Immigration Enforcement: Preliminary Observations on Employment Verification and Worksite Enforcement Efforts
Published: 2005-06-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The opportunity for employment is one of the most important magnets attracting illegal aliens to the United States. The Immigration Reform and Control Act (IRCA) of 1986 established an employment eligibility verification process and a sanctions program for fining employers for noncompliance. Few modifications have been made to the verification process and sanctions program since 1986, and immigration experts state that a more reliable verification process and a strengthened worksite enforcement capacity are needed to help deter illegal immigration. In this testimony, GAO provides preliminary observations from its ongoing assessment of (1) the current employment verification process and (2) U.S. Immigration and Customs Enforcement's (ICE) priorities and resources for the worksite enforcement program and the challenges it faces in implementing that program.
section_title: What GAO Found
paragraphs: The current employment verification (Form I-9) process is based on employers' review of documents presented by new employees to prove their identity and work eligibility. On the Form I-9, employers certify that they have reviewed documents presented by their employees and that the documents appear genuine and relate to the individual presenting the documents. However, document fraud (use of counterfeit documents) and identity fraud (fraudulent use of valid documents or information belonging to others) have undermined the employment verification process by making it difficult for employers who want to comply with the process to ensure they hire only authorized workers and easier for unscrupulous employers to knowingly hire unauthorized workers. In addition, the number and variety of documents acceptable for proving work eligibility has hindered employer verifications efforts. In 1998, the former Immigration and Naturalization Service (INS), now part of the Department of Homeland Security (DHS), proposed revising the Form I-9 process, particularly to reduce the number of acceptable work eligibility documents, but DHS has not yet finalized the proposal. The Basic Pilot Program, a voluntary program through which participating employers electronically verify employees' work eligibility, shows promise to enhance the current employment verification process, help reduce document fraud, and assist ICE in better targeting its worksite enforcement efforts. Yet, several current weaknesses in the pilot program's implementation, such as its inability to detect identity fraud and DHS delays in entering data into its databases, could adversely affect increased use of the pilot program, if not addressed. The worksite enforcement program has been a low priority under both INS and ICE. For example, in fiscal year 1999 INS devoted about 9 percent of its total investigative agents' time to worksite enforcement, while in fiscal year 2003 it allocated about 4 percent. ICE officials told us that the agency has experienced difficulties in proving employer violations and setting and collecting fine amounts that meaningfully deter employers from knowingly hiring unauthorized workers. In addition, INS and then ICE shifted its worksite enforcement focus to critical infrastructure protection after September 11, 2001.

section_title: Letter
paragraphs: I appreciate the opportunity to be here today to participate in this hearing  on worksite enforcement and employer sanctions efforts. As we and  others have reported in the past, the opportunity for employment is one of  the most important magnets attracting illegal aliens to the United States.  To help address this magnet, in 1986 Congress passed the Immigration  Reform and Control Act (IRCA), which made it illegal for individuals and  entities to knowingly hire, continue to employ, or recruit or refer for a fee  unauthorized workers. The act established a two-pronged approach for  helping to limit the employment of unauthorized workers: (1) an  employment verification process through which employers verify all newly  hired employees’ work eligibility and (2) a sanctions program for fining  employers who do not comply with the act. Efforts to enforce these  sanctions are referred to as worksite enforcement and are conducted by  U.S. Immigration and Customs Enforcement (ICE).
As the U.S. Commission on Immigration Reform reported, immigration  contributes to the U.S. national economy by providing workers for certain  labor-intensive industries and contributing to the economic revitalization  of some communities. Yet, the commission also noted that immigration,  particularly illegal immigration, can have adverse consequences by helping  to depress wages for low-skilled workers and creating net fiscal costs for  state and local governments. Following the passage of IRCA, the U.S.  Commission on Immigration Reform and various immigration experts have  concluded that deterring illegal immigration requires, among other things,  strategies that focus on disrupting the ability of illegal immigrants to gain  employment through a more reliable employment eligibility verification  process and a more robust worksite enforcement capacity. In particular,  the commission report and other studies have found that the single most  important step that could be taken to reduce unlawful migration is the  development of a more effective system for verifying work authorization.  In the nearly 20 years since passage of IRCA, the employment eligibility  verification process and worksite enforcement program have remained  largely unchanged. Moreover, in previous work, we reported that  employers of unauthorized aliens faced little likelihood that the  Immigration and Naturalization Service (INS) would investigate, fine, or  criminally prosecute them, a circumstance that provides little disincentive  for employers who want to circumvent the law.
