United States General Accounting Office
GAO Report to the Commissioner of the
Immigration and Naturalization Service
July 1997
INS MANAGEMENT
Follow-up on Selected
Problems
GAO/GGD-97-132
United States
GAO General Accounting Office
Washington, D.C. 20548
General Government Division
B-260846
July 22, 1997
The Honorable Doris Meissner
Commissioner
Immigration and Naturalization
Service
Dear Ms. Meissner:
This report discusses the progress that the Immigration and Naturalization Service (INS) has
made toward addressing long-standing management problems. It discusses actions taken by INS
to address management problems and areas that continue to need attention.
This report contains recommendations to you. The head of a federal agency is required by 31
U.S.C. 720 to submit a written statement on actions taken on these recommendations to the
Senate Committee on Governmental Affairs and the House Committee on Government Reform
and Oversight not later than 60 days after the date of the report. A written statement also must
be sent to the House and Senate Committees on Appropriations with the agency’s first request
for appropriations made more than 60 days after the date of the report.
We are sending copies of this report to the Attorney General, the Director of the Office of
Management and Budget, and other interested parties. We will also make copies available to
others on request.
If you or your staff have any questions concerning this report, please contact me at
(202) 512-8777. This report was done under the direction of Evi L. Rezmovic, Assistant Director,
Administration of Justice Issues. Other major contributors are listed in appendix VII.
Sincerely yours,
Norman J. Rabkin
Director, Administration
of Justice Issues
Executive Summary
The Immigration and Naturalization Service (INS), an agency of the
Purpose Department of Justice, has received considerable public attention in
recent years as immigration, especially illegal immigration, has become a
focus of national attention. From fiscal year 1993 to fiscal year 1997, INS’
budget more than doubled, and its personnel resources increased by about
45 percent to more than 26,000 positions.
In 1991, GAO reported that INS was experiencing severe management
problems in a variety of areas.1 Specifically, GAO reported that among other
things, INS (1) lacked clearly defined priorities, (2) lacked management
control over regional commissioners, (3) had poor internal
communications and outdated policies and procedures, (4) did not use
workload data to allocate resources and had budget management and
resource allocation problems that perpetuated backlogs in processing
immigrants’ applications for adjustment of status and naturalization, and
(5) had unreliable financial information that resulted in inadequate budget
monitoring.
Because of the history of management problems and the recent dramatic
growth in INS’ resources, GAO initiated this review to determine what
progress INS had made in these areas. Specifically, GAO’s follow-up review
assessed whether INS had (1) developed goals and priorities to guide
planning and resource allocation, (2) revised its organizational structure,
(3) improved internal communications and updated its field and
administrative manuals, (4) improved the process of allocating budgetary
resources, and (5) improved its capability to monitor its financial status.
GAO’s audit work was conducted between March 1995 and February 1997.
The scope of GAO’s follow-up work for this report did not include
evaluating the recent issues that have arisen regarding the effectiveness of
specific program areas or components, such as the naturalization program,
criminal alien removal program, and delays in implementing several major
automation systems. Nonetheless, other GAO work on some of those issues
indicated that they share, at least in part, common causes in terms of some
of the long-standing management weaknesses discussed in this report.
INSis responsible for both administering immigration-related services and
Background enforcing immigration laws and regulations. INS headquarters in
Washington, D.C., administers its functions through a network of 3
1
Immigration Management: Strong Leadership and Management Reforms Needed to Address Serious
Problems (GAO/GGD-91-28, Jan. 23, 1991).
Page 2 GAO/GGD-97-132 INS Management Problems
Executive Summary
regional offices, 33 district offices, and 21 Border Patrol sectors
throughout the United States. Immigration-related services include such
activities as port-of-entry admissions and processing requests for
adjustment of status, naturalization, and work authorization. Enforcement
responsibility includes such activities as border control, apprehension of
illegal residents and workers, and detention and removal of criminal
aliens.
In 1990, Congress created the Commission on Immigration Reform, which
was tasked with reviewing and evaluating the impact and implementation
of U.S. immigration policy. The Commission’s work, still ongoing as of
March 1997, has indicated that implementation of immigration policies is
beset with problems. In 1994, the Commission reported that illegal aliens
were entering the United States too easily, unlawful residents of the
United States were not being removed, and legal immigrants encountered
too much difficulty in gaining entry to the United States. That report
concluded that “[t]he United States can do a more effective job, but only
with additional financial resources and the political will to take action.”
Since 1994, additional laws have been enacted to strengthen immigration
policy and to provide additional resources to INS. For example, the Violent
Crime Control and Law Enforcement Act of 1994 increased penalties for
such offenses as failure to depart, illegal reentry, and document fraud. It
also authorized additional resources for criminal alien deportations and
detention bed space and provided for asylum claims to be processed more
expeditiously.
More recently, Congress passed the Illegal Immigration Reform and
Immigrant Responsibility Act of 1996. This law provides for
(1) improvements in border control through increased resources and
enhanced use of technology, (2) provisions to help facilitate legal entry,
(3) increased resources for investigators to perform interior enforcement
activities, (4) enhanced enforcement and penalties against alien smuggling,
(5) provisions to further deter the use of fraudulent documents, (6) revised
procedures for removal of inadmissible and deportable aliens, (7) pilot
programs for enforcement of restrictions against employment of illegal
aliens, and (8) restrictions on benefits for aliens. In addition, recently
passed welfare reform legislation, the Personal Responsibility and Work
Opportunity Reconciliation Act of 1996, also has implications for
significantly increasing INS’ naturalization applications workload.
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Executive Summary
INS will also be affected by the Government Performance and Results Act
of 1993 (referred to as the Results Act or GPRA), which provides a
statutory framework for achieving more results-oriented management. The
Results Act requires federal agencies to develop strategic plans by
September 30, 1997, that contain mission statements and outcome-related
strategic goals. Once the mission and outcomes are articulated, agencies
are to align their activities, processes, and resources so that they support
their missions and goals.
Amidst these new developments, INS has continued to receive attention
from GAO, the media, and Congress concerning internal management
issues. Such issues are important because how well INS manages its
budgetary and personnel resources has a direct impact on its ability to
efficiently and effectively carry out its mission. In the context of rapid
growth in resources and growing demand for both law enforcement and
provision of services to legal immigrants, INS has undertaken new
initiatives intended to improve how it is managed.
INS has made progress toward addressing some of its management
Results in Brief problems, but much remains to be done and top management attention is
still required. Since the appointment of a new Commissioner in 1993, INS
has developed a strategic plan, implemented a priorities management
process, taken steps to use priorities and workload information to allocate
resources, and implemented a new organizational structure intended to
provide for more direct oversight of field units. Sustained top management
attention and commitment to continuously improve operational
performance will be needed to ensure that these changes have the
intended effect. Less progress has been made on other needed
improvements, such as providing employees with clear guidance on how
to implement the immigration laws by issuing updated policies and
procedures manuals and establishing clear channels of communication
within the new organizational structure. Additionally, INS selected a new
financial management system without focusing first on conducting an
analysis of its business processes—a practice that GAO guidelines for
acquiring information technology endorsed and Congress required in
legislation.
INSissued a strategic plan in 1994 to guide its decisionmaking and
policymaking and to set the stage for the implementation of a priorities
management process. The agency developed annual goals and priorities
and used them in fiscal years 1995 and 1996 to plan and allocate new
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Executive Summary
resources provided by Congress. However, INS, like other government
agencies, is in the early stages of implementing the Results Act’s
requirements. INS recognizes that it has not yet implemented a coordinated
Results Act effort, especially in terms of the measures it has in place.
In addition, in 1994 the Commissioner established a new organizational
structure with four Executive Associate Commissioners (EAC) and regional
directors who report to one of the executive associate commissioners. The
reorganization reportedly has improved oversight of district offices and
Border Patrol sectors but has also created some internal communication
problems. A lack of clear guidance has also hampered internal
communication and may be impeding front-line employees in carrying out
their mission-related activities.
INS implemented several initiatives intended to improve upon its processes
for allocating budgetary resources. INS made improvements in planning
resource allocations to be more consistent with agencywide annual
priorities and workload demands. Furthermore, INS has contracted with a
consultant to develop a software program that is compatible with existing
staffing models. In addition, the consultant is to review and refine the
deployment planning process and the prototype automated software
support. This effort is intended to move INS toward better deployment
planning. INS’ efforts appear to be steps in the right direction, but
continued management support and attention will be required to ensure
that the intended results are achieved.
INS has had long-standing problems with its financial management system
and is in the process of acquiring a new one. INS implemented some
interim strategies to facilitate budget execution monitoring to assist it until
a new financial management system is in place. INS selected a financial
management system in March 1997, even thought it had not defined its
business processes before it selected the new system. GAO guides on
information management2 and the Clinger-Cohen Act3 discuss the need to
analyze business processes before acquiring a new system. GAO’s 1994
guide stated that information system projects that do not focus on process
2
Executive Guide: Improving Mission Performance Through Strategic Information Management and
Technology; Learning From Leading Organizations (GAO/AIMD-94-115, May 1994); Assessing Risks and
Returns: A Guide for Evaluating Federal Agencies’ IT Investment Decision-making (GAO/AIMD-10.1.13,
February 1997 Version 1); and Business Process Reengineering Assessment Guide (GAO/AIMD-10.1.15,
April 1997 Version 3).
3
The Omnibus Consolidated Appropriations Act of 1997 renames both the Federal Acquisition Reform
Act of 1996 and the Information Technology Management Reform Act of 1996 as the “Clinger-Cohen
Act of 1996.”
Page 5 GAO/GGD-97-132 INS Management Problems
Executive Summary
improvements typically fail or reach only a fraction of their potential. To
mitigate the risks associated with its approach, INS plans to analyze its
business processes during implementation of the new system, finalize a
detailed implementation plan, and develop a risk management plan.
GAO did not determine how successful each individual INS action has been
in addressing management problems. Moreover, GAO recognizes that it is
not reasonable to expect that all problems would be corrected
immediately and that adjustments will be necessary as these and future
changes are fully implemented. However, GAO’s survey of INS managers
conducted in the fall of 1995—a year after the Commissioner’s initial
policy and organizational changes—and subsequent interviews with INS
managers indicated that although many managers perceived that some
initiatives were having a positive effect, communications problems and
other challenges remained. Problems INS has experienced recently in
several key program areas—e.g., naturalization, criminal alien deportation
programs—appear to be, at least in part, caused by some of the
long-standing weaknesses in key management functions addressed in this
report, such as organizational structure, budgeting and financial
management, and management and administrative communications.
Principal Findings
INS Implemented a To better focus its attention on key mission and operational priorities, INS
Strategic Plan and Priority developed and issued a strategic plan in 1994. The INS strategic
Management System plan—Toward INS 2000, Accepting the Challenge—identified eight major
strategic priorities, including such challenges as facilitating compliance
with immigration laws, deterring unlawful migration, and reengineering INS
work processes. Top INS headquarters and field managers participated in
the development of this strategic plan. GAO’s fall 1995 survey confirmed
that INS’ mission and priorities were clear to a majority of INS managers. A
majority of managers who said they had a basis to judge also agreed that
the strategic planning process had aided INS headquarters and regional
planning and decisionmaking. (See pp. 31 through 33 and pp. 37 and 38.)
To facilitate achievement of the strategic priorities identified in the plan,
INS implemented a priorities management process in fiscal year 1995.
Specific annual goals related to strategic priorities were identified for
special management attention, including the establishment of objectives,
Page 6 GAO/GGD-97-132 INS Management Problems
Executive Summary
tasks, time frames, and performance measures. In fiscal year 1996, to
further focus management attention on the most important goals, INS
ranked the annual goals according to their priority. By assigning senior INS
managers specific responsibility for achieving the annual priority goals, INS
intended to establish better organizational and individual accountability.
These steps appear to be consistent with the intent of GPRA. Although INS’
initial steps in developing a strategic plan and management priorities have
been positive, GAO’s past work at INS and at other agencies indicates that to
be successful, such initiatives require sustained top management attention
and commitment to continuously improve program performance. (See pp.
32 through 35 and p. 39.)
INS Reorganized Before 1994, INS’ 33 district directors and 21 Border Patrol chiefs were
supervised by a single senior INS headquarters manager. To reduce this
supervisory span of control and to improve program planning, review, and
integration, the Commissioner reorganized INS in 1994. The reorganization
established EAC positions for (1) policy and planning, (2) program
development, (3) management, and (4) field operations. The EAC for Field
Operations has overall responsibility for managing INS’ operational field
activities through three regional directors, who have been delegated
budget and personnel authority over the district directors and Border
Patrol chiefs in their respective geographic areas. (See pp. 21 through 25.)
GAO found that the reorganization succeeded in shifting some management
authority to officials closer to the field activities, and many INS managers
that GAO interviewed perceived the reorganization as a positive step in
providing oversight of field units. However, the implementation of the
headquarters reorganization also appears to have created some
uncertainty among INS managers and field staff about the relative roles and
responsibilities of the offices of some of the EACs. This uncertainty has
been amplified by internal questions about possible staffing imbalances
among the offices. GAO found that no analysis had been done, for example,
to determine the appropriate number of staff needed for the office of
program development, given the reassignment of some of its
responsibilities to other offices. (See pp. 40 through 43 and p. 48.)
Internal Communications Managers responding to GAO’s survey in late 1995 indicated that poor
and Currency of Manuals communication, especially between headquarters and field units, was a
Problematic problem. The EACs took some steps during 1995 to clarify their roles and
channels of communication, but INS managers and staff told GAO in the
Page 7 GAO/GGD-97-132 INS Management Problems
Executive Summary
spring of 1996 that they still had difficulty determining the proper channels
through which to obtain policy guidance or implement program initiatives.
Communication problems continued to be evident in April 1997, when a
consultant to the Department of Justice reported that three different
versions of guidance on naturalization procedures had been distributed
throughout INS and that some offices were using the wrong version. (See
pp. 43 through 48.)
Lack of up-to-date policies and procedures was a finding of GAO’s 1991
review. Although INS has begun to update its field and administrative
manuals, no updated manuals had been issued as of February 1997.4
According to INS, in the absence of current manuals, managers and staff
needed to seek oral guidance more frequently than would otherwise have
been the case. Confusion over some offices’ roles and responsibilities may
result in further strain on agency communications and could result in
inconsistencies in guidance across locations.
In late 1995, a project officer was appointed to focus responsibility for
completing the field manuals. INS field manuals contain guidance on
program operations, such as how to conduct border inspections or
process alien applications. The project officer told GAO that the updating of
these manuals had been slowed in the past and at the time of GAO’s review
because priority for use of available staff resources was given to
developing regulations to implement new legislation. Part of the
Inspections Field Manual was expected to be issued in May 1997. The
project officer began work on other manuals in the spring of 1996, but
work was halted to develop regulations. A revised version of the
administrative manual, which contains guidance on such matters as
personnel procedures, cash collection, and use of firearms, had been
drafted, but negotiations about changes with the INS employee unions had
slowed finalization of the manual for several years. In the spring of 1996,
steps were taken to set priorities for union review of the administrative
manual segments, but at the time of GAO’s review, no milestone had been
established for the issuance of the manual. (See pp. 51 through 54.)
INS Took Steps to Improve Beginning in fiscal year 1995, INS incorporated the Commissioner’s
Processes for Allocating priorities into decisions about the allocation of new budget resources,
Resources such as those provided by the Violent Crime Control and Law
4
In commenting on a draft of this report, INS officials said that agreement had been reached with INS
unions that 51 of the 295 chapters of the administrative manual needed only minor modifications and
did not affect work practices. INS staff were notified in April 1997 that those chapters were issued in
computerized form.
Page 8 GAO/GGD-97-132 INS Management Problems
Executive Summary
Enforcement Act of 1994. INS also took steps to use workload information
in making decisions on the allocation of resources, as GAO recommended
in 1991. (See pp. 62 through 66.)
The Departments of Commerce, Justice, and State Appropriations Acts
annually require INS and other agencies that receive funding under these
acts to notify the House and Senate Appropriations Committees of
adjustments in funding allocations within an account. This reprogramming
process applies whether funding is from fees or general funds. The
Department of Justice requires that its components wait to implement
reprogrammings until a response from Congress is received. In fiscal year
1994, according to INS officials, the agency experienced a dramatic decline
in applications filed, which resulted in a commensurate decline in revenue
available to fund its operations. Consequently, INS took steps to reduce
spending to ensure that it did not exceed available balances. (See pp. 68
through 70.)
Therefore, in fiscal year 1995, when INS experienced a dramatic increase in
applications filed, it delayed its reprogramming proposal to increase
permanent staff in order to determine whether, and at what level,
workload increases would continue. As a result, INS did not obtain
approval to reallocate funds until late in the fiscal year. Because the late
funding delayed planned hiring to meet the workload demands, it
contributed significantly to a doubling of the delay in processing
immigrants’ applications for adjustment-of-status and naturalization. For
example, the average delay in processing naturalization applications went
from 8.2 months at the end of fiscal year 1994 to 17.3 months at the end of
fiscal year 1995. INS prepared a proposal for additional spending authority
earlier in fiscal year 1996 to address the continuing workload increase.
(See pp. 70 through 75.)
