Information Technology: Near-Term Effort to Automate Paper-Based Immigration Files Needs Planning Improvements
Released: 2006-05-01T00:00:00

Letter

Background

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.

A-Files Are Important to Mission Operations of USCIS and Other Agencies

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.

USCIS Intends to Address Limitations in Its IT and Data-Sharing Environments

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.

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

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.

Long-Term A-Files Automation Effort Is Being Re-evaluated; It Is Too Early to Determine Whether It Is Being Effectively Managed

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.

USCIS Is Not Effectively Managing Its Near-Term A- Files Automation Effort

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.

Conclusions

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.

Recommendations for Executive Action

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.

Agency Comments

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.

Objective, Scope, and Methodology

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.

Comments from the Department of Homeland Security

GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.