My testimony today is drawn from our ongoing work for this  subcommittee to assess the employment verification process and ICE’s  worksite enforcement program. Specifically, I will discuss our preliminary  observations on (1) the current employment verification process and  (2) ICE’s priorities and resources for the worksite enforcement program  and the challenges it faces in implementing that program.
We developed these preliminary observations by reviewing federal laws  and information obtained from ICE, U.S. Citizenship and Immigration  Services (CIS), and Social Security Administration (SSA) officials in  headquarters and selected field locations. We examined regulations,  guidance, past GAO reports, and other studies on the employment  verification process and the worksite enforcement program. We also  analyzed the results and examined the methodology of an independent  evaluation of the Basic Pilot Program, an automated system through which  employers electronically check employees’ work eligibility information  against information in Department of Homeland Security (DHS) and SSA  databases, conducted by the Institute for Survey Research at Temple  University and Westat in June 2004. Furthermore, we analyzed data on  employer use of the Basic Pilot Program and on worksite enforcement and  assessed the data reliability by reviewing them for accuracy and  completeness, interviewing agency officials knowledgeable about the data,  and examining documentation on how the data are entered, categorized,  and verified in the databases. We determined that the independent  evaluation and these data were sufficiently reliable for the purposes of our  review. We conducted the work reflected in this statement from  September 2004 through June 2005 in accordance with generally accepted  government auditing standards. We plan to complete our analysis and  prepare a report for issuance later this summer.
subsections: section_title: Background
paragraphs: The Illegal Immigration Reform and Immigrant Responsibility Act  (IIRIRA) of 1996 required INS and SSA to operate three voluntary pilot  programs to test electronic means for employers to verify an employee’s  eligibility to work, one of which was the Basic Pilot Program. The Basic  Pilot Program was designed to test whether pilot verification procedures  could improve the existing employment verification process by reducing  (1) false claims of U.S. citizenship and document fraud; (2) discrimination  against employees; (3) violations of civil liberties and privacy; and (4) the  burden on employers to verify employees’ work eligibility.
The Basic Pilot Program provides participating employers with an  electronic method to verify their employees’ work eligibility. Employers  may participate voluntarily in the Basic Pilot Program, but are still  required to complete Forms I-9 for all newly hired employees in  accordance with IRCA. After completing the forms, these employers query  the pilot program’s automated system by entering employee information  provided on the forms, such as name and social security number, into the  pilot Web site within 3 days of the employees’ hire date. The pilot program  then electronically matches that information against information in SSA  and, if necessary, DHS databases to determine whether the employee is  eligible to work, as shown in figure 1. The Basic Pilot Program  electronically notifies employers whether their employees’ work  authorization was confirmed. Those queries that the DHS automated  check cannot confirm are referred to DHS immigration status verifiers  who check employee information against information in other DHS  databases.
In cases when the pilot system cannot confirm an employee’s work  authorization status either through the automatic check or the check by an  immigration status verifier, the system issues the employer a tentative  nonconfirmation of the employee’s work authorization status. In this case,  the employers must notify the affected employees of the finding, and the  employees have the right to contest their tentative nonconfirmations by  contacting SSA or CIS to resolve any inaccuracies in their records within  8 days. During this time, employers may not take any adverse actions  against those employees, such as limiting their work assignments or pay.  Employers are required to either immediately terminate the employment,  or notify DHS of the continued employment, of workers who do not  successfully contest the tentative nonconfirmation and those who the pilot  program finds are not work-authorized.
section_title: Various Weaknesses Have Undermined the Employment Verification Process, but Opportunities Exist to Enhance It
subsections: section_title: Current Employment Verification Process Is Based on Employers’ Review of Documents
paragraphs: In 1986, IRCA established the employment verification process based on  employers’ review of documents presented by employees to prove identity  and work eligibility. On the Form I-9, employees must attest that they are  U.S. citizens, lawfully admitted permanent residents, or aliens authorized  to work in the United States. Employers must then certify that they have  reviewed the documents presented by their employees to establish identity  and work eligibility and that the documents appear genuine and relate to  the individual presenting them. In making their certifications, employers  are expected to judge whether the documents presented are obviously  counterfeit or fraudulent. Employers are deemed in compliance with IRCA  if they have followed the Form I-9 process, including when an  unauthorized alien presents fraudulent documents that appear genuine.