Although INS has incorporated strategic priorities into its budget
decisionmaking and has begun to develop processes to improve the
allocation of resources based on analysis of workloads, use of workload
information varied among INS’ program offices. A May 1996 INS consultant’s
study of how the agency deploys its personnel resources concluded that
INS’ current processes tended to be reactive rather than prospective and
were driven more by resources that were available than by a
determination of workload-driven requirements. The study concluded that
better workload data were needed and that models currently in use
needed to be updated. INS has hired an additional consultant to identify
personnel deployment planning process improvements; that effort, which
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Executive Summary
includes design, installation, implementation and testing of a prototype,
was scheduled to be completed in June 1997. INS intends to contract for
enhancements to the model for other resource needs, such as equipment
and facilities. (See pp. 67 and 68.)
GAO, the Department of Justice’s Inspector General, and the Justice
INS Did Not Follow Management Division have all reported on serious weaknesses with INS’
Fundamental principal accounting system—the Financial Accounting and Control
Practices for System. GAO reported that these problems persisted as recently as 1993
and 1995,5 and the Justice Management Division assessments of the
Acquiring a New system in 1993, 1994, and 1995 revealed that actions had not been taken to
Financial Accounting address recommended improvements. Inaccurate financial data; unreliable
and antiquated financial management systems; and insufficient internal
System controls over allocation, obligation, and expenditure of funds have made it
difficult for managers in INS headquarters to readily determine the financial
status of INS field units. These problems, in turn, made it difficult for INS to
monitor budget execution and to make sound budgetary decisions. (See
pp. 75 and 76.)
To improve financial management, INS took interim steps, such as
managing some resources at the regional level rather than the local level.
These steps were intended to improve the efficiency of collecting financial
information by reducing the number of reporting units and to facilitate the
collection of surplus6 funds from the field for reallocation to unfunded
needs. INS has also implemented an independent position tracking system
intended to better manage personnel resources. (See p. 79.)
INS has also taken action toward implementation of a new financial
management system. On March 31, 1997, the agency selected a new
financial management system that is to have a phased implementation. INS
expects to implement some core functions at key financial management
locations at the start of fiscal year 1998. However, INS did not analyze its
financial management processes before selecting its new system. Previous
GAO work highlights the importance of business process analyses prior to
5
Immigration Issues: Making Needed Policy and Management Decisions on Immigration Issues
(GAO/T-GGD-93-18, Mar. 30, 1993); and INS: Update of Management Problems and Program Issues
(GAO/T-GGD-95-82, Feb. 8, 1995).
6
INS uses the term surplus funds to refer to funds that were not used during the fiscal year for
Personal Services and Benefits and therefore become available for other purposes.
Page 10 GAO/GGD-97-132 INS Management Problems
Executive Summary
information system acquisition. Specifically, GAO’s February 1997 guide,7
which provides a structure for evaluating and assessing how well a federal
agency is selecting and managing its information technology resources,
stated that a key hazard in acquiring information technology is that the
new system will automate outmoded, inefficient business processes. Also,
the Clinger-Cohen Act of 1996 requires executive agencies to analyze
processes before making significant investments in information
technology. The act sought to remedy the dilemma of using technology to
correct process problems by insisting that process redesign drive the
acquisition of information technology, and not the other way around.
According to INS, it had an urgent need to replace its system by fiscal year
1998. The agency also believed that due to the urgency, it could not
perform an analysis of its financial management processes before
selecting a new system. To mitigate the risks of its approach, INS plans to
perform business process analyses during implementation and develop a
comprehensive implementation plan and risk management plan. (See pp.
81 through 85.)
GAO recommends that the INS Commissioner (1) further clarify the roles
Recommendations and responsibilities of the EACs and determine whether staffing
adjustments are needed to fully implement the objectives of the
reorganization, (2) establish milestones for issuance of manuals or the
parts of manuals that can stand alone, (3) develop a strategy and schedule
for periodically evaluating the new deployment planning process to ensure
that it is compatible with INS’ key planning processes and provides
information managers need to adequately plan for resource needs and
make resource decisions, and (4) take steps to mitigate the risks
associated with INS’ planned approach for acquiring a new financial
management system. Such steps should include fully implementing plans
to analyze its current financial management processes and determining
future financial management process needs, finalizing a comprehensive
implementation plan, and fully developing and implementing a risk
management plan.
INSreviewed a draft of this report. INS said that it was pleased that GAO had
Agency Comments recognized its progress in developing a strategic plan, initiating an annual
priorities process, improving the resource allocation process, and linking
resource allocations to the Commissioner’s annual priorities. INS said that
7
Assessing Risks and Returns: A Guide for Evaluating Federal Agencies’ IT Investment
Decision-making (GAO/AIMD-10.1.13, February 1997, Version 1).
Page 11 GAO/GGD-97-132 INS Management Problems
Executive Summary
its staff were working on GAO’s recommendations to clarify roles and
responsibilities, establish milestones for issuance of manuals or parts of
manuals, and develop a strategy and schedule for periodically evaluating
the new deployment planning process. INS presented additional
information for actions that it is performing or plans to perform to mitigate
the risks associated with having selected a new financial management
system without first performing process analysis. GAO agrees that these
actions, if carried out effectively, are more consistent with the approach
that GAO’s work has indicated would mitigate risk, and the
recommendation on this issue was revised accordingly.
Page 12 GAO/GGD-97-132 INS Management Problems
Page 13 GAO/GGD-97-132 INS Management Problems
Contents
Executive Summary 2
Chapter 1 18
A New Era for INS 18
Introduction Past Management Problems 26
Objective, Scope, and Methodology 28
Chapter 2 29
INS’ Strategic Plan and Annual Priorities Provided Direction 31
INS Made Progress Reorganization Restored Regional Directors to Manage Field 39
Toward Some Units
Reorganization Not Fully Implemented 40
Management Goals of Field and Policy Manuals Still Have Not Been Updated 51
the Reorganization, Survey Results on Gains Made as a Result of Reorganization Were 54
but Others Continue Mixed
Conclusions 58
to Be Problematic Recommendations 60
Agency Comments 60
Chapter 3 62
INS Made Improvements in Planning Resource Allocations 62
Improvements Made Process for Notifying Congress of Need for Additional Funds 68
to Management of From Fee Account Contributed to Application Backlogs
Monitoring of Budget Resources Suffered From Inadequate Data 75
Budget Resources, but INS Contracted for Assistance to Strengthen Its Budget Process 80
Problems Persist and Improve Its Financial Management System
Conclusions 82
Recommendations 83
Agency Comments and Our Evaluation 84
Appendixes Appendix I: Roles and Responsibilities for the Offices of the 86
Executive Associate Commissioners and Regional Directors for
Field Operations
Appendix II: Objective, Scope, and Methodology 89
Appendix III: Survey Methodology 92
Appendix IV: GAO Survey on INS Management Issues 95
Appendix V: INS’ Fiscal Years 1995 and 1996 Priorities 119
Appendix VI: Comments From the Commissioner of the 122
Immigration and Naturalization Service
Appendix VII: Major Contributors to This Report 126
Page 14 GAO/GGD-97-132 INS Management Problems
Contents
Tables Table 2.1: Goals INS Established for the 1994 Reorganization 30
Table 2.2: Survey Responses Indicate Communication and 46
Coordination Problems
Table 2.3: Managers’ Responses to the Question: Generally, How 56
Successful or Unsuccessful Do You Think the Reorganization Has
Been in Achieving the Following Goals?
Table 3.1 INS’ Use of WAMs and Workload Data in Planning 65
Fiscal Year 1995 and 1996 Resource Allocations
Table 3.2: Average Projected Wait Times for INS Processing of 73
I-485 Adjustment-of-Status and N-400 Naturalization Applications
at the Start and End of Fiscal Year 1995
Table III.1: Survey Response Rates 93
Table V.1: INS’ Fiscal Year 1995 Priorities 119
Table V.2: INS’ Fiscal Year 1996 Priorities 121
Figures Figure 1.1: INS’ Organizational Structure, 1991 22
Figure 1.2: INS’ Organizational Structure, November 1994, With 24
Revisions as of March 1997
Figure 1.3: Key Events in the 1994 Reorganization 26
Figure 2.1: A Majority of INS Managers Responded That INS’ 33
Mission and Priorities Are Clear
Figure 2.2: General Structure of the INS Priority Management 35
Program
Figure 2.3: Many INS Managers Perceived That the Fiscal Year 38
1995 Strategic Planning Process That Identified Nine Priorities
Aided Headquarters, Regional, and Budget Execution Planning
and Decisionmaking
Figure 3.1 Timeline of Key Activities for INS’ Fiscal Year 1995 71
Reprogramming
Page 15 GAO/GGD-97-132 INS Management Problems
Contents
Abbreviations
EAC Executive Associate Commissioner
FACS Financial Accounting and Control System
HITS Hiring Tracking System
INS Immigration and Naturalization Service
IRCA Immigration Reform and Control Act
JMD Justice Management Division
NAPA National Academy of Public Administration
OMB Office of Management and Budget
POSTS Position Tracking System
PS&B Personal Services and Benefits
VCRTF Violent Crime Reduction Trust Fund
WAM Workload Analysis Model
Page 16 GAO/GGD-97-132 INS Management Problems
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Chapter 1
Introduction
During the 1990s, heightened anxieties about legal and illegal immigration
have placed the Immigration and Naturalization Service (INS) in the
forefront of public attention. Congress has significantly increased the
agency’s resources to primarily enhance INS’ enforcement of immigration
policy and laws. INS has promoted naturalization and increased
enforcement activities to deter illegal immigration. At the same time, INS
has undergone a significant reorganization to address management
problems that have troubled it for years.
Since 1993, INS has had a change in leadership, its budget has increased by
A New Era for INS over 100 percent, and it has experienced an unprecedented increase in
naturalization applications. INS has also been under increased pressure
from Congress, states, and citizens to reduce illegal immigration. In 1993,
within the framework of the administration’s multiyear immigration
initiative, INS announced plans to more aggressively enforce immigration
laws to prevent illegal immigration. The multiyear plan is intended to
protect U.S. borders, reduce work incentives for illegal immigrants,
expeditiously remove criminal aliens, stop asylum abuse, reinvent and
revitalize INS, and encourage legal immigrants to become naturalized
citizens. In addition, INS reorganized to improve its oversight of field
operations and enhance its management capabilities.
INS Has New Leadership In November 1993, INS’ current Commissioner was sworn in. In
and More Resources to March 1995, she testified before the House Committee on Appropriations
Implement Immigration that when she took office in 1993, “[I]mmigration was a backburner issue.
Its budget was insufficient because it failed to keep pace with INS’
Laws complicated and growing responsibilities.”1
Since 1993, with congressional and presidential support, INS’ budget has
been increased dramatically to enable the agency to better implement and
enforce immigration laws. INS anticipates that at the end of fiscal year 1997
its budget appropriation will be $3.2 billion, which represents an increase
of 113 percent over the fiscal year 1993 level of $1.5 billion, and an
increase of 23 percent over the fiscal year 1996 level of $2.6 billion.
1
Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations for
1996: Hearings before a Subcommittee of the House Committee on Appropriations, 104th Cong., lst
Sess. pt.7, at 613 (1995) (statement of Doris Meissner, Commissioner, INS).
Page 18 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
At the end of fiscal year 1996, INS’ estimated on-board strength of full-time
permanent employees was about 23,000.2 This represents about a
28-percent increase over the fiscal year 1993 level of about 18,000
employees. INS’ fiscal year 1997 appropriation provided for more than
26,000 positions, about a 44-percent increase over 1993.
More Aliens Applying for As debates in Congress and in state legislatures focus on burdens created
Naturalization and Other by both illegal and legal immigrants, an increasing number of legal
Status Changes permanent residents across the country are seeking U.S. citizenship, often
years after they first became eligible to apply. In fiscal year 1995, INS
experienced unprecedented increases in naturalization applications, which
grew from approximately 600,000 in fiscal year 1994 to over 1.2 million in
fiscal year 1996.
Federal and state actions have prompted legal aliens to apply for
naturalization. For example, welfare proposals that were considered in
Congress during 1995 to deny federal assistance to legal immigrants who
were not citizens contributed to a spurt in naturalization applications.
Subsequent passage of the Personal Responsibility and Work Opportunity
Reconciliation Act of 19963 made changes in the eligibility of noncitizens
for federal, state, and local benefits that according to an INS official,
contributed to more applications for naturalization. INS could also see a
significant increase in naturalization applications as aliens who qualified
for legal status under amnesty provisions in the 1986 Immigration Reform
and Control Act (IRCA) became eligible to apply for naturalization. In
addition, the Commissioner’s fiscal year 1995 annual priorities for INS
included promoting naturalization through public education programs.
Furthermore, Proposition 187, which passed in California in
November 1994,4 may have motivated some legal aliens to apply for
naturalization because of its general anti-immigrant sentiment. This
legislation is intended to bar illegal immigrants from obtaining
educational, social, and nonemergency medical services.
2
INS also has about 3,000 part-time employees who have a role in adjudicating applications and
inspecting travelers.
3
P.L. 104-193, August 22, 1996.
4
Proposition 187 was a California ballot initiative to deny most public services to illegal immigrants. It
was adopted in November 1994 but was promptly challenged in court as unconstitutional. A federal
judge put a hold on the state’s implementation of the initiative, pending resolution of the court
challenges.
Page 19 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
INS also had a surge in applications during fiscal year 1995 from aliens who
sought to adjust their status. This surge resulted from the amendment
adding subsection 245(i) to the Immigration and Nationality Act of 1952.
Subsection 245(i) permits aliens within certain categories (e.g., entered
without inspection, worked illegally, or overstayed their visas) to apply for
permanent residence if physically present in the United States and eligible
to receive immigrant visas in their own countries.5 Initially, these aliens
paid a sum of five times the standard filing fee in addition to the standard
filing fee.6 During fiscal year 1996 and the first quarter of fiscal year 1997,
INS continued to receive a high level of new applications.
INS Is Placing More Most of INS’ fiscal year 1996 increased resources were to go toward
Emphasis on strengthening border control and, to a lesser extent, to stronger workplace
Strengthening Border enforcement to reduce the lure of jobs to illegal immigrants and expedited
deportation of criminal aliens. INS’ strategy for controlling illegal entry
Control, Enforcing across U.S. borders between ports of entry includes adding border patrol
Employer Sanctions, and agents; placing fencing and lighting strategically; and using all-terrain
Removing Criminal Aliens vehicles, infrared scopes, and other new equipment.
Although IRCA mandated that employers verify job applicants’ employment
eligibility,7 according to the U.S. Commission on Immigration Reform, the
law has not been effectively enforced.8 INS has received funding to increase
enforcement of employer sanctions, and in fiscal year 1996 it received
authorization to hire 384 new investigators and support staff to conduct
and assist in workplace inspections. The agency is also taking steps to
issue work authorization documents that are designed to be
fraud-resistant, tamper-proof, and cost-effective, and to pilot-test other
methods of verification.
The removal of criminal aliens from the United States is another key
component of INS’ comprehensive strategy to prevent and deter illegal
migration. A focus of the criminal alien removal initiative has been more
5
Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies 1995
Appropriations and 1994 Supplemental Appropriations, P.L. 103-317, 8 U.S.C. 1255(i). See INS:
Information on Aliens Applying for Permanent Resident Status (GAO/GGD-95-162FS, June 8, 1995).
6
The filing fee was changed, however, by an amendment in the recently enacted Illegal Immigration
Reform and Immigrant Responsibility Act of 1996. The amendment to 245(i) set the amount of this fee
at $1,000, effective at the end of December 1996. P.L. 104-208 (1996), 8 U.S.C. 1255(i).
7
8 U.S.C. 1324a.
8
U.S. Immigration Policy: Restoring Credibility, A Report to Congress, U.S. Commission on
Immigration Reform, Sept. 1994.
Page 20 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
expeditious removal of aliens incarcerated in federal and state prisons and
local correctional facilities. INS’ stated strategy includes deporting more
criminal aliens by increasing detention capacity; streamlining
administrative procedures for deportation; and expanding its Institutional
Hearing Program, which is designed to place criminal aliens in deportation
hearings so they can be readily deported upon their release from prison.
INS Reorganized One of the first tasks the new Commissioner undertook in 1993 was to
reorganize INS. The reorganization was designed to address a span of
control problem that INS had identified as an unintended consequence of a
1991 reorganization and to alleviate other management problems
identified by others, such as the National Academy of Public
Administration (NAPA) and Congress.
The 1991 reorganization had centralized oversight of district offices and
Border Patrol sectors under one manager in headquarters. INS’
Commissioner at that time gave the program managers in headquarters
increased budget authority to allocate funding for personnel within their
programs in the second quarter of fiscal year 1990. Politically appointed
regional commissioners were replaced with career managers, who were
called regional administrators. These regional administrators provided
administrative support to field offices but did not exercise authority over
field operations. Figure 1.1 depicts INS’ structure as a result of the 1991
reorganization.
Page 21 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
Figure 1.1: INS’ Organizational Structure, 1991
Security Commissioner
International Affairs
and Outreach
Deputy Commissioner
Internal Audit
Congressional and
General Counsel Field Support Strategic Planning
Public Affairs
Executive Associate Commissioner Executive Associate Commissioner
EEO
for Management for Operations
Associate Associate Associate Commissioner Associate Associate
Commissioner Commissioner Human Resources and Commissioner Commissioner
IRM Finance Administration Enforcement Examinations
Personnel Detention
Data General Adjudication
Records and and Investigations Inspections
Systems Administration and
Career Deportation Nationality
Development
Accounting Legalization and
Intelligence Border
Project and Administrative
Budget Patrol
Integration Financial Appeals
Management
Regional Offices District Offices Border Patrol Sectors
Legend
Reporting relationship for administrative functions.
