 

Major Contributors to This Report

General Government

Division

Thomas J. Jurkiewicz, Assistant Director

Patrick R. Mullen, Evaluator-in-Charge

Nancy A. Patterson, Assignment Manager

Theodore H. Saks, Senior Evaluator

Thomas Beall, Technical Adviser

Office of the General

Counsel

Ann H. Finley, Senior Attorney

Page 27 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
Related GAO Products

Immigration Statistics: Status of the Implementation of National Academy

of Sciences’ Recommendations (GAO/GGD-98-119, June 9, 1998).

Program Evaluation: Agencies Challenged by New Demand for

Information on Program Results (GAO/GGD-98-53, Apr. 24, 1998).

Statistical Agencies: Proposed Consolidation and Data Sharing Legislation

(GAO/T-GGD-98-91, Mar. 26, 1998).

Statistical Agencies: Consolidation and Quality Issues (GAO/T-GGD-97-78,

Apr. 9, 1997).

Statistical Agencies: A Comparison of the U.S. and Canadian Statistical

Systems (GAO/GGD-96-142, Aug. 1, 1996).

Statistical Agencies: Statutory Requirements Affecting Government

Policies and Programs (GAO/GGD-96-106, July 17, 1996).

Federal Statistics: Principal Statistical Agencies’ Missions and Funding

(GAO/GGD-96-107, July 1, 1996).

Government Statistics: Proposal to Form a Federal Statistical Service

(GAO/T-GGD-96-93, Mar. 22, 1996).

Statistical Agencies: Adherence to Guidelines and Coordination of Budgets

(GAO/GGD-95-65, Aug. 9, 1995).

(966703) Page 28 GAO/GGD-98-155 Producing Information on the U.S. Resident Foreign-Born
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