INS Budget: Overhiring and Decline in Revenues Have Created Fiscal Stress

Published by the Government Accountability Office on 1999-03-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                        United States General Accounting Office

GAO                     Testimony
                        Before the Subcommittee on Commerce, Justice, State, the
                        Judiciary, and Related Agencies, Committee on
                        Appropriations, House of Representatives

Not to be Released
3:00 p.m. EST
                        INS BUDGET
March 24, 1999

                        Overhiring and Decline in
                        Revenues Have Created
                        Fiscal Stress
                        Statement for the Record by
                        Norman J. Rabkin, Director
                        Administration of Justice Issues
                        General Government Division


             Mr. Chairman and Members of the Subcommittee:

             I am pleased to submit this statement for the record as you consider the
             fiscal year 2000 budget request for the Immigration and Naturalization
             Service (INS). In your letter requesting that we examine INS budget issues,
             you noted a concern that “INS has incurred budget shortfalls” for fiscal
             year 1999. We have sought to determine (1) INS’ overall fiscal condition in
             fiscal year 1999, and (2) how factors such as overhiring and a decline in
             Examinations Fee applications have affected INS’ fiscal situation.

             After discussions with officials in INS, the Department of Justice (DOJ),
             and the Office of Management and Budget (OMB), and based on our
             analysis of INS budget documents, we concluded that INS is not
             experiencing an overall budget shortfall at this time. The hiring policy that
             INS followed in fiscal year 1998 in an attempt to meet congressional and
             administration expectations resulted in INS having to commit a greater
             share of its fiscal year 1999 budget to salaries and benefits than in prior
             years. Overall, however, INS currently has more discretionary funds than it
             had in fiscal year 1998. With respect to the Examinations Fee account, INS
             overestimated the number of applications it would receive and did not
             detect the consequent revenue shortfall for months because of computer
             programming errors. When it became apparent that the anticipated
             revenues would not be realized, INS decided to seek reprogramming of
             funds from other accounts to cover the costs. The overhiring and reduced
             Examinations Fee revenues contributed to most INS programs having less
             discretionary funding in fiscal year 1999 than in fiscal year 1998.

             Although INS has not experienced an overall budget shortfall, the
             combination of higher personnel costs, declining Examinations Fee
             revenues, and the resultant need to reduce discretionary funding
             allocations to most programs has created fiscal stress for the agency.

             As shown in figure 1, INS has benefited from significant increases in its
Background                                                                     1
             regular appropriations and appropriations from its fee accounts. Funding
             increases have continued in fiscal year 1999 with Congress providing over
             $3.9 billion. When funding from the Working Capital Fund, carryover
             balances, and certain reimbursements are added to this figure, INS’
             operating budget totals approximately $4.0 billion for fiscal year 1999.

              INS fees are appropriated from special fund receipt accounts to provide reimbursement to INS’
             Salaries and Expenses account for certain expenses. Fees can only be used for purposes as authorized.

             Page 1                                                                  GAO/T-GGD/AIMD-99-129

Figure 1: INS Funding for New Budget
Authority, Fiscal Years 1994-1999 (est.)

                                           Note: Includes reimbursements in the Salaries and Expenses account. Does not include
                                           appropriations to the Immigration Emergency Fund.
                                           Source: OMB, Budgets of the United States Government, fiscal years 1996 - 2000

                                           INS divides its operating budget into four categories of spending: (1)
                                           mandatory expenses, e.g., rent; (2) personal salaries and benefits; (3) set-
                                           asides, such as employee relocations, vehicle acquisitions, and background
                                           investigations; and (4) discretionary funding. For purposes of this review,
                                           the first three categories can be grouped together as expenses that either
                                           have first claim on a budget because they must be paid or are considered
                                           integral to an agency’s operations. Although many of these expenses
                                           directly benefit field operations, most are centrally-funded at headquarters.
                                           The last category—discretionary funding—funds personnel costs for other-
                                           than-permanent employees; discretionary overtime; travel; cash awards;
                                           some types of procurements; and day-to-day operating expenses, such as
                                           equipment maintenance and lease of copiers. Table 1 shows data provided
                                           by INS on its end-of-year allocation for fiscal year 1998 compared with its
                                           current allocation for fiscal year 1999, by spending categories.

                                               INS refers to salaries and benefits for its personnel as “personal salaries and benefits.”

