Homeland Security: Overstay Tracking Is a Key Component of a Layered Defense
Published: 2003-10-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Each year, millions of visitors, foreign students, and immigrants come to the United States. Visitors may enter on a legal temporary basis--that is, with an authorized period of admission that expires on a specific date--either (1) with temporary visas (generally for tourism,business,or work) or, in some cases (2) as tourists or business visitors who are allowed to enter without visas. (The latter group includes Canadians and qualified visitors from 27 countries who enter under the visa waiver program.) The majority of visitors who are tracked depart on time, but others overstay. Four of the 9/11 hijackers who entered the United States with legal visas overstayed their authorized periods of admission. This has heightened attention to issues such as (1) the extent of overstaying, (2) weaknesses in our current overstay tracking system, and (3) how the tracking system weaknesses and the level of overstaying might affect domestic security.
section_title: What GAO Found
paragraphs: Significant numbers of foreign visitors overstay their authorized periods of admission. The Department of Homeland Security estimates the resident overstay population at 2.3 million as of January 2000. Because the starting point for this estimate is the 2000 census, it does not cover short-term overstays who have not established residence here. It also omits an unknown number of potential long-term overstays from Mexico and Canada. Because of unresolved weaknesses in DHS's current system for tracking arrivals and departures (e.g.,noncollection of some departure forms and inability to match other departure forms to arrivals), there is no accurate list of overstays. Two new tracking initiatives are intended to address these weaknesses. NSEERS, the National Security Entry and Exit Registration System, does not cover most visitors. US-VISIT, the U.S. Visitor and Immigrant Status Indicator Technology, a more comprehensive,automated program, is being phased in. While its design and implementation face a number of challenges, evaluating US-VISIT against the weaknesses GAO identifies here would increase its potential for success. The current tracking system's weaknesses limit control options and make it difficult to monitor potential terrorists who enter the country legally. Like other illegal immigrants, overstays obtain jobs with fraudulent identity documents, including jobs at critical infrastructure locations, such as airports. Thus, tracking issues can affect domestic security and are one component of a layered national defense. Improving the tracking system could work with intelligence, investigation, information-sharing, and other factors to help counter threats from foreign terrorists.

section_title: Letter
paragraphs: I am pleased to be here today to discuss overstays—that is, foreign  citizens who enter the United States legally but do not leave when their  authorized period of admission expires. Overstay issues have gained  heightened attention because some of the 9/11 hijackers had overstayed  their periods of admission. While our work is ongoing, my remarks will  focus on describing our results to date concerning weaknesses in the current overstay tracking system, and potential impacts on domestic security.  the extent to which overstaying occurs,  In examining these issues, our main information sources include  (1) relevant GAO and other government reports, (2) interviews with  officials and staff at the U.S. Department of Homeland Security (DHS) and  the U.S. Department of Justice, and (3) a variety of data, including  quantitative data from DHS’s overstay tracking system (based on the I-94  form), data that DHS developed, at our request, from Operation Tarmac  (the sweep that identified overstays and other illegal immigrants working  at U.S. airports), and facts about the arrivals, departures, and overstay  status of the 9/11 hijackers and others involved in terrorism.
Our scope did not include aspects of immigration or domestic security  unrelated to overstaying. While the vast majority of overstays appear to be  motivated by economic opportunities, the few who are potential terrorists  could represent a significant threat to our domestic security. An effective  strategy to address this risk is best developed within the larger context of  a layered defense for domestic security. Intelligence, investigation, and  information-sharing are key ingredients supporting this defense, which is  designed and implemented by a wide range of agencies, including DHS, the  Department of Justice, the Department of State, and the Social Security  Administration, among others.
To summarize the results of our analysis of overstay issues and domestic  security, we found that
Overstaying is significant and may be understated by DHS’s recent  estimate.
The current system for tracking foreign visitors has several weaknesses.
It is more difficult to ensure our domestic security because of the  weaknesses in the tracking system and the level of overstaying that  apparently occurs.