Source: Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies
Appropriations for 1994, Hearings before a Subcommittee of the House Committee on
Appropriations, 103rd Cong., 1st Sess. pt. 2B, at 3(1993).
Page 22 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
The 1994 reorganization sought to remedy at least two problems with the
1991 structure. First, the Commissioner thought the agency’s field
performance was uneven and poorly coordinated. In particular, the
headquarters operations office had an unrealistically large span of control
because of its responsibility for overseeing the operations of 33 district
offices and 21 Border Patrol sectors. Second, the Commissioner believed
that program planning, review, and integration had suffered because the
operations office was preoccupied with matters that should have been
handled by field managers and therefore could not focus on program
planning. To address these and other problems, the new structure
(1) established a new Office of the Executive Associate Commissioner
(EAC) for Field Operations to oversee field operations; (2) redesignated the
previous EAC for Operations as the EAC for the Office of Programs to
develop and disseminate policies, procedures, and other appropriate
guidelines required for program execution servicewide and to provide
analytical and evaluative support related to specific program operations;
(3) established an Office of Policy and Planning under an EAC to replace
the previous Office of Strategic Planning; and (4) established the EAC for
Management with many of the same management functions as it had under
the previous organizational structure, plus some new ones. The purpose of
establishing the Office of Policy and Planning at an executive level was to
reinforce the importance of servicewide planning on an annual and
long-term basis and to provide appropriate attention to macrolevel
immigration policy development and issue analysis. Figure 1.2 depicts INS’
organizational structure after the reorganization and at the time of our
review.
Page 23 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
Figure 1.2: INS’ Organizational Structure, November 1994, With Revisions as of March 1997
Congressional
General Counsel Commissioner Relations
Deputy Commissioner
Public Affairs Internal Audit
Executive Associate Commissioner Executive Associate Commissioner Executive Associate Commissioner Executive Associate Commissioner
for Programs for Field Operations for Policy and Planning for Management
Office of Office of Office of Office of Information
Administrative
Enforcement Examinations Regional Regional Planning b Policy b Resources
Centers b
Director Director Management
Western Central
Region Region
Adjudications Systems
Investigations and Finance
Integration
Nationality Districts/ Districts/
Sectors Sectors
Detention Data Financial
and Inspections Systems Management
Deportation Office of
International
Regional
Affairs
Director
Eastern
Service Region Human
Intelligence Center Resources and Budget
Operations Administration
Districts/ Foreign
Sectors Districts
Asset Records Administration Security
Forfeiture
Human Files and
Border Administrative Resources Forms
Patrol a Appeals and Management
Development
Legend:
Program planning Policy planning
Equal
Employment
Opportunity
Oversight of field operations Administrative support
a
Function detailed to Office of Field Operations in June 1995.
Page 24 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
b
Incorporated into revised 1995 organizational chart.
Source: 8 C.F.R. 100.2, 1996 and INS.
Figure 1.2 shows that the regional offices now report to the Office of Field
Operations and have line authority over the district offices and Border
Patrol sectors. The regional offices are managed by regional directors
rather than regional administrators. The district offices and sectors are to
provide direct service to applicants for benefits and carry out statutory
enforcement responsibilities in their respective geographical areas.
Support and services are to be delivered to field offices through four
administrative centers.
All of the EACs are to serve as principal advisors to the Commissioner and
Deputy Commissioner, who is the Chief Operating Officer for INS. The EACs
also are to participate in the budget formulation and execution processes
as do the regional directors. Further information on the specific roles and
responsibilities for the offices of the EACs and the regional directors is
presented in appendix I.
Implementation of the current organization began in July 1994 and was
officially in place in October 1994. Some of the EACs were acting in their
positions prior to their official appointments to the new posts. Figure 1.3
shows some of the key events related to the 1994 reorganization.
Page 25 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
Figure 1.3: Key Events in the 1994
Reorganization
Year Month Event
1993 November Commissioner tasked a management group to develop and recommend
options for a new organizational structure.
1994 January Attorney General approved INS reorganization plan.
February Commissioner outlined in a memo to all employees the plan to reorganize
and return to a decentralized structure. The new structure (1) established
four executive associate commissioners (EACs) and (2) provided for
career regional directors to have authority to oversee field units and
manage field units' budgets.
July EACs for Field Operations, Programs, and Management offices
appointed to positions.
July Regional director for Central Regional Office appointed.
September Regional directors for Eastern and Western Regional Offices appointed.
October Effective date for new organizational structure.
November EAC for Policy and Planning appointed.
December Final rule for INS reorganization printed in the Federal Register.
1995 October Regional directors assumed responsibility for controlling allocation of
personnel, salaries, and benefits funds to field units.
Source: INS.
Several of our past reports identified significant management problems
Past Management that have troubled INS for years.9 Our Immigration Management report
Problems identified many management problems related to INS leadership, service
delivery, the budget process, the financial management system, and the
organizational structure. Major problems cited in the reports included the
following:
• INSlacked clearly defined priorities and goals.
• INS’organization was fragmented both programmatically and
geographically. In our report we attributed part of the fragmentation to the
inability of INS’ leadership to control the politically appointed regional
9
Immigration Management: Strong Leadership and Management Reforms Needed to Address Serious
Problems (GAO/GGD-91-28, Jan. 23, 1991); Financial Management: INS Lacks Accountability and
Controls Over Its Resources (GAO/AFMD-91-20, Jan. 24, 1991); and Information Management:
Immigration and Naturalization Service Lacks Ready Access to Essential Data (GAO/IMTEC-90-75,
Sept. 27, 1990).
Page 26 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
commissioners, who routinely used their authority to thwart headquarters’
efforts to allocate resources and manage programs.
• INS’ leadership had not adequately defined the roles of the two key
enforcement divisions, Border Patrol and Investigations, which resulted in
overlapping responsibilities, inconsistent program implementation, and
ineffective use of resources.
• Poor communications led to weaknesses in INS’ formulation of some
policies and procedures, and policy information was outdated.
• Budget management and resource allocation problems perpetuated
backlogs for processing aliens’ applications.
• Budgets were not based on agencywide priorities, and the budget process
did not adequately use workload to allocate staff.
• Unreliable financial information resulted in inadequate budget monitoring.
In response to management problems that were documented by an
internal Department of Justice audit in December 1988 and our 1990 and
1991 management reports, in 1990, Justice requested that NAPA provide INS
and Justice with a strategy to assist in the determination of the critical
management problems that needed to be addressed and courses of action
available to address them. The team preparing the NAPA report did not
conduct its own management review but instead relied on our studies,
audits and inspections by the Department of Justice’s Inspector General
and Justice Management Division, other INS and Justice documents, and
interviews with various officials. The NAPA report focused on providing
another perspective on the management problems and recommendations
to resolve them. NAPA’s findings generally agreed with our management
review findings but offered some different recommendations to resolve
the problems.10
INSmanagement problems have continued, as indicated in testimony by
the Department of Justice Inspector General before the House
Appropriations Committee in February 1997. The Inspector General
reported that INS failed to conduct criminal history checks before granting
applications for citizenship, INS managers in Miami and the Eastern
Regional Office intentionally misled a congressional delegation, and some
major systems in INS’ automation initiatives were behind schedule.
10
Managerial Options for the Immigration and Naturalization Service, A Report for the U.S. Department
of Justice, National Academy of Public Administration, Feb. 1991.
Page 27 GAO/GGD-97-132 INS Management Problems
Chapter 1
Introduction
The objective of this review was to follow up on our past INS management
Objective, Scope, and report to determine whether steps had been taken to correct some of the
Methodology most significant management problems identified. Specifically, we
determined whether INS had
• developed goals and priorities to guide planning and resource allocation,
• revised its organizational structure,
• improved internal communications and updated its field and
administrative manuals,
• improved the process of allocating budgetary resources,
• improved its capability to monitor its financial status.
We used a variety of techniques to determine whether INS had taken steps
to address management problems. We reviewed past management studies
of INS; sent a survey in September 1995 to 3,676 career and appointed INS
managers and senior staff agencywide; and conducted interviews with
managers in headquarters, the regional offices, and certain district and
sector offices. We also reviewed agency documents on the reorganization
and budget execution. We began our audit work during the first fiscal year
that the reorganization was implemented. Therefore, our findings
represent INS’ progress in accomplishing its goals as of the time of our
review. The scope of this review cut across various INS program areas (e.g.,
employment verification and naturalization); components (e.g., Border
Patrol and Office of Investigations); and field offices (e.g., districts and
sectors); however, we did not evaluate the effectiveness of specific
program areas, components, or field offices. Furthermore, we did not
review management issues identified more recently, such as delays in
implementing several major automation systems. Appendix II provides a
more detailed description of our objectives, scope, and methodology.
Further details of the survey methodology are presented in appendix III.
We did our work between March 1995 and February 1997 in accordance
with generally accepted government auditing standards. We requested
comments on a draft of this product from the Commissioner of the
Immigration and Naturalization Service, and her comments are presented
and evaluated in chapters 2 and 3.
Page 28 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
The purpose of INS’ reorganization in 1994 was to address a broad
spectrum of management problems. The INS Commissioner wanted to
reduce headquarters’ span of control over field units to help improve field
supervision. In addition, the reorganization sought to improve servicewide
planning and policy development, strengthen operational program
planning, and enhance communications. We identified these management
areas as problems in our past studies. Table 2.1 lists INS’ management goals
for the reorganization, the intent of the goals, and the structural or role
change made to facilitate accomplishment of the management goals.
Page 29 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
Table 2.1: Goals INS Established for
the 1994 Reorganization Goal Intent Structure/role change
Goal 1
Develop a capability and To provide long-range Establishment of the Office
commitment to plan for the program and priority of Policy and Planning
future, set customer service planning
standards, and establish
quantitative performance
measures to enable INS to
evaluate its programs and
service delivery
Goal 2
Decentralize To decentralize the INS Regional directors were to
decisionmaking and management structure supervise the district
delegate authority to directors and Border Patrol
persons geographically chiefs. Regional directors
closer to the locations were also given authority to
where work is being done manage personnel and
funds for the districts and
sectors.
Goal 3
Empower field operational To directly involve regional Regional directors were to
units to improve the directors in field activities to oversee district directors
delivery of services to provide consistency in field and Border Patrol chiefs.
customers operations
Goal 4
Create a clearer sense of To combine major functions Establishment of the Office
mission by knitting together and place them in separate of Programs, the Office of
INS’ major functions and offices, such as program Policy and Planning, and
programs planning, policy planning, the Office of Field
and field operations Operations
Goal 5
Reengineer major To establish planning Establishment of the Office
processes, such as those across INS rather than have of Policy and Planning
that develop and each headquarters program
disseminate organizational office planning for its own
policy and guidelines, and program without
that are outdated considering agencywide
approaches to handling needs
records and information
Source: Federal Register, Vol. 59, No. 224, p. 60066, Nov. 22, 1994, and interviews with INS
officials tasked with recommending a revised organization structure.
Consistent with these goals and with alleviating a problem identified in our
1991 management report, INS developed a strategic plan and has set annual
priorities. A majority of INS’ managers who responded to our survey in the
fall of 1995 and expressed an opinion indicated that the annual priorities
aided planning and decisionmaking. Also, managers whom we interviewed
told us that they perceived that oversight of field operations had improved
Page 30 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
under the reorganization. In addition, INS decentralized its management
structure by restoring regional directors to manage field units, which is
intended to help improve field supervision.
Although some progress was made toward addressing past management
problems through INS’ reorganization, the implementation of the
reorganization has yet to address others and created some new problems.
INS’ implementation of the reorganization did not clearly delineate the
responsibilities and authority of the Office of Field Operations and the
Office of Programs, causing confusion for some managers. Also, poor
communication continued as a problem that was exacerbated by the
reorganization and the lack of up-to-date field and policy manuals.
In our 1991 management review, we reported that INS lacked a strategic
INS’ Strategic Plan plan and that past priority management processes were not successful. We
and Annual Priorities also stated that past efforts to implement agencywide planning systems
Provided Direction lacked sustained top management support, managers were not held
accountable for achieving goals and objectives, and priorities were not
used in planning for decisionmaking. INS’ current leadership developed a
strategic long-term plan and established annual goals and objectives.
Annual priorities were used to plan and make resource decisions in fiscal
years 1995, 1996, and 1997. Top managers were major participants in the
annual priorities management process, and INS’ objectives had
performance measures.
INS Developed a Strategic In 1993, INS began an 18 month strategic planning process that included all
Plan top INS headquarters and field managers, as well as external stakeholders
interested in and affected by INS’ mission, to brainstorm issues facing the
agency over the next decade. A strategic planning work group comprising
a cross-section of INS program representatives and managers was
established to guide the development of INS’ strategic plan. Subsequently,
teams were formed to develop goals, objectives, and alternative strategies
for each key area. In the spring of 1994, the team leaders presented their
recommendations to the INS executive staff. In November 1994, INS
formally issued Strategic Plan: Toward INS 2000, Accepting the Challenge.
The INS Strategic Plan presented a blueprint intended to take INS into the
next century. The plan included the Commissioner’s vision for INS and a
mission statement. Eight major strategic directions, which were to guide
decision- and policymaking within INS, emerged from the planning process.
Page 31 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
The eight strategic directions were: (1) facilitate compliance with
immigration laws, (2) deter unlawful migration, (3) reinvent INS work
processes, (4) build partnerships to manage the immigration system,
(5) promote professionalism, (6) carefully collect and communicate
immigration information, (7) concentrate resources, and (8) measure
effectiveness. These strategic directions were to be the guiding operating
principles for development of more specific issue area program goals and
objectives.
INS’strategic planning effort was undertaken at about the same time that
Congress passed the Government Performance and Results Act of 19931
(the Results Act). Also referred to as GPRA, the Results Act provided a
statutory framework for achieving more results-oriented management and
requires federal agencies to develop strategic plans by September 30, 1997,
that contain mission statements and outcome-related strategic goals.
Annual Priority Process During fiscal year 1995, INS also started to implement an annual priorities
Initiated management process. Annual priorities, referred to as the Commissioner’s
Priorities Program, include a statement of annual goals in support of INS’
strategic plan. According to INS, annual priorities seek to address both the
key current operational imperatives for the fiscal year and, to the extent
possible, the strategic goals and objectives previously identified. INS
defined a priority goal as that part of the INS mission, strategic direction, or
area of activity that the Commissioner has identified for special
management attention. Priority goals are defined as change-oriented
initiatives that address areas of high visibility, a new or renewed interest
that would not otherwise have received adequate attention, or special
needs that the Commissioner deems compelling. A particular goal may be
included in the Commissioner’s annual priorities for 1 or more years. Each
goal has several objectives that contribute to accomplishment of the goal,
and objectives within a priority are intended to be accomplished in 1 year.
Objectives are to have specific tasks, time frames for accomplishing tasks,
and performance measures.
During fiscal year 1995, INS had nine priority goals. According to the EAC
for Policy and Planning, the 1995 priority goals were not ranked in their
order of importance. For fiscal year 1996, INS had six annual priority goals,
which were ranked in their order of importance. See appendix V for more
information on the annual priority goals for fiscal years 1995 and 1996.
1
P.L. 103-62, August 3, 1993.
Page 32 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
The Commissioner communicated her commitment to the 1995 priority
goals at the annual Commissioner’s conference held in November 1995.
We found that INS’ mission and priorities were clear to a majority of INS’
managers. Figure 2.1 shows that 66 percent of the managers who
responded to our 1995 survey thought that INS’ overall mission was
somewhat clearly or very clearly communicated. Similarly, 61 percent of
the managers who responded to our 1995 survey believed that INS’
priorities have been somewhat clearly or very clearly communicated.2
Figure 2.1: A Majority of INS Managers
Responded That INS’ Mission and
Priorities Are Clear Percentage of INS managers responding
80
66
61
60
40 39
34
20
0
Overall mission Priorities
Somewhat or very clear
Somewhat or very unclear
Source: Analysis of GAO 1995 survey responses.
2
This particular question has a 4-point scale rather than the 5-point scale that is generally used.
Page 33 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
INS Managers Are Charged The Commissioner emphasized the importance of priority management by
With Implementing the assigning responsibility for its implementation to key members of the
Commissioner’s Priority executive staff. In fact, in the new organizational structure, priority
management planning and implementation are primary responsibilities of
Program the EAC for Policy and Planning. As shown in figure 1.2, the EAC for Policy
and Planning function is at the same organizational level as executives
responsible for field operations, management, and program planning.
The EACs, General Counsel, assistant commissioners, and regional
directors are responsible for accomplishing goals and objectives.
Specifically, each of the EACs and the General Counsel, who report to the
Commissioner and Deputy Commissioner, are lead officials responsible
for the oversight and accomplishment of one or more of the priority goals.
Lead officials are to take “ownership” of a priority and be responsible for
directing, coordinating, and integrating the activities of cross-cutting
programs in order to achieve the priority. Assistant commissioners or
regional directors are generally the action officers responsible for
accomplishing the objectives within a priority. For example, the EAC for
Programs was the lead official for the 1995 goal to reduce incentives for
unlawful migration. This goal had several objectives, one of which was to
analyze and reinvent employer sanctions.3 The action officers for this
objective were the regional directors for the eastern and western regions
and the Assistant Commissioner for Investigations at headquarters. Figure
2.2 illustrates the general structure for the priority management process
and the responsible officials, using one of the 1995 priority goals as an
example.
