IMMIGRANT 

INTEGRATION

U.S. Citizenship and 

Immigration Services 

Could Better Assess 

Its Grant Program 

Report to the Ranking Member, 

Committee on Homeland Security, 

House of Representatives

December 2011

GAO-12-274

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-274, a report to the 

Ranking Member, Committee on Homeland 

Security, House of Representatives

December 2011

IMMIGRANT INTEGRATION

U.S. Citizenship and Immigration Services Could 

Better Assess Its Grant Program 

Why GAO Did This Study

In 2009, about 39 million foreign-born 

people lived in the United States.

Immigrant integration is generally 

described as a process that helps 

immigrants achieve self-sufficiency, 

political and civic involvement, and 

social inclusion. The Department of 

Homeland Security’s (DHS) U.S. 

Citizenship and Immigration Services 

(USCIS) is responsible for a key

activity that fosters political and civic 

involvement—the naturalization and 

citizenship process. USCIS’s Office of 

Citizenship (OoC) supports this 

process mainly through grants to 

immigrant-serving entities, but also 

with outreach activities and education

materials. Other governmental and 

nongovernmental entities play a role in 

immigrant integration as well. GAO 

was asked to determine (1) the steps 

USCIS has taken to implement its 

integration programs and the extent to 

which it has assessed its grant 

program in particular, and (2) what

federal mechanism exists to coordinate 

integration efforts. Among other things, 

GAO examined documentation on 

mission objectives and performance 

measures on immigrant integration and

conducted interviews with officials in a 

nongeneralizable sample of cities and 

community-based organizations as 

well as senior USCIS officials about 

their immigrant integration efforts. 

What GAO Recommends

GAO recommends that USCIS set 

interim milestones for an internal and 

external evaluation of its immigrant 

integration grant program, to the extent 

that it receives fiscal years 2012 and 

2013 appropriations for the program.

DHS concurred with our 

recommendation.

What GAO Found

USCIS has implemented immigrant integration efforts through outreach activities, 

educational materials, and a grant program, and established various measures 

for assessing its grant program, but has not yet set interim milestones for 

planned evaluations of the program. From 2008 to 2011, OoC reported 

conducting more than 300 significant outreach events to promote citizenship 

awareness and civic integration. Further, nearly half of OoC’s funding over the 

past 3 fiscal years—about $19.8 million—was spent on grants aimed at preparing 

immigrants for the naturalization process. The grants were made to a myriad of 

governmental and nongovernmental organizations, including public school 

systems and community and faith-based organizations. OoC has established 

various measures for assessing grantees’ performance under its grant program. 

These measures include, for example, the number of participants enrolled in 

grantees’ citizenship instruction and naturalization preparation programs, the 

number of participants who passed their naturalization examinations, and the 

proportion of participants who received grantees’ services and self-reported that 

they naturalized during the year of the grant program. However, USCIS has 

identified inherent limitations with these measures, such as that its data were 

incomplete in part because data were self-reported by program participants, and 

not all program participants reported to grantees whether they passed the 

naturalization examination and naturalized. In January 2011, USCIS drafted a 

statement of work for a contractor to develop an evaluation plan that would allow 

USCIS to measure the grant program’s performance and long-term impact, and 

this may help address these limitations. According to USCIS, it did not complete 

this statement of work or award a contract for an evaluation plan because, at that 

time, the agency was uncertain whether it would receive appropriations in fiscal 

year 2011 to continue the grant program, and the program has no authorizing

statute. The final fiscal year 2011 law, enacted in April 2011, did allow the use of 

appropriations to fund the grant program, but USCIS did not proceed with 

developing an evaluation plan. In November 2011, USCIS reported that it plans 

to conduct an internal and external evaluation of the program in fiscal years 2012 

and 2013, respectively, contingent on appropriations for the grant program. 

However, USCIS has not yet set interim milestones for these evaluations. Setting 

such milestones, contingent on the receipt of funding, could help USCIS 

strengthen its planning for conducting those evaluations, consistent with program 

management standards. 

No federal agency has been tasked with coordinating immigrant integration 

efforts, but actions are under way to provide strategic direction and guidance for 

immigrant integration. Local government and nongovernmental officials told GAO 

that federal direction was lacking, which created challenges in program 

coordination. In response to a 2010 OoC report to the Office of Management and 

Budget, which called for developing a federal strategy on immigrant integration, 

in June 2010 the White House Domestic Policy Council formed the Interagency 

Working Group on the Federal Role of Immigrant Integration to assess the roles 

and equities of the federal government in promoting immigrant integration and to 

better coordinate integration efforts across agencies. Because the work of this

group has not yet been completed, it is too early to know if, and to what extent, it 

will provide leadership for a national immigrant integration capability.

View GAO-12-274. For more information, 

contact Richard M. Stana at (202) 512-8777 or 

stanar@gao.gov.
Page i GAO-12-274 Immigrant Integration

Letter 1 

Background 6

USCIS Has Developed and Implemented Programs to Support 

Immigrant Integration but Could Strengthen Assessment of Its 

Grant Program 11

No Single Federal Agency Has Been Tasked with Coordinating 

Immigrant Integration Efforts, but Actions Are Under Way to 

Provide a Strategy and Guidelines 25

Conclusions 28

Recommendation for Executive Action 29

Agency Comments and Our Evaluation 29

Appendix I Objectives, Scope, and Methodology 31

Appendix II Examples of Federal, State, and Local Immigrant Integration Efforts 36

Appendix III Comments from the Department of Homeland Security 39

Appendix IV GAO Contact and Staff Acknowledgments 41

Tables

Table 1: USCIS Programs and Activities That Aim to Support Civic 

Integration of Immigrants 7

Table 2: Sources and Uses of OoC Budget Funds for Fiscal Years 

2009 through 2011 8

Table 3: Federal Programs by Immigrant Integration Area Category 10

Table 4: Examples of OoC Publications and Web-Based Resources 

to Help Immigrants Prepare for Citizenship 13

Table 5: OoC’s Reporting Requirements for the Citizenship and 

Integration Grant Program’s Grantee Activities, Fiscal 

Years 2009 through 2011 19

Contents
Page ii GAO-12-274 Immigrant Integration

Abbreviations

DHS Department of Homeland Security

OoC Office of Citizenship 

USCIS U.S. Citizenship and Immigration Services

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Page 1 GAO-12-274 Immigrant Integration

United States Government Accountability Office

Washington, DC 20548

December 16, 2011

The Honorable Bennie G. Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

Dear Mr. Thompson:

Immigration is a major force affecting this country’s social and economic 

development, and welcoming lawful immigrants reflects one of the 

nation’s distinctive characteristics. In 2009, it was estimated that about 39 

million foreign-born individuals lived in the United States, making up more 

than 12 percent of the U.S. population—the largest share since 1920.1 Of 

these, approximately 17 million were naturalized citizens;

2 11 million were 

temporary or permanent residents with lawful status; 3

 

1 Congressional Budget Office, A Description of the Immigrant Population: An Update

(Washington, D.C.: June 2011).

and 11 million were 

noncitizens without lawful immigration status. Integrating about 11 million 

noncitizens with lawful immigration status into American society, with the 

possibility of integrating potentially millions more if Congress passed 

comprehensive immigration reform, would be a challenging task and

raises questions about how this would be accomplished and by whom. 

Immigrant integration is generally described as a process that helps 

immigrants achieve self-sufficiency, political and civic involvement, and 

social inclusion in American communities. Numerous governmental and 

2 A naturalized citizen is a foreign-born individual who has become a U.S. citizen through 

the naturalization process, by fulfilling requirements set forth in the Immigration and

Nationality Act, including, in most cases, having resided in the United States as a lawful 

permanent resident for at least 5 years. As part of the naturalization process, applicants 

must first be eligible for naturalization. They must complete an application for 

naturalization (N-400), appear for an interview, pass an English and civics test (in most 

cases), and take an oath of allegiance at a naturalization ceremony.

3 Lawful permanent residents may be eligible to naturalize, while temporary residents are

authorized to live and work in the United States for a limited period of time and are not 

eligible to naturalize. Temporary residents do not include visitors, such as those with valid 

tourist visas, and they are not included in the total estimate of 39 million foreign-born 

individuals living in the United States. Noncitizens without lawful immigration status are 

those individuals who are in the country without legal authorization either because they 

entered illegally or entered legally with a valid visa but overstayed their authorized time in 

the country.

 
 

Page 2 GAO-12-274 Immigrant Integration

nongovernmental organizations provide some form of immigrant 

integration support. The Department of Homeland Security’s (DHS) U.S. 

Citizenship and Immigration Services (USCIS) has responsibility for a key 

immigrant integration-related area—the naturalization and citizenship 

process.4 The Office of Citizenship (OoC) within USCIS is responsible for 

implementing immigrant integration activities that fall within the 

naturalization and citizenship process. The primary focus of these 

activities is to prepare lawful permanent residents for citizenship by, 

among other things, helping them attain the English language skills and 

civics knowledge required for naturalization.5

You asked us to review the extent to which the federal government has 

programs in place to support and coordinate immigrant integration 

activities. In response to your request, this report discusses the programs 

and activities at USCIS. Specifically, it examines (1) what steps USCIS 

OoC aims to accomplish 

this by awarding grants to help immigrant-serving organizations with 

citizenship preparation programs, conducting outreach and public 

education activities to promote integration and citizenship, and developing 

educational materials on the naturalization process. The largest single 

activity that accounted for nearly half of OoC’s budget over the past 3 

years was its Citizenship and Integration Grant Program, which provides 

competitive grants to public and private nonprofit organizations to 

facilitate their ability to assist lawful permanent residents in becoming 

naturalized U.S. citizens. In addition to USCIS, other federal agencies 

provide some assistance for immigrant integration. For example, the 

Department of Health and Human Services provides economic integration 

assistance as part of its Refugee Resettlement program and the 

Department of Education provides funding to states to support linguistic 

integration in connection with its English language acquisition grants. In 

addition, various state and local governments and nongovernmental 

organizations provide an array of services that assist with the integration 

process.

 

4 The term nongovernmental organization includes, among other things, educational 

institutions, for-profit firms, and nonprofit firms, such as voluntary organizations.

5 As part of the citizenship and naturalization process, with limited exceptions, immigrants 

must show that they can read, write, and speak English; and have a basic knowledge of 

U.S. history and government (i.e., civics). A lawful permanent resident is any person who 

is not a citizen of the United States who has been lawfully accorded the privilege of 

residing permanently in the United States as an immigrant in accordance with the 

immigration laws, such status not having changed. See 8 U.S.C. § 1101(a)(20).
 

