Information Technology: Near-Term Effort to Automate Paper-Based Immigration Files Needs Planning Improvements
Published: 2006-03-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The United States Citizenship and Immigration Services (USCIS) relies on about 55 million paper-based files to adjudicate applications for immigration status and other benefits. Ensuring the currency and availability of these manual files, referred to as alien files, or A-Files, is a major challenge. To address this challenge, USCIS has initiated efforts, both long and near term, to automate the A-Files. The long-term effort is now being re-examined within the context of a larger USCIS organizational transformation initiative. In the near term, USCIS has begun a digitization program, which it estimates will cost about $190 million over an 8-year period to electronically scan existing paper files and store and share the scanned images. GAO was asked to determine whether USCIS was effectively managing its A-Files automation efforts.
section_title: What GAO Found
paragraphs: USCIS's effectiveness in managing its long-term effort for automating the A-Files cannot yet be determined because the scope, content, and approach for moving from paper-based to paperless A-Files has yet to be defined. Nevertheless, GAO believes that USCIS's recent decision to re-examine prior agency plans for a strategic A-Files automation solution within the context of an agencywide transformation strategy appropriately recognizes the integral support role that information technology plays in organizational and business transformation. GAO also believes that the success of USCIS's organizational transformation depends on other key supporting practices, such as having a comprehensive and integrated transformation plan (goals and schedules) and results-oriented performance measures. With respect to USCIS's near-term A-Files automation effort, known as the Integrated Digitization Document Management Program (IDDMP), effective planning is not occurring. In particular, USCIS has not developed a plan governing how it will manage this program and its contractors, and it has not developed an evaluation plan for its ongoing digitization concept of operations pilot test, even though it has either awarded or plans to award contracts totaling about $20 million for this pilot. In addition, USCIS officials told us they do not yet know which A-Files immigration forms will be scanned. Without a defined scope and adequate planning, this program is at risk of falling short of expectations.

section_title: Letter
paragraphs: The United States Citizenship and Immigration Services (USCIS) within the  Department of Homeland Security (DHS) relies on more than 55 million  paper-based files, each containing between one and hundreds of pages of  immigration information, to adjudicate applications for immigration status  and other benefits. These alien files (A-Files) are kept for 75 years, and the  data contained in these files are also used by federal, state, and local  agencies.
Ensuring the currency and availability of these paper files to support a  range of agency mission needs is a major challenge for USCIS. To address  this challenge, USCIS plans to pursue both long-term and near-term A-Files  automation efforts. While the scope, content, and approach to its long-term  efforts have not yet been defined, in the near-term, USCIS has begun the  Integrated Digitization Document Management Program (IDDMP), which it  estimates will cost about $190 million over an 8-year period. This program  provides for electronically scanning paper forms and associated  documents contained in the A-Files, storing the resulting electronic images,  and providing user access to the images. Thus far, USCIS has either  awarded, or plans to award, five contracts to pilot test a digitization  concept of operations. These contracts are being funded primarily with  funds that were set to expire by the end of September 2005.
As part of your request that we review USCIS’s management and use of the  A-Files, we agreed to determine whether USCIS was effectively managing  its A-Files automation efforts. To accomplish this objective, we reviewed  available plans and contractor statements of work pertaining to the  automation efforts. We conducted our review from August 2005 through  February 2006 in accordance with generally accepted government auditing  standards. Details on our objective, scope, and methodology are provided  in appendix I.
subsections: section_title: Background
paragraphs: A mission of USCIS is to provide timely and accurate information and  services to immigrant and nonimmigrant aliens as well as to federal  employees who make informed decisions about, for example, granting  citizenship and approving immigration benefits. To perform this mission,  staff dispersed among approximately 89 of USCIS’s field offices require,  among other things, access to an alien applicant’s case history information.  Currently, this information resides primarily in the paper-based A-Files.