3
INS is responsible for enforcing the employer sanctions provision of IRCA. IRCA requires employers
to verify the employment eligibility of workers and imposes civil and criminal penalties, e.g., sanctions
against employers who knowingly hire unauthorized workers.
Page 34 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
Figure 2.2: General Structure of the INS Priority Management Program
Priority goal Lead official Objectives Action officers
EAC Office of Programs Engage in increased employment Assistant Commissioner for
compliance and enforcement efforts Investigations
Special Assistant to the Executive
Reduce incentives for Associate Commissioner for the
unlawful migration Office of Field Operations
Expand INS' employer assistance by Assistant Commissioner for
providing supporting information and Investigations
direction to both employers and Acting Director of the Office of
employees through revised publica- Employer and Labor Relations
tions, informational advertisement
campaigns, and selected personal Special Assistant to the Executive
appearances Associate Commissioner for the
Office of Field Operations
Simplify the status/eligibility verifica- Assistant Commissioner for
tion process by reducing the Adjudications and Nationality
numberof documents used and by
improving the security and time- Associate Commissioner for
liness of INS-issued documents Information Resources
Management
Executive Associate Commissioner
for the Office of Programs
Analyze and develop recommenda- Assistant Commissioner for
tions for major systemic change and Investigations
pilot activities to test new approaches
Regional Director Eastern
Regional Office
Regional Director Western
Regional Office
Source: INS implementation plan for its 1995 annual priorities.
According to INS guidance on the annual priorities management program,
the program provides a means by which organizational and individual
accountability can be established. Furthermore, quarterly reviews provide
for periodic evaluation of progress toward achieving the objectives.
Although we did not evaluate whether INS had achieved its priorities, we
note that in our 1991 management report we said that various planning
Page 35 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
systems INS had used since 1980 fell into disuse after top management
support for them faded. Thus, we believe that the ultimate success of the
annual priorities management system will be dependent on the sustained
commitment of top management.
Three Stages of Priority INS guidance states that there must be a correlation between priority
Process Coincide With planning and budget formulation and between priority implementation and
Budget Planning and budget execution. According to INS guidance, the Commissioner’s
Priorities Program has three principal stages: (1) priority identification,
Monitoring (2) implementation planning, and (3) assessment and reporting. Priority
identification is to take place between April and June each year so that the
Commissioner can approve and issue priority statements for the next
fiscal year by July 1. Implementation planning is to occur between July
and mid-September so that approval of the annual priorities can coincide
with the beginning of the fiscal year. According to an INS official, since the
start of the fiscal year 1996 priorities cycle, INS has also combined the
annual priorities reporting and assessment reviews and budget execution
financial reviews so that the annual priorities are an integral part of the
budget monitoring process.
Fiscal year 1995 was the first year that the Commissioner issued annual
priorities. Because the annual priorities were identified in the fall of 1994
and implementation plans were not formally issued until January 1995,
they were not used in budget formulation for fiscal year 1996, which would
have begun in the spring of 1994. However, according to INS officials,
priorities were used in budget execution planning for new initiatives in
fiscal years 1995 and 1996. Also, during the fiscal year 1995 quarterly
reviews, the assessment of the annual priorities implementation was
conducted concurrently with the budget financial review. We discuss the
link between the annual priorities and the budget process further in
chapter 3.
For fiscal year 1996, INS identified its annual priorities in August 1995.
According to INS officials and INS budget guidance, the emphasis for fiscal
year 1996 was to allocate new budget resources to support the
Commissioner’s 1996 priorities. According to an INS official, new resources
for fiscal year 1997 were used to support the 1997 priorities. INS was also
examining ways that it could estimate obligations to specific annual
priorities.
Page 36 GAO/GGD-97-132 INS Management Problems
Chapter 2
INS Made Progress Toward Some
Management Goals of the Reorganization,
but Others Continue to Be Problematic
Similar to many other government agencies, INS’ fiscal year 1996 budget
was subject to several continuing resolutions, and the agency experienced
periods of employee furloughs. For fiscal year 1996, prescribed time
frames for establishing performance measures and assessment of the
annual priorities were not followed. According to a memorandum
prepared by the EAC for Policy and Planning, management of the 1996
annual priorities was an iterative process, and implementation plans were
revised as needed to address changes caused by the furloughs and the
delay in receiving a final budget from Congress.
According to an INS official, INS needs to link the fiscal year priorities,
which are to be finalized in the two quarters preceding the beginning of
the new fiscal year, and INS’ budget formulation, which occurs 2 years
before the actual fiscal year involved. To that end, in December 1996, INS
engaged in a process for obtaining headquarters and field manager input to
identify priorities that should be addressed for fiscal year 1999. This
activity reportedly led to initial identification of fiscal year 1999 priorities,
which are serving as the backdrop for the development of the fiscal year
1999 spring budget plan.
Survey Results Indicated In our survey, we asked INS managers their opinions on the extent to which
Many Managers Believed the strategic planning process, which identified nine priorities for fiscal
Annual Priorities Aided year 1995, had aided INS. Thirty-eight to 54 percent of the managers
responded that they had no basis to judge. However, of those who had an
Planning and opinion, a majority of managers responded positively. Figure 2.3 shows
Decisionmaking that INS managers who had an opinion perceived that the strategic
planning process aided INS headquarters and regional planning and
decisionmaking from “some extent” to “ a very great extent.” Seventy-nine
percent of the managers who expressed an opinion said that the process
aided headquarters planning, and 81 percent of the managers who
expressed an opinion responded that the process aided regional planning.
Seventy-four percent of the managers who expressed an opinion said that
the process aided headquarters decisionmaking, and 79 percent of the
managers who expressed an opinion said that the process aided regional
decisionmaking. A majority of survey respondents who expressed an
opinion also perceived that the priorities process aided budget execution.
Sixty-eight percent of the managers who expressed an opinion said that
the process aided budget execution planning, and 67 percent of the
Page 37 GAO/GGD-97-132 INS Management Problems
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managers who expressed an opinion said that the process aided budget
execution decisions.4
Figure 2.3: Many INS Managers
Perceived That the Fiscal Year 1995
Extent aided (as a percent)
Strategic Planning Process That
Identified Nine Priorities Aided
100
Headquarters, Regional, and Budget
Execution Planning and
Decisionmaking
80
60
40
20
0
13 s
81
= n
40
02
= s
= ing
= s
98
52
= n
82
n sion
n gio
n rter
n rter
n gio
10
12
12
10
13
n
e
an
e
a
ua
i
R
R
ec
=
qu
Pl
q
n
D
ad
ad
He
He
Planning Decisions Budget execution
Some, moderate, great, very great extent
Little or no extent
Source: Analysis of GAO 1995 survey responses.
These responses showed that progress had been made toward using
annual priorities to plan and make decisions. However, 19 to 33 percent of
4
For survey responses on whether the priorities had aided INS, we have deviated from the usual
presentation by combining the response scales “to some extent” through “to a very great extent” and
kept the response scale “to little or no extent” separate. We did this to measure whether the strategic
planning process has had an impact, not to measure the degree of the impact. Figure 2.2 shows the
extent to which priorities were perceived to be helpful. We did not include respondents who answered
“no basis to judge” in our analysis.
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the INS managers responded that priorities had marginally, i.e. to little or
no extent, aided planning and decisionmaking. This indicated that some
managers believed that more could be done in this area.
INS Priority Management The Results Act was passed in 1993 to, among other things, improve the
Process Included Some effectiveness and efficiency of federal programs by establishing a system
Tasks Required for to set performance goals and measure results. The Act is to improve the
performance of governmental programs through a set of integrated
Implementation of the activities that include strategic planning, setting annual performance
Government Performance targets, measuring progress toward reaching those targets, and reporting
and Results Act on results. INS took some early steps consistent with the goals of the Act’s
requirements with the establishment of its strategic plan in 1994 and the
implementation of the Commissioner’s Annual Priorities Program in fiscal
year 1995. INS officials told us that during the development of the fiscal
years 1996 and 1997 implementation plans, increased attention was given
to establishing and tracking performance measures that would align with
the Results Act. INS officials said that they recognized that additional
efforts are still required to fine-tune performance measurement, reporting,
and coverage of appropriate program activities. In April 1997, INS officials
told us that both the Office of Planning and the Office of Budget were
combining efforts to review the Act’s measures. GAO’s past work at INS and
at other agencies indicates that to be successful, such initiatives require
continued top management attention and commitment to continuously
improve program performance.
The 1994 reorganization restored regional directors into the chain of
Reorganization command to supervise district directors and Border Patrol chiefs. As a
Restored Regional result, according to some managers, district directors and Border Patrol
Directors to Manage chiefs received more supervision. Prior to the 1994 organization, the EAC
for Operations was responsible for directly supervising 33 district
Field Units directors and 21 Border Patrol chiefs. Some managers told us that district
directors and Border Patrol chiefs were often able to operate
independently of headquarters direction. The current Commissioner
considered this span of control too large and supervision too far removed.
Under the current organization, the EAC for Field Operations is to provide
headquarters direction to the field by supervising the three regional
directors. Each regional director in turn is to supervise an average of 18
district directors and Border Patrol chiefs. According to INS managers,
with the smaller span of control, regional directors can be more
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but Others Continue to Be Problematic
responsive to field needs and provide more oversight than the EAC for
Operations could under the previous structure. According to a
headquarters Field Operations manager, an assistant district director, and
a deputy regional director, the strength of the regional structure lies in the
direct, personal contact between regions and districts. This is reportedly
better than the former structure, because headquarters does not have the
resources to respond to all the districts and sectors and is too far removed
from the field to know the problems that the field is having.
In addition to reestablishing a regional structure with oversight
responsibility for field units, INS’ reorganization delegated resource
allocation authority to regional directors to provide consistency in field
operations and improve the delivery of services. According to regional
directors, they had gradually begun to exercise their new authorities. For
example, one regional director told us of having taken the unprecedented
act of moving a couple of positions from one district to another.
Furthermore, regional offices began to manage personal services and
benefits (PS&B) funds for district offices and Border Patrol sectors
beginning in fiscal year 1996. PS&B funds are payroll costs and represent
the majority of INS’ budget. The allocation and management of PS&B funds
were being maintained at the district and sector levels during fiscal year
1995. Two regional directors told us that the district directors were no
longer able to act independently.
Managers responding to our survey were divided in their perceptions of
the success of the reorganization. Generally, 35 to 40 percent of managers
responding to our survey believed that the reorganization was somewhat
or very unsuccessful in clarifying lines of authority, delegating authority to
persons geographically closer to locations where work was being done,
and decentralizing decisionmaking. About 20 percent of the managers
responding believed that the reorganization had been very or somewhat
successful in achieving these goals.5 More information on the survey
results and our interpretation of them is presented later in this chapter.
Probing the reasons behind these survey responses was beyond the scope
of our study.
At the time of our review, INS had not fully defined the responsibilities and
Reorganization Not authorities of the offices of Field Operations and Programs, nor had it
Fully Implemented determined staffing levels for these offices on the basis of their new
5
This survey question listed 11 goals and had 8 response categories. For more details, see appendix IV,
question 34.
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but Others Continue to Be Problematic
responsibilities. Also, INS had not improved communications and
coordination among offices or updated field manuals and the policy
manual, as we previously recommended. We recognize that the
Commissioner did not expect the reorganization to correct all problems
immediately and that adjustments are needed as a new organizational
structure is implemented. However, we believe that fully implementing the
reorganization as soon as possible would help INS work more efficiently
and help achieve the goals of the reorganization.
Our survey and interviews with managers indicated that headquarters and
field managers were confused and frustrated because INS’ implementation
of its new organizational structure left unclear the differences in
responsibility and authority between the Office of Field Operations and
the Office of Programs. Also, INS did not determine the staffing levels that
would be needed for the Office of Field Operations to carry out its new
functions, did not determine the staffing levels for the Office of Programs
to meet its changed responsibilities, and did not move all operational
activities to the Office of Field Operations. Some INS managers told us that
they were having difficulty determining whom to coordinate with, when to
coordinate, and how to communicate with each other because they were
unclear about headquarters offices’ responsibilities and authority. Some
managers also said that they believed resources in the Office of Field
Operations were insufficient to meet field needs.
Responsibilities and In December 1994 INS published an organizational chart and general
Authority of the Office of description of the roles and responsibilities of the Office of Field
Field Operations and Operations and the Office of Programs in the Federal Register (see ch. 1).
However, we were told by headquarters and field managers that INS had
Office of Programs Were not clearly delineated the respective roles and responsibilities of these two
Unclear offices. As stated by an INS field manager, “Neither [office] seems to know
the limits of its responsibilities nor the parameters of its authority.” INS
managers whom we interviewed also said that because the authority of the
EACs was not clear, decisions that should have been made at the EAC level
often had to go to the Deputy Commissioner for resolution.
In our interviews with INS managers and in comments written on our
survey, some managers indicated that they felt frustrated by a lack of clear
understanding of responsibilities and authority at headquarters. As one INS
manager stated on our survey:
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“With respect to the whole reorganization of 1994, there seemed to be little thought given
to its implementation and actual practical working[s] beyond just an organizational chart.
Overnight the [re]organization was implemented with virtually no transition, leaving . . .
each office [to] themselves to figure out what to do. Rather than plan for this organization
in some detail, it was left to personal ideas of the top management who gained the new
positions in the new structures to determine what would happen.”
INS managers whom we interviewed provided examples to demonstrate the
lack of clear delineation of responsibility between the Office of Field
Operations and the Office of Programs. One example related to the
development of the deployment plan for interior enforcement for fiscal
year 1996. The Office of Programs drafted the deployment plan because it
does the program planning for allocating resources to meet the
Commissioner’s priorities. It sought input from the field units and
subsequently provided a draft to the other EACs. When the EAC for Field
Operations received the Program Office’s subsequent draft, he determined
that the revised draft did not adequately consider or incorporate field
concerns. The EAC for Field Operations sent his own draft proposal for a
deployment plan to the field units with assumptions different from those
in the plan prepared by the Office of Programs. The field units provided
input to the second draft proposed by the Office of Field Operations.
Subsequently, the Deputy Commissioner intervened and instructed the
two EACs to develop a single proposal that they could agree upon.
Another example provided to us involved the selection of employees from
the field to train as instructors for firearms courses. A district manager
said that headquarters Field Operations staff asked the region to provide a
list of employees to attend instructor training for new firearms that were
being issued. The district manager provided a list to headquarters of
employees that the district wanted to recommend for instructor training.
The headquarters Field Operations staff selected employees from the list
to attend the training.
Subsequently, the headquarters Programs office staff asked the district
manager to provide a list of employees to be trained as instructors for the
firearms training. The district manager provided the Office of Programs
the same list of employees recommended for instructor training, and the
staff in the Programs office selected from it. The Office of Programs and
the Office of Field Operations selected different employees from the lists
provided. It was initially unclear to the district manager who was
responsible and had the authority to select employees for instructor
training. The Office of Programs ultimately made the decision on who
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would take the instructor training but, according to the district manager
who provided this example, field staff were confused and frustrated by the
situation.
Some headquarters and field managers whom we interviewed told us that
it is difficult to separate program planning activities and operational
activities. For example, some headquarters managers said it is clear that
the Office of Programs is responsible for such things as planning where
resources should be allocated and that the Office of Field Operations is
then responsible for implementing the use of resources as planned. But, as
stated by an INS official, it is unclear where planning ends and
implementation begins. This had implications for where responsibilities
and authorities should begin and end and where coordination is needed.
An example that illustrates the difficulty in separating program planning
and implementation was the development of a new automated system for
allowing people to enter the United States at remote locations along the
northern border.6 According to INS officials, the headquarters program
office was working with staff in the district office in Montana to test the
use of new systems for the northern border. The headquarters Program
Office manager and the staff in Montana proceeded to develop the new
systems without including the region or the Office of Field Operations
until they needed staff for the project. The region did not know that it
would have to provide a staff position to the Montana office in order to
implement the new technology until the Program Office contacted the
Field Operations office when the resource was needed. The region was not
involved in the program planning for this initiative but was eventually
responsible for providing the district resources to support it. This started
out as a planning activity but became an operational one.
Communication Processes In a February 1994 memo to INS employees, the Commissioner stated that
Within the New Structure the new organizational structure would build communication capabilities.
Had Not Been Clearly As one of its new responsibilities, the Office of Programs was to develop
communication capabilities. However, under the reorganization, it had
Defined and difficulty developing new communication paths with the rest of the
Communicated agency. Managers in the Investigations Office of Programs told us they
initially thought that their chain of command for communicating with the
districts was through the Office of Field Operations. This reportedly
6
At selected remote ports-of-entry that are not open 24 hours, local residents on both sides of the
border are to be able to apply for a permit allowing them to cross the border during the hours when
the port is closed using new technology for identification. Montana piloted the use of computerized
voice recognition and video conference by inspectors located at the nearest 24-hour port-of-entry.
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became too burdensome over time. Consequently, according to these
headquarters program managers, the EAC for Field Operations provided
oral guidance to the field units on when it was appropriate for the
headquarters Programs Office to contact the field directly and when the
Programs Office should go through the Office of Field Operations.