Page 3 GAO-12-274 Immigrant Integration

has taken to implement immigrant integration programs and the extent to 

which it has assessed the effectiveness of its grant program, and (2) what

federal mechanism exists to coordinate governmental and 

nongovernmental immigrant integration efforts.

To determine the steps USCIS has taken to implement immigrant 

integration programs and the extent to which it has assessed its grant 

program, we reviewed the Homeland Security Act of 2002,6 and 

examined documentation on mission objectives and performance 

measures identified by DHS and USCIS on immigrant integration. These 

included DHS’s strategic plan for fiscal years 2008 through 2013, 2010 

Quadrennial Homeland Security Review Report,

7 Budget in Brief reports 

for fiscal years 2011 and 2012,8 and annual performance reports;9

USCIS’s strategic plan, strategic goals, and initiatives; and USCIS’s 

Citizenship and Integration Grant Program requirements and guidance.10

 

6 Pub. L. No. 107-296, 116 Stat. 2135.

We interviewed senior officials from DHS’s Office of Policy Development 

and USCIS offices, including OoC, the Office of Public Engagement, the 

Office of Policy and Strategy, and the Field Operations Directorate to 

discuss their roles and responsibilities related to immigrant integration. 

Further, we selected a nongeneralizable sample of 10 locations for site 

visits and telephone interviews. Using estimates from the U.S. Census 

Bureau’s 2010 American Community Survey and data from DHS’s Office 

of Immigration Statistics, we selected these 10 locations based on various 

factors, including the total number of foreign-born residents, whether the 

region had a mixture of nationalities, the number with limited English 

proficiency, the number of lawful permanent residents eligible for 

naturalization, and recognition accorded to locations’ immigrant 

integration programs. We made site visits to Baltimore, Maryland; 

7 DHS, Quadrennial Homeland Security Review Report: A Strategic Framework for a 

Secure Homeland (Washington, D.C.: February 2010).

8 DHS, DHS Budget in Brief Fiscal Year 2011 (Washington, D.C.: 2010), and DHS Budget 

in Brief Fiscal Year 2012 (Washington, D.C.: 2011).

9 The Quadrennial Homeland Security Review replaced the DHS strategic plan on 

February 1, 2010. 

10 DHS, USCIS Office of Citizenship, Grant Reviewer Manual: A Guide to Reviewing the 

FY2010 Citizenship and Integration Grant Program Proposals and Objective Review Plan 

for the Fiscal Year 2010 Citizenship and Integration Grant Programs (Washington, D.C.: 

2010).
 

Page 4 GAO-12-274 Immigrant Integration

Chicago, Illinois; Los Angeles, California; and Washington, D.C., and 

conducted in-person interviews with USCIS officials from four district and 

field offices; representatives from 10 nongovernmental organizations, 

including grantees and subgrantees; and officials in government 

immigrant integration offices about their efforts to foster immigrant 

integration. We also conducted semistructured telephone interviews with 

city government officials in New York, New York; Boston, Massachusetts; 

Richmond, Virginia; Seattle, Washington; Houston, Texas; and Miami, 

Florida; and discussed their initiatives and efforts to foster immigrant 

integration. Our site visit and telephone interview results cannot be 

generalized to other locations, but they provided us with valuable insights 

about actions USCIS has taken to support immigrants’ integration, how 

USCIS grant recipients are using award funds to support integration, and 

actions taken by city governments to address integration needs. We 

reviewed documentation on USCIS’s outreach efforts, educational 

resources, fiscal year 2009 grant program results, and grantees’ fiscal 

year 2010 quarterly performance reports to USCIS.11 We compared 

USCIS’s mechanisms for assessing the results of its grant program 

against Standards for Internal Control in the Federal Government, which 

states, among other things, that managers should assess the quality of 

performance over time and determine proper actions in response to 

findings. We also compared them against GAO guidance on performance 

measurement and evaluation.12

To determine what federal mechanism exists to coordinate governmental 

and nongovernmental immigrant integration efforts, we reviewed the 2008 

report of the presidentially commissioned Task Force on New Americans, 

which included recommendations on providing leadership in immigrant 

integration and the extent to which the recommendations have been 

implemented. We also reviewed DHS reports, such as OoC’s 2010 report, 

We reviewed all of OoC’s immigrant 

integration programs and focused on the grant program because it was 

OoC’s single largest budget activity and the program for which it collected 

some data on outcomes; that is, the extent to which lawful permanent 

residents who were served by OoC grantees passed the naturalization 

examination and naturalized.

 

11 USCIS uses data on performance measures that grantees collect to track their progress 

in meeting performance goals outlined in their grant proposals.

12 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 
 

Page 5 GAO-12-274 Immigrant Integration

Improving Federal Coordination on Immigrant Integration, and its 2004 

report, Helping Immigrants Become New Americans: Communities 

Discuss the Issues, to identify DHS’s findings on the extent to which 

federal leadership is needed, and in what areas. We reviewed DHS’s 

Quadrennial Homeland Security Review Report and the annual reports 

and strategic plans of DHS, USCIS, and OoC to identify DHS’s goals for 

providing federal leadership. Further, we interviewed key officials from 

DHS’s Office of Policy Development and USCIS offices, including OoC, 

the Office of Public Engagement, the Office of Policy and Strategy, and 

the Field Operations Directorate, to identify existing federal leadership 

and coordination activities for immigrant integration throughout the 

department. We interviewed officials in the four USCIS field offices 

mentioned above to identify the federal leadership role played by USCIS 

field offices on a local level. We met with city officials and communitybased organization representatives in each of the cities where the four 

USCIS field offices are located and conducted semistructured telephone 

interviews with city government officials in the six additional cities 

mentioned above to obtain their perspectives on the role of the federal 

government in supporting immigrant integration. The information from the 

interviews is not generalizable to all cities or community-based 

organizations, but provided valuable insights into how such organizations 

view the federal government’s support of immigrant integration.

We conducted this performance audit from September 2010 through 

November 2011 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. Appendix I 

contains additional details about our scope and methodology.
 

Page 6 GAO-12-274 Immigrant Integration

Through OoC, USCIS manages the programs and activities within DHS 

that are most directly associated with the civic integration of immigrants.13

Created by the Homeland Security Act of 2002, OoC’s mandate is to 

promote instruction and training on citizenship responsibilities for 

immigrants interested in becoming naturalized citizens of the United 

States.14 To accomplish this, OoC competitively awards grants to help 

immigrant-serving organizations implement citizenship preparation 

programs aimed at promoting civic integration through naturalization; 

conducts outreach and public education activities to promote and raise 

awareness of citizenship and immigrant integration; and develops 

educational resources on the naturalization process for lawful permanent 

residents and organizations that help prepare immigrants for citizenship. 

Outreach activities may include providing technical assistance to 

providers of citizenship education services; conducting training 

workshops for adult educators and volunteers on how to prepare 

immigrants for citizenship; making presentations to educate and inform 

immigrants about the process of becoming a U.S. citizen; and attending 

conferences, organizing special naturalization ceremonies, and 

participating in public events to help promote an awareness of citizenship 

and immigrant integration. Table 1 summarizes USCIS’s programs and 

activities that aim to support the citizenship aspect of immigrant 

integration and the goals for those programs and activities.

 

13 According to USCIS officials, in order to help achieve its overall goal of supporting 

immigrants’ integration and participation in American civic culture, USCIS aims to foster a 

deeper understanding of United States history and the basic civic values that unite 

Americans when preparing immigrants to pass the U.S. citizenship test. 

14 Section 451(f) of the Homeland Security Act created the Chief of the Office of 

Citizenship position within USCIS and made the Chief responsible for promoting 

instruction and training on citizenship responsibilities for immigrants interested in 

becoming naturalized citizens of the United States, including the development of 

educational materials. See Pub. L. No. 107-296, § 451(f), 116 Stat. at 2197 (codified at 6 

U.S.C. § 271(f)).

Background 

U.S. Citizenship and 

Immigration Services’ Role 

in the Civic Integration of 

Immigrants
 

Page 7 GAO-12-274 Immigrant Integration

Table 1: USCIS Programs and Activities That Aim to Support Civic Integration of Immigrants

Programs and activities Immigrant integration goals

Citizenship and Integration Grant Programa

Provide competitive grants to public and private nonprofit organizations to 

facilitate their ability to assist lawful permanent residents in becoming naturalized 

U.S. citizens. 

To expand the availability of quality citizenship 

preparation programs that can have an effect on 

an immigrant’s integration experience through 

(1) civics-focused English as a second language 

instruction, (2) U.S. history and government (i.e. 

civics), instruction and (3) naturalization 

application preparation assistance.

Citizenship Outreach –

Participate in national, regional, and local events for immigrants and immigrantserving organizations to engage stakeholders on citizenship and civic integration 

issues.

Citizenship Public Education and Awareness Initiative – 

Raise awareness about the rights, responsibilities, and importance of U.S. 

citizenship and the free educational tools and resources available to help eligible 

lawful permanent residents prepare for citizenship through outreach, 

organizational partnerships, and paid media through print, radio, and digital 

advertisements and a public service announcement video.

Teacher training workshops – Provide professional development and 

educational assistance to adult educators and community and faith-based 

organizations that teach and prepare immigrants for the naturalization process.

Naturalization information sessions – Provide free public information sessions, 

including videos and mock interview demonstrations, to help immigrants learn 

about naturalization eligibility, testing, and citizenship rights and responsibilities.b

Naturalization ceremonies – Celebrate the meaning and value of citizenship to 

immigrants.c

To provide information and support to a broad 

range of stakeholders on topics such as immigrant 

integration and its linkage to the citizenship and 

naturalization process. To serve as an opportunity 

to disseminate information on naturalization 

eligibility and on USCIS’s citizenship education 

programs and activities.

Educational Resources on the Naturalization Process

The Citizenship Resource Center – Provide information (1) to learners on 

educational materials available to prepare for the naturalization interview and 

English and civics portions of the naturalization test, (2) to adult educators and 

volunteers on basic strategies for teaching citizenship and the free materials for 

use in the classroom, and (3) on building organizational capacity to provide 

citizenship preparation services in communities.

Pamphlets and printed educational materials – Provide information on the 

naturalization process and the rights, responsibilities, and benefits of citizenship.