section_title: Form I-9 Process Is Vulnerable to Document and Identity Fraud
paragraphs: Since passage of IRCA in 1986, document and identity fraud have made it  difficult for employers who want to comply with the employment  verification process to ensure they hire only authorized workers. In its  1997 report to Congress, the Commission on Immigration Reform noted  that the widespread availability of false documents made it easy for  unauthorized aliens to obtain jobs in the United States. In past work, we  reported that large numbers of unauthorized aliens have used false  documents or fraudulently used valid documents belonging to others to  acquire employment, including at critical infrastructure sites like airports  and nuclear power plants. In addition, although studies have shown that  the majority of employers comply with IRCA and try to hire only  authorized workers, some employers knowingly hire unauthorized  workers, often to exploit the workers’ low cost labor. For example, the  Commission on Immigration Reform reported that employers who  knowingly hired illegal aliens often avoided sanctions by going through the  motions of compliance while accepting false documents.
section_title: The Number and Variety of Acceptable Documents Hinders Employer Verification Efforts
paragraphs: The number and variety of documents that are acceptable for proving  work eligibility have complicated employer verification efforts under  IRCA. Following the passage of IRCA in 1986, employees could present 29  different documents to establish their identity and/or work eligibility. In a  1997 interim rule, INS reduced the number of acceptable work eligibility  documents from 29 to 27. The interim rule implemented changes to the  list of acceptable work eligibility documents mandated by IIRIRA and was  intended to serve as a temporary measure until INS issued final rules on  modifications to the Form I-9. Since the passage of IRCA, we and others  have reported on the need to reduce the number of acceptable work  eligibility documents to make the employment verification process simpler  and more secure. In 1998, INS proposed a further reduction in the  number of acceptable work eligibility documents to 14, but the proposed  rule has not been finalized. According to DHS officials, the department is  currently assessing possible revisions to the Form I-9 process, including  reducing the number of acceptable work eligibility documents, but has not  established a target time frame for completing this assessment and issuing  regulations on Form I-9 changes.
section_title: The Basic Pilot Program Shows Promise to Enhance Employment Verification, but Challenges Exist to Increased Use
paragraphs: Various immigration experts have noted that the most important step that  could be taken to reduce illegal immigration is the development of a more  effective system for verifying work authorization. In particular, the  Commission on Immigration Reform concluded that the most promising  option for verifying work authorization was a computerized registry based  on employers’ electronic verification of an employee’s social security  number with records on work authorization for aliens. The Basic Pilot  Program, which is currently available on a voluntary basis to all employers  in the United States, operates in a similar way to the computerized registry  recommended by the commission, and shows promise to enhance  employment verification and worksite enforcement efforts. Only a small  portion—about 2,300 in fiscal year 2004—of the approximately 5.6 million  employer firms nationwide actively used the pilot program.
The Basic Pilot Program enhances the ability of participating employers to  reliably verify their employees’ work eligibility and assists participating  employers with identification of false documents used to obtain  employment by comparing employees’ Form I-9 information with  information in SSA and DHS databases. If newly hired employees present  counterfeit documents, the pilot program would not confirm the  employees’ work eligibility because their employees’ Form I-9 information,  such as the false name or social security number, would not match SSA  and DHS database information when queried through the Basic Pilot  Program.
Although ICE has no direct role in monitoring employer use of the Basic  Pilot Program and does not have direct access to program information,  which is maintained by CIS, ICE officials told us that program data could  indicate cases in which employers do not follow program requirements  and therefore would help the agency better target its worksite  enforcement efforts toward those employers. For example, the Basic Pilot  Program’s confirmation of numerous queries of the same social security  number could indicate that a social security number is being used  fraudulently or that an unscrupulous employer is knowingly hiring  unauthorized workers by accepting the same social security number for  multiple employees. ICE officials noted that, in a few cases, they have  requested and received pilot program data from CIS on specific employers  who participate in the program and are under ICE investigation. However,  CIS officials told us that they have concerns about providing ICE broader  access to Basic Pilot Program information because it could create a  disincentive for employers to participate in the program, as employers  may believe that they are more likely to be targeted for a worksite  enforcement investigation as a result of program participation. According  to ICE officials, mandatory employer participation in the Basic Pilot  Program would eliminate the concern about sharing data and could help  ICE better target its worksite enforcement efforts on employers who try to  circumvent program requirements. Moreover, these officials told us that  mandatory use of an automated system like the pilot program could limit  the ability of employers who knowingly hired unauthorized workers to  claim that the workers presented false documents to obtain employment,  which could assist ICE agents in proving employer violations of IRCA.