However, headquarters program managers told us that in practice, some
headquarters Field Operations staff continued to require that all
communications go through their office. Also, field units continued to
consider their appropriate channel of communication to be through the
regions and the Office of Field Operations. At the time of our review, INS
had not provided any written guidance on what needs to be communicated
and coordinated and when it should happen.
In March 1996 we met with the Commissioner and Deputy Commissioner
to obtain their perspectives on particular problems that managers in the
agency had described to us. During this meeting they told us that it would
be appropriate for field managers to communicate with headquarters
program managers without going through the Office of Field Operations
when program managers are seeking information or getting the field’s
input. The Commissioner told us that headquarters program managers
need to talk with the field to develop policies and assess the effectiveness
of policies. According to the Deputy Commissioner, the headquarters
program managers should go through the Office of Field Operations and
regional directors when they are tasking the field to do something that will
involve consumption of operational resources.
Nonetheless, according to headquarters program managers, some staff in
the Office of Field Operations continued to require program staff to go
through their office before contacting the field. This was reportedly the
case regardless of the purpose of the contact. Some headquarters program
managers reported that they have received mixed messages from the
Office of Field Operations on the circumstances under which they can
communicate directly to the field.
Another example of problems with the channels of communication
pertained to who had responsibility for a priority and the lack of
coordination between offices. We were told by some INS managers that
communication problems had occurred between the Office of Policy and
Planning and the Office of Programs. Headquarters program managers in
the investigations program area believed that the Office of Policy and
Planning had developed a priority objective for antismuggling but had not
consulted with the headquarters investigation managers even though the
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but Others Continue to Be Problematic
headquarters investigations program area has an antismuggling branch
that has a role in planning for the area. The investigations program
managers responsible for antismuggling activities said they would have
liked to have been involved. According to one official, it was unclear
whether the Office of Policy and Planning did not see a need for their
involvement or if there were not enough people in the Office of Policy and
Planning to coordinate the sharing of products. However, according to an
Office of Policy and Planning official, the EAC for Field Operations—not
Policy Planning—was the lead official for a priority that included this
objective. The official said that the Office of Field Operations did not
include the Office of Programs Investigations Division staff in the process
and, thus, was not employing the proper approach to priority management
by involving appropriate offices.
Survey Responses INS managers responding to several questions in our September 1995
Reflected Problems With survey indicated that there were problems coordinating and
Communication and communicating, particularly between headquarters and field units.
Sixty-three percent of the managers indicated that poor communications
Coordination was a problem to a great and very great extent.7 Ninety-two percent of the
managers responded that headquarters should consult more with the field
when developing policy. Seventy-three percent of the managers responded
that headquarters was not in touch with events, problems, and concerns of
the field. Fifty-nine percent of the managers responded that coordination
and cooperation among INS units needed improvement to a great or very
great extent. Although field managers were more likely to respond that
headquarters should consult the field more and that headquarters was not
in touch with events and concerns of the field, a majority of both
headquarters and field managers responded that there was a problem.
Table 2.2 presents these survey results for all managers combined and for
headquarters managers and field managers separately.
7
The analysis of survey data in this paragraph does not include respondents who answered “no basis to
judge.”
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Table 2.2: Survey Responses Indicate Communication and Coordination Problems
Percent of
All Headquarters Field
Question Statement Response category managers managers managers
Thinking about the Headquarters should Agree or strongly agree 92 83 95
implementation of INS consult more with the field
internal policy, would you when developing policy.
agree or disagree with the
following statements as they
apply servicewide?
Do you agree or disagree Headquarters is in touch Disagree or strongly 73 64 76
with the following statements with events, problems, and disagree
concerning INS as an concerns in the field.
organization?
In your opinion, to what Coordination and To a great or very great 59 70 56
extent, if at all, do you feel cooperation among INS extent
the following areas need units.
improvements servicewide?
Source: Analysis of GAO 1995 survey.
The following written comments from INS managers in our survey further
illustrated the perceived problems with communication and coordination
in the fall of 1995:
• “The Commissioner’s reorganization has created so many layers of
oversight that it delays all communications to the field. Even on routine
program or operational matters, all communications must go through the
EAC for Field Operations.”
• “Since the reorganization, the lines of authority and communication
between Programs and Field Operations have become more complex. We
need better understanding and cooperation among all INS functions.”
• “The reorganization has created lots of confusion in our office. Many areas
do not know if they report to the regional office or headquarters . . . .
There is no clear definition of who reports where.”
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INS Attempted to Clarify INShas taken actions to try to solve some of the concerns about roles,
Responsibilities and responsibilities, and communications. In April 1995, the EAC for Field
Communication Processes, Operations sent an electronic mail message to the western region
requesting feedback on the reorganization and suggestions for
but Problems Had Not Yet communication mechanisms. The Western Regional Director forwarded
Been Resolved the request to the districts and sectors under his jurisdiction and then
provided their comments to the Office of Field Operations. Several district
directors and Border Patrol chiefs reported many of the same
coordination and communication problems that were reported to us from
the cross-section of managers whom we interviewed. We could not
determine whether a message had been sent to the other regional offices,
but the regional managers for the eastern and central region told us that
they did not remember such a request.
In August 1995, the EACs and staff from the headquarters Field Operations
and Programs offices met and discussed their roles, responsibilities, and
communication issues. The EAC for Field Operations summarized the
results of the meeting and communicated them to the regional and
international affairs directors. The summary defined the roles of each of
the offices.
The summary said that Field Operations was looking to the Office of
Programs to develop plans, conduct analysis, and devise tools for tracking
progress in the field. In addition, according to the EAC’s summary, the
group agreed that the Office of Programs would conduct an inventory of
reports that it prepares that could be shared with the Office of Field
Operations. The summary also stated that the group agreed there would be
more active sharing of information between the two offices.
The EAC’s summary listed actions to be taken by the Office of Field
Operations and the Office of Programs. These included developing
mechanisms for Field Operations to provide input to the Office of
Programs and clarifying Field Operations organizational structure for
liaison purposes. The summary also recommended that the Office of
Programs and the Office of Field Operations set up regular meetings at the
assistant commissioner level with structured agendas. Furthermore, the
summary presented other ideas that the group discussed, such as
(1) having an 800 number for the reporting of problems and incidents,
(2) including managers from the Office of Management in a later meeting,
and (3) discussing at a later meeting where the Office of Policy and
Planning fits in.
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According to an INS official in the Office of Field Operations, the summary
was provided to the regional directors but was not shared with the Office
of Programs. The Office of Programs did not prepare a summary of the
meeting, according to officials in that office.
In the spring of 1996, we interviewed several headquarters investigations
and detention and deportation program managers about problems
between headquarters and field managers. We also recontacted some field
managers in the central and western regions about problems described to
us earlier in the review. According to several headquarters program
managers, some improvements had occurred, but communication
problems continued. The weekly meetings between the managers in the
individual program offices and the Office of Field Operations provided a
mechanism for sharing some information on routine operations, but the
participating officials did not have the authority to make major decisions.
Several field managers that we recontacted told us that there was still
confusion in the field regarding responsibilities and communication. A
recent example of continuing communication problems was reported by a
consultant to the Justice Department who was reviewing INS’
naturalization procedures. The consultant reported that three different
versions of guidance on naturalization procedures had been distributed
throughout INS and that some offices were using the wrong version. One
version was a copy of the memorandum signed by the Commissioner,
another was an unsigned electronic version of the memorandum with
different attachments, and the third was an early version drafted for the
Deputy Commissioner’s signature.
Staffing Level for the Several managers whom we interviewed stated that the Office of Field
Office of Field Operations Operations had not been sufficiently staffed to accomplish its function and
Was Perceived to Be duties. According to the EAC for Field Operations, the initial plan for the
reorganization intended that the Office of Field Operations have a
Insufficient relatively small staff and that the regional office staff be an extension of
the headquarters office. The expectation was that regional offices would
be more involved with the districts and sectors and would respond to their
needs. However, as the reorganization evolved, the headquarters office
found that it needed more staff at headquarters to accomplish its
functions. A June 1994 organization chart provided for 29 positions in the
Office of Field Operations. According to an INS official in the Office of
Field Operations, as of March 1996, the Office of Field Operations had 41
authorized positions, of which 32 were filled. No analysis had been done to
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determine what the staffing levels should be in relation to the
responsibilities of the headquarters Office of Field Operations.
Headquarters investigations managers in the Office of Programs provided
an example of the problem of insufficient staffing level in the Office of
Field Operations. Within the Field Operations office, three people handled
field issues for investigation activities; and in each of the three regions,
three or four staff were dedicated to investigations work. According to the
headquarters program managers in investigations, the investigations staff
in the Field Operations Office were overwhelmed because there were
about 2,000 investigators in the field units seeking assistance from the few
staff in the regional office and headquarters Field Operations. Several
managers told us in interviews and through written comments on our
September 1995 survey that the headquarters field operations office was
not sufficiently staffed to handle the workload.
Some Office of Programs managers told us that they felt that they had to
respond to field inquiries and assist the Office of Field Operations because
that office was unable to handle the numerous calls and accompanying
heavy workload. According to these headquarters program officials, field
managers called them for assistance because they were unable to reach
headquarters Field Operations staff. However, some staff in the
headquarters Office of Field Operations perceived that headquarters
program officials were unwilling to relinquish the authority they formerly
had over field operations.
Staffing Level for the According to managers in headquarters, the regional offices, and field
Office of Programs Had units, staffing levels for the Office of Programs were not changed as a
Reportedly Not Been result of the reorganization even though the responsibilities of the office
had changed.
Reassessed After
Responsibilities Changed Some managers outside of the Office of Programs perceived that there was
an imbalance between resources in the Office of Programs and the Office
of Field Operations, and some survey respondents commented that the
personnel resources of the Office of Programs remained the same despite
the change in its role and responsibilities. For example, at headquarters,
the Office of Programs had 531 authorized positions compared to the 41
authorized positions in the Office of Field Operations in March 1996.
Further, the investigations program in the Office of Programs had 46 staff
and, as mentioned previously, the Office of Field Operations’
investigations staff consisted of 3 people, according to INS officials. It
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would seem logical that with changed responsibilities, INS would need to
reassess its staffing of this office.
Leaving Operational One of the objectives of the reorganization was to separate program
Activities in the Office of planning and operational activities so that headquarters program
Programs Caused Some managers could focus on program planning and not be involved in the
day-to-day operations. However, INS management decided that some
Confusion operational activities should remain in the Office of Programs. According
to the headquarters program managers whom we interviewed in the
Investigations and Detention and Deportation Offices, some operational
activities were left in the headquarters Office of Programs because the
workload needed to be done at headquarters and was too large for the
Office of Field Operations to take over. These program managers also told
us that another reason operational activities were left in the headquarters
Programs office was that the staff had particular expertise in a particular
program area that was relevant to both planning and operations.
According to the Commissioner and Deputy Commissioner, INS needed the
mix in expertise of staff left in the Programs Office to do the program
planning functions. However, headquarters program managers told us that
because they continued to do operational activities, they did not feel that
they were able to devote enough time to planning activities.
We did not identify all the operational activities that continued to be the
responsibility of the Office of Programs, but through interviews we were
able to identify a sample of the kinds of operational activities that
remained there. Management of the Mariel Cubans8 and juveniles in
detention facilities are two activities that were left in the Office of
Programs. According to INS officials, the caseload for processing Mariel
Cubans was too large for the newly created Office of Field Operations to
handle. In the case of juveniles, headquarters program managers told us
that they had the expertise to contract for juvenile bed space. Until the
reorganization, the Office of Programs’ detention and deportation staff
handled both the planning and operational aspects of detaining juveniles.
Since they had the experience, INS management decided to have the staff
in Programs continue handling both planning and operations for juveniles.
Other operational activities that remained in the Office of Programs
included processing of applications for immigrant benefits through INS’
four service centers, oversight of the witness security program, and review
and approval of requests for authority to conduct undercover operations.
8
Mariel Cubans are Cuban nationals who were allowed to enter the United States as refugees in 1980.
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We found no evidence that field units were unable to accomplish their
missions because some operational functions remained in the Office of
Programs. However, several headquarters and regional managers told us
that having operational functions remain in the Office of Programs
contributed to the confusion regarding when and how to coordinate with
the Office of Field Operations.
Through the reorganization, INS sought to create a structure that would
Field and Policy enable it to reengineer major processes, such as those that develop and
Manuals Still Have disseminate organizational policy and guidelines. We reported in 1991 that
Not Been Updated policy information was outdated, and we found in this review that policy
information still has not been updated. INS was in the process of updating
manuals in some program areas but not in others. Sections of the manuals
are to be issued as they are completed, but no revised manuals or sections
of manuals had been issued as of February 1997.9
INS Was Beginning to Six program areas10 are to have field manuals containing policies and
Update Field Manuals procedures on how to implement the immigration laws. These field
manuals are basic reference tools for managers. For example, INS
managers rely on the inspector’s field manual to explain the procedures
for inspecting cruise ships and cargo vessels and the necessary forms for
each of these inspections. If a stowaway is found, the field manual also
explains the procedures INS employees are expected to follow.
According to an INS official, until 1995, no work had been done on the
manuals for about 5 years. To help alleviate this problem, in November
1995, INS assigned a project officer specifically responsible for updating
manuals.11 The project officer told us that in the past and at the time of our
review, completion of field manuals had been delayed because staff
assigned to develop them had been sidetracked to develop regulations to
implement legislation. In a briefing report used in March 1996, INS stated
that the lack of updated field manuals had created a burden for employees
because they had to search out too many sources of information on
9
In commenting on a draft of this report, INS officials said that agreement had been reached with INS
unions that 51 of the 295 chapters of the administrative manual needed only minor modifications and
did not affect work practices. INS staff were notified in April 1997 that those chapters were issued in
computerized form.
10
The six program areas are inspections, adjudications and nationality, detention and deportation,
investigations, Border Patrol, and intelligence.
11
This excludes the Border Patrol manual, which is being updated by the Border Patrol Program Office.
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immigration laws or regulations. This had reportedly made it difficult for
employees to follow INS procedures because they received conflicting
information on procedures. The briefing report said that the lack of
current manuals also led to field officers creating policy locally, and this
compounded the confusion and the difficulties in coordination.
INS was in the process of updating the Inspections Field Manual and
expected that parts of the revised manual would be issued in May 1997. INS
began updating the Adjudications and Nationality Field Manual in March
1996. The project officer said that in the spring of 1996 he had also held
preliminary meetings with the detention and deportation and
investigations program area officials to discuss updating their manuals.
However, according to the project officer, as of February 1997, nothing
more had been accomplished on these manuals because he had to respond
to a higher priority to develop legislatively mandated regulations. The
intelligence program area is to have a chapter in each of the other five
program area field manuals in addition to having its own general manual
on procedures to follow for reporting intelligence information. The
Intelligence Program Office is to develop the general Intelligence Field
Manual.
INS Had Drafted a Revised INS staff rely on the administrative manual to provide information on
Administrative Manual but internal technical policies that are not related to immigration law. The
Was Not Sure When It administrative manual includes information on procedures, such as cash
collection, disciplinary actions, firearms, uniforms, personnel issues, and
Would Be Issued financial management. INS took about 2 years to revise the manual, and
several additional years have passed as changes were being negotiated
with the employee unions.
According to an INS official, as part of the partnership agreement that INS
has with its employee unions, the unions can review changes to the
administrative manual and field manuals. When INS completed a draft of
the administrative manual in 1993, the two unions were given the draft to
review. According to INS’ labor relations manager and a union president,
the changes made to the administrative manual were voluminous, and the
unions were unable to review it expeditiously. As a result, negotiations
with the unions on the changes have gone on for more than 3 years. In the
spring of 1996, INS management and the unions agreed on a list of sections
in the draft manual that needed to be reviewed with the unions and have
prioritized the list to expedite the process. The section on use and storage
of firearms is the first item on the priority list.
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Due to the negotiations between INS and the unions, INS had not yet
established a timeline for completing the revised administrative manual as
of February 1997. According to the INS official directing the field manuals
project, sections of the administrative manual may be issued when they
are finalized with the unions. To avoid similar delays with the field
manuals, INS management was seeking agreement with the unions on small
sections of each manual as they are approved by INS management. This
was done with the draft section of the Inspections Manual and worked
well, according to the project officer.
The following written comments by respondents to our survey illustrate
INS’ problems communicating policies and procedures in the fall of 1995:
• “The Administrative Manual is extremely out-of-date. There have been
numerous times that I have researched an issue and arrived at a
conclusion, only to be told by [the] Region that, ‘That’s so old; we don’t
follow that anymore.’ If it’s still ‘on the books’ then I should be able to use
it as a tool for completing my work. Of course, the alleged current policy
or procedure is rarely validated by a written issuance.”
• “With regard to . . . policy implementation, field personnel all do their own
thing. There is not one place an officer can go for direction. The . . .
operating instructions are out of date and policy wires often don’t make it
to the field.”
• “The reorganization was recent, and it is understandable that policies and
procedures may still be in the process of being developed, but
headquarters should at least communicate that guidance is in process and
provide interim guidance. As an example, legislation effective October 1,
1995 calls for charging fees for some services at the land border. No policy
guidance for collecting the fees has been issued. Over $50,000 was
collected in San Diego the first week. Apparently, there was a disconnect
between the Office of Programs and the Office of Field Operations about
who is responsible for implementing the program. It should be a
coordinated effort. Even if headquarters is still in the process of
developing the policies and procedures, interim guidelines, such as ‘follow
the district’s cash collection procedures’ would have been fine.