To assist lawful permanent residents with 

acquiring the knowledge and necessary skills to 

become a U.S. citizen by, among other things, 

making resources available to immigrants that will 

provide a deeper understanding of U.S. history 

and government, the naturalization process, U.S. 

citizenship benefits, and settlement and 

participation in the community. To assist adult 

educators and volunteers to improve their content 

knowledge on citizenship and teach them 

strategies for enhancing their citizenship 

instruction programs.

Sources: GAO analysis of agency documentation and interviews with agency officials.

a

Although the Citizenship and Integration Grant Program has no authorizing statute, the grant 

program was established in fiscal year 2009 pursuant to the Consolidated Security, Disaster 

Assistance and Continuing Appropriations Act, 2009 (Pub. L. No. 110-329, 122 Stat. 3574), which 

included $1.2 million for competitively awarded grants to organizations promoting the rights and 

responsibilities of citizenship. In fiscal year 2010, USCIS changed the name of its grant program from 

“Citizenship” to “Citizenship and Integration.” 

b

Naturalization information sessions are carried out primarily by community relations officers and 

other field office personnel within district and field offices.

c

USCIS conducts naturalization ceremonies as part of its efforts to achieve its objective on ensuring 

that the naturalization process is a meaningful experience.
 

Page 8 GAO-12-274 Immigrant Integration

To implement its immigrant integration programs and activities, OoC uses 

funds from two sources—funds that are provided through the 

appropriations process and funds that are allocated from USCIS’s 

Immigration Examinations Fee Account. This account consists of fees 

that USCIS collects from persons filing for immigration benefits (for 

example, the fees charged to persons who file for naturalization) and 

deposits into the fee account. As shown in table 2, OoC uses 

(1) appropriated funds to support its grant program, including the grant 

awards, grant program staff salaries and other grant administration 

expenses, as well as citizenship public education and awareness 

activities and (2) fee account funds for non-grant program staff salaries 

and expenses, and activities including citizenship educational materials 

development and dissemination, teacher training, naturalization test 

implementation, and other operational expenses. Importantly, nearly half 

of OoC’s budget over the past 3 years—$19.8 million of $42.6 million (46 

percent)—was allocated to its grant program, which includes the funds 

awarded and program administration and operational expenses for the 

grant program.

Table 2: Sources and Uses of OoC Budget Funds for Fiscal Years 2009 through 2011 

Dollars in millions

Fiscal year 

2009

Fiscal year 

2010

Fiscal year 

2011

Three-year 

total budget

OoC’s total budget $7.6 $17.0 $18.0 $42.6

Sources and uses of funds

Appropriated funds $1.2 $11.0 $11.0 $23.2

Citizenship and Integration Grant Program funds awarded $1.2 $8.1 $9.0 $18.2

Grant program staff salaries-(full-time equivalents (FTE)) $0

(0 FTE)

$0.3

(6 FTE)

$0.7

(6 FTE)

$1.0

Grant program administration and operational expenses $0 $0.3 $.3 $0.6

Citizenship Public Education and Awareness Activities $0 $2.4 $1.0 $3.4

USCIS fee account funds $6.4 $6.0 $7.0 $19.4

Salaries $2.2

(17 FTE)

$2.2

(16 FTE)

$2.3

(19 FTE)

$6.7

Citizenship educational resources (development, design, 

translation, printing, dissemination)

$2.8 $2.9 $3.8 $9.5

Teacher training workshops $0.1 $0.1 $0.1 $0.3

Other operation expenses (travel, training, supplies, equipment) $0.8 $0.6 $0.6 $2.0

Naturalization test implementation $0.5 $0.2 $0.1 $0.8

Source: USCIS.

Note: Numbers may not add to totals because of rounding.
 

Page 9 GAO-12-274 Immigrant Integration

In addition to OoC’s immigrant integration activities, USCIS’s Office of 

Public Engagement and community relations officers within USCIS’s 

district and field offices devote a portion of their time to conducting 

citizenship-related outreach activities. Specifically, the Office of Public 

Engagement assists OoC with carrying out its citizenship outreach 

initiatives on a national level and, at the local level, USCIS districts are 

required each quarter to conduct at least one citizenship-related outreach 

activity in the form of a naturalization information session.

Providing immigrant integration support to immigrants is a multifaceted 

effort that is dispersed across governmental and nongovernmental 

sectors. At the federal level, a wide array of federal programs provide 

assistance to immigrants and support various aspects of immigrant 

integration, but those programs are not specifically categorized as directly 

supporting integration. Based on data that the Office of Management and 

Budget collected in September 2010, 13 federal agencies across the 

federal government reported offering a total of 79 programs that either 

directly or indirectly supported immigrant integration.15 These federal 

agencies self-identified programs they perceived as supporting immigrant 

integration because, according to OoC, there is no standard 

programmatic definition for immigrant integration. As part of OoC’s review 

of these data, it placed these 79 programs into four categories it identified 

as broad areas of immigrant integration, as shown in table 3.

 

15 In September 2010, the Office of Management and Budget tasked OoC with analyzing 

budget and programmatic information that the Office of Management and Budget collected 

from federal agencies on federal programs that directly and indirectly supported immigrant 

integration.

Immigrant Integration 

Efforts Are Multifaceted 

and Carried Out by 

Governmental and 

Nongovernmental 

Organizations
 

Page 10 GAO-12-274 Immigrant Integration

Table 3: Federal Programs by Immigrant Integration Area Category

Immigrant integration 

category Category definition and general description

Total number of 

programs

Civic Occurs when all community members belong, are secure in their rights, can 

exercise their liberties, and share ownership for the community’s future.

12

Economic Occurs when all workers are prepared to meet the challenges of the 21st century 

workplace, understand their rights as part of the labor force, are empowered with 

the tools to excel up career ladders and obtain economic self-sufficiency, and are 

employed in workplaces that are fair–fostering a level playing field for all workers—

and diverse, healthy, and safe environments where every worker’s contribution is 

respected.

25

Linguistic Occurs when all non-English-proficient individuals have acquired the necessary 

English language skills and related cultural knowledge in order to meaningfully 

participate and fully contribute to their community.

8 

Health and social 

services, nutrition, 

administrative, and legal

Occurs when immigrants’ integration is focused on other aspects of integration that 

are not related to civic, economic, or linguistic integration. 

34

Source: GAO analysis of agency documents.

The federal programs reported providing immigrant integration support 

by, among other things, making grants, establishing partnerships, and 

providing direct services. Civic integration included OoC’s citizenship 

programs; economic integration included refugee resettlement assistance 

provided by the Department of Health and Human Services; and linguistic 

integration included English language acquisition grants provided to 

states by the Department of Education.16 The data do not represent all 

federal programs that support immigrant integration and do not provide a 

complete estimate of federal funding because a number of programs did 

not report a funding amount. Additionally, agency officials self-identified 

the programs they perceived as supporting integration.17

 

16 These programs represent examples of the 79 federal programs that agencies selfreported as supporting immigrant integration to the Office of Management and Budget. 

Further, the 

information collected by the Office of Management and Budget included 

some programs that served the general population but included immigrant 

populations as a subset. For example, the Department of Agriculture’s 

National School Lunch Program offers low-cost or free lunches to children 

from low-income families, which includes immigrants and nonimmigrants. 

17 OoC identified other agencies with programs supporting immigrant integration that did 

not respond to the data request.
 

Page 11 GAO-12-274 Immigrant Integration

Additional examples of federal, state, and local immigrant integration 

programs and efforts are described in appendix II.

From 2008 to 2011, OoC reported conducting more than 300 significant 

outreach events to promote citizenship awareness and civic integration 

and establish partnerships with governmental and nongovernmental 

organizations to help encourage immigrants’ civic integration. Significant 

outreach efforts could include conferences, special naturalization 

ceremonies organized by OoC, meetings and training events, and 

presentations to encourage immigrants to become more integrated into 

American civic culture. Based on OoC’s fiscal year 2011 quarterly reports, 

examples of its significant outreach activities included meetings with 

representatives from the Colorado Immigrant Rights Coalition to discuss 

state and local immigrant integration initiatives and discussions with the 

Colorado African Organization on OoC’s tools and how they could be 

used to promote citizenship and immigrant integration. OoC also met with 

the National League of Cities’ to discuss how OoC can provide support in 

their efforts to promote citizenship and immigrant integration.

OoC reported that since fiscal year 2008, it has held 86 citizenship 

education training workshops for nearly 6,000 adult educators and 

volunteers working with immigrants across the country. OoC training 

workshops are designed to enhance the skills needed to teach U.S. 

history, civics, and the naturalization process to immigrant students. For 

the 36 requests for training workshops that OoC reported receiving in 

USCIS Has Developed 

and Implemented 

Programs to Support 

Immigrant Integration 

but Could Strengthen 

Assessment of Its 

Grant Program

USCIS Conducts Outreach 

and Develops Resources 

for Citizenship and 

Naturalization
 

Page 12 GAO-12-274 Immigrant Integration

fiscal year 2011, it conducted 32 training workshops across 22 states.18

In addition to OoC, the community relations officers in USCIS district and 

field offices conduct citizenship outreach. USCIS field offices reported 

that during fiscal year 2011, they held 444 naturalization information 

sessions for more than 22,600 attendees. All representatives we 

interviewed from 18 governmental and nongovernmental organizations, 

including grantees and subgrantees, told us that USCIS’s naturalization 

information sessions have helped reach lawful permanent residents 

eligible to naturalize and influenced their preparation for and decision to 

become citizens. USCIS has also sponsored special naturalization 

ceremonies across the country, and since 2006, it has partnered with the 

National Park Service to hold ceremonies at 22 national park sites.

In 

fiscal year 2011, as part of its Citizenship Public Education and 

Awareness Initiative, OoC launched public service announcements to 

raise awareness about the rights, responsibilities, and importance of U.S. 

citizenship and the free educational tools and resources available to help 

eligible permanent residents prepare for citizenship.

19

OoC offers a variety of free publications and web-based resources to 

educate immigrants on the citizenship and naturalization process; help 

adult educators and organizations prepare immigrants for acquiring 

citizenship; and help facilitate a smoother transition for immigrants into 

their communities. Some examples of the publications and web-based 

resources offered by OoC and agencies with which OoC has formed 

partnerships to develop and enhance these resources are provided in 

table 4.

 

18 States where OoC offered training workshops in fiscal year 2011 were Arizona, 

Arkansas, California, Colorado, Florida, Georgia, Indianapolis, Iowa, Kentucky, Maine, 

Minnesota, Mississippi, New Hampshire, New Mexico, New York, Ohio, Oregon, 

Pennsylvania, South Carolina, Tennessee, Texas, and Washington. 