                                           Page 2                                                                          GAO/T-GGD/AIMD-99-129

Table 1: INS Allocations for Fiscal Years
1998 and 1999 (in Millions of Dollars)                                          Personal
                                            Fiscal               Mandatory   salaries and                Discretionary
                                            year                  expenses       benefits   Set-asides        funding       Total
                                            1998                    $252.1      $1,800.7       $299.4        $1,515.7    $3,867.9
                                            1999                     304.6        1,816.9        363.0        1,545.6     4,030.2
                                            Source: INS, Office of Budget.

                                            To determine (1) INS’ overall fiscal condition, and (2) how factors such as
Scope and                                   overhiring and a decline in Examinations Fee applications have affected
Methodology                                 INS’ fiscal situation, we interviewed officials in INS’ Offices of Budget,
                                            Personnel, Facilities, and Field Operations. To get additional perspectives
                                            on INS’ funding status, we interviewed officials in DOJ’s Justice
                                            Management Division and OMB’s Justice and General Services
                                            Administration Branch. We reviewed INS budget documents prepared for
                                            fiscal year 1999 that were submitted to the Justice Department, OMB, and
                                            Congress, as well as those prepared for internal use, to document and
                                            analyze changes in funding. In addition, INS provided memorandums and
                                            briefing documents relevant to our work and additional supporting
                                            material prepared specifically for our review. Our work was performed in
                                            Washington, D.C., during February and March 1999, in accordance with
                                            generally accepted government auditing standards.

                                            Since 1996, INS has been making a concentrated effort to fill both its
Overhiring Policy                           existing vacancies and many new positions authorized by Congress each
Created Fiscal Stress                       year. However, throughout this period, attrition of staff already on-board
                                            and reported difficulties in hiring new staff have impeded INS from filling
                                            many positions. In an attempt to remedy this situation, INS allowed field
                                            offices to hire 4 percent more than their number of funded positions
                                            during fiscal year 1998. As discussed below, this policy, combined with
                                            other fiscal pressures, resulted in most INS programs having less
                                            discretionary funding in fiscal year 1999 than in fiscal year 1998.

                                            Between the end of fiscal years 1995 and 1998, INS’ on-board staff
                                            increased from 18,823 to 27,941. INS anticipates adding another 3,000 staff
                                            by the end of fiscal year 1999. However, according to INS officials,
                                            throughout this period, the number of staff on board generally lagged
                                            behind authorized levels. INS officials attribute the lag to (1) significant
                                            new authority to hire provided by Congress each year, (2) high rates of
                                            attrition of on-board staff throughout the year, and (3) difficulty in
                                            recruiting and retaining a group of qualified candidates from outside of INS
                                            to fill vacancies as they arise.

                                            Page 3                                                          GAO/T-GGD/AIMD-99-129

Since 1996, INS has taken several steps to overcome these difficulties.
First, to ensure that its workforce would expand rather than shift
internally, INS directed field staff to hire for only entry level positions.
Second, INS allowed field managers to select a larger pool of candidates to
consider for employment than they were authorized to hire because it was
anticipated that a number of candidates would (1) not make it through the
pre-appointment process, or (2) no longer be available by the time INS
could make an offer of employment. Third, with approval, field managers
were permitted to hire 2 percent more than their number of funded
positions. The over-hiring was supposed to occur in field offices where
attrition or new hiring authority was anticipated. The over-hired positions
were supposed to be used to fill vacancies as soon as they occurred so that
field office hiring would not exceed funded levels for the year. At the start
of fiscal year 1998, regional directors requested, and the Commissioner
approved, an increase in the over-hire authority to 4 percent. During fiscal
year 1998, the number of INS staff on board increased from 86 to nearly 97
percent of INS’ funded level.

The large amount of fiscal year 1998 hiring created fiscal stress for the
agency by increasing certain payroll costs beyond budgeted levels.
According to INS officials, beginning in fiscal year 1998, there was a rapid
acceleration in the on-board rate of Border Patrol agents, Investigators,
and Detention and Deportation officers. These positions were over-hired
for substantial periods during fiscal year 1998. This created a funding
problem because INS allocated personal services and benefits (PS&B) for
funded positions only--not over-hired ones. As of May of 1998, INS
projected that the PS&B portion of one of its accounts—Salaries and
Expenses—would have a deficit of $16.1 million by the end of the fiscal
year. The Border Patrol program accounted for most of the projected
deficit. The nine other accounts that also provide funding for PS&B were
projected to have surpluses or have negligible deficits.