The Basic Pilot Program may enhance the employment verification  process and a mandatory program could assist ICE in targeting its  worksite enforcement efforts. However, weaknesses exist in the current  program. For example, the current Basic Pilot Program cannot help  employers detect identity fraud. If an unauthorized worker presents valid  documentation that belongs to another person authorized to work, the  Basic Pilot Program would likely find the worker to be work-authorized.  Similarly, if an employee presents counterfeit documentation that contains  valid information and appears authentic, the pilot program may verify the  employee as work-authorized. DHS officials told us that the department is  currently considering possible ways to enhance the Basic Pilot Program to  help it detect cases of identity fraud, for example, by providing a digitized  photograph associated with employment authorization information  presented by an employee.
Delays in the entry of information on arrivals and employment  authorization into CIS databases can lengthen the pilot program  verification process for some secondary verifications. Although the  majority of pilot program queries entered by employers are confirmed via  the automated SSA and DHS verification checks, about 15 percent of  queries authorized by DHS required secondary verifications in fiscal year  2004. According to CIS, cases referred for secondary verification are  typically resolved within 24 hours, but a small number of cases take  longer, sometimes up to 2 weeks, due to, among other things, delays in  entry of employment authorization information into CIS databases.  Secondary verifications lengthen the time needed to complete the  employment verification process and could harm employees because  employers might reduce those employees’ pay or restrict training or work  assignments, which are prohibited under pilot program requirements,  while waiting for verification of their work eligibility. DHS has taken  steps to increase the timeliness and accuracy of information entered into  databases used as part of the Basic Pilot Program and reports, for  example, that data on new immigrants are now typically available for  verification within 10 to 12 days of an immigrant’s arrival in the United  States while, previously, the information was not available for up to 6 to 9  months after arrival.
According to CIS officials, current CIS staff may not be able to complete  timely secondary verifications if the number of employers using the  program significantly increased. In particular, these officials said that if a  significant number of new employers registered for the program or if the  program were mandatory for all employers, additional staff would be  needed to maintain timely secondary verifications. Currently, CIS has  approximately 38 Immigration Status Verifiers allocated for completing  Basic Pilot Program secondary verifications, and these verifiers reported  that they are able to complete the majority of manual verification checks  within their target time frame of 24 hours. However, CIS estimated that  even a relatively small increase in the number of employers using the  program would significantly slow the secondary verification process and  strain existing resources allocated for the program.
section_title: Low Priority and Implementation Challenges Have Hindered Worksite Enforcement Efforts
subsections: section_title: Worksite Enforcement Remains a Low Priority
paragraphs: Worksite enforcement was a low priority for INS and continues to be a low  priority for ICE. In the 1999 INS Interior Enforcement Strategy, the  strategy to block and remove employers’ access to undocumented workers  was the fifth of five interior enforcement priorities. We have reported  that, relative to other enforcement programs in INS, worksite enforcement  received a small portion of INS’s staffing and enforcement budget and that  the number of employer investigations INS conducted each year covered  only a fraction of the number of employers who may have employed  unauthorized aliens. Furthermore, INS investigative resources were  redirected from worksite enforcement activities to criminal alien cases,  which consumed more investigative hours by the late 1990s than any other  enforcement activity. After September 11, 2001, INS and ICE focused  investigative resources on national security-related investigations.  According to ICE, the redirection of resources from other enforcement  programs to perform national security-related investigations resulted in  fewer resources for traditional program areas, like worksite enforcement  and fraud.
The resources INS and ICE devoted to worksite enforcement have  continued to decline. As shown in figure 2, between fiscal years 1999 and  2003, the most recent fiscal year for which comparable data are available,  the percentage of agent workyears spent on worksite enforcement efforts  generally decreased from about 9 percent, or 240 full-time equivalents, to  about 4 percent, or 90 full-time equivalents.
