IMMIGRATION

BENEFITS

INS Not Making

Timely Deposits of

Application Fees

United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on Immigration and Claims, Committee

on the Judiciary, House of

Representatives

September 2000

GAO/GGD-00-185

United States General Accounting Office General Government Division

Washington, D.C. 20548

Page 1 GAO/GGD-00-185 INS Fee Deposits

B-285116

September 29, 2000

The Honorable Lamar Smith

Chairman, Subcommittee on

Immigration and Claims

Committee on the Judiciary

House of Representatives

Dear Mr. Chairman:

One of the Immigration and Naturalization Service’s (INS) primary

functions is to provide services or benefits that facilitate entry, residence,

employment, and naturalization of legal immigrants. To recover the costs

that it incurs in providing benefits, INS is authorized to charge fees to

recipients of INS services.1

Individuals who apply for INS benefits must

send their application form and appropriate fee, if any, to one of INS’ 4

regional service centers or 33 district offices. Federal agencies, including

INS, are generally required by Department of the Treasury regulations to

deposit fees totaling $5,000 or more on the same day or day after they are

collected.

This report responds to your request that we determine the (1) extent to

which INS made timely deposits of the fees that it collected from aliens

who applied for benefits, and (2) potential costs to the government if INS

fee deposits were not timely. In responding to your request, we analyzed

data on applications2

that INS received during fiscal year 1999 and fees that

INS was to deposit into the Immigration Examinations Fee Account

(IEFA)3

in the U.S. Treasury.

1 Generally, INS has discretion to waive application fees for applicants who establish that they are

unable to pay the fee.

2

Our analyses included both applications and petitions received by INS. Aliens submit applications to

INS when they seek benefits for themselves, such as U.S. citizenship. Petitions are filed on behalf of

aliens, such as when employers petition on behalf of employees or parents petition on behalf of

children. For purposes of this report, the term “application” is used to refer both to applications and

petitions.

3

The 1989 Department of Justice Appropriation Act established IEFA to reimburse any appropriation

for expenses in providing immigration and naturalization services. P.L. 100-459, 102 Stat. 2186, 2203

(1988). The Illegal Immigration Reform and Immigrant Responsibility Act established the Immigration

Detention Account, into which certain additional fees for adjustment of status are deposited. P.L. 104-

208, 110 Stat. 3009, 3009-648, 3009-649 (1996).
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Because the data maintained by INS were not complete, we were unable to

fully determine the extent to which INS complied with Department of the

Treasury regulations requiring that receipts totaling $5,000 or more be

deposited on the same day if they were received prior to the deposit cutoff

time, or the next day if they were received too late to meet the cutoff time.

INS maintained initial application acceptance processing4data for its four

service centers, which handled about 75 percent of the applications

received. However, INS did not maintain such data for its 33 district

offices, which handled the remaining 25 percent of applications received.

In fiscal year 1999, INS service centers did not generally make timely fee

deposits. Whereas Treasury requires that fees totaling $5,000 or more be

deposited on the same day or the day after they are received, INS took, on

average, at least 12 additional days beyond Treasury’s time requirement.

We estimate that the resulting interest cost to the government, or the cost

for interest incurred on debt or other obligations, was about $640,000 in

fiscal year 1999. Our estimates are conservative because we did not have

data on certain phases of the fee deposit process—such as the amount of

time that applications remained unopened in service center mailrooms—

that may have caused additional delays in the time taken to deposit fees.

Any additional delays would have increased the amount of interest cost to

the government. We also found that INS’ contract for application

processing services provided the contractor with more time to make fee

deposits than is allowed by Treasury regulations.

We are making recommendations for INS to improve its information on

timeliness and comply with Treasury regulations. INS generally agreed

with our findings and recommendations and said that making timely and

accurate fee deposits is an agency priority. However, INS expressed

several concerns about our methodology, which we address near the end

of this report.

