INS processed approximately 1.3 million citizenship applications between August 31, 1995, and September 30, 1996; 1,049,867 of the applicants were naturalized. During this period, INS initiated a number of efforts, under a program called “Citizenship USA,” to accelerate and streamline its process for naturalizing citizens. In its December report, KPMG stated that while INS’ efforts greatly increased the volume of applicants who were processed and approved, the potential for error also increased during this period. In an effort to determine if past naturalization efforts were adjudicated correctly, INS reviewed selected naturalization cases approved between August 31, 1995, and September 30, 1996. EOIR was to provide quality assurance assistance for INS’ review. KPMG, under contract with JMD, monitored and validated INS’ review. A primary naturalization criterion is that applicants must be able to establish good moral character to become naturalized citizens. Under certain circumstances, applicants who fail to reveal their criminal histories or who have been convicted of certain crimes, such as crimes involving moral turpitude (e.g., certain felonies and certain misdemeanors), cannot, by statute, establish good moral character. To judge if any citizenship applicants have failed to establish good moral character, INS, with assistance from the FBI, was to identify those applicants who have criminal histories. Previously, to identify these applicants, INS required that aliens submit fingerprint cards with their applications for naturalization. Each fingerprint card was to include a complete set of fingerprints and other identifying information, such as the alien’s name and date of birth. INS was to send each fingerprint card to the FBI for it to determine if an alien had a criminal history record on file. Part of the naturalization process was to include an interview between an INS adjudicator and the applicant. The interview, which is done under oath, was to include a discussion about any criminal history of the applicant—that is, arrests or convictions—which should be available at the time of the interview. To judge if naturalization cases that were processed between August 31, 1995, and September 30, 1996, were adjudicated correctly and if the naturalization process had adequate controls, INS reviewed selected cases to judge, on the basis of the information in the files, if the naturalized citizens were of good moral character. INS, with the FBI’s assistance, identified 80,856 criminal histories for applicants believed to be naturalized during this period with records that included felonies, misdemeanors, or INS administrative arrests or convictions. An aspect of this review was to identify aliens who may not have revealed their arrests or convictions. After reviewing criminal histories provided by the FBI, INS identified 17,257 applicants who were naturalized between August 31, 1995, and September 30, 1996, with criminal history records of arrests for felonies or other potentially disqualifying crimes. To conduct the review, INS requested the 17,257 case files from its field offices. Only 16,858 of the requested case files were reviewed because INS field units could not locate 399 case files. Accordingly, INS reviewed 16,858 criminal histories and corresponding case files in an attempt to judge if these aliens should have been naturalized. Under KPMG’s monitoring, INS activities included (1) collecting the appropriate criminal history records from the FBI, (2) sorting and categorizing these records, (3) matching (and filing) these records with the appropriate INS case file for the naturalized alien, (4) assigning case files to review adjudicators, and (5) ensuring that the case files were consistently reviewed and contained a standardized worksheet summarizing the results of the adjudicator’s review. Using a standardized worksheet, INS adjudicators reviewed the case files of these aliens and made independent judgments about the initial adjudication decisions. KPMG monitored the review adjudicators’ work. In addition to the 399 alien case files that INS could not locate, another estimated 300 criminal history records were not available for review and therefore were not included with the 80,856 criminal histories. The 300 criminal history records apparently had been in transit between the FBI and INS and were received too late to be included in the INS review. KPMG reported that INS’ preliminary assessment of the approximately 300 alien criminal history records was that most of these aliens had only old administrative arrests or were never naturalized. Furthermore, INS concluded that even if the case files for these aliens had been received in time for the review, very few of them would have been included in the INS review. To help ensure consistency among the INS review adjudicators in their decisionmaking, KPMG took a number of actions. These actions included the following: teaching the adjudicators how to complete the standardized worksheets in a consistent manner, checking the case files and standardized worksheets after the adjudicators’ reviews were completed, requiring a total review of all daily work from any adjudicators for whom significant errors in completing the