INS officials attributed the deficit in part to previous and projected over-
hiring by field offices. INS officials told us that some field offices would
over-hire, but then not use the over-hired position to fill their vacancies. In
some cases, they said this occurred because there was a mismatch
between the positions that had been over-hired and the vacancies that

 The overselection involved INS conducting such pre-hire activities as background checks and medical
examinations for several candidates who were potentially eligible for a single position. By doing this,
INS hoped that when a position became available, a candidate could be brought on board immediately.
 INS’ budget is funded in 17 separate accounts. Ten of these accounts provide funding for a variety of
expenses including PS&B, which pays for the salaries and benefits of full-time permanent staff.

Page 4                                                                    GAO/T-GGD/AIMD-99-129

occurred. They said another reason for the deficit was a miscoding of $2.5
million in obligations for newly hired personnel to the Salaries and
Expenses account instead of the Violent Crime Reduction Trust Fund
(VCRTF) account.

In response to the anticipated deficit, in May 1998, the Office of Budget
issued guidance to executive staff. The guidance said the over-hire policy
was not intended to permit field offices to remain up to 4 percent over the
authorized number of positions for extended periods of time. The guidance
listed four actions to be taken: (1) correct miscoding of new hires from the
Salaries and Expenses account to the VCRTF account; (2) ensure all new
hires are coded to the correct account; (3) manage subsequent hiring to
resolve over-hiring of officer positions; and (4) redirect, by the Office of
Budget, $6.5 million to cover the remainder of the anticipated year-end
PS&B deficit. The guidance warned that if hiring continued to exceed
authorized levels, discretionary funds would have to be used to cover the
projected deficit in PS&B funds.

However, as of August 1998, the projected deficit of PS&B funds in the
Salaries and Expenses account had increased to $20 million. To respond to
this situation, according to budget officials, field staff were directed to
reduce staff on board to funded levels. At the end of fiscal year 1998,
however, certain enforcement positions were still over-hired. According to
an INS budget official, the over-hired positions accounted for about $12
million in PS&B deficits. Approximately 50 percent of that amount was
covered by unobligated discretionary funds that were reallocated by INS
regions to PS&B.

In the past, according to INS and Justice Department officials, PS&B
funding that was not used to pay personnel costs was reallocated to help
fund other spending. To successfully implement the policy of hiring up to
funded levels during fiscal year 1998, INS had to commit a larger share of
its budget to pay for personnel costs. This meant that a smaller share of
funds would be available to address other needs. For example, to pay an
$80 million settlement with the Investigation Union, INS has been paying in
annual $10 million installments from its Investigations lapsed PS&B funds.
As a result of the increased hiring in fiscal year 1998, the Investigations

 Regardless of the number of vacancies that may exist at the beginning of the fiscal year, the Office of
Budget allocates enough PS&B funds to pay for all on-board full-time permanent positions plus
planned new hires, and attrition back-fills. Since fiscal year 1997, INS has been using a model to
project PS&B funding needs by pay period through the end of the fiscal year. The model uses data on
hiring, attrition, and actual spending. INS uses the output from the model in quarterly financial reviews
to help assess its financial position.

Page 5                                                                      GAO/T-GGD/AIMD-99-129

program reportedly did not have sufficient lapsed dollars to fund the $10
million installment. As a result, the Office of Budget set aside $10 million
of Investigations funding at the beginning of fiscal year 1999 to pay the
current year installment. This meant that the Investigations program
received substantially fewer dollars for discretionary spending.

To illustrate the impact of hiring up to funded levels on INS’ budget, if INS
remained at the 86 percent on-board level that existed at the beginning of
fiscal year 1998, then about $250 million in PS&B funds would have been
available to spend on other needs. But, INS finished fiscal year 1998 with
nearly 97 percent of its funded positions filled. If INS remained at the 97
percent on-board level throughout fiscal year 1999, it would have $60
million in PS&B funds after meeting payroll costs. This would be $190
million less than PS&B funds available with an 86 percent on-board level.