To improve the reliability and currency of the A-Files, as well as their  accessibility to geographically and organizationally dispersed users, USCIS  intends to automate the A-Files, beginning with scanning certain forms  contained in the A-Files and storing the resulting electronic images. While  these automation efforts were to be part of their IT Transformation  Program, both A-Files automation and the IT Transformation Program  were recently incorporated into an agencywide organizational and business  transformation effort referred to as the USCIS Transformation Strategy.
subsections: section_title: A-Files Are Important to Mission Operations of USCIS and Other Agencies
paragraphs: A-Files are a critical component of the USCIS mission of ensuring the  integrity of the immigration system. These files are used by USCIS staff to  make immigration and citizenship decisions. Maintaining the currency of  these files and distributing them in a timely manner has been a long- standing challenge.
An A-File is the set of records USCIS maintains on certain individuals to  document their interaction with USCIS in actions prescribed by the  Immigration and Nationality Act and other regulations. The single most  important set of records kept by USCIS are A-Files. An A-File contains  between one and hundreds of pages of documents and forms, such as  submitted benefits and naturalization forms, photographs, fingerprints, and  correspondence from family members or third-party sponsors. According  to USCIS, A-File information is used to  grant or deny immigration-related benefits,  capture subsequent status changes,  prosecute individuals who violate immigration law,  document chain of custody for enforcement,  control and account for records in compliance with the code of federal   certify the existence or nonexistence of records.
USCIS estimates that it currently has more than 55 million of these paper- based files, each of which is to be maintained for a 75-year period.
Generally, USCIS processes for adjudicating alien benefit requests vary by  type of application or form, and may involve creating, searching,  transporting, obtaining, examining, updating, or storing the A-File. Figure 1  is an example of one such process: the Family-Based Adjustment of Status,  also referred to as the Application to Register Permanent Residence, or  Form I-485. The process of submitting this form involves both manual and  automated steps.
As illustrated in figure 1, the alien submits the I-485, along with the required  fee and supporting information, to a USCIS “lock box” in Chicago that is  operated by the Department of the Treasury on behalf of USCIS. Treasury  then captures the form electronically and creates an extract file containing  selected I-485 data elements that it sends in an electronic format to the  USCIS National Benefits Center (NBC), along with the original paper form  and supporting information. NBC prepares a daily upload file of all cases  that need biometric appointments. This information is used to schedule an  interview and direct the applicant to the Application Support Center, where  biometrics, such as fingerprints, will be captured. NBC obtains the paper  application and the selected electronic data elements, and inputs the data  elements into the Computer Linked Application Management System 3  (CLAIMS 3). In addition, NBC searches a USCIS electronic index system,  known as the Central Index System (CIS), to determine whether an A-File  already exists for the individual. If an A-File does not exist, one is created.  If one does exist, NBC determines its location by accessing an additional  system called the National File Tracking System (NFTS), which tracks the  physical location of the A-File. When NBC obtains the requested A-File, it  merges the Form I-485 into the A-File. NBC then performs an initial name  check using the Interagency Border Inspection System and the Federal  Bureau of Investigation (FBI) National Name Check Program, and updates  the A-File with the results.
While NBC is processing the application, the Application Support Center is  collecting the applicant’s biometrics and sending the data electronically to  the FBI, where a criminal background check is performed on the applicant.  When the FBI has completed the background check, it sends the results to  NBC, which then prints the results and adds them to the A-File.
When the A-File contains the I-485 application, biometrics, and background  check results, it is transported to the USCIS local office closest to the  applicant for a ruling on the applicant’s request. The local office reviews  the file, interviews the applicant, and makes a decision on the permanent  residence request. The A-File is then transported to the National Records  Center in Missouri for storage (see fig. 2).
According to a recent report by the DHS Inspector General (IG), this paper- based process is costly. For example,  the estimated costs for copiers and  copy paper for one USCIS service center is more than $400,000 per year.  Further, according to senior USCIS officials, the agency spends  approximately $13 million each year transporting A-Files within USCIS and  to other bureaus and agencies.