The Department of the Treasury, in its role as chief financial agent of the

federal government, is responsible for effectively managing the cash

operating accounts and debt financing to ensure sufficient funds are

available to meet the financial obligations of the federal government when

they become due. This involves investing excess cash balances in interestbearing accounts, holding cash at the Federal Reserve, or issuing

marketable debt securities to the public when estimated cash outlays are

expected to exceed estimated cash receipts. To accomplish effective cash

4

By initial application acceptance processing, we mean the initial clerical stages of handling incoming

applications, prior to adjudication by INS examiners.

Results in Brief

Background
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management, federal agencies are required to use cash management

practices and techniques that will accelerate and control collections,

ensure prompt deposit of receipts, improve control over disbursement

methods, and eliminate idle cash balances.

At INS’ four service centers, which maintain automated initial application

acceptance processing data, contractors process applications in two

stages. First, in the mailroom, INS contractor clerks are to open incoming

mail, sort it according to type of application form, and screen each

application to ensure that it is signed and that the proper fee is enclosed. If

either the signature is missing or the fee amount submitted is incorrect, the

application is to be rejected and returned to the applicant. For each nonrejected application, a clerk is to prepare an application file. Second, in

data entry, clerks are to enter data from all applications, except

naturalization applications, into INS’ Computer Linked Application

Information System (CLAIMS). Fees are to be separated from the

application, data on the fee is to be entered into the computer, and the fee

is to be prepared for deposit. For naturalization applications, the checks

are to be separated before all the application data are entered into

CLAIMS. Fees are to be en route to deposit within one workday of data

entry. They are to be deposited for credit into the IEFA account of the U.S.

Treasury. At the end of each work shift, INS’ contractor is responsible for

recording the number of accepted applications of each type received and

processed during the shift, and the number remaining unprocessed at the

end of the shift. The contractor uses the Automated Task Order

Management System (ATOMS), an internal corporate management tool, to

record this information and monitor its workload and productivity.

Applications are to be processed in the order in which they were received.

In fiscal year 1999, INS deposited $628 million into IEFA.

INS maintained initial application acceptance processing data for its 4

service centers, which together accounted for 75 percent of applications

that INS received in fiscal year 1999. However, such data were not

maintained for INS’ 33 district offices, which accounted for approximately

25 percent of applications received. Therefore, we could not calculate how

long district offices took to process applications and deposit fees, or what

additional costs the government may have incurred if deposits were not

timely.

INS’ Fee Deposit Data

Incomplete
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Our analysis of fiscal year 1999 data indicated that INS service centers did

not, on average, deposit application fees within the time period required by

Treasury regulations. In addition, INS provided more time to its contractor

to make fee deposits than is allowed by Treasury regulations. To reduce

the processing float and improve the availability of funds, Department of

the Treasury regulations require that federal agencies deposit fees totaling

$5,000 or more on the same day that they are received prior to the deposit

cutoff time. Money received too late in the day to meet the deposit cutoff

time is to be deposited on the following business day.5

Collections totaling

less than $5,000 may be accumulated and deposited when the total reaches

$5,000. However, deposits are to be made by Thursday of each week,

regardless of the amount accumulated. According to INS officials, service

centers receive more than $5,000 in application fees each day. INS requires

its contractor to complete initial application acceptance processing (i.e.,

key data into a computer system on the application and fee) within 2

workdays after the applications are received, and to ensure that fees are en

route to deposit within 1 workday of completing initial application

acceptance processing.

In fiscal year 1999, INS service centers took, on average, at least 12

additional days beyond Treasury’s time requirement to make fee deposits.