Viewing these results in the context of our nation’s layered defense, we  believe that improving the tracking system could work together with other  factors—especially intelligence, investigation, and information-sharing—  to help counter threats from foreign terrorists.
subsections: section_title: Background
paragraphs: Each year, millions of visitors, foreign students, and immigrants come to  the United States. Visitors may enter on a legal temporary basis—that is,  with an authorized period of admission that expires on a specific date—  either with temporary visas (generally for tourism, business, or work)  issued by the Department of State or, in some cases, as tourists or  business visitors who are allowed to enter without visas. The latter group  includes Canadians and qualified visitors from 27 countries who enter  under the Visa Waiver Permanent program. The large majority of these  visitors depart on time, but others overstay.
Our definition of an overstay in this testimony is specifically this:  An overstay is a foreign visitor who is legally admitted to the United  States for a specific authorized period and remains in the United States  after that period expires, unless an extension or a change of status has  been approved.
Although overstays are sometimes referred to as visa overstays, this is  technically a misnomer for two reasons. First, a visitor can overstay the  authorized period of admission set by the DHS inspector at the border  while still possessing a valid visa. (For example, a visitor with a 6- month multiple-entry visa from the Department of State might be issued  a 6-week period of admission by the DHS inspector and remain here for  7 weeks, thus overstaying.) Second, some visitors are allowed to enter  the United States without visas and to remain for specific periods of  time, which they may overstay.
Form I-94 is the basis of the current overstay tracking system. For visitors  from most countries, the period of admission is authorized (or set) by a  DHS inspector when they enter the United States legally and fill out this  form. Each visitor is to give the top half to the inspector and to retain the  bottom half, which should be collected on his or her departure.
When visiting the United States for business or pleasure, two major groups  are exempt from filling out an I-94 form:
Mexicans entering the United States with a Border Crossing Card (BCC) at  the Southwestern border who intend to limit their stay to less than 72  hours and not to travel beyond a set perimeter (generally, 25 miles from  the border) and
Canadians admitted for up to 6 months without a perimeter restriction.Thus, the majority of Canadian and Mexican visits cannot be tracked by  the current system, because the visitors have not filled out Form I-94.  Tracking should be possible for almost all other legal temporary visitors,  including visitors from visa waiver countries, because they are required to  fill out the form.
Terrorists might be better prevented from legally entering the United  States if consular officials and DHS inspectors used improved watch lists  to screen visa applicants and make border inspections. However, some  terrorists may continue to slip through these border defenses. Keeping all  dangerous persons and potential terrorist-suspects from legally entering  the United States is difficult because some do not match the expected  characteristics of terrorists or suspicious persons; in addition, some may  not be required to apply for visas (that is, citizens of Canada or one of the  27 visa waiver countries).
Watch lists have been improved somewhat since 9/11, but further  improvements are needed. For example, earlier this year we reported that  the State Department “with the help of other agencies, almost doubled the  number of names and the amount of information” in its Consular Lookout  and Support System. We also reported that “the federal watch list  environment has been characterized by a proliferation of [terrorist and  watch list] systems, among which information sharing is occurring in some  cases but not in others.”
In this testimony today, we focus primarily on an overstay’s illegal  presence within the United States and the potential consequences for  domestic security. Viewed in terms of individuals, the overstay process  can be summarized as aliens’ (1) legally visiting the United States, which  for citizens of most nations is preceded by obtaining a passport and a visa  and requires filling out Form I-94 at the U.S. border; (2) overstaying for a  period that may range from a single day to weeks, months, or years; and, in  some cases, (3) terminating their overstay status by exiting the United  States or adjusting to legal permanent resident status (that is, obtaining a  green card). Beyond that, the overstay process can be viewed more  broadly in the context of our nation’s layered defense. For example, figure  1 illustrates many issues in this defense that we have analyzed in  numerous reports—ranging from overseas tracking of terrorists to  stateside security for critical infrastructure locations and aviation.
section_title: The Extent of Overstaying Is Significant and May Be Understated by DHS’s Estimate
paragraphs: Significant numbers of visitors overstay their authorized periods of  admission. A recent DHS estimate put the January 2000 resident overstay  population at 1/3 of 7 million illegal immigrants, or 2.3 million. The  method DHS used to obtain the 1/3 figure is complex and indirect, and we  plan to evaluate that estimate further. However, the 2.3 million overstay  estimate excludes specific groups, and we believe, therefore, that it  potentially understates the extent of overstaying.