Besides USCIS’s need for A-Files, DHS’s Immigration and Customs  Enforcement (ICE), Customs and Border Protection (CBP), and U.S.  Visitor and Immigrant Status Indicator Technology (US-VISIT) need access  to either the data in the A-Files or the A-Files themselves, as do agencies  external to DHS, including the FBI, the Department of State, and state and  local governments. For example, USCIS officials told us that the FBI uses  A-Files data in performing law enforcement activities. In addition, USCIS  documentation shows that ICE uses A-Files as the principle source of  information for prosecuting aliens who have committed crimes and for  immigration removal proceedings; CBP uses A-Files when it interviews and  arrests aliens; and the Department of State uses data within the A-Files  when issuing visas to alien visitors. According to USCIS officials, obtaining  access to these A-Files has been a long-standing problem.
section_title: USCIS Intends to Address Limitations in Its IT and Data-Sharing Environments
paragraphs: The limitations in the USCIS IT and data-sharing environments are not  confined to the A-Files. According to a recent report by the DHS IG, USCIS  uses duplicative, nonintegrated, and inefficient data systems that have  limited information sharing, resulting in data integrity and reliability  problems. For example, adjudicators may need to access more than a  dozen systems using between 5 and 17 passwords, and may have to restart  these systems multiple times to process a given application. In addition, the  IG reported that the networks and hardware platforms across USCIS  offices are outdated and inconsistent. The IG also reported that past  problems in this IT environment have led to small, disparate business  process re-engineering initiatives that were narrowly focused and were not  sufficiently coordinated across the organization to enable standardized  processes.
To address these limitations, USCIS began an IT Transformation Program  in March 2005 that was led by the agency’s Office of the Chief Information  Officer (OCIO) and was intended to move USCIS progressively toward a  paperless environment that facilitates information sharing. In January 2006,  USCIS reported that this IT transformation effort was being subsumed into  a new, long-term organizational and business transformation effort,  referred to as the USCIS Transformation Strategy. Under this strategy,  according to USCIS officials, long-term solutions to its A-Files automation  needs will be pursued within the context of business process re- engineering.
In the interim, however, USCIS still intends to reduce the volume of paper  associated with its existing A-Files through a program called the Integrated  Digitization Document Management Program (IDDMP). According to  USCIS, the goals of the IDDMP are to  comply with laws governing electronic information storage and access   reduce the backlog of immigration benefit requests, ensure timely  access to files, and reduce paper-based file storage and transportation  costs; and  respond to a statement in The 9/11 Commission Report that all points in  the border system—from consular offices to immigration services  offices—will need appropriate electronic access to an applicant’s file.
To accomplish these objectives, IDDMP is to convert paper forms and  documents in existing A-Files to electronic images and manage the  retrieval, movement, retention, and disposition of these images. The  program is not intended to change existing USCIS core business processes,  but rather to merely reduce the amount of paper associated with these  business processes and improve user access to these scanned forms and  documents. The program is estimated to cost about $190 million over 8  years, which includes planning, acquisition of hardware and software  products and services, and operations and maintenance.
As part of the IDDMP, USCIS initiated a digitization and storage pilot to  scan approximately 1 million A-Files that include adjudicated I-485 forms  and supporting documents (each containing about 100 pages). The  purpose of the pilot is to validate that the digital format satisfies user  needs, to identify network storage requirements, and to provide insight into  potential scanning and storage problems. According to USCIS program  officials, the pilot involves five separate contracts, three of which are  primarily funded from $20 million that Congress had designated for “the  historical records project to convert immigration records into an  electronic, digitally-accessible format.” The other contracts were awarded  using other USCIS funding. Officials told us that they needed to move  quickly to obligate these funds before they were due to expire at the end of  September 2005, so they awarded four of the contracts in September 2005.  A description of each of the contracts follows.
Records digitization facility. According to program officials, this  contract is intended to set up a facility for scanning the piloted number of  A-Files and for scanning future A-Files. The contract is to cover preparing  the documents for scanning, scanning the documents, and performing  quality assurance checks on the captured images. It also is to cover  indexing the scanned images using the meta-data standards defined in the  requirements definition contract portion of the digitization pilot and  temporarily storing the images in a staging server until they are accessed  under the enterprise document management service contract. According to  officials, this contract was originally awarded in September 2005, and a  protest was filed in October 2005. During the course of the protest, the  agency took corrective action, which included re-evaluation of the  proposal; the protest was dismissed, the original award was vacated, and a  new award is expected in March 2006. The estimated value of the new  contract is $14 million.