Because INS often did not deposit its cash receipts, cash that would

otherwise have been invested in an interest-bearing account, disbursed to

settle financial obligations, or used to buy back debt securities to lower

financing costs remained idle. We estimate that the resulting interest cost

to the government, or the cost for interest incurred on debt or other

obligations, was about $640,000 in fiscal year 1999. Our figures on time and

cost are lower-bound estimates because we did not have data to determine

the amount of time that (1) applications remained unopened in service

center mailrooms, or (2) it took service centers to deposit fees after

completing data entry. In addition, we did not have data to determine how

much additional cost INS may have incurred if district offices did not

deposit fees on the same day of or the next day after receipt.

Our analysis indicated that, throughout fiscal year 1999, there were delays

in making fee deposits in each of the four service centers. Although there

may have been several reasons for the delays, our analysis indicates that a

1999 change in the naturalization application fee may have been associated

with an increase in INS’ application workload. The increase in workload

was temporary, but it may have contributed to delays in processing

applications. On January 15, 1999, the fee for naturalization applications

5 Treasury Financial Manual, vol. 1, part 6, sec. 8030.20.

Delays in Making Fee

Deposits Resulted in

Interest Costs to the

Government
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Page 5 GAO/GGD-00-185 INS Fee Deposits

increased from $95 to $225. During the month of the fee increase, service

centers received a total of about 274,000 naturalization applications,

substantially more than in any prior or subsequent month of the fiscal year.

In January, the number of naturalization applications received was over 3

times greater than the number received in October or November 1998, over

2 times greater than the number received in December 1998, and over 7

times greater than the number received during any single month from

February to September 1999. Counting all application types, the total

number of applications received by INS service centers in January 1999

was about 496,000, while no more than 379,000 applications were received

during any other month of the fiscal year. Although we did not have the

data to determine whether most of the applications that INS received in

January arrived before January 15, it is possible that applicants sought to

submit their applications prior to January 15 in order to avoid paying the

higher fee, thereby contributing to a large application workload,

processing delays, and untimely fee deposits.

In a September 1998 management letter report to INS, the Justice

Inspector General noted INS’ lack of timeliness in making fee deposits.

Based on a sample of INS cash receipts from fiscal year 1998, the Inspector

General found that INS did not consistently and in a timely manner deposit

and record the cash receipts.

INS officials told us that they are aware that a discrepancy exists between

Treasury’s fee deposit requirement for agencies and INS’ performance

requirement for its service center contractor. They acknowledged that INS’

contract for initial acceptance application processing provides up to 3 days

for the contractor to deposit fees totaling $5,000 or more, whereas

Treasury’s requirement is that such amounts be deposited on the same day

of or the next day after receipt. They said that in their next contract for

service center operations support services, which is to be awarded on

September 30, 2000, they planned to require the contractor to conform

with Treasury’s deposit guidelines.

INS has some procedures in place to determine whether its offices have

made timely fee deposits. From September 1998 through September 1999,

INS’ Office of Internal Audit conducted seven reviews as part of INS’

Program for Excellence and Comprehensive Tracking (INSpect). INSpect

reviews are internal reviews of district offices and service centers6

and

6

Since 1995, INS’ Office of Internal Audit has conducted such management effectiveness reviews of

agency field offices. INSpect reviews are to focus on areas that are vulnerable to fraud, waste, abuse,

or mismanagement; determine compliance with rules, regulations, and procedures; and assess

management effectiveness. The functions reviewed include finance, records, files and forms,
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include procedures for determining whether fees totaling $5,000 or more

are deposited within 24 hours of receipt. In its INSpect reviews, INS

determines compliance with the fee deposit requirement by using a 24-

hour criterion. Of the seven reviews, INS found that three districts

deposited fees within 24 hours of receipt, and that one district did not. In

the remaining three reviews, covering two service centers and one district

office, INS did not cover the timeliness of deposits. According to INS

officials, application acceptance processing at these three locations was

done by contractor staff, and INS quality analysts were responsible for

monitoring their performance.