After meeting payroll expenses, mandatory costs, and other expenses set
aside for centrally-funded items that support service-wide needs, INS
currently had about $71.8 million more in discretionary funds, overall, than
it had in fiscal year 1998. Within INS, the Office of Field Operations, which
distributes funding to field offices, had more discretionary funds than it
had in fiscal year 1998, while all other headquarters offices received less
discretionary funds.

Although, overall, the Office of Field Operations received more
discretionary funds than in fiscal year 1998, some programs within the
Office of Field Operations received less. Table 2 provides a breakdown of
how the 11 programs under the Office of Field Operations fared. Initially,
in December 1998, when the Office of Budget communicated to the Office
of Field Operations how much it would have available in discretionary
funds, the total amount appeared to be $199 million less than was allocated
in fiscal year 1998. However, according to INS officials, this amount did
not yet include $270.7 million that was available from Examinations Fee
funds, Salaries and Expenses funds for Adjudications and Naturalization
program initiatives, and Working Capital funds. The amounts available
from these funds had not yet been allocated because detailed spending
plans needed to be developed first. Including the $270.7 million, the Office
of Field Operations would have had $71.7 million more in discretionary
funds, overall. In January 1999, the $270.7 million was allocated and,
following feedback from the field about the inadequacy of the funds
initially communicated, headquarters executive staff redirected $47.7
million to field operations for discretionary funds. These actions resulted
in a total allocation that was $120.6 million more than in fiscal year 1998.

Page 6                                                  GAO/T-GGD/AIMD-99-129

                                             Five of the 11 programs under the Office of Field Operations had less
                                             discretionary funds than in fiscal year 1998.

Table 2: Discretionary Funding Allocations to Field Operations (Dollars in Millions)
                                             Partial fiscal
                           End of fiscal     year 1999           Increase/            Fiscal year 1999 Increase/                 Percent change
                           year 1998         allocationa         (decrease) from      allocation       (decrease) from           from fiscal year
Program                    allocation        12/23/98            fiscal year 1998     1/28/99          fiscal year 1998          1998
Inspections                         $109.5              $99.9              ($9.6)              $103.3            ($6.2)                      -5.7
Border Patrol                         86.5               57.4              (29.1)                89.5               3.1                       3.5
Investigations                        41.3                 9.3             (32.0)                21.9            (19.4)                    -47.0
Detention and
Deportation                         463.8              420.3                (43.5)               426.0                (37.8)                 -8.1
Intelligence                          0.5                1.4                   0.9                 1.9                   1.4                309.6
Adjudications and
Naturalization                       38.7                 6.7               (32.0)               176.2                137.4                355.0
International Affairs                46.6                 7.0               (39.6)                35.0                (11.6)               -24.9
Training                              0.5                 0.4                (0.1)                 0.5                   0.0                 0.3
Data and Communication                1.9                 2.4                  0.5                32.9                  31.0             1,657.0
Information and Resource
Management                           12.3                 0.2               (12.1)                 38.4                 26.1                211.5
Management and
Administration                        5.6                3.2                (2.4)                  3.4                 (2.2)                -39.7
Total                               807.1              608.1              (199.0)                929.0                121.9                  15.1
                                             Note: Rounding may affect the calculation of percentages and totals.
                                              Excludes $270.7 million that was available, but had not yet been calculated and communicated to the
                                             field. This amount consisted of $171.7 million in Examinations Fee funds, $92.0 million in S&E funds
                                             for Adjudications and Naturalization program initiatives, and $7.0 million in Working Capital funds.
                                             Source: Immigration and Naturalization Service, Office of Budget and Office of Field Operations.

                                             According to a DOJ official, these problems were not communicated to
                                             Congress until January 22, 1999. According to INS Office of Budget
                                             officials, the potentially difficult fiscal situation for fiscal year 1999 was
                                             conveyed internally at meetings with (1) resource management staff in
                                             July 1998, (2) executive staff and regional directors in August 1998 during
                                             the third quarterly financial review, and (3) INS managers in October 1998
                                             at the annual Commissioner’s conference. However, initial budget
                                             allocations were not made until December 11, 1998, nearly the end of the
                                             first quarter of fiscal year 1999. According to budget officials, the
                                             allocations were made in December because of the complicated nature of
                                             the appropriation. Office of Field Operations officials said they were
                                             surprised by the magnitude of the reductions in discretionary funds.