By definition, DHS’s estimate of 2.3 million overstays as of January 2000  represents only a part of the total overstay problem. DHS’s estimate of 7  million illegal immigrants is limited to illegals who settled and were  residing here at the time of the 2000 census. It includes only overstays  who were in the actual census count or included in corrections for  possible undercounts of illegal immigrants.
DHS’s estimate of overstays as of January 2000 is not defined to include  the following groups:  a.  Visitors filling out Form I-94 who overstay for short periods of time. Many such persons are not likely  to be included in the 2000 census, which is the starting point of DHS’s  2.3 million estimate of the resident overstay population. In our ongoing  work, we will examine indicators of the magnitude, and significance, of  short-term overstaying among visitors who fill out I-94 forms.  b.  Mexican and Canadian visitors not filling out Form I-94 who overstayed and settled here. Overstays in this group are included  in DHS’s estimate of 7 million illegal immigrants, but they are  categorized as illegal immigrants other than overstays. This is because  DHS used I-94 data from the early 1990s and projected these data  forward to obtain the 1/3 overstay proportion. overstay for short periods. As indicated above, many short-term  overstays are not included in the 2000 census, which is the starting  point of DHS’s 2.3 million estimate of the resident overstay population.
These groups are illustrated in figure 2.
In part because of coverage issues, the extent of overstaying has not been  definitively measured. In addition, the accuracy of DHS’s estimate of the  resident overstay population is not known with precision. Other limited  data points may help illustrate the possible magnitude.
For this testimony, we obtained two small-sample sources of data. First,  we identified a government-sponsored survey, reported in 2002, that had  (1) sampled more than 1,000 adult green-card holders, (2) asked them  about their prior immigration status, and (3) found that more than 300  respondents self-reported prior illegal status. From the computer run we  requested, we found that of the roughly 300 former illegals, about 1/3 said  they were former overstays, with most of the remaining 2/3 reporting prior  illegal border crossing.
Second, we obtained data from Operation Tarmac, the 2001–03 sweep of  airport employees who had access to sensitive areas. Although Operation  Tarmac investigators had collected information on overstaying, they did  not systematically record data for overstays versus illegal border crossers.  We requested that DHS manually review a sample of case files and identify  overstays. DHS reported to us that of 286 sampled cases in which illegal  immigrant airport workers (that is, overstays and illegal border crossers)  were arrested or scheduled for deportation, 124 workers, or about 40  percent, were overstays.
While both the survey data and the airport data represent rough small- sample checks, they provide some additional support for concluding that  overstays are not rare.
section_title: Unresolved Tracking System Weaknesses Heighten the Overstay Problem
subsections: section_title: I-94 Tracking System Weaknesses Limit Control Options
paragraphs: One weakness in DHS’s system for tracking the paper Form I-94—its  limited coverage of Mexican and Canadian visitors—was discussed in the  section above. In our previous work, we have pointed to at least three  other weaknesses in this tracking system:
Failure to update the visitor’s authorized period of admission or  immigration status. We reported earlier this year that DHS does not  “consistently enter change of status data . . .  integrate these data with  those for entry and departure.” DHS told us that linkage to obtain  updated information may occur for an individual, as when a consular  official updates information on an earlier period of admission for someone  seeking a new visa, but DHS acknowledged that linkage cannot be  achieved broadly to yield an accurate list of visitors who overstayed.