To determine the extent to which INS service centers made timely fee

deposits in fiscal year 1999, we analyzed data from the ATOMS database,

which contained the contractor’s daily data on the number of applications

received, processed, and pending at the service centers. We used the data

to estimate the average number of days it took INS to make fee deposits

beyond Treasury’s time requirement. We calculated the average by

summing the total number of excess processing days in fiscal year 1999

and dividing by the total number of applications processed during that

year. To obtain the total number of excess processing days, we summed

the number of applications that remained unprocessed each day in each

service center’s mail room and data entry stage for each application type

over all the days of the fiscal year.

We estimated the interest cost to the government for each application type

by first multiplying the application type’s fee by the total number of excess

processing days and the fiscal year 1999 Marketable Treasury Bill average

interest rate of 4.9 percent. We then divided the result by the number of

days in the fiscal year. To obtain the total interest cost, we summed the

interest cost accumulated each excess day in each service center’s mail

room and data entry for each application type over all the days of the fiscal

year.

We did not independently verify the reliability or completeness of the

ATOMS database. However, key contractor staff assured us that ATOMS

data integrity was high, and we performed limited testing to determine if

data were accurately entered into the ATOMS database.

adjudications, detention and deportation, inspections, investigations, security, property management,

facilities, procurement, human resources and development, equal employment opportunity, legal

proceedings, and intelligence.

Scope and

Methodology
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Page 7 GAO/GGD-00-185 INS Fee Deposits

The appendix provides additional detail on our methodology for

calculating excess processing days and the associated interest cost to the

government.

We performed our work between October 1999 and July 2000 in

accordance with generally accepted government auditing standards.

INS did not have the data necessary to determine how long district offices

took to deposit application fees after applications arrived in their

mailrooms. Based on data that were available, we estimate that in fiscal

year 1999, INS service centers did not make timely deposits of applications

fees, resulting in about $640,000 in interest cost to the government. In

addition, INS’ contract for application processing services provided more

time for the contractor to deposit fees than is allowed by Treasury

regulations.

We recommend that the INS Commissioner

• institute procedures for recording information on application acceptance

processing at district offices to include data that would permit INS to

monitor district compliance with Treasury deposit regulations,

• implement INS plans to require that the contractor make fee deposits in

accordance with Treasury regulations,

• determine which service centers and district offices do not comply with

the fee deposit requirement and why the noncompliance occurs, and

• take appropriate action to ensure that timely fee deposits are made.

We requested comments on a draft of this report from the Attorney

General and the Secretary of the Treasury.

The Treasury Department had no comments on the draft report. On

September 13, 2000, we met with INS’ Associate Commissioner for Service

Center Operations, Assistant Director for Internal Audit, and other INS

officials to obtain their oral comments on the draft report. INS generally

agreed with our findings and agreed with our recommendations in

principle. It stated that making timely and accurate fee deposits is a

priority for INS and a working group has been formed to examine cash

management practices. However, INS expressed several concerns about

our review, including (1) our focus on a fiscal year that INS considered to

be atypical because of changes in application fee structure, (2) our use of

Conclusions

Recommendations

Agency Comments and

Our Evaluation
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Page 8 GAO/GGD-00-185 INS Fee Deposits

the contractor’s ATOMS database for determining fee deposit timeliness,

and (3) uncertainty about how we did our analyses.

With respect to INS’ concern that fiscal year 1999 was atypical because

INS changed its application fee structure during that year, we agree that

fiscal year 1999 was atypical in this particular respect. We present analysis

results in this report that indicate that the January 15, 1999, change in the

naturalization fee may have contributed to an increase in workload and

processing delays. However, the report also notes that the Justice

Inspector General found problems with INS fee deposits in fiscal year

1998. We have no basis for determining how typical or atypical application

acceptance processing was in fiscal year 1999 relative to other years. A

number of factors—including changes in fees, laws, policies, and agency

priorities—can affect the number of applications received by INS and the

amount of time INS takes to process them. INS is responsible for timely

processing of applications regardless of the year-to-year fluctuation in

receipts. Our specific reason for focusing on fiscal year 1999 was that we

were asked to review data from 1999 and it was the most current year for

which complete data were available.