Enterprise document management service. This contract, awarded in  September 2005, is to gather technical requirements for the design and  implementation of a system to electronically manage the scanned images  created by the records digitization process. In addition, the contractor is to  design and implement a system capable of ensuring image and data quality  and compliance with the DHS document management standard. It also  includes development of a Web infrastructure and implementation of user  interface software components. The value of this contract is about $2.3  million.
Storage facility infrastructure. Under this contract, awarded in  September 2005, the contractor is to provide hardware, software, and a  wide area network for the digitization and storage process. The value of  this contract is about $7.2 million.
Records business process re-engineering. This contract, which was  awarded in September 2005, includes determining how I-485 A-Files are  currently used for adjudicating permanent residence requests and  documenting the process for compilation, movement, digitization, and  lockdown of I-485 A-Files. The contractor is also to determine how to  effectively relocate the I-485 forms to the records digitization facility. The  estimated value of this contract is $487,400.
Requirements definition. This contract, which was awarded in October  2005 using fiscal year 2006 funds, covers gathering and documenting non- USCIS stakeholder digitization and document management requirements,  including the meta-data requirements for indexing the scanned documents.  As of December 2005, the first draft of requirements had been reviewed by  USCIS and some of the external stakeholders, including ICE, CBP, and the  Department of State. The contractor’s next steps are to refine the  requirements and develop, among other things, the plans of action and a  concept of operations for the digitization and document management  processes. The value of this contract is about $451,000.
section_title: USCIS Effectiveness in Managing Long-Term A-Files Automation Efforts Remains to Be Seen, but Near-Term Document Digitization Program Is Not Being Effectively Managed
paragraphs: It is not yet possible to determine the effectiveness of USCIS’s management  of its long-term A-Files automation effort because this effort is not yet  under way. However, USCIS currently has a near-term A-Files automation  effort under way (IDDMP) that it is not effectively managing. Specifically,  USCIS has not developed a program management plan to guide program  execution and provide the basis for reliable cost and schedule estimates,  and it does not have a plan for evaluating its IDDMP concept of operations  pilot test of a document scanning capability. According to USCIS officials,  these plans do not exist because the program is just getting started.  Nevertheless, five contracts have either been awarded or are to be awarded  under this program, a pilot test is under way, and significant program costs  are anticipated. Without effective planning, IDDMP is at risk of falling short  of expectations and its funding requests cannot be justified.
subsections: section_title: Long-Term A-Files Automation Effort Is Being Re-evaluated; It Is Too Early to Determine Whether It Is Being Effectively Managed
paragraphs: As we have previously reported, technology alone cannot be relied on to  solve long-standing and fundamental business problems, such as USCIS’s  dependence on paper-laden A-Files. Instead, our work has shown that such  organizational and business transformation requires a number of key,  interdependent elements working collectively to effect meaningful and  long-lasting institutional change and mission improvement. These elements  begin with strong, sustained executive leadership to direct and oversee  organizational reforms. Other elements include a comprehensive and  integrated business transformation plan, strategic management of human  capital, effective processes and related tools (such as an enterprise  architecture to provide a business and technology blueprint and associated  road map), and results-oriented performance measures that link  institutional, unit, and individual personnel goals, measures, and  expectations.
Until recently, USCIS had high-level, technology-focused plans for  modernizing its information systems environment, including plans for  automating its A-Files. These plans were part of the OCIO’s IT  Transformation Program, which included four components: (1)  establishing and evolving a mature CIO organization; (2) improving the IT  infrastructure; (3) implementing an information-based architecture to  facilitate information standardization, security, and sharing; and (4)  providing new business capabilities. However, agency officials told us in  January 2006 that the IT Transformation Program has been reconsidered  and will now be incorporated into a broader effort referred to as the USCIS  Transformation Strategy. While this broader organizational and business  transformation strategy has yet to be formally documented, officials told us  that the strategy will, among other things, align IT modernization with  broader organizational and business process changes. Restated, the IT  modernization will be neither separate from nor the driver of  organizational transformation. Rather, it will support and enable  organizational transformation. To illustrate, one approach to long-term A- Files automation could potentially involve doing away with both paper  forms and electronic images of these forms and instead provide for the  electronic capture of data when the applications are filed using Web-based  services and management of the captured data via corporate data  warehouses to facilitate data access and sharing.