Lack of reliable address information and inability to locate  visitors. Some visitors do not fill in destination address information on  Form I-94 or they do so inadequately. A related issue that we reported in  2002 is DHS’s inability to obtain updated address information during each  visitor’s stay; such information could be a valuable addition to the arrival,  departure, and destination address information that is collected.
Missing departure forms. We reported in 1995 that “airlines are  responsible for collecting . . . departure forms when visitors leave   . . . . But for some visitors who may have actually left the United States   record of the departures.” DHS acknowledges that this is still  a concern, that the situation is analogous for cruise lines, and that  noncollection is a larger problem for land exits.
Our recent work has also drawn attention to identity fraud, demonstrating  how persons presenting fraudulent documents (bearing a name other than  their own) to DHS inspectors could enter the United States. Visitors  whose fraudulent documents pass inspection could record a name other  than their own on their I-94 form.
In our current work, we have identified two further weaknesses in the  tracking system. One weakness is the inability to match some departure  forms back to corresponding arrival forms. DHS has suggested that when a  visitor loses the original departure form, matching is less certain because  it can no longer be based on identical numbers printed on the top and  bottom halves of the original form. The other weakness is that at land  ports (and possibly airports and seaports), the collection of departure  forms is vulnerable to manipulation—in other words, visitors could make  it appear that they had left when they had not. To illustrate, on bridges  where toll collectors accept I-94 departure forms at the Southwestern  border, a person departing the United States by land could hand in  someone else’s I-94 form.
Because of these weaknesses, DHS has no accurate list of overstays to  send to consular officials or DHS inspectors. This limits DHS’s ability to  consider past overstaying when issuing new visas or allowing visitors to  reenter.
More generally, the lack of an accurate list limits prevention and  enforcement options. For example, accurate data on overstays and other  visitors might help define patterns to better differentiate visa applicants  with higher overstay risk. And without an accurate list and updated  addresses, it is not possible to identify and locate new overstays to remind  them of penalties for not departing. Such efforts fall under the category of  interior enforcement: As we previously testified, “historically . . . over five  times more resources in terms of staff and budget   border enforcement than . . .  interior enforcement.” Despite large  numbers of overstays, current efforts to deport them are generally limited  to (1) criminals and smugglers, (2) employees identified as illegal at  critical infrastructure locations, and (3) persons included in special  control efforts such as the domestic registration (or “call in” component)  of the NSEERS program (the National Security Entry and Exit Registration  System). DHS statisticians told us that for fiscal year 2002, the risk of  arrest for all overstays was less than 2 percent. For most other overstays  (that is, for persons not in the targeted groups), the risk of deportation is  considerably lower.
The effect of tracking system weaknesses on overstay data is illustrated by  the inaccurate—and, according to DHS, inflated—lists of what it terms  “apparent overstays” and “confirmed overstays.” For fiscal year 2001  arrivals, the system yielded a list of 6.5 million “apparent overstays” for which DHS had no departure  record that matched the arrivals and an additional list of a half million “confirmed overstays,” or visits that  ended after the visitors’ initial periods of admission expired (see  appendixes I and II).
However, DHS has no way of knowing how many of the 6.5 million are real  cases of overstaying and how many are false (because some of these  visitors had, for example, departed or legally changed their status). Even  the half million “confirmed overstays” are not all true cases of overstaying,  because some visitors may have legally extended their periods of  admission.
In the past, we made a number of recommendations that directly or  indirectly address some of these system weaknesses, but these  recommendations have not been implemented or have been only partially  implemented. (Of these, four key recommendations are in appendix III.)
section_title: DHS Intends Its New Tracking Initiatives to Address System Weaknesses, but Issues Remain
paragraphs: DHS has begun two initiatives intended to remedy some of the weaknesses  we have discussed. DHS recently began, as part of NSEERS, an effort to  register visitors at points of entry (POE) to the United States, conduct  intermittent interviews with registered visitors while they are here, and  have government inspectors register departures. But the POE effort does  not cover most visitors because it focuses on persons born in only eight  countries. Moreover, NSEERS procedures do not involve inspectors’  observing departures—for example, registration occurs not at airport  departure gates but at another location at the airport. Also, inspectors do  not generally accompany registrants to observe their boarding.