Headquarters does not see the urgency. They do not see the people lining
up with applications.”
• “I was recently told by a regional staff employee that it was not the policy
to put things out in writing. How are employees suppose[d] to know what
to do if they are not told. I believe the word is ‘chaos.’ (confusion)
[Headquarters] needs to know [and] understand the needs of district [and]
sectors. [Headquarters] needs to establish written policies in a multitude
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of areas using input from field office personnel. [Headquarters] must
communicate with regional personnel as well as field offices when
establishing procedures.”
• “Dissemination of policies in my unit is sometimes through hearing instead
of in writing . . . execution of policies differ greatly . . .”
INSidentified goals for the reorganization to help it manage better. We
Survey Results on asked a question on our survey about the success of the reorganization in
Gains Made as a accomplishing INS’ goals, and respondents to the survey had mixed
Result of opinions. Concerning the reorganization’s success in clarifying lines of
authority, for example, 20 percent of the managers responded that the
Reorganization Were reorganization was very successful or somewhat successful, 21 percent
Mixed responded that the reorganization was as successful as unsuccessful, and
41 percent responded that the reorganization had been somewhat or very
unsuccessful. Another 15 percent of the managers responded that they had
no basis to judge. Table 2.3 presents the question that we asked managers
and responses by INS’ managers on the success of the reorganization in
achieving some of the goals. A complete list of the goals and managers’
responses can be found in appendix IV.
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Table 2.3: Managers’ Responses to the
Question: Generally, How Successful
or Unsuccessful Do You Think the
Reorganization Has Been in Achieving
the Following Goals? Goals
Clarifying lines of authority
Delegating authority to persons geographically closer to locations where work is being
done
Decentralizing decisionmaking authority
Improving processes to develop and disseminate organizational policy and guidelines
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Managers responding
Very or
somewhat As successful as Somewhat or very Goal achieved prior to Too early to No basis to
successful unsuccessful unsuccessful reorganization say judge
20% 21% 41% 2% 3% 15%
22 18 36 1 4 20
22 18 35 1 5 20
17 21 44 1 4 13
Note: Percentages may not add to 100 percent due to rounding.
Source: Analysis of GAO 1995 survey.
There were several possible reasons cited by various INS managers as to
why the percentage of managers who thought the reorganization had been
unsuccessful in achieving certain goals was roughly twice as great as the
percentage who thought the reorganization had been successful. First,
they said overlaps in the roles and responsibilities of the Offices of
Programs and Field Operations may have led managers to believe that
lines of authority were unclear. Second, we were told that regional
directors did not assume all of their new authority immediately, and the
agency was going through a transition phase the first year. Thus, some
managers could have perceived that the reorganization had not
accomplished its goal for delegating authority closer to where the work is
performed or decentralizing authority. A third reason given was that not
enough time had passed for significant changes to occur. For example,
some of the goals of the reorganization, such as developing planning
capability, improving the delivery of services, and establishing quantitative
performance measures, could take several years to accomplish.
Furthermore, INS had not begun to implement some of the strategies to
achieve its goals. For example, in March 1996, the Commissioner told us
that the agency has not formalized processes to disseminate information
and procedures.
In April 1996, INS’ Office of Policy and Planning began a review of the 1994
reorganization. According to an INS official, the review was an ongoing
effort, and, as the need for organizational changes or refinements are
identified, changes can be included in future INS plans and budgets.
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INShas taken some steps to address long-standing management problems.
Conclusions INSdeveloped a strategic plan and initiated an annual priorities
management process—initial steps in the Results Act process. We believe
that such efforts are important components of effective planning and
decisionmaking. The priorities process had top management support, had
been linked with planning and decisions for resource allocations, and had
been clearly communicated throughout the organization. The long-term
impact is yet to be determined and will require that top management
persist in its commitment to using priority management for planning and
decisionmaking.
INSachieved some of its management goals for the reorganization, but, as
can be expected in the first years of implementing a new structure, not all
management goals were achieved. INS reestablished a regional structure
with oversight responsibility of district directors and Border Patrol chiefs;
and regional directors have been delegated authority to manage the field
resources, which places responsibility closer to where the work is
performed. It is too soon to determine whether the organizational changes
will improve customer services and enforcement activities.
According to many managers we interviewed, the lack of delineation of
responsibilities and authority between the Office of Programs and the
Office of Field Operations had caused confusion for headquarters and field
managers. For example, separate requests to a field manager from each of
the offices to identify trainers resulted in a duplication of effort and in
different employees being selected as potential trainers from the same list.
Furthermore, headquarters and field managers perceived that too many
decisions that should be resolved at the EAC levels had to go to the Deputy
Commissioner for resolution because lines of responsibility and authority
were not clear. The agency had not clearly defined the responsibilities and
authority of the Office of Field Operations and the Office of Programs in
relation to each other and to other INS units and had not clearly defined
how and when these offices should coordinate with each other.
INS’new structure and the Commissioner’s Priority Program had created
new ways of communicating. Managers reported to us that they were
confused and frustrated about when and how to communicate with each
other. INS’ new structure and the Commissioner’s Priority Program
required that communication and coordination cut across the agency. The
EAC for Field Operations had reportedly provided oral guidance on
communications between the Office of Programs and the field units and
had taken some actions to address communication problems. However,
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these efforts did not appear to have provided a clear understanding of
what communication is needed and when it should occur. INS had not
provided any written guidance on what needs to be communicated and
coordinated and when it should happen for this new way of working.
The agency reorganized in 1994 and created a new Office of Field
Operations, created new Regional Director offices, and changed the role of
the previous EAC for Operations to EAC for Programs. However, the agency
did not determine what resources would be needed for these offices to
carry out their new responsibilities. One of INS’ goals for the reorganization
was to enhance program planning capabilities by relieving headquarters
program managers of responsibility for day-to-day operations. Yet, some
operational activities remained with the Office of Programs. According to
headquarters program managers, they did not have any more time for
program planning as a result of the reorganization. Although INS provided
reasons for some activities remaining in the Office of Programs, this may
be counterproductive to accomplishing an intended goal of the
reorganization to create a clearer sense of mission by separating policy
planning, program planning, and field operations.
INS’field and administrative manuals had not been updated since we
reported the lack of policies and procedures as a problem in 1991. One of
the goals of the reorganization was to improve the processes for
dissemination of organizational policy and guidelines. The lack of current
manuals made it difficult for employees to carry out their mission-related
activities and led to field officers creating policy locally. The agency was in
the process of revising some of the field manuals and finalizing approval of
the revised administrative manual. In the past and at the time of our
review, completion of field manuals had been delayed because staff
assigned to develop them had been sidetracked to develop regulations to
implement legislation. The administrative manual had not been issued
because of negotiations between INS and its two unions. INS had not
established milestones for issuing manuals or parts of manuals. Having
milestones could help INS management to recognize when slippage occurs
and focus the need to remain vigilant with respect to issuing current
guidance.
Overall, we found that the reorganization had addressed some of the
management problems identified in past reports, but the reorganization
had not been fully implemented. INS was beginning to evaluate the 1994
reorganization as we concluded our review.
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We recommend that the INS Commissioner take the following actions to
Recommendations help achieve the reorganization goals:
• provide written guidance to all INS managers on the responsibilities and
authority of the EACs for Field Operations and Programs in relation to each
other;
• provide written guidance on the appropriate coordination and
communication methods and channels between offices to include
(1) when and how Field Operations and Programs should coordinate and
communicate with each other, (2) when and how the Office of Programs
should coordinate and communicate with the regional offices and the
districts and sectors, and (3) when and how the Office of Policy and
Planning should coordinate and communicate with the other offices;
• determine whether staffing levels need to be adjusted for Programs, Field
Operations, and regional offices to accomplish their prescribed roles and
responsibilities consistent with the respective mission and workloads for
each office;
• establish milestones for issuance of manuals or parts of manuals that can
stand alone; and
• incorporate into INS’ current evaluation of the reorganization the issues
raised in this report so that they can be addressed as INS attempts to fully
achieve the goals of the reorganization.
INS provided written comments on a draft of this report, which are printed
Agency Comments in full in appendix VI. INS said that it agreed with our assessment that some
objectives of the reorganization had not been achieved and stated that it
has proposed changes to improve lines of responsibility that address many
of the concerns raised in the report.
INSprovided technical comments separately, which we incorporated
where appropriate. INS also provided updated information on the
administrative manual. According to INS officials, INS and the unions
reviewed 85 of the 295 chapters of the administrative manual to identify
ones that needed only minor modifications and did not constitute changes
in working conditions. Following this review, 51 chapters were issued in a
computerized format in December 1996, and the EAC for Management sent
a memo to field offices in April 1997 to inform staff that these new
chapters were available for their use. We added this information to our
report. INS was to meet with union representatives again in June to review
another group of 70 to 80 chapters to identify ones that require minor
modifications and do not constitute changes in working conditions so that
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more chapters can be issued. Chapters that need further negotiation are to
be handled at a later date.
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In 1991, we reported that INS’ budget allocations had not been based on
agencywide priorities, INS had not adequately used workload information
as a factor in making budget allocations, and budget management and
resource allocation problems perpetuated backlogs for processing aliens’
applications for naturalization and adjustment of status. We also reported
that INS’ primary accounting system was outmoded and had weak internal
controls, and the use of unreliable financial information had resulted in INS
inadequately monitoring its budgetary resources.
During our review of INS’ fiscal year 1995 budget execution process, we
found that INS (1) had improved its management of budget resources by
using annual priorities to help make budget allocation decisions and using
workload information for planning to some extent in four of its six
program areas,1 and (2) was seeking to improve its capability to use
workload information in each of its program areas. However, problems
persisted because INS continued to (1) experience resource allocation
problems that caused field offices to have backlogs in processing alien
applications and (2) lack accurate, complete, and consistent data to
efficiently monitor budgetary resources.
INShas been taking steps intended to improve workload analysis, improve
the data it uses to monitor the budget, and implement a new financial
management system. Although these steps, if fully implemented, should
move INS in a positive direction toward resolution of the problems we
identified, continued top management attention to monitoring progress
and reducing the risks associated with these initiatives will be necessary.
For several years, INS acknowledged the need to make better use of the
INS Made agency’s financial resources. Accordingly, INS took several steps intended
Improvements in to improve its allocation of budgetary resources. INS sought to find ways to
Planning Resource better match resources to workload demands and performance at each
field location and to more strongly link program activities to strategic
Allocations planning. As discussed in chapter 2, INS initiated a strategic planning
process that tied annual priorities and performance measures to resource
allocation. In addition, steps were taken to improve the use of workload
data in deciding how to allocate resources in the six major INS program
1
Adjudications and nationality, Border Patrol, detention and deportation, inspections, intelligence, and
investigations are the six major INS program areas.
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areas. Also, for the first time, INS developed a table of organization2 to
assist the various field and program units in planning and managing
personnel resources. In addition, deployment plans were being used in
fiscal year 1996 to allocate new resources. Finally, INS developed a
long-range growth management plan to assist the agency in accomplishing
its resource allocation goals of directing the additional resources provided
by Congress to priorities and workload demands.
Resource Allocations As discussed in chapter 2, in 1995 INS began implementing a priorities
Linked to Priorities management process to establish annual priorities in support of, among
other things, its strategic plan. The purpose of these priorities was to
provide a means of monitoring crosscutting program initiatives important
to the agency’s mission. They provided a mechanism to tie agency
resources to annual priority activities. Under this approach, senior INS
executives were required to make recommendations to the Commissioner
on priorities for budget formulation, allocations for budget execution, and
other resource issues that have an agencywide effect. The goal was to
ensure that allocation of budgetary resources supports the
Commissioner’s annual priorities.
INS receives funding through the appropriations process from several
sources. These sources include: (1) general revenues, (2) the Violent
Crime Reduction Trust Fund3 (VCRTF), and (3) various fees paid by users of
immigration services. INS linked its allocation of additional resources from
these funds to program initiatives and annual priorities. At the beginning
of fiscal year 1995, INS instituted a priorities implementation review
process that established connections among the strategic plan, priorities,
budget initiatives, and program requirements. Extending this effort, INS
then linked the priorities implementation review sessions to its quarterly
financial review process. The quarterly financial reviews helped identify
needs for additional funding and the availability of resources that had not
been obligated and that could be reallocated to other priorities or agency
needs. The intended outcome of the linkage was to ensure that resource
allocation decisions were consistent with the agency’s annual priorities.
2
A table of organization is a document prepared by INS’ Office of Budget in conjunction with the
various field and program units. It provides detailed information to unit managers on authorized
funded staffing levels.
3
A separate account in the Treasury, the Violent Crime Reduction Trust Fund was created by the
Violent Crime Control and Law Enforcement Act of 1994 (P.L. 103-322, 42 U.S.C. 14211). Amounts in
the Fund are to be used for the purposes authorized in that act.
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Steps Taken to Better INS has taken steps to better use and incorporate workload
Incorporate the Use of models—referred to in INS as workload analysis models (WAMs)—into its
Workload Information budget allocation decisions. The purpose of WAMs is to help determine the
distribution of current personnel resources and to base projected future
staffing needs on operational priorities and cross-cutting programmatic
needs. WAMs were designed as a management tool to assist INS officials in
basing program resource allocation decisions on workload distribution
while maintaining flexibility to respond to changing events, circumstances,
and emerging priorities. Under the reorganized management structure
created in 1994, the role of INS’ program offices was to shift away from
managing field resources. The new focus of these offices was to be on
program development and integration that anticipate growing workloads
and demands on the agency. Program offices were to be primarily
responsible for developing, maintaining, and utilizing WAMs that provide INS
managers with information to enable them to respond to changes in
workload demands. Much of the information included in the workload
models relies on workload data from the various INS field and service
units.
We interviewed cognizant officials and found that the type and use of
workload information varied among the six major INS program areas. As
table 3.1 shows, during fiscal years 1995 and 1996, four of the six program
areas used workload data to some extent for planning and allocation
purposes. Inspections used a WAM; adjudications used WAMs for service
centers, but not for district offices; investigations had a WAM in place, but it
was not used; intelligence had no model but utilized workload
information; and neither Border Patrol nor detention and deportation had
WAMs or used workload data to project how to allocate budgetary
resources.
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Table 3.1 INS’ Use of WAMs and Workload Data in Planning Fiscal Year 1995 and 1996 Resource Allocations
WAM in place? Workload data used?
INS Program Yes No Yes No Brief description of situation
Adjudications and WAM was used to recommend allocation of resources
Nationality among adjudication service centers.
—Service Centers • • No evidence that WAM was used for planning and
—District Offices • • projecting allocation of resources in district offices.
Border Patrol • • According to an INS official, allocation of resources in this
program area in fiscal year 1995 was decided primarily
by program initiatives and agency and congressional
priorities, which continued into fiscal year 1996.
Detention and Deportation • • INS had entered into a contract to develop a WAM for this
program area. No evidence of the use of workload data in
planning and projecting resource allocations.
Inspections • • Detailed WAM and automated workload data collection
system were in place and were used in planning and
projecting resource allocations.
Intelligence • • No WAM existed. An INS official said that INS utilized
workload information in making resource allocation
decisions in fiscal years 1995 and 1996.
Investigations • • Detailed WAM was in place. However, it had not been
used in planning and projecting resource allocations
since 1992. Workload information was considered in
making some of the resource allocation decisions in fiscal
years 1995 and 1996.
Source: INS documents and interviews with cognizant officials.
Inspections, investigations, and the adjudications service centers had
mathematical workload analysis models. Inspections’ model seemed to be
the most sophisticated because it took baseline information from ports of
entry and did computer simulations to estimate personnel resource needs
under different scenarios and changing priorities. The investigations
workload model used data to estimate a weighted workload based on the
relative size of work among districts and the priority of the work area, e.g.,
removal of criminal aliens and proactive investigations of major alien
smuggling organizations to project future workload allocations. The
adjudications service centers’ workload information was based on
incoming receipts and the productivity per employee, among other things,
to project resources needed to meet workload demands.
Despite not having WAMs, the adjudications district offices and intelligence
used workload information to decide how to allocate resources in fiscal
years 1995 and 1996. Border Patrol resource allocations were based on
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priorities and program initiatives that among other things, sought to
increase the number of agents on the border to deter illegal entry into the
United States. The detention and deportation program area has a contract
with a firm to develop mathematical workload analysis models that are
intended to identify the most effective distribution of current personnel
resources and to project future staffing needs.
We did not attempt to evaluate how effectively the units were using WAMs
or workload data to help them allocate resources. We also did not attempt
to verify the quality of the workload data being utilized by the INS
programs. However, INS’ efforts to improve workload information and the
use of models to make resource decisions are steps in the right direction.
Other Steps Taken in INS has taken further steps intended to improve the linkage between
Fiscal Year 1996 to workload and the way it allocates and tracks the deployment of its
Improve Resource resources. In fiscal year 1996, INS began providing tables of organization to
its various resource managers, developed deployment plans to manage the
Allocation allocation of additional resources that were being provided by Congress,
and developed a long-range plan for growth management.
Tables of Organization Tables of organization are a management tool intended to assist managers
with resource allocation planning. The information in the tables of
organization allows INS managers to compare the existing staff distribution
to funded personnel levels. According to INS headquarters officials, INS
tries to ensure that the tables of organization are updated quarterly to
reflect changes in authorized funded staffing levels. Prior to the use of the
tables of organization, INS resource managers did not have information
readily available on authorized funding levels to use in making hiring plans
and resource allocation decisions.