19 USCIS conducts naturalization ceremonies to help achieve its objective of ensuring that 

the naturalization process is a meaningful experience and its overall goal of supporting 

immigrants’ integration and participation in American civic culture. 
 

Page 13 GAO-12-274 Immigrant Integration

Table 4: Examples of OoC Publications and Web-Based Resources to Help Immigrants Prepare for Citizenship

Resource Description Partnering agencies

U.S. Citizenship Welcome Packet For all new citizens, the welcome packet includes the 

U.S. passport application from the Department of State 

and A Voter’s Guide to Federal Elections from the U.S. 

Election Assistance Commission. The packet also 

includes information on updating Social Security 

records following naturalization and understanding 

employment practices.

Department of State, U.S. 

Election Assistance Commission, 

Social Security Administration, 

and Department of Justice

Preparing for the Oath: U.S. History and 

Civics for Citizenship

This is an interactive web-based learning tool intended 

to support aspiring citizens’ efforts to prepare for the 

civics portion of the naturalization test. It presents 

videos and activities that showcase artifacts from the 

Smithsonian Institution’s collections and exhibitions.a

Smithsonian Institution’s National 

Museum of American History

U.S.A. Learns - www.USALearns.org This is an online tool for individuals who want to learn or 

improve their English skills. It offers practice activities in 

listening, reading, writing, speaking, and life skills 

necessary for success at work and in the community.

Department of Education, Office 

of Vocational and Adult Education

WelcometoUSA.gov, Civics and 

Citizenship Toolkit

WelcometoUSA.gov is a comprehensive web portal 

intended to provide new immigrants and immigrantreceiving communities with information on settling in the 

United States and preparing for citizenship. The Civics 

and Citizenship Toolkit contains educational materials 

intended to help immigrants learn about the United 

States.

Partnerships under the Task 

Force on New Americansb

Welcome to the United States: A Guide 

for New Immigrants

This is a guide is intended to provide comprehensive 

information to help lawful permanent residents learn 

about the U.S. system of government and settle into 

everyday life in the United States.

Department of Education, Office 

of Vocational and Adult Education

Sources: GAO review of agency documentation and interviews with agency officials.

a

According to USCIS, this effort will be launched in February 2012.

b

Under the Task Force on New Americans, USCIS partnered with the Departments of Agriculture, 

Commerce, Defense, Education, Health and Human Services, Housing and Urban Development, the 

Interior, Justice, Labor, State, and the Treasury.

As of August 2011, OoC reported distributing over 29,000 copies of its 

Civics and Citizenship Toolkit.20

 

20 The Civics and Citizenship Toolkit contains a comprehensive guide on settling in the 

United States; civics flash cards and a video on U.S. history and government; civics 

lessons based on questions and answers on the naturalization test; the Citizen’s Almanac, 

a booklet on the declaration of Independence and Constitution of the United States; and a 

start-up guide on ideas for programs and services to help immigrants in their communities 

adjust to life in the United States and prepare for citizenship.

In March 2010, OoC distributed the 

Toolkit to all public libraries in the City of Los Angeles to help librarians 
 

Page 14 GAO-12-274 Immigrant Integration

assist eligible immigrants who are seeking naturalization. This effort was 

part of the partnership between OoC and the City of Los Angeles to 

promote citizenship and civic integration.

All representatives we interviewed from 18 governmental and 

nongovernmental organizations, including grantees and subgrantees 

serving immigrants, told us that they have used OoC’s publications to 

provide immigrants with information on becoming U.S. citizens and 

getting settled in the United States. Some also told us that they rely on 

OoC’s educational resources to provide consistent information to 

immigrants on the naturalization process, and some grant recipients 

include them in their English and citizenship classes. Some also stated 

that USCIS’s redesign of the naturalization test and OoC’s naturalization 

test study materials have helped immigrants prepare for naturalization 

and relate to basic concepts about the structure of government and 

American history. Additionally, several of the local government officials 

we spoke to indicated that because their offices often serve as 

clearinghouses for immigrant communities and refer individuals to local 

services or community-based organizations to assist them with various 

aspects of immigrant integration, including citizenship, they often access 

USCIS’s Citizenship Resource Center website for information when 

responding to immigrant requests for assistance on the naturalization 

process.

Through OoC’s Citizenship and Integration Grant Program, which 

provides support for citizenship education and naturalization preparation, 

USCIS aims to help immigrants become civically integrated members of 

their communities. USCIS officials told us that the agency’s role in 

immigrant integration is limited to involvement in civic integration, with 

programs and initiatives designed to support immigrants on the path to 

citizenship, because USCIS has no legislative directive mandating it to 

support other aspects of integration. Further, OoC officials told us that the 

agency faces uncertainty from year to year as to whether the program will 

continue to exist, as the grant program has no authorizing statute and 

USCIS Awards Grants for 

Citizenship and 

Naturalization but Could 

Strengthen Its Planning for 

Conducting Evaluations of 

Its Grant Program

USCIS Administers a Grant 

Program to Support Citizenship 

Education and Naturalization 

Preparation 
 

Page 15 GAO-12-274 Immigrant Integration

operates under annual DHS appropriations. With funding in fiscal years 

2009 through 2011, OoC provided grants to a myriad of governmental 

and nongovernmental organizations, including public school systems, 

community colleges, community and faith-based organizations, adult 

education organizations, public libraries, and literacy organizations, under 

the following grant categories:

• Direct Services Grant – Citizenship Instruction Only. This grant 

provides funding to help grantees prepare lawful permanent residents 

for the civics and English (reading, writing, and speaking) components 

of the naturalization test. Grantees are required to provide U.S. history 

and government instruction and civics-focused English as a second 

language instruction.

• Direct Services Grant – Citizenship Instruction and Naturalization 

Application Services. This grant funds activities aimed at providing the 

citizenship instruction discussed above, as well as assisting lawful 

permanent residents with completing their naturalization applications 

and preparing them for the naturalization interview.

• National Capacity Building Grant. This grant is intended to provide 

federal funding to eligible national, regional, or statewide 

organizations with multiple sites to build capacity among their local 

affiliates/members to promote immigrant integration through direct 

citizenship services to lawful permanent residents. The funds are 

intended to provide support for organizations’ program management, 

organizational capacity building, and technical assistance, as well as 

for affiliates/members to develop and implement sustainable local 

citizenship preparation programs.21

During the first year of the grant program in fiscal year 2009, OoC 

received 293 applications for citizenship grant funds and made 

competitive 1-year grant awards totaling $1.2 million to 13 organizations 

to help them improve and enhance their existing citizenship assistance 

programs. For this first year of the grant program, OoC reported that 

 

21 The national, regional, or statewide organization that submits the application is referred 

to as the principal applicant. The local affiliates/members included under the national 

capacity building grant are referred to as subapplicants. For fiscal year 2009, USCIS 

provided funding for the Direct Services grant. In fiscal year 2010, USCIS provided 

funding for (1) the Direct Services grant, and those funds could be used for citizenship 

instruction and naturalization application activities, and (2) the National Capacity Building 

grant. In fiscal year 2011, USCIS provides funding opportunities in three ways: (1) Direct 

Services – Citizenship Instruction Only, (2) Direct Services – Citizenship Instruction and 

Naturalization Application Services, and (3) National Capacity Building.
 

Page 16 GAO-12-274 Immigrant Integration

nearly 55,000 immigrants were provided outreach, received direct 

citizenship services, or both. Of the approximately 55,000 immigrants who 

received services from grantees, OoC reported that about 50,000 

received information on citizenship preparation and the rights and 

responsibilities of citizenship provided through outreach activities and it 

was estimated that at least 5,000 participated in a citizenship education 

class or received assistance with the naturalization application. 

Specifically, grantees used funds to provide services to a range of 

immigrants defined by USCIS as priority immigrant groups,

22

For fiscal year 2010, the second year of the grant program, OoC received 

365 applications and made competitive 1-year grant awards totaling 

$8 million to 56 organizations. Of these, 48 grants were awarded to help 

organizations provide direct services to lawful permanent residents, and 8 

grants were awarded to help national immigrant-serving organizations 

with member/affiliate structures provide technical assistance to increase 

the long-term capacity of the subapplicants to provide direct services to 

lawful permanent residents. As of the fourth quarter, which ended on 

September 30, 2011, these organizations reported that, for fiscal year 

2010, more than 21,480 immigrants were provided services and about 

12,747 immigrants had enrolled in a citizenship education instruction 

course. Based on quarterly reports submitted by grantees to OoC, 

grantees reported providing naturalization application services to about 

15,094 program participants of whom about 7,277 submitted an 

application for naturalization and 3,122 had naturalized. Fiscal year 2010 

was the first year that OoC awarded national capacity building grants 

specifically designed to allow organizations to establish or enhance local 

including

elderly immigrants in retirement communities in San Diego, California; 

low-income immigrants in New York; and refugees with low literacy levels 

in St. Louis, Missouri. Grantees also built community partnerships to 

strategically increase their impact. For example, one grantee in 

Providence, Rhode Island, used grant funds to strengthen a consortium of 

five immigrant-serving organizations. This consortium accounted for 28 

percent of all fiscal year 2009 naturalizations reported under the grant 

program.

 

22 Fiscal year 2009 grantees served one or more priority immigrant groups, such as soon 

to be eligible lawful permanent residents 65 years or older; refugees or those granted 

asylum; lawful permanent residents under the Violence Against Women Act (VAWA); U or 

T-Visa, or Special Immigrant Juvenile Visa holders, and other disadvantaged groups as 

defined in the grant proposal.
 

Page 17 GAO-12-274 Immigrant Integration

citizenship preparation programs through eligible service providers. 

Examples of local capacity building activities proposed by grantees 

included addressing the unmet educational needs of low-income adults 

with limited English proficiency and literacy in Atlanta, Georgia, and 

Nashville, Tennessee; Vietnamese immigrant communities in Houston, 

Texas; and refugees and immigrants in Erie, Pennsylvania, and Raleigh, 

North Carolina, among others.

For fiscal year 2011, the third year of the grant program, OoC received 

324 applications and, in September 2011, made competitive 2-year grant 

awards totaling $9 million to 42 organizations. Specifically, of the 106 

applicants for Citizenship Instruction only grants, USCIS awarded 

approximately $1.6 million to 11 organizations. Of the 195 applications for 

Citizenship Instruction and Naturalization Application services grants, 

USCIS awarded approximately $5.6 million to 28 organizations, and of 

the 23 applicants for the National Capacity Building grant, USCIS 

awarded approximately $1.8 million to 3 organizations.