US-VISIT, the U.S. Visitor and Immigrant Status Indicator Technology, is  DHS’s new tracking system intended to improve entry-exit data. The first  phase of US-VISIT, now being rolled out, uses passenger and crew  manifest data, as well as biometrics, to verify foreign visitors’ identities at  airports and seaports. DHS plans three additional phases and will link its  data to other systems that contain data about foreign nationals. If  successfully designed and implemented, US-VISIT could avoid many of the  weaknesses associated with the Form I-94 system.
We believe special efforts are needed to ensure US-VISIT’s success. DHS  concurred with our recent report, pointing to risks and the need for  improved management of US-VISIT. For example, we reported that, among  other issues, “important aspects defining the  program’s  operating environment are not yet decided  facility needs are  unclear and challenging.” Our recommendations included, among others,  that DHS develop acquisition management controls and a risk  management plan for US-VISIT, as well as defining performance standards.
We also believe that checking US-VISIT’s program design against the  weaknesses of the Form I-94 system, outlined here, might help in  evaluating the program and ensuring its success.
section_title: Overstay Issues May Complicate Efforts to Ensure Domestic Security
subsections: section_title: Tracking System Weaknesses Encourage Overstays and Hamper Some Counterterrorism Efforts
paragraphs: Tracking system weaknesses may encourage overstaying on the part of  visitors and potential terrorists who legally enter the United States. Once  here, terrorists may overstay or use other stratagems—such as exiting and  reentering (to obtain a new authorized period of admission) or applying  for a change of status—to extend their stay. As shown in table 1, three of  the six pilots and apparent leaders were out of status on or before 9/11,  two because of short-term overstaying.
Additionally, a current overstay recently pled guilty to identity document  fraud in connection with the 9/11 hijackers. Two others with a history of  overstaying were recently convicted of crimes connected to terrorism  (money-laundering and providing material support to terrorists); both had  overstayed for long periods.
Terrorists who enter as legal visitors are hidden within the much larger  populations of all legal visitors, overstays, and other illegals such as  border crossers. Improved tracking could help counterterrorism  investigators and prosecutors track them and prosecute them, particularly  in cases in which suspicious individuals are placed on watch lists after  they enter the country. The director of the Foreign Terrorist Tracking Task  Force told us that he considered overstay tracking data helpful. For  example, these data—together with additional analysis—can be important  in quickly and efficiently determining whether suspected terrorists were in  the United States at specific times.
As we reported earlier this year, between “September 11 and November 9,  2001 , . . . INS compiled a list of aliens  whose characteristics were similar to those of the hijackers” in types of  visa, countries issuing their passports, and dates of entry into the United  States. While the list of aliens was part of an effort to identify and locate  specific persons for investigative interviews, it contained duplicate names  and data entry errors. In other words, poor data hampered the  government’s efforts to obtain information in a national emergency, and  investigators turned to private sector information. Reporting earlier that  INS data “could not be fully relied on to locate many aliens who were of  interest to the United States,” we had indicated that the Form I-94 system  is relevant, stressing the need for improved change-of-address notification  requirements. INS generally concurred with our findings.
section_title: Overstays’ Employment in Sensitive Airport Jobs Illustrates Potential Effects on Domestic Security
paragraphs: DHS has declared that combating fraudulent employment at critical  infrastructures, such as airports, is a priority for domestic security. DHS  has planned and ongoing efforts to identify illegal workers in key jobs at  various infrastructures (for example, airport workers with security  badges). These sweeps are thought to reduce the nation’s vulnerability to  terrorism, because, as experts have told us, (1) security badges issued on  the basis of fraudulent IDs constitute security breaches, and (2) overstays  and other illegals working in such facilities might be hesitant to report  suspicious activities for fear of drawing authorities’ attention to  themselves or they might be vulnerable to compromise.