Workyear data for fiscal year 2004 cannot be directly compared with  workyear data for previous fiscal years because of changes in the way INS  and ICE agents entered and categorized data in their respective case  management systems. However, ICE data indicate that the agency  allocated about 65 full-time equivalents to worksite enforcement in fiscal  year 2004.
In addition, the number of notices of intent to fine issued to employers as  well as the number of unauthorized workers arrested at worksites have  also declined. Between fiscal years 1999 and 2004, the number of notices  of intent to fine issued to employers for improperly completing Forms I-9  or knowingly hiring unauthorized workers generally decreased from 417 to  3. (See figure 3.)
The number of worksite arrests declined by about 84 percent from 2,849 in  fiscal year 1999 to 445 in fiscal year 2003. (See figure 4.)
section_title: Difficulties Proving Employer Violations, Collecting Fines, and Detaining Aliens Have Weakened the Worksite Enforcement Program
paragraphs: The difficulties that INS and ICE have experienced in proving that  employers knowingly hired unauthorized workers and in setting and  collecting fine amounts that meaningfully deter employers from knowingly  hiring unauthorized workers have limited the effectiveness of worksite  enforcement efforts. In particular, the availability and use of fraudulent  documents has not only undermined the employment verification process,  but has also made it difficult for ICE agents to prove that employers  knowingly hired unauthorized workers. In 1996, the Department of Justice  Office of the Inspector General reported that the proliferation of cheap  fraudulent documents made it possible for the unscrupulous employer to  avoid being held accountable for hiring illegal aliens. In 1999, we reported  that the prevalence of document fraud made it difficult for INS to prove  that an employer knowingly hired an unauthorized alien. ICE officials  told us that employers who they suspect knowingly hire unauthorized  workers can claim that they were unaware that their workers presented  false documents at the time of hire, making it difficult for agents to prove  that the employer violated IRCA.
According to ICE officials, when agents can prove that an employer  knowingly hired an unauthorized worker, difficulties in setting and  collecting meaningful fine amounts have undermined the effectiveness of  worksite enforcement efforts and the deterrent effect of employer fines.  Under IRCA, employers who fail to properly complete, retain, or present  for inspection a Form I-9 may be administratively fined from $110 to  $1,100 for each employee. Employers who knowingly hire or continue to  employ unauthorized aliens may be administratively fined from $275 to  $11,000 for each employee, depending on whether the violation is a first or  subsequent offense. ICE officials told us fine amounts recommended by  both INS and ICE agents were often negotiated down in value during  discussions between agency attorneys and employers. These officials said  that the agency mitigates employer fines because doing so may be a more  efficient use of government resources than pursuing employers who  contest or ignore fines, which could be more costly to the government  than the fine amount sought. Furthermore, the amount of mitigated fines  may be, in the opinion of some ICE officials, so low they believe that  employers view it as a cost of doing business, and they believe the fines do  not provide an effective deterrent for employers who attempt to  circumvent IRCA. In addition, the Debt Management Center, which is  responsible for collecting fines issued against employers for violations of  IRCA, has faced difficulties in collecting the full amount of fines from  employers. According to ICE, the agency has faced difficulties in  collecting fines from employers for a number of reasons, for example,  because employers went out of business or declared bankruptcy. In such  instances, the agency determines whether to pursue collection of  employer fines based on the level of resources needed to pursue the  employer and the likelihood of collecting the fine amount.
Finally, the Office of Detention and Removal has limited detention space,  and unauthorized workers detained during worksite enforcement  investigations are a low priority for that space. In 2004, the Under  Secretary for Border and Transportation Security sent a memo to the  Commissioner of U.S. Customs and Border Protection and the Assistant  Secretary for ICE outlining the priorities for the detention of aliens.  According to the memo, aliens who are subjects of national security  investigations were among those groups of aliens given the highest priority  for detention, while those arrested as a result of worksite enforcement  investigations were to be given the lowest priority. According to ICE  officials, the lack of sufficient detention space has limited the  effectiveness of worksite enforcement efforts. For example, they said that  if investigative agents arrest unauthorized aliens at worksites, the aliens  would likely be released because the Office of Detention and Removal  detention centers do not have sufficient space to house the aliens and they  may re-enter the workforce, in some cases returning to the worksites from  where they were originally arrested.