With respect to INS’ concern that the contractor’s ATOMS database was

not designed to track time frames for processing applications and

therefore may not have been an appropriate information source for

determining fee deposit timeliness, we disagree. Prior to deciding to use

ATOMS data, we consulted with INS officials about what data system(s)

were available to address the objectives of our review. We learned that

ATOMS contained daily workload data that could be used to provide a

useful measure of fee deposit timeliness and interest cost. We also learned

that ATOMS was, and still is, the only comprehensive data system

containing information on every application type submitted to INS. Finally,

as we indicate in the report, although we did not independently verify the

reliability or completeness of the ATOMS database, we did limited testing

to determine if data were accurately entered into ATOMS. We also

interviewed the key contractor staff responsible for managing the system

and they assured us that data integrity was high. Although INS

acknowledged that making timely fee deposits can be problematic, it

remained skeptical about the number of excess days that we obtained in

our calculations. INS indicated that it planned to engage in efforts to use

its own data—rather than contractor-maintained data—to monitor the

timeliness of fee deposits in the future.

Finally, with respect to INS’ questions about how we did our data analyses,

we provided an explanation in our meeting, and we added a Scope and
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Page 9 GAO/GGD-00-185 INS Fee Deposits

Methodology appendix to the report that expanded our description of the

analytic approach. Additionally, during the course of the review, we

engaged in three meetings with INS officials and technical staff to discuss

our methodology. We believe that the information we have added to the

report clarifies our analytic methodology.

We are providing copies of this report to Representative Sheila Jackson

Lee, Ranking Minority Member of your Subcommittee; Senators Spencer

Abraham and Edward Kennedy, Chairman and Ranking Minority Member,

Senate Judiciary Subcommittee on Immigration; the Honorable Janet

Reno, Attorney General; and the Honorable Doris Meissner,

Commissioner, Immigration and Naturalization Service. We will make

copies available to others upon request.

If you have any questions, please contact Evi L. Rezmovic or me at 202-512-

8777. The key contributors to this assignment were Jay Jennings, Jim

Fields, and George Quinn.

Sincerely yours,

Richard M. Stana

Associate Director, Administration of

Justice Issues
Appendix

Scope and Methodology

Page 10 GAO/GGD-00-185 INS Fee Deposits

To determine the extent to which INS service centers made timely fee

deposits in fiscal year 1999, we analyzed data from the ATOMS database,

which contained the contractor’s daily data on the number of applications

received, processed, and pending at the service centers. The ATOMS

database includes the number of unprocessed applications of each type

held each night in the contractor’s workload inventory. The data for each

type are available separately for the mail room and data entry stage for

each service center.

We estimated the average number of days that INS took to deposit fees

beyond Treasury’s time requirement by summing the total number of

excess processing days in fiscal year 1999 and dividing by the total number

of applications processed during that year. We took a conservative

approach to determining whether applications accumulated excess

processing days. If our calculations indicated that a group of applications

remained unprocessed for one full day and two consecutive nights, then

we calculated that each application in the group accumulated one excess

processing day. Although we did not have individual application-level data,

we could calculate this because INS officials told us that service centers

always process applications, within any particular application type, in the

order in which they are received. Therefore, to determine the number of

unprocessed applications each day, we used the number of applications

that had been held overnight before a processing day began and then

subtracted the number processed during the day.

To obtain the total number of excess processing days, we summed the

number of excess processing days accumulated each day in each service

center’s mail room and data entry stage for each application type over all

the days of the fiscal year. We adjusted the data to account for the fact that

a portion of applications did not proceed from the mail room to data entry,

possibly because they were rejected in the mail room because they lacked

a signature or the alien submitted an incorrect fee. We reduced the number

of unprocessed applications in the mail room stage by 11 percent for

naturalization applications, 20 percent for applications with fees that

changed in October 1999, and 15 percent for applications with no fee

change in fiscal year 1999.