Several of the grantees and subgrantees we spoke with told us that 

OoC’s grant program has helped them to, among other things, address 

their clients’ need to improve their English language skills so they can 

pass the naturalization test. In Chicago, Illinois, where we met with two 

organizations that received direct service grants, representatives from 

one organization told us it was using funds to established two additional 

citizenship instruction courses aimed at low- and preliterate Latinos with 

less than a first grade reading level. They also told us that the curriculum 

for these courses was developed to achieve a seventh grade reading 

level, which the organization identified as the level needed to pass the 

naturalization test. An additional organization had developed and 

disseminated information specifically for lawful permanent residents who

have suffered from domestic violence, persecution, and other abuses, 

which can interfere with their ability to seek assistance for acquiring 

citizenship. Another grantee in Los Angeles, California, had directed 

funds to serve lawful permanent residents who had suffered persecution, 

working with local faith-based groups to reach out to these individuals. A 

direct services grantee in Baltimore, Maryland, told us it used funds to 

sustain its ability to provide tuition-free English language and citizenship

instruction because its previous funding sources had been cut. The 

participants who we spoke with at this site said that their reasons for 

participating in the program were to learn English so they could 

communicate better and be self-sufficient and to obtain citizenship so 

they could gain better employment and higher education opportunities. 

One participant told us that the free instruction she was receiving helped 
 

Page 18 GAO-12-274 Immigrant Integration

increase her English proficiency and motivated her to seek other 

opportunities to continue learning. She also indicated that she had 

submitted an application for naturalization and continues to prepare for 

the citizenship test as a result of the citizenship instruction that she 

received.

Of the three organizations we contacted that had received funding under 

the National Capacity Building grant, representatives from one national 

capacity building organization told us they are expanding services to 

Haitians and Cubans in Greensboro, North Carolina. Representatives 

from a subgrantee told us that the grant has allowed them to access 

updated and innovative materials, curricula, and teaching methods and 

helped them to develop the capability for expanding the grantee’s 

program from providing only legal and court services to Iranians, Iraqis, 

and Armenians to also establishing the ability to provide additional 

services to clients on the path to citizenship. Representative from another 

organization told us that they planned to provide services to over 1,700 

immigrants through four subgrantees establishing citizenship services 

under the grant.

Grantees can use their Citizenship and Integration Program grant funds 

on a variety of activities. For reporting purposes, OoC classifies these 

eligible activities into (1) citizenship instruction (e.g., instruction in English 

as a second language and U.S. history and government); (2) outreach 

and training (e.g., staff and volunteer training); and (3) naturalization 

application services (e.g., assistance with preparing and completing 

naturalization applications), as shown in table 5. For each of these 

categories of activities, OoC has required grantees to collect and report 

data on program outputs, which measure the quantity of program 

activities and other deliverables, such as the number of participants 

enrolled in grantees’ citizenship instruction and naturalization preparation 

programs.23

 

23 Office of Management and Budget Circular A-11 states that output measures describe 

the level of activity that will be provided over a period of time, including a description of the 

characteristics (e.g., timeliness) established as standards for the activity. Outputs refer to 

the internal activities of a program (i.e., the products and services delivered). 

In addition to these outputs, OoC has collected some 

information on outcome measures to demonstrate the extent to which 

grantees’ programs are helping program participants complete the 

naturalization process, such as collecting data on participants’ 

naturalization examination results and the proportion of participants who 

OoC Has Measures for 

Assessing Its Grant Program 

but Could Benefit by 

Establishing Milestones for 

Planned Evaluations of the 

Program 
 

Page 19 GAO-12-274 Immigrant Integration

received grantees’ services and self-reported that they naturalized during 

the year of the grant program.24

Table 5: OoC’s Reporting Requirements for the Citizenship and Integration Grant Program’s Grantee Activities, Fiscal Years 

2009 through 2011

Grantee activities and reporting requirements

Fiscal 

year Citizenship instruction Outreach and training Naturalization application services 

2009 Activities

• English as a second language

• English literacy and civics 

education (EL/Civics), or 

Citizenship Instruction

Reporting requirement

• Number of enrolled citizenship 

education students 

Activities

• Citizenship-focused 

outreach

• Staff and volunteer 

training

Reporting requirement

• Nonea,b 

Activity

• Assistance with preparing and completing the 

naturalization process, including case 

management

Reporting requirements

• Number of naturalization applications 

submitted

• Number of lawful permanent residents served 

who passed the naturalization test

• Number of lawful permanent residents who 

naturalized

 

24 According to Office of Management and Circular A-11, outcomes describe the intended 

result of carrying out a program or activity. They define an event or condition that is 

external to the program or activity and that is of direct importance to the intended 

beneficiaries, the public, or both. 
 

Page 20 GAO-12-274 Immigrant Integration

Grantee activities and reporting requirements

Fiscal 

year Citizenship instruction Outreach and training Naturalization application services 

2010 Activities

• Civics-focused English as a 

second language instruction

• Citizenship instruction (U.S. 

history and government) to 

prepare lawful permanent 

residents for the civics and 

English reading, writing, and 

speaking components of the 

naturalization test

Reporting requirements

• Number of newly enrolled 

citizenship education students 

(lawful permanent residents only)

• Number of lawful permanent 

residents served who passed the 

naturalization test and who failed 

the test

• Countries of origin of the lawful 

permanent residents served

Activities

• Citizenship-focused 

outreach

• Staff and volunteer 

training

Reporting requirements

• Description of outreach 

efforts in narrative section 

of performance report

• Number of new volunteers 

recruited and trained

Activity

• Services including legal and case 

management services to support the 

naturalization application and interview 

process

Reporting requirements

• Number of naturalization applications 

submitted

• Number of lawful permanent residents 

provided with naturalization eligibility 

screening and legal advice

• Number of lawful permanent residents served 

who passed the naturalization test and who 

failed the test

• Countries of origin of the lawful permanent 

residents served

• Number of lawful permanent residents who 

became naturalized U.S. citizens who met the 

following criteria: (1) received naturalization 

eligibility screening and advice or (2) received 

assistance preparing the naturalization 

application
 

Page 21 GAO-12-274 Immigrant Integration

Grantee activities and reporting requirements

Fiscal 

year Citizenship instruction Outreach and training Naturalization application services 

2011 Activities

• Civics-focused English as a 

second language instruction

• Citizenship instruction (U.S. 

history and government) to 

prepare lawful permanent 

residents for the civics and 

English reading, writing, and 

speaking components of the 

naturalization test

Reporting requirements

• Number of newly enrolled 

citizenship students

• Number of students who 

completed pre- and post 

assessment tests

• Number of assessed students 

who demonstrated improvement 

on the post assessment test

• Countries of origin of the lawful 

permanent residents served

• Number of students who 

submitted a naturalization 

application with no legal services 

from the organization

• Number of lawful permanent 

residents served who passed the 

naturalization test and who failed 

the test

• Percentage of students 

demonstrating progress

• Number of classes offered

• Number of students who 

naturalized

Activities

• Citizenship-focused 

outreach

• Staff and volunteer 

training

Reporting requirements

• Description of outreach 

efforts in narrative section 

of performance report

• Number of new volunteers 

recruited and trained

Activity

• Services including legal and case 

management services to support the 

naturalization application and interview 

process

Reporting requirements

• Number of students for whom the organization 

prepared and submitted a naturalization 

application and met the following criteria: 

(1) currently enrolled or were previously 

enrolled citizenship students who submitted a 

naturalization application with the assistance 

of the organization’s legal representative or 

attorney or (2) those who were not enrolled in 

one of the organization’s citizenship classes 

and have submitted a naturalization 

application with the organization’s assistance

• Number of G-28 forms submitted (Notice of 

Entry of Appearance as Attorney or Accredited 

Representative) submitted as required when 

representing immigration matters before DHS, 

whether in person or through the preparation 

or filing of an application for naturalization by 

the organization’s legal representative or 

attorney

• Number of lawful permanent residents 

provided with eligibility screening and legal 

advice

• Countries of origins of the lawful permanent 

residents served

• Number of lawful permanent residents who 

naturalized who met the following criteria: 

(1) enrolled in one of the organization’s 

citizenship classes and received naturalization 

legal services from an accredited 

representative or attorney prior to naturalizing 

or (2) received only naturalization application 

and legal services and naturalized during the 

grant period

Source: GAO analysis of USCIS information.

a

According to OoC, for fiscal year 2009 it did not require grantees to report on outreach and training.

However some grantees collected this data and submitted it as part of their performance report to 

OoC.

b

According to OoC, the reporting requirement applied only to those grantees that provided information 

on outreach and training activities in their grant proposals.
 

Page 22 GAO-12-274 Immigrant Integration

In January 2011, USCIS reported on the results of its measures for the 

fiscal year 2009 grant program based on data submitted by grantees. 

However, USCIS identified limitations on the reported results. Specifically, 

USCIS reported that its data on the number of participants who received 

naturalization application services and passed the naturalization 

examination, and who ultimately became naturalized, were incomplete in 

part because grantees relied on data that were self-reported by program 

participants, and not all program participants reported to grantees 

whether they passed the naturalization examination and naturalized. 

Further, there was a time lag between when program participants 

received naturalization application services and when they passed their 

naturalization examinations and became naturalized. For example, 

USCIS reported that for fiscal year 2009, about 1,804 participants 

received naturalization application services and submitted a naturalization 

application during the 1-year grant performance period. Of the 1,804 

participants, OoC estimated that about 46 percent submitted the 

application during the third and fourth quarters of the year. USCIS 

reported that because its average time for completing the processing of 

naturalization applications was 4.7 months, it was possible that those 

program participants who applied for naturalization toward the end of the 

year naturalized after the grant performance period ended. USCIS did not 

ask grantees to collect information on naturalization examination results 

and the number of naturalizations of program participants that occurred 

after the grant period ended.

To help address this issue, for the fiscal year 2010 and 2011 grant 

programs, OoC provided additional guidance and technical assistance to 

grantees on how to collect and report program data. These included

holding training sessions on grant program reporting guidelines, the types 

of reports to use in collecting and reporting data on a quarterly basis, and 

strategies for compiling data and activities from the grant performance 

period to prepare and submit final reports to OoC. Additionally, OoC 

provided grantees with 3 additional months beyond the end of the grant 

performance period to collect and report information on the number of 

participants who passed the naturalization examination and naturalized.