USCIS’s more broadly based organizational and business transformation  concept, in which IT modernization will be treated as an enabler rather  than an independent undertaking or a driver, is more consistent with  effective transformation practices employed by successful organizations.  However, our experience has shown that successful organizations also  perform other key elements related to organizational and business  transformation. As we have previously reported, these elements are as  follows:  Ensure top leadership drives the transformation. Leadership must  set the direction, pace, and tone and provide a clear, consistent rationale  that brings everyone together behind a single mission.
Establish a coherent mission and integrated strategic goals to  guide the transformation. Together, these define the culture and  serve as a vehicle for employees to unite and rally around.
Focus on a key set of principles and priorities at the outset of the  transformation. A clear set of principles and priorities serves as a  framework to help the organization create a new culture and drive  employee behaviors.
Set implementation goals and a timeline to build momentum and  show progress from day one. Goals and a timeline are essential  because the transformation could take years to complete.
Dedicate an implementation team to manage the transformation  process. A strong and stable team is important to ensure that the  transformation receives the attention needed to persevere and be  successful.
Use the performance management system to define responsibility  and assure accountability for change. A “line of sight” shows how  team, unit, and individual performance can contribute to overall  organizational results.
Establish a communication strategy to create shared  expectations and report related progress. The strategy must  effectively communicate with employees, customers, and stakeholders.
Involve employees to obtain their ideas and allow them to  participate in the transformation. Employee involvement  strengthens the process and allows them to share their experiences and  shape policies.
Build a world-class organization. Building on a vision of improved  performance, the organization adopts the most efficient, effective, and  economical personnel, system, and process changes and continually  seeks to implement best practices. One such practice is the use of an  enterprise architecture.
The degree to which USCIS incorporates each of these key elements into  its current transformation efforts will help to determine the success of its  efforts, including the automation of its A-Files.
section_title: USCIS Is Not Effectively Managing Its Near-Term A- Files Automation Effort
paragraphs: Industry best practices and information technology program management  principles stress the importance of effective planning in the management  of programs, such as IDDMP. Inherent in such planning is the development  and use of program management plans, which define, among other things,  program goals and major milestones, delineate work tasks and products  and the associated schedules and resources for achieving them, define  management processes and structures (e.g., processes and structures for  tracking and overseeing contractors), identify key players and stakeholders  and their roles and responsibilities, and specify performance measures and  reporting mechanisms. They also require plans for testing and evaluating  program products and capabilities, including plans for evaluating the  results of pilot-testing efforts. Pilot evaluation plans include goals and  objectives, tasks, time frames, resource needs, roles and responsibilities,  and evaluation criteria and results measures. Such plans are essential to  ensuring, among other things, that programs are executed properly and  that funding requests are reliably derived.
USCIS has yet to develop either an IDDMP management plan or a pilot  evaluation plan. According to USCIS OCIO officials, the IDDMP is only now  being initiated, and the program office, including program staff, is not fully  in place. Thus, they said it is too early to expect these plans to exist.  Nevertheless, USCIS has awarded four contracts and is in the process of  awarding a fifth related to the program; these contracts total about $20  million, including an ongoing digitization and storage technology pilot test,  and it estimates that it will spend $190 million over an 8-year period on the  program. At the same time, officials told us they do not yet know which of  the roughly 50 types of forms associated with A-Files will be scanned and  stored or the sequence in which form types will be scanned. If all forms are  scanned, information provided by USCIS shows that scanning and storage  could cost as much as $550 million.