                                              Office of Budget officials said this year’s budget execution process was complicated by (1) the three-
                                             week delay in final appropriations, (2) numerous base transfers between appropriated and fee
                                             accounts, (3) the division of the S&E account into separate enforcement and benefits accounts, which
                                             also affected all fee accounts, reimbursable agreements, and transfers that reimburse the split S&E

                                             Page 7                                                                     GAO/T-GGD/AIMD-99-129

                            INS continues to pursue the goal of hiring to its authorized level. However,
                            as of January 6, 1999, the Executive Associate Commissioner for Field
                            Operations cancelled the over-hire authority for all programs except, in
                            certain circumstances, those funded by the Examinations Fee Account.

                            In formulating its fiscal year 1999 budget, INS projected in November 1997
Declines in                 that it would receive 6.9 million Adjudications and Naturalization
Examinations Fee                         7
                            applications, and that these would produce $862 million in revenues for its
Revenues and Delays         Examinations Fee account. In July 1998, INS was projecting 5.6 million
                            applications and $560 million in revenues for this account. INS
in Detecting the            overestimated the number of applications—in particular, the number of
Declines Added to INS’      naturalization applications--that would be submitted to INS, and because
Fiscal Stress               of computer problems, it was not able to detect the downturn in
                            applications in a timely fashion. In August 1998, DOJ submitted a
                            reprogramming request for $171 million, of which $88 million was to help
                            cover the decline in Examinations Fee revenues.

INS Erroneously Expected    INS uses statistical modeling methods to estimate anticipated applications
                            and associated revenues. Based on receipts collected since October 1991,
Examinations Fee Revenues   the statistical analyses forecast receipts for the coming year. For fiscal
to Continue Increasing in   year 1999, the original forecasts were made in November 1997. Revisions
Fiscal Year 1999            were made in March, June, and July 1998. INS also has a working group,
                            the Examinations Fee Working Group, that meets at least quarterly to
                            review the statistical forecasts and decide whether to make adjustments to
                            the statistical estimates. The working group is composed of
                            representatives from the Offices of Budget, Policy and Planning (Statistics
                            Branch), Field Operations (Immigration Services Division) and Programs
                            (Adjudications and Naturalization Branch). The group’s main
                            responsibility is to formulate monthly and annual receipt projections for
                            the Examinations Fee account. The Statistics Branch develops the
                            statistical model for each of the applications based on workload and/or
                            receipts. The working group uses this information to develop its
                            projections for the Examinations Fee account. In addition, INS consults
                            with community based organizations (CBOs) to obtain their input

                            accounts, and (4) the fiscal year 1999 reprogramming for naturalization initiatives that was submitted
                            as a separate request in August.

                             The function of the Adjudications and Naturalization program is to process, adjudicate, and grant or
                            deny applications for benefits provided under the immigration laws. Adjudication activities include,
                            among other things, processing applications for permanent resident status, petitions for relatives, and
                            workers’ applications. Naturalization activities include, among other things, the examination of aliens
                            to determine their qualifications for naturalization and issuance of citizenship documents.

                            Page 8                                                                     GAO/T-GGD/AIMD-99-129

  concerning the activities of immigrant groups. None of these sources
  anticipated the decline in applications and revenues that occurred in fiscal
  year 1998.

  A specific type of naturalization application, referred to as N-400 by INS,
  made up the single largest component, both in terms of the number of
  applications (estimated to be 21 percent in fiscal year 1999) and revenues
  generated (estimated to be 39 percent in fiscal year 1999), of the
  Examinations Fee account. INS projected in November 1997 that in fiscal
  year 1999, it would receive nearly 1.5 million N-400 applications, and that
  these would produce approximately $334 million in Examinations Fee
  revenue. In June 1998, INS lowered its fiscal year 1999 projections to
  700,000 applications and $127 million in revenue.

  INS officials have developed some hypotheses, including the following, to
  explain the unanticipated drop in applications:

• Based on contacts with several community based organizations (CBOs),
  INS believed that CBOs were stockpiling naturalization applications in an
  effort to help eligible aliens meet a January 1998 deadline for filing certain
  types of adjustment of status applications. INS officials expected that
  naturalization applications would surge after the deadline. However, it
  turned out that CBOs were not stockpiling naturalization applications, and
  the expected surge did not occur.
• Legislative changes restored some benefits for aliens, reportedly causing a
  reduction in the demand for naturalization.
• Naturalization applications have peaked from among the 2.7 million aliens
  who were granted amnesty by the Immigration Reform and Control Act of
  1986. However, evidence of this did not become clear until well into fiscal
  year 1998.
• INS had a large backlog of N-400 applications, perhaps creating a
  disincentive for applicants to apply for naturalization.