We calculated that, in fiscal year 1999, INS accumulated 43,717,722 excess

days of unprocessed applications, and that INS service centers processed

3,621,962 applications in the data entry stage. Dividing the excess days by

the total number of processed applications, we arrived at an average of 12

additional days beyond Treasury’s time requirement for INS to make fee

deposits in fiscal year 1999.
Appendix

Page 11 GAO/GGD-00-185 INS Fee Deposits

We estimated the interest cost to the government for each application type

by first multiplying the application type’s fee by the total number of excess

processing days and the fiscal year 1999 Marketable Treasury Bill average

interest rate of 4.9 percent. We then divided the result by the number of

days in the fiscal year. To obtain the total interest cost, we summed the

interest cost accumulated each excess day in each service center’s mail

room and data entry for each application type over all the days of the fiscal

year.

To illustrate our method for calculating the number of excess days and

interest costs, suppose that, on a given Tuesday morning in November

1999, contractor clerks in a service center mail room began their day with

1,000 Petitions for Alien Relatives (Form I-130) held over from the

previous day. If the mail room processed 375 I-130s during the two shifts

on that Tuesday, then 625 I-130s would have remained unprocessed and

left over for the first shift on Wednesday. Of the 625 unprocessed I-130s,

we calculated that 125, or 20 percent, would later be rejected, and 500

would not be rejected. Because the 500 non-rejected I-130s were not

processed on either Monday or Tuesday, we calculated that they would

have accounted for 500 excess days of interest cost. The fee for each I-130

was $110 in November, so the 500 forms would have had $55,000 in fees

attached to them. The associated interest cost to the government for the

500 unprocessed I-130s in that service center on that single day would have

been $7.38. 1 The daily interest cost is calculated by multiplying the

collected fee total of $55,000 by the fiscal year average interest rate of 4.9

percent and dividing by 365.

We performed a similar calculation for the data entry stage for the same

day and same service center. For example, if the first data entry shift on

Tuesday had 3,000 I-130s left over from the last shift on Monday, and if the

data entry staff processed 400 I-130s during the two shifts on Tuesday,

then 2,600 I-130s remained for the next day’s shift. Since fees from these

2,600 forms were not deposited on either Monday or Tuesday, INS would

have incurred 2,600 excess interest days for Tuesday. We would calculate

that the 2,600 undeposited I-130 fees accounted for $286,000 in collected

fees (2,600 times $110) and $38.39 in interest costs ($286,000 times 4.9

percent divided by 365) for the Tuesday in question.

For forms that entered the mail room or data entry stage on Friday or

Saturday, we did not begin computing interest costs associated with

1

As explained later in the appendix, we adjusted our final estimate of interest cost to account for the

fact that INS waived the fee for a portion of the applications.
Appendix

Page 12 GAO/GGD-00-185 INS Fee Deposits

unprocessed forms until Monday because the fees from these forms could

not have been deposited on Saturday or Sunday. We also did not count

holidays as contributing to interest costs in these cases. For unprocessed

forms that entered the mail room or data entry stage on days other than

Friday or Saturday, we computed interest costs for the weekend because

the fees from these forms could have earned interest during that time had

they been deposited without delay. In these cases, we counted holidays as

contributing to interest costs.

Our calculations of timeliness and interest cost to the government took

into account (1) the changes in fee schedules in fiscal year 1999; (2) that

many of the applications processed in the period following the fee change

dates were accompanied by fees at the previous, lower rates; (3) the

number of applications that were rejected during initial processing without

their fees being accepted; (4) the additional days of interest cost during

weekends and holidays; (5) that the naturalization application fee is

removed from the application and may be sent for deposit before data

entry, and (6) that INS waived the fee on approximately 13,000

applications in fiscal year 1999.