However, USCIS continues to face two inherent challenges in collecting 

complete data on grantees’ performance. First, grantees may require 

program participants to provide them with information on their 

naturalization examination results and naturalization status. However, 

according to USCIS, it is not feasible for grantees to obtain data on the 

naturalization examination results and naturalization status for all 

participants served through grant-funded programs because, among 
 

Page 23 GAO-12-274 Immigrant Integration

other things, participants may choose not to report their results to 

grantees or may decide not to naturalize. USCIS has instructed grantees 

to develop a plan for working to obtain self-reported data for all program 

participants, but it acknowledges that grantees may not be able to obtain 

complete data from all program participants. Second, while USCIS has 

extended the time period for grantees to report program data, USCIS may 

not complete the processing of naturalization applications submitted by 

program participants near the end of the performance period, given the 

average reported application processing time of 4.7 months.

To further strengthen its measurement of the performance of its grant 

programs, USCIS announced its plan to conduct an evaluation of the 

Citizenship and Integration Grant Program in the fiscal year 2011 grant 

solicitations. However, USCIS has not yet conducted such an evaluation. 

In January 2011, USCIS drafted a statement of work for a contractor to 

refine the strategic plan for the grant program and develop an evaluation 

plan that would allow USCIS to measure the grant program’s 

performance and long-term impact, and which may provide options to 

help address these limitations. According to USCIS, it did not complete 

this statement of work or award a contract for an evaluation plan 

because, at that time, the agency was uncertain whether it would receive 

appropriations in fiscal year 2011 to continue the grant program. DHS’s 

fiscal year 2011 appropriations act, enacted in April 2011, allowed the use 

of appropriated funds for the grant program.25

In November 2011, USCIS reported that it plans to conduct an internal 

evaluation of the grant program in fiscal year 2012 by, among other 

things, assessing grantee data against stated program goals, program 

assumptions, inputs, program activities, output targets, and outcomes. 

According to USCIS, these data will be used to determine how resources, 

However, USCIS did not 

proceed with finalizing its statement of work or contracting for 

development of an evaluation plan because it was unsure of whether it 

would receive funding in fiscal year 2012 for the grant program. USCIS 

requested about $19.7 million for fiscal year 2012 to fund through 

appropriations all OoC’s programs and activities, including the grant 

program.

 

25 See Department of Defense and Full-Year Continuing Appropriations Act, 2011, Pub. L. 

No. 112-10, div. B, §§ 1101(a)(3), 1102, 1639, 125 Stat. 38, 102, 103, 145. See also 

Department of Homeland Security Appropriations Act, 2010, Pub. L. No. 111-83, 123 Stat. 

2142, 2164-65 (2009); H.R. Rep. No. 111-298, at 117 (2009) (Conf. Rep.).
 

Page 24 GAO-12-274 Immigrant Integration

activities, and outputs link together to meet short-term performance 

metrics and longer-term outcomes (program goals) of the grant program. 

Further, contingent on the availability of funds, USCIS reported that in 

fiscal year 2013 it plans to contract for an external evaluation of the 

overall grant program. USCIS intends for the contractor to examine how 

well the current evaluation methodology measures the program’s success 

in meeting its goals, identify what aspects of the program contributed to 

those achievements, and discover what barriers exist to the program 

achieving its ideal results. Additionally, USCIS intends for the contractor 

to make recommendations for improving evaluation methods for the grant 

program and the effectiveness of program administration.

Internal and external evaluations, such as those that USCIS has 

announced its intention to implement, could help the agency reassess the 

goals, objectives, and measures of its grant program, including helping to 

address inherent challenges with USCIS’s current measures, and better 

evaluate the extent to which the program is achieving those goals and 

objectives. Based on its uncertainty about whether the grant program will 

continue to receive funding, USCIS has not yet established interim 

milestones for its internal and external evaluations of the grant program, 

such as milestones for initiating and completing the evaluations. Although 

USCIS has stated its intention to conduct grant program evaluations in 

fiscal years 2012 and 2013, USCIS also announced plans for an external 

evaluation in fiscal year 2011, but as indicated, did not initiate or complete 

that evaluation. Program management standards state that successful 

execution of any program includes developing plans that include a 

timeline for program deliverables.26 Standards for Internal Control in the 

Federal Government and the Office of Management and Budget also call 

for agencies to have performance measures and indicators that are linked 

to mission, goals, and objectives to allow for comparisons to be made 

among different sets of data so that corrective actions can be taken if 

necessary.27

 

26 The Project Management Institute, The Standard for Program Management (2006).

Further, according to USCIS, a program-specific evaluation 

of the grant program is a good way to objectively determine whether the 

current program framework is achieving stated program goals, whether 

grantees meet desired performance outcomes, how various program 

implementation characteristics might correlate to other indicators of 

program success, and whether the grant program should continue. To the 

27 See GAO/AIMD-00-21.3.1. 
 

Page 25 GAO-12-274 Immigrant Integration

extent that USCIS receives funding in fiscal years 2012 and 2013 for the 

grant program, initiating the planned internal and external evaluations 

could provide USCIS with a mechanism for better evaluating its grant 

program. By setting interim milestones for these evaluations, USCIS 

could strengthen its planning efforts to develop and implement the 

evaluations.

To date, no single federal entity has been designated to lead the creation, 

implementation, and coordination of a national immigrant integration 

capability. Immigrant integration efforts are dispersed across federal, 

state, and local governments, as well as nongovernmental organizations. 

In the absence of federal coordination, officials in city governments and 

representatives from nongovernmental organizations told us that they

faced challenges in carrying out their immigrant integration efforts. For 

example, one representative of a community-based nongovernmental 

organization said that immigrant integration efforts vary in different 

regions in the country, and that it would be helpful if the federal 

government had better guidelines on what constitutes immigrant 

integration and what is expected of organizations providing immigrant 

integration services. Another nongovernmental organization 

representative noted that a lack of coordination in immigrant integration 

has resulted in a number of nonprofit organizations competing for funds, 

such as for language classes serving noncitizens with different levels of 

English proficiency. Additionally, government officials for three cities 

noted that in the absence of federal guidance for immigrant integration, 

state and local governments have been setting immigration policies 

independently, some of which set a negative tone toward immigrants, 

making it difficult to successfully integrate immigrants. Officials in one of 

the three cities added that this may adversely affect the attitudes of 

immigrant populations toward government, even when the immigrants do 

not reside in those places.

Our previous work has highlighted the benefits of actions that selected 

federal agencies have taken to enhance and sustain collaborative efforts, 

including the ability to leverage resources, improve quality, and expand 

services.28

 

28 GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, 

All representatives we interviewed from 15 governmental and 

GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

No Single Federal 

Agency Has Been 

Tasked with 

Coordinating 

Immigrant Integration 

Efforts, but Actions 

Are Under Way to 

Provide a Strategy 

and Guidelines
 

Page 26 GAO-12-274 Immigrant Integration

nongovernmental offices indicated a need for a national immigrant 

integration strategy, federal coordination for immigrant integration efforts, 

or both. For example, some representatives said that the federal 

government could help stakeholders forge nationwide partnerships and 

learn about best practices, and that a national strategy would help 

develop a more consistent approach to immigrant integration. Also, 

organizations such as the Migration Policy Institute, the National League 

of Cities, and the Massachusetts Immigrant and Refugee Advocacy 

Coalition have called for a federal immigrant integration strategy.

There has been recognition that improved coordination of immigrant 

integration efforts would be beneficial, and there have been calls at the 

federal level to develop a national immigrant integration capability. For 

example, in 2006, a presidential executive order established a task force, 

chaired by the Secretary of Homeland Security and comprising 

representatives from 11 federal departments, including DHS, to provide 

direction to the federal government and make recommendations to the 

President on immigrant integration. The task force was also to provide 

direction to executive departments and agencies on integration, 

particularly through instruction in English, civics, and history. The task 

force’s 2008 report called for a national integration effort and stated that 

federal institutionalization of immigrant integration would lend credibility 

and support to federal, state, and local governments and other sectors of 

society. DHS officials said that DHS facilitated the task force’s activities 

and led the effort to produce a final report, but no agency was designated 

as the leader for a national immigrant integration effort. The task force, 

while still technically active, has not met since the issuance of the report 

in December 2008, according to DHS officials. Additionally, DHS’s 2010 

Quadrennial Homeland Security Review Report states that one of DHS’s 

goals is to strengthen and effectively administer the immigration system 

by promoting the integration of lawful immigrants. This is to be carried out 

by providing leadership, support, and opportunities to immigrants to 

facilitate their integration into American society. The Quadrennial 

Homeland Security Review Report notes that immigrant integration 

requires leadership, but it does not delineate a framework for 

accomplishing this. Instead, the Quadrennial Homeland Security Review 

Report notes that homeland security-related functions are dispersed and 

decentralized and DHS is just one of several components involved in 

carrying out the Quadrennial Homeland Security Review’s strategic 

framework. OoC officials told us that coordinating immigrant integration 

activities nationwide could help immigrants navigate federal programs, 

contribute to the development of a federal strategy and policy guidance, 

help set measurable goals for immigrant integration, create opportunities 
 

Page 27 GAO-12-274 Immigrant Integration

for the federal government to liaise with state governments and 

nongovernmental organizations, and facilitate sharing best practices and 

leveraging public-private partnerships.

We previously reported that achieving meaningful national results in many 

policy and program areas requires a combination of coordinated efforts 

among various actors across federal agencies and among state, local, 

and nongovernmental organizations.29

As a result of OoC’s 2010 report to the Office of Management and 

Budget, which called for developing a federal strategy on immigrant 

integration, the White House Domestic Policy Council convened a group 

to focus on immigrant integration.

Such coordination requires 

leadership commitment, agreed-upon goals and strategies, clearly 

identified roles and responsibilities, and compatible policies and 

procedures to be effective. USCIS officials stated that they believe that 

DHS is uniquely situated to coordinate a multiagency effort given its 

competencies in areas such as immigration services, immigrant 

integration resources, enforcement, community security, among other 

things. For example, according to USCIS officials, the agency has access 

to all foreign-born individuals going through the U.S. immigration process. 