To alleviate this problem, INS began drafting tables of organization with its
resource managers starting with the fourth quarter of fiscal year 1995. The
first table of organization drafted was for the Border Patrol Program. In
April 1996, INS provided a draft consolidated table of organization to all
headquarters and field locations for review. The final version was
distributed in July 1996. The tables of organization are intended to help INS
manage staffing for the various INS units, including regional offices, Border
Patrol sectors, adjudications service centers, and district offices.
Deployment Plans In fiscal year 1996, INS formalized the use of deployment plans with the
intent of ensuring that additional resources received during the year were
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allocated in a way that was consistent with priorities, program initiatives,
and identified workload needs. Deployment plans are management tools
intended to specify when and where to distribute new positions. These
deployment plans had generally been developed through an iterative
process that included statistical analysis and field input. For example, an
INS official responsible for managing the development of the deployment
plan for the interior border enforcement initiative said that WAMs and the
table of organization have served as a base of information for developing
deployment plans. INS’ Interior Enforcement Deployment Plan outlines
specific steps to be taken in fiscal year 1996 for the deployment of new
resources to key geographic locations in support of established priorities,
program initiatives, and workloads for fiscal year 1996.
Growth Management Plan INSalso took steps in fiscal year 1996 to implement a growth management
plan that included long-range deployment planning and a management
process that tied into budget formulation and priorities planning,
incorporated congressional requirements, and projected general plans for
growth, by location. As part of this effort, INS had developed a long-range
plan that was intended to assist the agency in managing planned growth in
the size of its officer workforce and support staff through fiscal year 1998.
The growth management plan called for INS to implement its deployment
plans by building sound multiyear staffing models and to redesign its
deployment plans to incorporate projected growth. The growth
management plan outlined goals for recruiting, hiring, and training officers
and support staff and for ensuring field readiness to absorb planned
growth. INS intended to monitor these plans to ensure that any required
adjustments could be made in a timely manner.
Independent Study In April 1996, INS hired a consultant to do an independent analysis of how
INS deploys its personnel resources, including an assessment of the
strengths and weaknesses of WAMs and deployment planning processes.
The results of the May 1996 independent study indicated that INS’
processes tended to be reactive rather than prospective and were driven
more by resources that were available than by a determination of actual
requirements. The consultant concluded in part that (1) workload was not
adequately captured and reflected in the processes that were intended to
recommend staff allocations and (2) WAMs currently in use needed to be
updated to better serve as forecasting tools. Among other things, the
consultant recommended that INS develop a minimum 5-year, rolling
strategic planning process; develop an INS-wide requirements-based model
to assist planners at all levels that builds on the strengths of existing
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stand-alone tools, such as WAMs; and conduct further analyses to formulate
a more integrated INS deployment planning process.
In response to these recommendations, INS hired another consultant to
identify deployment planning process improvements that were needed;
assess INS’ deployment planning requirements; develop a stand-alone,
automated deployment planning tool for INS, which included design,
installation, implementation, and testing of a prototype software program;
and train selected INS personnel on the implementation of the software
program. The prototype software program is to initially help plan for
deploying personnel resources by service locations and is to be capable of
expanding to include planning for training, equipment, and facilities. The
prototype is also to be compatible with existing automated staffing
models. The contractor was to accomplish its tasks by June 1997. INS
intends to contract for enhancements to the model for other resource
needs, such as equipment and facilities.
Approximately one-third of INS’ funds in fiscal year 1995 were derived from
Process for Notifying fees, with the Immigration Examinations Fee Account being the largest.
Congress of Need for The demand for examinations fee services, and therefore funding levels,
Additional Funds fluctuates more than for other INS fee activities. Consequently,
examination fee levels are more likely to require adjustments after the
From Fee Account current year budget has been enacted. If INS anticipates a need for a
Contributed to change in funding authority as a result of higher or lower-than-expected
fee collections, then INS is to prepare a reprogramming proposal for
Application Backlogs transmittal by the Department of Justice to the Office of Management and
Budget (OMB) and, subsequently, to the appropriation subcommittees with
jurisdiction over the Department of Justice.
INSstarted fiscal year 1995 with a higher-than-expected adjudications
workload. An amendment adding subsection 245(i) to the Immigration and
Nationality Act of 1952 and California’s Proposition 187, passed in
November 1994, led to a dramatic surge in the demand for adjudication
benefits in 1995. INS also experienced a tremendous growth in its
examinations fee account receipts because of (1) a new
adjustment-of-status application process under the 245(i) amendment and
increased fees from that provision, and (2) increases in the number of
naturalization applications received. When INS determined that the
increase in the number of applications was likely to persist and that it
needed to respond to the additional demand for services, it took steps to
notify Congress of the need to use additional funds from the Immigration
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Examinations Fee Account.4 A proposal for additional spending authority
was submitted to Congress in the third quarter of the fiscal year.
According to INS officials, INS wanted to determine the extent to which the
number of applications would rise after the passage of the 245(i)
amendment and whether the growth would continue. Therefore, it
monitored data on application rates for the first 3 months of fiscal year
1995. After INS determined that there was a need for additional funding, the
internal and external processes for planning, preparing, and reviewing the
proposal for reprogramming of funds consumed another 4 months before
the proposal could go to Congress. As a result, backlogs and average wait
times for processing applications continued to grow in the field units.
INS Reprogramming During most of fiscal year 1994, INS experienced a lower-than-normal level
of receipts. Consequently, INS proposed several reprogrammings to
decrease spending for activities funded by the Examinations Fee Account.
However, INS experienced a surge in applications in the final 2 months of
fiscal year 1994 and had a large pending workload going into fiscal year
1995. This workload was compounded by a further increase in the
applications filed during the first quarter of fiscal year 1995. As a result, INS
determined that it needed additional funding to hire people to process the
applications. According to an INS budget official, other fee accounts are
more predictable, which enables INS to project revenues more reliably.
Because the Examinations Fee Account has “peaks and valleys,”
reprogrammings are used to address the uncertainty of the workload in
this program area. But, according to INS officials, the reprogramming
process does not respond quickly enough to the need for additional funds.
As part of the 1995 congressional action, INS’ spending level authority for
the Examinations Fee Account was $291.1 million. In establishing this
funding level, the Conference Report acknowledged that it might not cover
INS’ full cost of inflation increases. The report directed that if INS realized
examination fee receipts in fiscal year 1995 that were higher than the
current estimate, INS should use those funds for base inflation costs, as
necessary, and to the extent possible, to provide additional resources for
the processing of naturalization applications. The conferees stated that
they expected to be notified of changes in spending plans as delineated by
4
INS’ Examinations Fee Account derives revenue from fees collected for processing 59 types of
applications, petitions, hearings, and appeals forms for immigration benefits, such as naturalization
and permanent resident status. INS collects fees and processes applications at 4 regional service
centers and 33 district offices.
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the reprogramming requirements of the appropriation bill.5 Under these
requirements, which are found in section 605 of the Appropriation Act,
notification to the Appropriation Committees of both Houses of Congress
must be provided 15 days in advance of reprogramming of funds.
In accordance with section 605 of the 1995 Appropriation Act and section
8 of the Department of Justice Appropriation Authorization Act, 1980, P. L.
96-132, the Department of Justice notified the House and Senate
Committees on Appropriations and the Judiciary of proposed
reprogramming actions for INS’ Examinations Fee Account, the
Legalization account, and the VCRTF in April 1995. The reprogramming
provided additional spending authority of $76.6 million.
Process for Proposing The Department of Justice requires INS and its other department
Reprogramming Actions components to prepare and submit a report containing a justification for
the reprogramming proposal. Justice also requires INS and its other
components to obtain congressional response to the reprogramming
action before expending any of the additional funds being sought. Several
internal and external layers of review and approval were required before a
reprogramming proposal could be forwarded to Congress. These layers
contributed to the time it took to process a reprogramming proposal.
INS officials said that before proceeding with a reprogramming proposal in
fiscal year 1995, INS managers decided that they needed data on the
aftermath of the 245(i) and proposition 187 legislation. INS officials said
that the agency decided to wait until 3 months of trend data on
applications were available before reacting to any increases in workload
demands. INS officials said that they took this approach because they
wanted to be certain that the increases in workload trends were not a
temporary surge in response to the passage of the new legislation.
Examinations fees collected in the first 2 months of fiscal year 1995
increased substantially and exceeded expectations. INS officials said they
assumed this increase was a temporary reaction in response to the new
legislation and not a trend that would continue. However, after the results
from the third month in the first quarter showed a continuing increase in
fees, INS officials determined it was not a short-term rush but a growing
demand that would require additional resources. Once a decision was
made to proceed in January 1995, officials said that internal discussions
5
Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies 1995
Appropriations and 1994 Supplemental Appropriations, P.L. 103-317; H.R. Rep. No. 103-708, 103d
Cong., 2d Sess at 35 (1994).
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were held to decide whether additional resources should be for permanent
or temporary personnel, given that the 245(i) amendment would expire in
October 1997. This discussion and development of the resource needs,
along with other internal reviews of reprogramming documents by INS
budget officials, EACs and their staffs, the Office of the General Counsel,
the Deputy Commissioner, and the Commissioner, took about 2 months.
External layers of review and approval also contributed to the amount of
time it took to obtain congressional response to the reprogramming
proposal. Justice and OMB reviewed the proposal before it was submitted
to Congress. Because INS waited 3 months before starting to draft the
reprogramming proposal and then the internal development and external
reviews took another 4 months, a reprogramming proposal was not
submitted to Congress until April 1995. Figure 3.1 shows the timeline of
key activities for INS’ reprogramming of funds in fiscal year 1995 to
respond to increasing adjudication workload demands.
Figure 3.1 Timeline of Key Activities
for INS’ Fiscal Year 1995 Year Month Activity
Reprogramming
1994 October 1- INS collected information on receipts from applications to adjust status
December 31 and naturalization petitions.
December An INS fee analysis group met to decide what to do in response to
increasing workload demands and to make projections of future
revenue receipts.
1995 January- Documentation requesting additional spending authority was prepared
March and reviewed internally.
March 3 Request for additional spending authority was forwarded to Justice for
approval.
March 3-28 Justice added an $11 million request for Community Relations Services
to carry out Operation Safe Haven to assist Cubans and Haitians.
March 28 Justice forwarded the request to Office of Management and Budget.
March 28- Office of Management and Budget reviewed, approved, and returned
April 11 request to Justice.
April 13 Justice forwarded request to Congress for House and
Senate review.
April 13- Congressional review period and communication with INS about use
June 6 of additional funds.
June 7 Congress responded in writing with formal approval and a few
modifications.
(Figure notes on next page)
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Source: Justice, INS, and OMB officials.
Average Wait Times for The time spent in the preparation and review of the fiscal year 1995
Adjudication Applications reprogramming proposal contributed to an increase in average projected
Grew During Fiscal Year waiting times for processing certain adjudication applications. For fiscal
year 1995, INS’ self-designated acceptable time for processing all I-485
1995 adjustment-of-status and N-400 naturalization applications was 4 months.6
Our analysis of applicant waiting times revealed that the average projected
agencywide waiting time for processing adjustment-of-status applications
during fiscal year 1995 grew from about 5 months as of September 30,
1994, to about 10 months as of September 30, 1995. The average projected
waiting time for the processing of naturalization applications grew from
about 8 months to about 17 months.
At the beginning of fiscal year 1995, 8 of the 33 INS districts exceeded INS’
acceptable processing time of 4 months by 1 month or more for
adjustment-of-status applications. At the end of fiscal year 1995, 18 of the
33 INS districts exceeded INS’ acceptable processing time of 6 months by 1
month or more. Twenty-one of the 33 INS districts exceeded the acceptable
processing time for processing naturalization applications by 1 month or
more at the beginning of the fiscal year compared to 26 of the 33 INS
districts at the end of the fiscal year.
During fiscal year 1995, average projected wait times for
adjustment-of-status applications more than doubled in 19 of the 33 INS
districts, as shown in table 3.2. In the Harlingen, Texas, District Office,
average projected wait times increased from an average of 27 months to an
average of 53 months.7 Average projected wait times for naturalization
applications more than doubled in 11 of the 33 districts. The average
projected wait time for naturalization in the Chicago District Office
increased from an average of 8 months to an average of 40 months and in
Miami from an average of 9 months to an average of 49 months.
6
INS set a priority for fiscal year 1996 to complete the processing of naturalization applications within
6 months and, in September 1996, revised the adjustment-of-status goal to 5 months.
7
The average projected wait times for adjustment-of-status applications for the Harlingen district
appear anomalous. We do not know if these wait times are correct or are due to an error.
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Table 3.2: Average Projected Wait Times for INS Processing of I-485 Adjustment-of-Status and N-400 Naturalization
Applications at the Start and End of Fiscal Year 1995
I-485 Applications to adjust status N-400 Naturalization applications
Average projected Average projected
wait time (in months) wait time (in months)
As of As of As of As of
INS District Offices September 30, 1994 September 30, 1995 September 30, 1994 September 30, 1995
Servicewide 4.5 9.5 8.2 17.3
Eastern region districts
Atlanta 1.6 5.1 5.1 7.7
Baltimore 9.7 1.6 3.9 6.8
Boston 2.2 7.6 2.8 7.9
Buffalo 2.3 2.2 5.6 4.5
Cleveland 1.2 4.3 3.7 9.9
Detroit 1.8 3.5 5.7 13.0
Miami 6.7 9.0 8.6 48.6
Newark 5.6 19.6 2.5 8.9
New Orleans 2.2 9.7 7.5 4.0
New York City 8.6 18.5 4.8 23.7
Philadelphia 1.7 4.7 6.1 5.4
Portland, Maine 2.1 1.6 10.3 1.5
San Juan, Puerto Rico 2.7 9.6 6.2 16.6
Washington, D.C. 4.1 7.9 3.5 6.5
Central region districts
Chicago 3.3 2.7 7.9 39.7
Dallas 2.4 4.2 12.7 11.0
Denver 2.2 3.6 3.9 5.2
El Paso 1.7 9.3 6.6 9.4
Harlingen, Texasa 26.5 52.8 11.9 11.2
Helena 6.8 3.8 5.6 3.9
Houston 4.7 16.8 8.6 16.0
Kansas City, Missouri 3.0 2.0 5.1 4.2
Omaha 1.8 7.3 1.5 10.2
San Antonio 3.5 11.8 4.6 5.4
St. Paul .1 .6 2.6 3.8
Western region districts
Anchorage 4.9 3.7 3.2 4.8
Honolulu 4.0 4.3 5.7 7.3
Los Angeles 9.7 19.6 12.6 26.3
Phoenix 6.1 12.9 9.7 10.5
(continued)
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I-485 Applications to adjust status N-400 Naturalization applications
Average projected Average projected
wait time (in months) wait time (in months)
As of As of As of As of
INS District Offices September 30, 1994 September 30, 1995 September 30, 1994 September 30, 1995
Portland, Oregon 0.5 10.1 4.1 9.5
San Diego 3.2 12.6 13.7 7.5
San Francisco 2.8 10.2 18.2 21.5
Seattle 2.0 4.4 9.2 7.4
Note: INS computed the processing wait times by dividing the number of applications pending at
month’s end by the number of applications completed for the month and multiplying by the
number of calendar days in the month. This method computes how long it would take to complete
all cases pending at the end of the month if the rate of completions remained constant.
a
The average projected wait times for adjustment-of-status applications for the Harlingen district
appear anomalous. We do not know if these wait times are correct or are due to an error.
Source: INS data.
INS officials attributed delays in the processing of adjudication applications
to the lack of authority to spend funds to hire additional personnel to
address increased workload demands.
INS Submitted Fiscal Year For fiscal year 1996, INS began drafting a reprogramming proposal in
1996 Reprogramming August 1995. The reprogramming proposal was submitted to the Justice
Proposal to Congress Department in September 1995, to OMB in October 1995, and to Congress in
November 1995. Congress responded in January 1996. The reprogramming
Earlier in the Fiscal Year provided additional spending authority for the Examinations Fee Account
to expedite the processing of naturalization applications and 245(i)
applications and to expand direct mail services and cover mandatory
expenses. An INS budget official said that this reprogramming action was
less complex than that of fiscal year 1995.
The fiscal year 1995 reprogramming was more complex because it
included several proposed actions within different sources of funds. INS’
fiscal year 1995 reprogramming proposed actions within its Examinations
Fee Account, Legalization Account, and VCRTF. It sought increased
resources for processing naturalization applications and
adjustment-of-status applications under the section 245(i) amendment;
disseminating information on the naturalization process; staffing and
contract support for Ask Immigration, which is INS’ public information
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system; supplementing operational and support components; and
increasing positions for the Institutional Hearing Program.
INS continued to experience problems in fiscal year 1995 with monitoring
Monitoring of Budget its budgetary resources because of inaccurate and incomplete data in its
Resources Suffered financial management system and inconsistencies in data available to and
From Inadequate Data provided by headquarters and field units. For example, INS experienced
problems monitoring its resources because the Budget Office did not have
the information it needed on commitments made by field units, staff
attrition, and hiring plans.