Since we could not determine from the data which applicants had their fee

waived by INS, our initial analyses assumed that fees were submitted with

all applications. We then reduced our estimate of the total interest cost by

the amount of interest cost that about 13,000 applications would have

generated. To do this, we made the assumption that the average waived fee

was $225, that applications with waived fees had an average of 12 excess

interest days, and that all of the waived fees were from service centers. We

calculated that the applications with waived fees accounted for less than

$5,000 in interest cost in fiscal year 1999, an amount that did not alter our

overall estimate of about $640,000.

In October 1998 and January 1999, INS increased the fees for most

application types. We factored these changes into our analyses by

calculating a lag time associated with processing applications received

under the former fee structure. That is, we considered the fact that some

of the previous lower-fee forms would continue to be processed even after

the fee change date. For example, the fee for naturalization applications

increased from $95 to $225 on January 15, 1999. On January 26, the number

of unprocessed naturalization applications at the data entry stage reached

a peak of 354,347, and our analyses assumed that all of them were

submitted with a $95 rather than a $225 fee. Our analyses indicated that

service center mail rooms completed processing of 354,347 naturalization

applications on June 24. Therefore, we assumed that all naturalization
Appendix

Page 13 GAO/GGD-00-185 INS Fee Deposits

applications processed through June 24 had payments of $95

accompanying them. This assumption had the effect of underestimating

INS’ accumulated interest cost because it is likely that some naturalization

applications received for mail room processing between January 15 and

June 24 were submitted with the higher payment of $225.

The reported interest cost of about $640,000 underestimates the total cost

due to untimely deposits because we did not have data to measure the

length of time that applications may have remained unopened in service

center mailrooms before processing began. We also could not determine

how long it took service centers to deposit the fees after contractor staff

completed initial application acceptance processing. INS does not have a

single database that would enable us to determine how much additional

time these steps in the process take. Our calculations assumed that there

were no delays during these additional stages. Additionally, our

calculations assumed that naturalization fees were deposited on the date

that they were separated from the applications, even if the deposits were

made after data entry. Finally, because data maintained by INS were

incomplete, we assumed that there were no delays in initial application

acceptance processing at INS’ 33 district offices, where about 25 percent

of the applications were processed.

We did not independently verify the reliability or completeness of the

ATOMS database. However, we took two steps that assured us that the

ATOMS data were sufficiently reliable and complete to meet the objectives

of the review. First, we interviewed the key INS contractor staff

responsible for managing the system to obtain information on the

reliability and completeness of ATOMS data. The contractor staff told us

that the application acceptance processing information captured in

ATOMS is of high quality. ATOMS data integrity is reportedly high for

several reasons, including (1) employees are trained in data entry, (2)

supervisors routinely review the information to ensure no over- or

undercounting, (3) staff are paid on the basis of productivity information

recorded in the system, and (4) intensive repeated reliance on the system

validates its accuracy. Second, we performed limited testing to determine

if data were accurately entered into the ATOMS database. Over a 2-day

period in July 1998, we observed and spoke with contractor staff who

processed applications in the mail room and data entry stage in INS’

Nebraska Service Center. For one application type, we compared the total

number of hard copy application files processed by the contractor to the

numbers they reported to their shift supervisor. These totals were entered

into ATOMS and used to generate summary productivity reports. In

addition, we tallied the total number of applications processed each day
Appendix

Page 14 GAO/GGD-00-185 INS Fee Deposits

and compared it to the totals that appeared on the summary report for

those days. We found no discrepancies in the reported totals for the mail

room and data entry stages for those days.

In addition to performing analyses of the data, we interviewed INS

officials, reviewed INS internal inspection reports, and reviewed Justice’s

report on the Office of Inspector General’s 1998 financial audit of INS.

Determining the causes for delays in initial application acceptance

processing was outside the scope of this review.
Page 15 GAO/GGD-00-185 INS Fee Deposits
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