USCIS has also established relationships with a number of 

nongovernmental organizations involved in immigrant integration through 

OoC’s outreach efforts and its grant program. Further, USCIS has 

engaged in dialogue at the local level and established partnerships at the 

local level. For example, USCIS and the City of Los Angeles signed a 

2010 letter of agreement to promote citizenship awareness, education, 

and outreach events throughout the city. USCIS officials acknowledged 

that USCIS’s resources and authority for undertaking such an effort are 

limited. The officials also said that since the release of the presidential 

task force’s 2008 report, DHS’s role in immigrant integration has been 

limited to those aspects of civic integration, such as citizenship and 

promoting the rights and responsibilities of citizenship, discussed earlier 

in this report.

30

 

29 GAO, The Upcoming Transition: GAO’s Efforts to Assist the 111th Congress and the 

Next Administration, 

OoC noted that the council formed the 

Interagency Working Group on the Federal Role of Immigrant Integration 

GAO-08-1174T (Washington, D.C.: Sept. 24, 2008).

30 We were unable to meet with officials from the White House Domestic Policy Council 

for the purposes of this report.
 

Page 28 GAO-12-274 Immigrant Integration

in June 2010 to assess the roles and activities of the federal government 

in promoting immigrant integration and to better coordinate integration 

efforts across agencies. According to DHS officials, USCIS is an active 

participant but not the lead agency in the council’s meetings.31 Based on 

OoC’s 2010 report to the Office of Management and Budget, the working 

group developed recommendations in support of a federal integration 

strategy and consolidation of informational resources, programs, and 

research through interagency collaboration. OoC’s report to the Office of 

Management and Budget also stated that in late 2010, the Domestic 

Policy Council disbanded the working group and convened the New 

Americans – Citizenship and Integration Initiative consisting of several 

members of the working group, and led by the Interagency Steering 

Committee.32 The report also stated that the steering committee later 

distilled the recommendations into three key immigrant integration policy 

areas: civic integration (naturalization and civic participation), economic 

integration (employment and economic advancement opportunities), and 

linguistic integration (learning English to facilitate daily life and support 

economic and social advancement). The steering committee also 

developed a 2011 action plan to guide the development of strategic 

initiatives in the three areas. However, according to DHS officials, a 

timeline for implementation of the recommendations has not been 

finalized, and any associated budget or planning process has not yet 

started. Because the work of this group has not yet been completed, it is 

too early to know if, and to what extent, it will provide leadership for a 

national immigrant integration capability.

Integrating immigrants into American society has economic, social, and 

security implications. We found numerous examples of how USCIS’s 

integration-related programs are helping immigrant populations. In 

addition, USCIS has taken action to develop and use mechanisms for 

 

31 According to a USCIS immigrant integration strategy memo, USCIS was notified by the 

council that it was to lead the interagency coordination effort on immigrant integration. 

However, DHS officials told us that this aspect of the memo is not being implemented as 

written because USCIS does not have the authority to direct the actions of other federal 

agencies. Currently, there is no document that clarifies USCIS’s coordination leadership 

role as outlined in the memo.

32 According to OoC’s 2011 report to the Office of Management and Budget, the 

Interagency Steering Committee is composed of representatives from the Departments of 

Education, Health and Human Services, Homeland Security, Justice, and Labor, as well 

as several Executive Offices of the President.

Conclusions 
 

Page 29 GAO-12-274 Immigrant Integration

collecting information on the outputs and outcomes of its integrationrelated programs, particularly its Citizenship and Integration Grant 

Program, which is OoC’s largest single budget activity. USCIS has faced 

inherent limitations in collecting complete data on grantees’ performance 

and has stated its intention to conduct an internal and external evaluation 

of the grant program, contingent on the program receiving future 

appropriations. Establishing interim milestones for such evaluations, 

including milestones for initiating and completing the evaluations, could 

help USCIS strengthen its planning efforts for the program.

To strengthen USCIS’s plans for evaluating the Citizenship and 

Integration Grant Program, we recommend that to the extent that USCIS 

receives program funding in fiscal years 2012 and 2013, the Director of 

USCIS establish interim milestones for conducting the planned internal 

and external evaluations of the grant program.

We provided a draft of this report to DHS for review and comment on 

November 23, 2011. On December 9, 2011, DHS provided written 

comments, which are reprinted in appendix III. In commenting on the draft 

report, DHS concurred with our recommendation that USCIS establish 

interim milestones for conducting its planned internal and external 

evaluations of the grant program, and identified actions planned or under

way to implement the recommendation.

DHS stated that to the extent that USCIS receives appropriated program 

funding and is allowed to use the funding for evaluation purposes, it 

would establish interim milestones for conducting an internal evaluation of 

the grant program in fiscal year 2012 and an external evaluation of the 

grant program in fiscal year 2013. DHS also provided additional 

information on the steps that USCIS’s OoC and Office of Policy and 

Strategy will take to jointly determine the scope of the evaluations. We 

believe that DHS’s proposed actions are consistent with the intent of the 

recommendation and should help strengthen USCIS’s planning effort for 

the grant program.

DHS also provided written technical comments, which we considered and 

incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of 

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

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 30 GAO-12-274 Immigrant Integration

report date. At that time, we will send copies to the Secretary of the 

Department of Homeland Security, relevant congressional committees, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov. 

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

contact me at (202) 512-8777 or stanar@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix III.

Sincerely yours,

Richard M. Stana

Director, Homeland Security and Justice Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-12-274 Immigrant Integration

This report examines (1) the steps the U.S. Citizenship and Immigration 

Services (USCIS) has taken to implement immigrant integration programs 

and the extent to which it has assessed the effectiveness of its grant 

program and (2) the federal mechanism to coordinate governmental and 

nongovernmental immigrant integration efforts.

To determine the steps USCIS has taken to implement immigrant 

integration programs and the extent to which it has assessed the results 

of its grant program, we reviewed program activities in USCIS because 

the focus on immigrant integration ties into its mission. We reviewed the 

Homeland Security Act of 2002,1 which created USCIS’s Office of 

Citizenship (OoC) to promote instruction and training and training on 

citizenship responsibilities.2 We also examined documentation on mission 

objectives and performance measures identified by the Department of 

Homeland Security (DHS) and USCIS on immigrant integration, including 

DHS’s strategic plan for fiscal years 2008 through 2013, 2010 

Quadrennial Homeland Security Review Report,

3 fiscal years 2011 and 

2012 Budget in Brief reports,4 and annual performance report for fiscal 

years 2010 through 2012;5 USCIS’s strategic plan for fiscal years 2008 

through 2012 and fiscal year 2011 strategic goals and select initiatives; 

and USCIS’s Citizenship and Integration Grant Program requirements 

and guidance.6

 

1 Pub. L. No. 107-296, 116 Stat. 2135.

We interviewed DHS senior officials from DHS’s Office of 

Policy Development and USCIS offices, including OoC, the Office of 

2 Section 451(f) of the Homeland Security Act created the Chief of the Office of 

Citizenship position within USCIS and made the Chief responsible for promoting 

instruction and training on citizenship responsibilities for immigrants interested in 

becoming naturalized citizens of the United States, including the development of 

educational materials. See Pub. L. No. 107-296, § 451(f), 116 Stat. at 2197 (codified at 6 

U.S.C. § 271(f)).

3 DHS, Quadrennial Homeland Security Review Report: A Strategic Framework for a 

Secure Homeland (Washington, D.C.: February 2010).

4 DHS, Budget-in-Brief Fiscal Year 2011 (Washington, D.C.: February 2010), and Budgetin-Brief Fiscal Year 2012 (Washington, D.C.: February 2011).

5 The Quadrennial Homeland Security Review replaced the DHS strategic plan on 

February 1, 2010. 

6 DHS, USCIS Office of Citizenship, Grant Reviewer Manual: A Guide to Reviewing the 

FY2010 Citizenship and Integration Grant Program Proposals and Objective Review Plan 

for the Fiscal Year 2010 Citizenship and Integration Grant Programs (Washington, D.C.: 

2010).

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-12-274 Immigrant Integration

Public Engagement, the Office of Policy and Strategy, and the Field 

Operations Directorate, to discuss their roles and responsibilities in how 

the department defines and designates immigrant integration activities 

and how it identifies and addresses immigrant integration needs. We 

reviewed USCIS documentation and educational materials on the U.S. 

citizenship and the naturalization process and strategies for outreach 

activities in support of immigrant integration, including the Civics and 

Citizenship Toolkit and the WelcometoUSA.gov website.

To identify and observe USCIS’s immigrant integration activities and 

community-level efforts by cities and immigrant-serving organizations, we 

selected a nonprobability sample of 10 locations for site visits and 

telephone interviews. We visited Baltimore, Maryland; Chicago, Illinois; 

Washington, D.C.; and Los Angeles, California. We conducted 

semistructured telephone interviews with officials in New York, New York; 

Boston, Massachusetts; Richmond, Virginia; Seattle, Washington; 

Houston, Texas; and Miami, Florida. Using estimates from the U.S. 

Census Bureau’s 2010 American Community Survey and data from 

DHS’s Office of Immigration Statistics, we selected these 10 locations 

based on various factors, including the total number of foreign-born 

residents, whether the region had a mixture of nationalities, the number 

with limited English proficiency, the number of lawful permanent residents 

eligible for naturalization, and recognition accorded the locations’ 

immigrant integration programs. Additionally, we took into account the 

proximity of USCIS offices and nongovernmental immigrant-serving 

organizations, as well as organizations awarded Citizenship and 

Integration Program grant funds in fiscal years 2009 or 2010.

During our site visits, we interviewed officials in USCIS’s Baltimore, 

Chicago, Los Angeles, and Washington, D.C., district offices to identify 

the role played by these offices in implementing USCIS local immigrant 

integration activities. In these four cities, and via telephone in the other six 

cities, we interviewed representatives of 10 community-based 

organizations, including grantees and subgrantees, and officials in 

government immigrant integration offices about their efforts to foster 

immigrant integration and how local efforts benefit from federal immigrant 

integration initiatives. Although our site visit and telephone interview 

results cannot be generalized to other locations with foreign-born 

populations, they provided us with valuable insights about actions USCIS 

has taken to support immigrants’ integration, how USCIS grant recipients 

are using award funds to support integration, and actions taken by city 

governments to address integration needs. 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-12-274 Immigrant Integration

To identify the steps DHS has taken to assess the results of its immigrant 

integration efforts, we reviewed DHS documents with stated immigrant 

integration directives and performance targets, and interviewed officials 

and staff at the DHS Office of Policy Development and USCIS offices, 

including OoC, the Office of Public Engagement, the Office of Policy and 

Strategy, and the Field Operations Directorate, to obtain clarification on 

DHS’s efforts to delegate responsibilities and capture results of intraagency actions to promote immigrant integration. We reviewed immigrant 

integration accomplishments detailed and summarized in DHS’s Budget 

in Brief reports for fiscal years 2011, and 2012. We reviewed OoC’s 

tracking information for its citizenship promotion and immigrant integration 

activities. We interviewed officials in USCIS district offices in the four 

cities we visited to obtain information about their citizenship promotion 

and immigrant integration outreach activities and the methods for 

capturing activity results. To determine how OoC assesses its immigrant 

integration efforts through its Citizenship and Integration Grant Program, 

we reviewed grantee performance results during the first funding round in 

fiscal year 2009, which had a 1-year performance period. We reviewed 

grantees’ reports to OoC on the number of participants registered for 

direct services citizenship and English instruction courses, naturalization 

applications filed, and participants naturalized, and we also examined 

program results reported by grantees and results obtained via OoC staffs’ 

on-site grantee performance monitoring during this performance period. 