section_title: Worksite Enforcement Focus Shifted to Critical Infrastructure Protection after September 11, 2001
paragraphs: In keeping with the primary mission of DHS to combat terrorism, after  September 11, 2001, INS and then ICE has focused its resources for  worksite enforcement on identifying and removing unauthorized workers  from critical infrastructure sites, such as airports and nuclear power  plants, to help reduce vulnerabilities at those sites. According to ICE  officials, the agency shifted its worksite enforcement focus to critical  infrastructure protection because unauthorized workers employed at  critical infrastructure sites indicate security vulnerabilities at those sites.  In conducting critical infrastructure operations, the agency has worked  with employers to identify and remove unauthorized workers and, as a  result, has not focused on sanctioning employers at critical infrastructure  sites. In 2003, ICE headquarters issued a memo requiring field offices to  request approval from ICE headquarters prior to opening any worksite  enforcement investigation not related to the protection of critical  infrastructure sites, such as investigations of farms and restaurants. ICE  officials told us that the purpose of this memo was to help ensure that field  offices focused worksite enforcement efforts on critical infrastructure  protection operations. Field office representatives reported that non­ critical infrastructure worksite enforcement is one of the few investigative  areas for which offices must request approval from ICE headquarters to  open an investigation and also reported that worksite enforcement is not a  priority unless it is related to critical infrastructure. In addition, some of  these representatives, as well as immigration experts we interviewed,  noted that the focus on critical infrastructure protection does not address  the majority of worksites in industries that have traditionally provided the  magnet of jobs attracting illegal aliens to the United States.
section_title: Concluding Observations
paragraphs: Efforts to reduce the employment of unauthorized workers in the United  States require a strong employment eligibility verification process and a  credible worksite enforcement program to ensure that employers meet  verification requirements. The current employment verification process  has not fundamentally changed since its establishment in 1986, and  ongoing weaknesses have undermined its effectiveness. The Basic Pilot  Program shows promise for enhancing the employment verification  process and reducing document fraud if implemented on a much larger  scale. However, the weaknesses identified in the current implementation  of the Basic Pilot Program, as well as the costs of an expanded program,  are considerations that will need to be addressed in deciding whether this  program, or a similar automated employment verification process, should  be significantly expanded or made mandatory. Even with a strengthened  employment verification process, a credible worksite enforcement  program would be needed because no verification system is foolproof and  not all employers may want to comply with IRCA.
We are continuing our work and expect to have several recommendations  aimed at improving employment verification and worksite enforcement  efforts.
This concludes my prepared statement. I would be pleased to answer any  questions you and the Subcommittee members may have.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For further information about this testimony, please contact Richard Stana  at 202-512-8777.
Other key contributors to this statement were Orlando Copeland,  Michele Fejfar, Ann H. Finley, Rebecca Gambler, Kathryn Godfrey,  Eden C. Savino, and Robert E. White.
section_title: Related GAO Products
paragraphs: Social Security: Better Coordination among Federal Agencies Could  Reduce Unidentified Earnings Reports. GAO-05-154. February 4, 2005.
Tax Administration: IRS Needs to Consider Options for Revising  Regulations to Increase the Accuracy of Social Security Numbers on  Wage Statements. GAO-04-712. August 31, 2004.
Immigration Enforcement: DHS Has Incorporated Immigration  Enforcement Objectives and Is Addressing Future Planning  Requirements. GAO-05-66. October 8, 2004.
Overstay Tracking: A Key Component of Homeland Security and a  Layered Defense. GAO-04-82. May 21, 2004.
Social Security Administration: Actions Taken to Strengthen Procedures  for Issuing Social Security Numbers to Noncitizens, but Some  Weaknesses Remain. GAO-04-12. October 15, 2003.
Homeland Security: Challenges to Implementing the Immigration  Interior Enforcement Strategy. GAO-03-660T. April 10, 2003.
Identity Fraud: Prevalence and Links to Alien Illegal Activities. GAO-02­ 830T. June 25, 2002.
Illegal Aliens: Significant Obstacles to Reducing Unauthorized Alien  Employment Exist. GAO/GGD-99-33. April 2, 1999.
Immigration and Naturalization Service: Overview of Management and  Program Challenges. GAO/T-GGD-99-148. July 29, 1999.
Immigration Reform: Employer Sanctions and the Question of  Discrimination. GAO/GGD-90-62. March 29, 1990.
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