Operation Tarmac swept 106 airports and identified 4,271 illegal  immigrants who had misused Social Security numbers and identity  documents in obtaining airport jobs and security badges. A much smaller  number of airport employees had misrepresented their criminal histories  in order to obtain their jobs and badges. The illegal immigrant workers  with access to secure airport areas were employed by airlines (for  example, at Washington Dulles International Airport and Ronald Reagan  Washington National Airport, this included American, Atlantic Coast,  Delta, Northwest, and United Airlines as well as SwissAir and British  Airways) and by a variety of other companies (for example, Federal  Express and Ogden Services). Job descriptions included, among others,  aircraft maintenance technician, airline agent, airline cabin service  attendant, airplane fueler, baggage handler, cargo operations manager,  electrician, janitorial supervisor, member of a cleaning crew, predeparture  screener, ramp agent, and skycap.
In the large majority of these cases, identity fraud or counterfeit IDs were  involved; without fraud or counterfeit documents, illegal workers would  not have been able to obtain the jobs and badges allowing them access to  secure areas.
As we discussed earlier in this testimony, when we obtained data on the  specific immigration status of workers who were arrested or scheduled for  deportation at 14 Operation Tarmac airports, we found that a substantial  number were overstays. A DHS official told us that Operation Tarmac is  likely not to have identified all illegal aliens working in secure areas of  airports.
section_title: Conclusion
paragraphs: Weaknesses in DHS’s current overstay tracking system and the magnitude  of the overstay problem make it more difficult to ensure domestic security.  DHS has recently initiated two efforts to develop improved systems, but  challenges remain. Designing and implementing a viable and effective  tracking system is a critical component of the nation’s domestic security  and continues to be a DHS priority. Viewing our results in the context of  our nation’s layered defense, we believe that improvements in the tracking  system must work together with other factors—such as intelligence,  investigation, and information-sharing—to help ensure domestic security.
Mr. Chairman, this concludes my statement. I would be happy to respond to any questions that you or other members of the Committee may have.
For information regarding this testimony, please contact  Nancy R. Kingsbury, Managing Director, Applied Research and Methods,  on 202-512-2700. Individuals who made key contributions to this testimony  are Donna Heivilin, Judy Droitcour, Daniel Rodriguez, and Eric M. Larson.
section_title: Appendix I: I-94 Data: Number of Foreign Visitor Arrivals by Air, Sea, and Land and “Overstay Cases,” Fiscal Year 2001
paragraphs: Annual “overstay cases”  (a mixture of real and false cases)
section_title: Appendix II: I-94 Data: “Overstay Cases” (A Mix of Real and False Cases) by Mode of Arrival and Citizenship, Fiscal Year 2001
paragraphs: Total “overstay cases” for visitors  for visitors who arrived by  Excludes many Mexicans or Canadians who, visiting for business and pleasure, are exempt from  Form I-94 procedures.
Most, but not all, visitors from Permanent Visa Waiver countries enter under this program. Visa  waiver countries in this tally are Andorra, Australia, Austria, Belgium, Brunei, Denmark, Finland,  France, Germany, Iceland, Ireland, Italy, Japan, Liechtenstein, Luxembourg, Monaco, Netherlands,  New Zealand, Norway, Portugal, San Marino, Singapore, Slovenia, Spain, Sweden, Switzerland, and  United Kingdom. (Excludes Argentina and Uruguay, which were visa waiver countries in fiscal year  2001.)