We interviewed OoC staff on their performance monitoring methods and 

how they supported grantees through guidance and technical assistance. 

We corroborated this information in our interviews with select grantees in 

the four selected cities. Additionally, we viewed some of the citizenship 

instruction programs, obtained grantee performance reports submitted to 

OoC, and obtained documentation on the results of OoC’s on-site grantee 

monitoring efforts. Lastly, we interviewed some individual program 

participants to learn about how the program had affected their progress 

toward the goal of becoming naturalized, their perceptions on citizenship, 

and their views on integrating into their communities. We compared 

USCIS’s information on the results of its grant program against Standards 

for Internal Control in the Federal Government, which states, among other 

things, that managers should assess the quality of performance over time 

and determine proper actions in response to findings.7

 

7 GAO, Standards for Internal Control in the Federal Government, 

We reviewed all of 

GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-12-274 Immigrant Integration

OoC’s programs and focused on the grant program because it was OoC’s 

single largest budget activity and the program that collected some data on 

outcomes, that is, the extent to which lawful permanent residents who 

were served by OoC passed the naturalization examination and 

naturalized.

To determine what federal mechanism exists to coordinate governmental 

and nongovernmental immigrant integration efforts, we reviewed the 2008 

report from the presidentially commissioned Task Force on New 

Americans to identify previous recommendations on providing leadership 

in immigrant integration and the extent to which the recommendations 

have been implemented. We reviewed DHS reports, such as OoC’s 2010 

report, Improving Federal Coordination on Immigrant Integration, and its 

2004 report, Helping Immigrants Become New Americans: Communities 

Discuss the Issues, to identify DHS’s findings on the extent to which 

federal leadership is needed, and in what areas. We reviewed DHS’s 

Quadrennial Homeland Security Review Report and the annual reports 

and strategic plans of DHS, USCIS, and OoC to identify DHS’s goals for 

providing federal leadership. We also interviewed key officials from DHS’s 

Office of Policy Development and USCIS offices, including OoC, the 

Office of Public Engagement, the Office of Policy and Strategy, and the 

Field Operations Directorate to identify the existing immigrant integration 

federal leadership and coordination activities for immigrant integration 

throughout the department. We interviewed officials in the four USCIS 

field offices mentioned above to identify the federal leadership role they 

played by USCIS field offices on a local level. We met with city officials 

and community-based organization representatives in each of the cities 

where the four USCIS field offices are located, and conducted 

semistructured telephone interviews with city government officials in the 

six additional cities mentioned above, to obtain their perspectives on the 

role of the federal government in supporting immigrant integration. The 

information from these interviews is not generalizable to all cities or 

nongovernmental organizations but provided valuable insights into how 

such organizations view the federal government’s support of immigrant 

integration. We reviewed laws and proposed legislation to identify existing 

and proposed policies for federal leadership in immigrant integration. We 

also consulted with outside researchers and reviewed their reports, 

including the Migration Policy Institute, the National League of Cities, and 

the National Conference of State Legislatures, to obtain their perspectives 

on immigrant integration issues faced by state and local governments and 

nongovernmental organizations and the extent to which the federal 

government has provided leadership in this area.
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-12-274 Immigrant Integration

We conducted this performance audit from September 2010 through 

November 2011 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
Appendix II: Examples of Federal, State, and 

Local Immigrant Integration Efforts

Page 36 GAO-12-274 Immigrant Integration

Federal agencies have at times worked together on aspects of immigrant 

integration, such as civics and English language education for 

immigrants. For example, in 2011, an amendment to a 2010 

memorandum of understanding was established between USCIS and the 

Smithsonian Institution National Museum of American History to develop 

a learning tool that supports aspiring citizens’ efforts to prepare for the 

civics portion for the naturalization test. Specifically, the National Museum 

of American History will provide instructional design and content expertise 

for the development of lesson plans and multimedia presentations that 

utilize content from the museum and other Smithsonian collections and 

will incorporate the civics questions that may be asked during the 

naturalization test.1 Separately, in 2010, USCIS provided funding to the 

National Institute for Literacy, for the expansion of the America’s Literacy 

Directory, a web-based directory about literacy programs, to incorporate 

citizenship preparation programs and classes.2 Also, as of July 2009, 

USCIS and the Department of Education had in place an interagency 

agreement to support a web-based tool for lessons in civics-and 

citizenship-oriented English language learning, according to Homeland 

Security and Educational Officials.3

State and local governments have also taken action to develop policies 

and plans to foster immigrant integration. For example, governors in 

Illinois, Maryland, Massachusetts, New York, and Washington have 

issued executive orders specifically to address immigrant integration 

issues.4

 

1 USCIS will provide funding to support this effort.

These executive orders called for establishing an advisory body 

(e.g., a committee or a council) made up of key stakeholders, such as 

state and local government officials and representatives of 

nongovernmental organizations, to make policy recommendations on 

immigrant integration. The advisory bodies have made recommendations 

2 According to USCIS, the National Institute for Literacy no longer exists and all content 

for this resource was transferred to the U.S. Department of Education. 

3 According to Education officials, USCIS also provided some funding to support this 

effort. 

4 Some states have taken other actions in support of immigrant integration. For example, 

Massachusetts, New York, have established offices that aim to administer programs that 

assist immigrants in achieving immigrant integration, including economic, social, and civic 

integration. Other states have established programs targeted at immigrant groups within 

certain state administrative offices, such as human services and labor offices. 

Appendix II: Examples of Federal, State, and 

Local Immigrant Integration Efforts
Appendix II: Examples of Federal, State, and 

Local Immigrant Integration Efforts

Page 37 GAO-12-274 Immigrant Integration

to, among other things, incorporate immigrant integration into state 

education, workforce, and financial service programs; promote English 

language proficiency and civics education; and centralize information 

available to immigrants upon their arrival to the community. A common 

objective of these executive orders was to develop policies and plans or 

recommendations to provide immigrants with the tools to become selfsufficient and contribute to their communities.

Local governments have also responded to the needs of immigrants in 

their communities in ways that address immigrant integration issues. In 

some cases, local officials serve as liaisons between city offices on 

activities that foster immigrant integration. For example, the liaisons may 

encourage offices to provide information in multiple languages on 

workforce training, library services, or other available services or to 

incorporate activities geared toward immigrants into local social service 

programs. Other local governments provide information clearinghouses 

for immigrant communities, referring individuals to local services or 

community-based organizations that can assist with various aspects of 

immigrant integration, including English and citizenship classes, legal 

services, and vocational training.

Across the country, governmental and nongovernmental organizations—

including community-based groups, social service organizations, ethnic 

associations, local public school systems, universities and community 

colleges, refugee resettlement agencies, health centers and hospitals, 

religious institutions, unions, and law firms—have joined together to form 

coalitions to advocate for and serve as resources to immigrants and 

promote their integration into American society. One example is the 

Massachusetts Immigrant and Refugee Advocacy Coalition, which seeks 

to promote the rights and integration of immigrants and refugees through 

policy analysis and advocacy, institutional organizing, training and 

leadership development, and strategic communications and consists of 

more than 130 organizations. In Illinois, more than 120 organizations—

including advocacy groups, religious institutions, and neighborhood 

associations—make up the Illinois Coalition for Immigrant and Refugee 

Rights, which seeks to promote full and equal participation in the civic, 

cultural, social, and political areas by immigrants. Both the Massachusetts 

and the Illinois coalitions are members of the National Partnership for 

New Americans, a nationwide alliance of 12 immigrant rights coalitions 

seeking to support citizenship and the integration of immigrants into 
Appendix II: Examples of Federal, State, and 

Local Immigrant Integration Efforts

Page 38 GAO-12-274 Immigrant Integration

American communities through outreach to immigrant groups, assistance 

with capacity building for small organizations in remote areas, and policy 

advocacy, among other things.5 The National Partnership for New 

Americans hosts an annual national immigrant integration conference, 

with past participation from representatives of the White House Domestic 

Policy Council, USCIS, and other governmental and nongovernmental 

organizations.6

In addition, the National League of Cities’ Municipal Action for Immigrant 

Integration program seeks to promote civic engagement and 

naturalization in cities and towns across the United States by providing 

resources and technical assistance and serving as an information 

clearinghouse for best practices. The Migration Policy Institute’s National 

Center on Immigrant Integration Policy, in partnership with the J.M. 

Kaplan Fund, is also providing annual monetary awards during a three 

year period to outstanding immigrant integration initiatives led by nonprofit 

or community organizations, businesses, public agencies, religious 

groups, or individuals. In addition to these broader initiatives, individual 

organizations in communities across the nation are involved in efforts to 

support immigrant integration, for example, through English language 

instruction, workforce development, and legal services. 

 

5 The National Partnership for New Americans consists of coalitions from California, 

Colorado, Florida, Illinois, Maryland, Massachusetts, New York, Oregon, Tennessee, 

Washington, and Wisconsin and the National Korean American Service and Education 

Consortium. 

6 GAO attended the 2010 National Immigrant Integration Conference in Boston, 

Massachusetts.
Appendix III: Comments from the Department 

of Homeland Security

Page 39 GAO-12-274 Immigrant Integration

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 40 GAO-12-274 Immigrant Integration
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 41 GAO-12-274 Immigrant Integration

Richard M. Stana, (202) 512-8777 or stanar@gao.gov

In addition to the contact named above, Evi Rezmovic, Assistant Director; 

Yvette Gutierrez-Thomas; Danielle Pakdaman; and Mya Dinh made 

significant contributions to this report. David Alexander assisted with 

design and methodology. Linda Miller provided assistance in report 

preparation, and Frances Cook provided legal support.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(440914)
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