standardized worksheets were found, requiring senior adjudicators to verify a sample of other adjudicators’ work each day, and identifying adjudicators’ recurring errors and providing additional guidance to those adjudicators to avoid the recurrence of the errors. In addition to the above actions, KPMG activities included (1) examining and categorizing each criminal history record and verifying that the record was part of the review, (2) safeguarding and securing files, and (3) promoting consistency of review adjudicator decisions by having discussions with the adjudicators when KPMG felt these discussions were needed. The INS adjudicators reviewed the case files of the 16,858 naturalized aliens with criminal history records that included records of arrests for felonies or other potentially disqualifying crimes to judge if the initial adjudications were proper. The review results were based only on the data in the case files at the time of the adjudicators’ reviews. In some cases, data may have been removed from or added to the INS case files after the initial decisions were made and before the files were reviewed. Also, although the adjudicators who made the initial decisions to approve the aliens’ naturalization applications had the benefit of discussing the naturalization applications with the aliens, the review adjudicators did not meet with the applicants. As shown in table 1, in its review of these 16,858 case files, INS designated each case as either “proper,” “requires further action,” or “presumptively ineligible.” According to INS officials, a case was designated as proper if the data in the case file supported the initial decision to naturalize the individual. A case was designated as requires further action if the data in the case file were insufficient to support a proper decision yet did not appear to indicate that the individual was barred from being naturalized. For example, some case files did not contain data about the dispositions of arrests that may have affected the individuals’ eligibility for naturalization. Cases involving a failure to disclose an individual’s criminal history were also classified as requires further action because the determination of whether the failure to reveal the criminal history affected the individual’s eligibility for naturalization required a legal determination that went beyond the scope of the INS review. A case was designated as presumptively ineligible if the data in the case file or the criminal history appeared to indicate that the alien should have been barred from being naturalized. INS is reviewing, for potential revocation, the 369 cases of those aliens who were judged to be presumptively ineligible as well as the 5,954 cases requiring further action. EOIR independently reviewed case files of previously naturalized aliens to provide quality assurance that INS’ decisions during the review were unbiased. EOIR reviewed a statistically valid sample of 557 alien case files from the universe of 16,858 cases involving aliens who had criminal history records. EOIR’s review was done separately from the INS adjudicators’ review. In conducting the review, EOIR teams of two staff each reviewed the alien case files at the Lincoln Service Center. The initial EOIR team received an orientation regarding the mechanics of properly completing the standardized worksheet. The lead EOIR staff member returned to the service center to provide the orientation to each subsequent team. The EOIR reviewers and the INS review adjudicators had the same decisions in 439 of the 557 cases (or 79 percent). Specifically, EOIR and INS independently judged that 288 cases were proper, 147 cases required further action, and 4 cases were presumptively ineligible (see table 2). The results for the 118 cases in which INS and EOIR reached different decisions were as follows: in 6 cases, INS judged that the aliens were presumptively ineligible, while EOIR judged that in 1 of these cases the initial adjudication decision was proper and in the other 5 cases further action was required by INS field units; in 40 cases, INS judged that further action was required by its field units, while EOIR judged that in 36 of these cases the initial adjudication decisions were proper and in the other 4 cases the aliens were presumptively ineligible; and in 72 cases, INS judged that the initial adjudication decisions were proper, while EOIR judged that in 68 of these cases further action was required by INS field units and in the other 4 cases the aliens were presumptively ineligible. Regarding the differences between the INS and EOIR decisions, KPMG reported that much of the naturalization process and the review of case file information required the reviewers to make subjective analyses. Therefore, according to KPMG, it was highly improbable that the reviewers would reach full agreement on all of the cases. KPMG stated that the major contributing factor to differences in INS’ and EOIR’s judgments was the interpretation of case file documentation regarding the applicants’ acknowledgment of prior criminal histories. KPMG added that, in many cases, EOIR and INS reviewers had to make subjective decisions as to whether sufficient case file documentation existed to justify their decisions.