The 25 countries in the NSEERS domestic registration program include (1) 8 countries also subject  to point-of-entry (POE) registration (Iran, Iraq, Libya, Pakistan, Saudi Arabia, Sudan, Syria, and  Yemen) and (2) 17 other countries (Afghanistan, Algeria, Bahrain, Bangladesh, Egypt, Eritrea,  Indonesia, Jordan, Kuwait, Lebanon, Morocco, North Korea, Oman, Qatar, Somalia, Tunisia, and  United Arab Emirates). The 123,000 total “overstay cases” (all modes of arrival) from these countries  in fiscal year 2001 include approximately 49,000 cases from the countries subject to POE registration  and approximately 73,000 cases from the other countries, excluding North Korea. The data exclude  North Korea from the NSEERS countries tally because DHS did not provide information separately for  North and South Korea.
section_title: Appendix III: Four Prior Recommendations to INS/DHS Related to Overstay Tracking, Data, or Estimates
paragraphs: 1. 	 We recommended that to improve the collection of departure forms,  the Commissioner of the Immigration and Naturalization Service  should ensure that INS examine the quality control of the  Nonimmigrant Information System database and determine why  departure forms are not being recorded. For example, this could  involve examining a sample of the passenger manifest lists of flights  with foreign destinations to determine the extent of airline compliance  and possibly developing penalties on airlines for noncompliance.  Discovery of the incidence of various causes of departure loss could  allow more precise estimation of their occurrence and development of  possible remedies. (U.S. General Accounting Office, Illegal Aliens:  Despite Data Limitations, Current Methods Provide Better  Population Estimates, GAO/PEMD-93-25 (Washington, D.C.: Aug. 5,  1993).)
INS agreed in principle with our recommendation to study why  departure forms are not being collected and subsequently initiated a  pilot project that was criticized by the Department of Justice Inspector  General and then discontinued. DHS has not told us of any further  efforts to study or determine why departure forms are not being  collected.  2. 	 We recommended that the Commissioner of INS should have new  overstay estimates prepared for air arrivals from all countries, using  improved estimation procedures such as those discussed in this report,  including, as appropriate, the potential improvements suggested by  INS or by reviewers of this report. (U.S. General Accounting Office,  Illegal Immigration: INS Overstay Estimation Methods Need  Improvement, GAO/PEMD-95-20 (Washington, D.C.: Sept. 26, 1995).)
INS initially concurred and produced revised estimates as part of its  comments on our report. However, in our response to INS’s comments,  we described the new estimates as a “first step” and identified  concerns about INS’s methodological procedures that we said needed  further study. DHS told us that it has not further studied making  overstay estimates by air arrivals. Valid estimation of overstays is  extremely difficult, given current tracking system weaknesses.  3. 	 We recommended that to promote compliance with the change of  address notification requirements through publicity and enforcement  and to improve the reliability of its alien address data, the Attorney  General should direct the INS Commissioner to identify and implement  an effective means to publicize the change of address notification  requirement nationwide. INS should make sure that, as part of its  publicity effort, aliens are provided with information on how to  comply with this requirement, including where information may be  available and the location of change of address forms. (U.S. General  Accounting Office, Homeland Security: INS Cannot Locate Many  Aliens because It Lacks Reliable Address Information, GAO-03- 188 (Washington, D.C.: Nov. 21, 2002).)
INS/DHS concurred with this recommendation and has identified it as  a long-term strategy that will require 2 years to fully implement. It has  been less than a year since we made this recommendation, and thus  there has not been sufficient time for DHS to implement it fully or for  us to review that implementation.  4. 	 We recommended that to provide better information on H-1B workers  and their status changes, the Secretary of DHS take actions to ensure  that information on prior visa status and occupations for permanent  residents and other employment-related visa holders is consistently  entered into current tracking systems and that such information  become integrated with entry and departure information when planned  tracking systems are complete. (U.S. General Accounting Office, H-1B  Foreign Workers: Better Tracking Needed to Help Determine H-1B  Program’s Effects on U.S. Workforce, GAO-03-883 (Washington, D.C.:  Sept. 10, 2003).)
DHS concurred with this recommendation, made just a month ago.  Sufficient time has not elapsed for DHS to implement this  recommendation.
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