The absence of program planning was also noted in a December 2005  workshop by one of the digitization and storage pilot contractors.  Discussion points during this workshop included IDDMP’s lack of a clear  vision and business objectives, critical gaps in the digitization approach,  confusion regarding terminology and roles and responsibilities, and the  lack of a management plan. Restated, this means that large sums of  resources are being invested, and much larger sums are likely to be  invested, on a program that lacks plans for ensuring that the resources are  invested effectively and that resource estimates are valid. According to  OCIO officials, while the funding estimates are a “guess,” $20 million in  funds were designated in fiscal year 2005 for converting historical  immigration records into a digitally accessible format, and they needed to  move quickly to obligate these funds before they expired at the end of  September 2005. These officials also told us that, while they did not have  time to fully establish and staff a program office that would have pre- empted the contractor’s concerns, they are now taking steps to deal with  the concerns. However, we have yet to receive documentation from USCIS  as to the scope and nature of the steps they are taking.
Without effective planning, including a clearly defined program scope,  IDDMP is at risk of falling short of expectations and its future funding  needs are not adequately justified.
section_title: Conclusions
paragraphs: While it is too early to determine how effectively USCIS is managing its  long-term A-Files automation effort, USCIS’s recent decision to reconsider  its long-term IT modernization plans—including the role of IT in the  agency’s broader organizational and business transformation efforts—was  both warranted and appropriate. As USCIS defines and pursues these  strategic transformation efforts, it is important that the agency adequately  incorporate the keys to successful organizational transformation discussed  in this report.
With respect to management of its near-term A-Files automation efforts,  key IDDMP planning activities are not being performed effectively. Given  the contractual commitments being made on IDDMP, as well as the  potential for the cost of this program to reach well into the hundreds of  millions of dollars, it is critical that USCIS expeditiously develop an  effective program management plan and pilot evaluation plan to guide the  execution of the program and the pilot test, respectively. Without these  plans, IDDMP is at risk of not meeting expectations and its funding needs  are not adequately justified.
section_title: Recommendations for Executive Action
paragraphs: To better ensure the success of USCIS’s long-term transformation efforts,  to include A-Files automation, we recommend that the Secretary of  Homeland Security direct the Director of USCIS to implement the following  two recommendations: 1. Ensure that the key elements to successful organizational and business  transformation cited in this report are employed.  2. Ensure that both a program management plan and a pilot evaluation  plan are expeditiously developed and approved for IDDMP, along with a  reliable estimate of funding requirements.
section_title: Agency Comments
paragraphs: In commenting on a draft of this report, the Department of Homeland  Security agreed with our recommendations and described actions that are  planned and under way to address them. It also provided technical  comments that we have incorporated, as appropriate. The department’s  comments are reprinted in appendix II.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from the  report date. At that time, we will send copies to the Secretary of Homeland  Security, the Director of the United States Citizenship and Immigration  Services, and appropriate congressional committees. We will also make  copies available to others on request. In addition, this report will also be  available at no charge on GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-3439 or hiter@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix III.
section_title: Objective, Scope, and Methodology
paragraphs: Our objective was to determine whether the United States Citizenship and  Immigration Service (USCIS) is effectively managing its alien files (A-Files)  automation efforts. To accomplish this objective, we reviewed and  analyzed USCIS’s information technology (IT) strategic plan, IT  Transformation Program planning documents, and IT Transformation  Program mission needs statement, as well as available documentation for  the Integrated Digitization Document Management Program (IDDMP). In  addition, we reviewed the A-Files budget submission to the Office of  Management and Budget, the digitization and storage contractor  statements of work, and requirements meeting minutes. Among other  things, we interviewed program officials, including the USCIS chief  information officer and the IDDMP manager. We also interviewed officials  from Immigration and Customs Enforcement and met with officials at the  Department of Homeland Security (DHS) Office of Inspector General to  discuss program management activities for the IDDMP.
We conducted our work at DHS headquarters offices in Washington, D.C.,  from August 2005 through February 2006 in accordance with generally  accepted government auditing standards.
section_title: Comments from the Department of Homeland Security
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, the following staff made key  contributions to this report: Michael Marshlick, Assistant Director; Elena  Epps; Kate Feild; and Nancy Glover.