   In 1994, in P.L. 103-317, Congress enacted section 245(i) of the Immigration and Nationality Act,
  which allowed illegal aliens in the United States to adjust status once they, because of family
  relationships or job skills, became eligible for permanent residency, provided they paid a penalty fee.
  This section of the act was to sunset on September 30, 1997. There was debate on extending the
  provision, and the result was that the section was terminated in the fiscal year 1998 Commerce,
  Justice, State and the Judiciary Appropriations Act, P.L. 105-119. However, it included a grandfather
  clause that gave illegal aliens until January 14, 1998, to file the application for adjustment of status.

  Page 9                                                                       GAO/T-GGD/AIMD-99-129

Computer Problems             INS did not have timely information to determine that the number of N-400
                              applications had begun to decline. The key reason for this was that
Prevented INS From            computer programming errors were not detected and resolved for an 8-
Detecting Downturn in         month period in fiscal year 1998. During this period, INS did not know how
Naturalization Applications   many N-400 applications were received.

                              In December 1997, INS tried to change its naturalization case processing
                              and tracking system, the Redesigned Naturalization Application Casework
                              System (RNACS), to show the date that naturalization applications were
                              received at INS, not the date that they began to be processed by INS
                              adjudicators. However, when INS began to use RNACS with the
                              applications receipt date incorporated into it, the system only recognized
                              those applications that were received and processed in the same month. If
                              the application was received in one month and processed in another
                              month, the end-of-month summary report produced by INS’ Office of
                              Information Resources Management did not capture the information on
                              date of receipt.

                              INS headquarters officials were reportedly skeptical of the low
                              naturalization numbers derived from RNACS. However, it took several
                              months for INS officials to determine that there was a problem with
                              RNACS because (1) it generally takes 5 to 6 weeks for INS field offices to
                              generate statistical information for headquarters which, in turn, is
                              compiled and reported by headquarters’ Office of Statistics, and (2) INS
                              headquarters officials were not certain whether the unexpectedly low
                              numbers of naturalization applications represented real behavior or a
                              reporting error. It then took several months to correct the computer
                              problem and generate new reports. As a result, between October 1997 and
                              May 1998, INS’ Examinations Fee Working Group did not have reliable
                              data on which to base revised estimates of N-400 applications for fiscal
                              years 1998 and 1999.

                              We also examined whether and why INS’ rental payment to the General
GSA Rental Payment            Services Administration (GSA) for fiscal year 1999 may exceed INS’
Was Higher Than               amount of appropriation identified for rent. We found that INS’ rental
Expected                      payment is expected to exceed the amount appropriated by $13.2 million.
                              For several reasons, Justice officials said, it is difficult to accurately
                              project rent costs, and the shortfall in INS’ funds for rent is not
                              inconsistent with what it has incurred in prior years.

                              As of March 1999, the anticipated GSA rental payment for INS for the
                              current fiscal year is $160.1 million. This is $9.9 million above what was

                              Page 10                                                 GAO/T-GGD/AIMD-99-129

requested in the President’s Budget for rent and $13.2 million higher than
the $146.9 million appropriated by Congress.

Arriving at an accurate projection of rental payments is difficult for INS
and other Justice components, according to Justice officials. INS’ GSA
rental payment exceeded its appropriation by $15 million in fiscal year
1998, $9 million in fiscal year 1997, and $5 million in fiscal year 1996.
According to INS and and Justice officials, year-to-year fluctuations in the
accuracy of rent estimates could be caused by such factors as (1) the
actual GSA rental payment for fiscal year 1999 being higher than that
anticipated by INS at the time that it formulates its budget; (2) changes in
INS programs after the end of the budget cycle (e.g., information on new
projects requiring space become available after the budget cycle has
ended); and (3) the difficulty of projecting requirements in an environment
of high growth, such as that experienced by INS in recent years.

Page 11                                                GAO/T-GGD/AIMD-99-129
Page 12   GAO/T-GGD/AIMD-99-129
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