Long-standing Problems A financial management system is to integrate accounting, budget,
With INS’ Financial personnel, and procurement systems, as well as other information
Management System systems.8 Inaccurate financial data; an unreliable and antiquated financial
management system; and insufficient internal controls over allocation,
obligation, and expenditure of funds have made it difficult for managers in
INS headquarters to readily determine the financial status of INS’ field units.
These serious financial management problems are not new at INS. They
have long affected INS’ ability to effectively manage and accurately report
the results of its program and administrative operations. The Department
of Justice’s Office of the Inspector General and Justice Management
Division (JMD) and we have issued several reports on the serious
weaknesses in INS’ internal controls and accounting system.
In 1991, we reported that INS’ primary accounting system —Financial
Accounting and Control System (FACS) —was outmoded and had weak
internal controls.9 These 1991 reports stated that weaknesses had existed
for many years and would require a commitment by INS leadership across
succeeding administrations to correct. We reported again in 1993 and 1995
about these problems.10
Furthermore, JMD assessments of problems identified with FACS in fiscal
years 1993, 1994, and 1995 revealed that actions had not been taken to
8
Framework for Federal Financial Management Systems, Joint Financial Management Improvement
Program (FFMSR-O, Jan. 1995).
9
Financial Management: INS Lacks Accountability and Controls Over Its Resources (GAO/AFMD-91-20,
Jan. 24, 1991); and Immigration Management: Strong Leadership and Management Reforms Needed to
Address Serious Problems (GAO/GGD-91-28, Jan. 23, 1991).
10
Immigration Issues: Making Needed Policy and Management Decisions on Immigration Issues
(GAO/T-GGD-93-18, Mar. 30, 1993); and INS: Update of Management Problems and Program Issues
(GAO/T-GGD-95-82, Feb. 8, 1995).
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address recommended improvements. Specifically, the JMD audits
concluded that FACS (1) lacked reliable information, (2) failed to comply
with administrative policies and procedures in regard to funds control, and
(3) contained significant weaknesses in internal controls over payments
and obligations. Managers within INS also perceived the need for
improvements in financial management. Seventy-two percent of the
respondents to our 1995 survey on INS management issues said that
servicewide improvements were needed to a great or very great extent in
INS’ financial management. The INS Commissioner told us that in the past,
INS was required to use Justice’s financial management information system
because Justice wanted all of its components on the same system. She said
that INS has always maintained that the Justice system would not meet INS’
management needs. In the spring of 1994, Justice reached an agreement
with INS that enabled the agency to develop its own financial management
system. However, INS did not receive funding to pursue a new financial
system until May 1995.
Since fiscal year 1992, quarterly financial reports have generally been
prepared for INS nationwide, encompassing every program and field office.
INS quarterly reports are intended to enable INS managers to better monitor
expenditures and availability of funds, make accurate end-of-year financial
projections of obligations, and allow for the timely preparation of requests
for changes in spending authority. Further, these quarterly reports are to
provide managers with the information that INS believes is necessary to
detect and address potential problems in a timely manner by comparing
budget allocations with obligations and projected spending. In addition, in
November 1994, INS appointed the EAC for Management as its Chief
Financial Officer, responsible for overseeing all of INS’ financial
management activities. The Chief Financial Officer’s responsibilities
include, among other things, overseeing the integration of budgeting and
accounting information; the preparation of financial statements; and the
production of complete, reliable, timely, and consistent financial
information.
Data From INS’ Financial During our review of INS’ fiscal year 1995 budget execution process, we
Accounting and Control found that adequate financial information was neither readily available nor
System Continued to Be being maintained in INS’ FACS. Consequently, INS budget officials and
managers did not have the requisite information in FACS to determine the
Inadequate amount of funds available in specific INS units or to prepare accurate
financial status reports. Consistent with what we found in 1991, INS’
financial accounting system in fiscal year 1995 still failed to provide INS
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managers with the financial management information they needed to
adequately control funds and evaluate program operations in an efficient
manner.
The information in FACS did not provide management with accurate and
complete financial information on its program and administrative
operations. Also, because much of the financial information that FACS
produced was not a correct reflection of the financial status of INS field
units, it was unreliable. In addition, INS’ financial management system did
not adequately integrate information that INS managers needed, such as
information on commitment of funds, attrition of staff, and hiring plans in
the field. For example, FACS had generally maintained data on commitment
of funds only at the INS headquarters level, which did not provide
headquarters or regional managers with detailed information on the
commitment of funds at specific INS field units. Commitments had
generally been tracked directly by the individual INS field locations.
INS Did Not Have FACS was not able to provide accurate data to INS managers on the financial
Complete Financial and status of each field unit. Also, the Office of Budget in headquarters did not
Personnel Information have ready access to personnel data that would have enabled it to identify
current and planned staffing levels in INS field units. To obtain the
Needed to Manage Its necessary accounting and personnel information for an accurate picture of
Budget Execution the financial status of its field units, managers in INS headquarters had to
rely on information obtained from each of INS’ 33 districts and 21 sectors.
For example, the Office of Field Operations, which is responsible for
managing resources in INS field units, had to obtain information on, among
other things, attrition of personnel, commitment of funds, and hiring plans
from INS’ 33 districts and 21 sectors to be able to project what funds would
be available for reallocation during quarterly financial reviews for fiscal
year 1995. In fiscal year 1995, the allocation and management of PS&B
funds, including information on financial commitments and vacant
positions associated with these funds, were being maintained at the
district and sector levels. Accurate information on spending in PS&B funds
in INS field units was not consistently available to managers at INS
headquarters or being readily maintained in INS’ financial accounting
system.
Inconsistencies Existed in Inconsistencies in the financial data being used by INS managers in
the Data Provided by INS headquarters and in the field resulted in very different projections of the
Resource Managers financial status of the various INS units. During fiscal year 1995, field unit
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projections of funds expected to be used and funds available to reallocate
differed significantly from initial projections that the Office of Budget had
developed from data in INS’ financial accounting system.
For example, relying on FACS data as of March 31, 1995, the Office of
Budget projected that the field would have about $115 million in surplus
funds through the end of the fiscal year.11 This was a baseline projection
that the Office of Budget used as a starting point to obtain input from the
field offices on the status of finances as part of the normal financial review
process. Subsequently, the Office of Field Operations, relying on data
provided by the INS regional offices and the 33 districts and 21 sectors,
projected that the INS field units would experience a $5 million shortfall in
funding for the remainder of fiscal year 1995.
Managers in INS headquarters and field units said that they spent a great
deal of time attempting to reconcile the $120 million difference in fiscal
year 1995 projections. Ultimately, the Office of Budget based and revised
its initial mid-year estimate on data provided by INS field units. After
incorporating field data on attrition of staff, commitment of funds, and
hiring plans, and reconciling other differences, the Office of Budget
indicated in its Prospective Financial Status report for the period ending
March 31, 1995, that about $25 million in surplus funds would be available
to Field Operations through the remainder of the fiscal year. This was
about $90 million less than the Office of Budget’s initial estimate of
$115 million in surplus funds.
Office of Budget officials said that the process of determining the financial
status of INS units was impeded by several factors. These officials said that
the following factors contributed to the problems:
• various officials responsible for collecting information to be used in the
financial reports used different data sources,
• various officials responsible for reporting financial data did not
consistently use formats that the budget office provided, and
• data provided by the field had errors.
11
INS uses the term surplus funds to refer to funds that were not used during the fiscal year for PS&B
and therefore become available for other purposes.
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INS Has Taken Interim INS has acknowledged that FACS is old and labor-intensive and has had
Steps Until New difficulty accounting for and controlling its resources in an accurate and
Accounting System Is timely manner. To work toward having more complete, accurate, and
useful information, in October 1996, INS decided to use a competitive
Available selection process to acquire a new financial management system through
an interagency agreement with a federal agency that could best meet its
user needs. The Office of Management and Budget endorses the use of
cross-servicing with other federal agencies as a cost effective and efficient
way to obtain services. In January 1997, a letter of interest and a
solicitation to acquire a system were sent to the Treasury Department, the
Commerce Department, and the Department of the Interior’s U.S.
Geological Survey. INS had identified these agencies as having the potential
for meeting its needs. Proposals were to be provided to INS by January 31,
1997; however, as of the beginning of February 1997, INS had one proposal
that it was evaluating and was negotiating an extension for proposals from
another agency. INS evaluated the proposals during February and
March 1997 and selected a vendor on March 31. INS’ solicitation for a
financial management system specified that the agency expected to have a
core financial management system implemented by October 1, 1997, to
meet the deadline agreed upon with the Department of Justice.
In the meantime, INS officials said that starting with the first quarter of
fiscal year 1996, PS&B resources were allocated and managed at the
regional level instead of at the district and sector levels. This change was
undertaken to alleviate, among other things, the need to collect
information from the 33 districts and 21 sectors. As previously presented,
INS developed a table of organization, which provided information to field
units and headquarters’ managers on authorized funded staffing levels.
This document was intended to help INS managers better monitor and
control personnel resources in the various INS units. According to an INS
official, the tables of organization data were manually compared to
on-board staffing level data to derive vacancy levels by office and major
occupations. This manual reconciliation process is a temporary measure,
which is to be eventually automated through implementation of a new
Position Tracking System (POSTS).
INS’implementation of the new Position Tracking System is to address the
lack of information on current staffing levels, staff attrition, vacancies, and
hiring plans. POSTS is to contain both the tables of organization control data
and data on occupied positions. When fully operational, POSTS is to provide
INS managers with an up-to-date summary of filled and vacant positions.
Additionally, POSTS is to interface with the new Hiring Tracking System
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(HITS) to provide INS managers with, among other things, an account by
location of all vacancies in INS. Neither of these systems was sufficiently
implemented as of April 1997 to provide useful data to support the
activities of the Office of Budget, but INS expects the systems to be
available throughout the agency by the end of fiscal year 1997.
Concerning inconsistencies in the data provided by the various INS units,
little was done to correct the problem until the beginning of fiscal year
1996. At that time, INS officials in the Office of Budget, Office of Field
Operations, and other INS units began working together to establish
mutually agreed-upon data sources and time frames and to develop
consistent and reliable reporting mechanisms to be used for the first
quarterly financial review of fiscal year 1996. On the basis of lessons
learned from prior financial reviews, a revised financial review process
and policy was developed with the intent to, among other things:
• ensure that all organizational components are using the same financial
data for review, projections, and adjustments;
• guarantee that all organizational components utilize the same automated
tools, algorithms, and methodologies to perform analyses and adjustments
to projections, thereby providing consistency and confidence in the
results, particularly the determination of available surplus funds; and
• maximize the effectiveness of planning the use of resources by utilizing
not only actual to-date surplus funds, but also projected surplus.
In April 1996, INS contracted with the National Academy of Public
INS Contracted for Administration (NAPA) to assist it with developing a framework to change
Assistance to its budget and financial management process and execution. INS stated in
Strengthen Its Budget the contract that it had taken steps to address problems in the budget and
financial management areas, but it believed it needed to further clarify and
Process and Improve strengthen the budget process at all levels of the organization. NAPA’s
Its Financial January 1997 report12 made 40 recommendations related to such issues as
budget account structure, budget formulation, budget execution, and
Management System organizational issues affecting budgeting. In addition, as part of the
process of developing recommendations to clarify and strengthen the INS
budget process at all levels of the organization, the NAPA project included
an analysis of how the INS budget process connected to the financial
management system and agency efforts to develop a new core financial
management information system.
12
Report by a Panel of the National Academy of Public Administration for the Immigration and
Naturalization Service, Budgeting for Performance: Strategy, Flexibility, and Accountability to Meet a
Demanding Mission, January 1997.
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The NAPA report raised concerns regarding (1) the quality of systems
requirements that INS developed; (2) the need to analyze and document
current “as is” business processes and develop targeted “to be” processes;
and (3) the need for systems integration analyses, among other things.
According to the NAPA report, INS’ acquisition of a new core financial
management information system will not resolve the long-standing
deficiencies in the agency’s financial management system because the root
cause of its problems lies in the domain of INS’ business processes and
procedures. The report stated that although a new financial information
system is needed, improvements in agency processes and procedures must
come first. NAPA also reported that various offices within INS were engaged
in activities that could be construed as process analysis activities, but
these activities were independent and were not part of an overall
systematic process improvement strategy, plan, and program. In a briefing
to the Justice Department in January 1997 on NAPA’s findings and
recommendations, INS recognized the need to address major process
problems and provided information on activities that it had undertaken
through its contract with a financial management consultant to identify
requirements and begin prioritizing options for business process
reengineering. However, NAPA questioned the quality of INS’ planning
efforts and was concerned about INS’ expectation to implement a new
financial system by October 1, 1997. According to an INS official, as of
January 1997, the agency was committed to implementing a new system by
October 1, 1997, because it wanted to meet the agreed-upon deadline
established with the Justice Department and because problems have been
long-standing, and the agency wanted to show that it is making progress
toward addressing them.
In July 1996, INS contracted with a financial management consultant to
(1) assist it with reviewing and revising processes and procedures in
anticipation of converting to a new financial system and (2) review
requirements for selected functional areas of the system to optimize
process improvements to be derived from the new system. INS’ financial
management consultant also suggested to INS that it should first define
business processes and clarify functional requirements before selecting a
new system. Specifically, the consultant stated that its experience and best
practices model incorporated the concept of defining and improving
business processes as an antecedent to the selection and use of
technology and software. The consultant made several recommendations,
one of which was for INS to establish a risk management plan to allow for
timely management action so that quality, schedule, and cost objectives
are achieved. Both NAPA and INS’ consultant raised concerns about the
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adequacy of INS’ planning efforts to acquire its new system and the
feasibility of implementing a core financial management system by
October 1, 1997.
Our previous and current work highlights how important it is for INS to
address the issues raised by NAPA and the consultant. Our May 1994 guide,13
which identified information and technology management best practices,
described how information systems initiatives must be focused on process
improvement and guided by an organizational architecture.14 The guide
also stated that information systems projects that do not focus on process
improvement typically fail or reach only a fraction of their potential. Our
February 1997 guide,15 which provides a structure for evaluating and
assessing how well a federal agency is selecting and managing its
information technology resources, stated that a key hazard in acquiring
information technology is that the new system will automate outmoded,
inefficient business processes. Another guide that we issued in April 199716
stated that technology is an enabler of process reengineering, not a
substitute for it. This guide also stated that acquiring technology in the
belief that its mere presence will somehow lead to process innovation is a
root cause of bad investments in information systems. The Clinger-Cohen
Act of 199617 requires executive agencies to conduct analyses of work
processes before making significant investments in information
technology. The act sought to remedy the dilemma of using technology to
correct process problems by insisting that process redesign drive the
acquisition of information technology, and not the other way around.
Thus, an assessment of current processes (process mapping, baselining,
benchmarking) should be completed before a decision is made about
acquiring technology.
Since fiscal year 1995, some, but not all, program areas used WAMs and
Conclusions workload information in deciding how to deploy resources. INS contracted
13
Executive Guide: Improving Mission Performance Through Strategic Information Management and
Technology; Learning From Leading Organizations (GAO/AIMD-94-115, May 1994).
14
Architectures explicitly define common standards and rules for both data and technology, as well as
mapping key processes and information flows.
15
Assessing Risks and Returns: A Guide for Evaluating Federal Agencies’ IT Investment
Decision-making (GAO/AIMD-10.1.13, February 1997 Version 1).
16
Business Process Reengineering Assessment Guide (GAO/AIMD-10.1.15, April 1997 Version 3).
17
The Omnibus Consolidated Appropriations Act of 1997 renames both the Federal Acquisition Reform
Act of 1996 and the Information Technology Management Reform Act of 1996 as the “Clinger-Cohen
Act of 1996.”
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with a consultant to develop a software program that would be compatible
with existing staffing models and that is intended to move INS toward
better deployment planning. In general, we believe that the use of WAMs
can help INS make resource allocation decisions, because INS will be able to
consider different factors and changing scenarios. Thus, we support INS’
initiative to develop WAMs and use models to improve resource allocation
planning.
INS has been taking steps to address the weaknesses in its financial
management system that have adversely affected financial reporting and
management at all levels and that hampered INS’ ability to prepare accurate
quarterly financial management reports in fiscal year 1995. The
improvements made during fiscal year 1996 address some of the
weaknesses associated with INS not having consistent and readily available
data but will not remedy the problems. INS selected a new financial
management system. Ultimately, the new system is intended to provide
consistent and reliable data, integrate information from other systems, and
produce accurate and complete information on commitment of funds,
attrition of staff, and hiring plans in the field. However, NAPA and INS’
financial consultant recommended that INS define its current business
processes and define its desired business processes before acquiring a
new system. Our guides on information management and the
Clinger-Cohen Act also endorse these practices. Problems with the
accuracy, completeness, and consistency of data that we identify in this
chapter are process issues, not technology issues. INS did not perform a
comprehensive analysis of its financial management processes before
selecting a new financial management system; therefore, the new financial
management system may not address process problems. As a result, INS
has incurred a risk that the system may not meet its financial management
requirements.
We recommend that the Commissioner of INS take the following actions:
Recommendations
• Develop a strategy and schedule for periodically evaluating the new
deployment planning process to help ensure that it is compatible with INS’
key planning processes and provides information needed by managers to
adequately plan for resource needs and make resource decisions.
• Take steps to mitigate the risks associated with INS’ planned approach for
acquiring a new financial management system. Such steps should include
fully implementing plans to analyze its current financial management
processes and determining future financial management process needs,
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finalizing a comprehensive implementation plan, and fully developing and
implementing a risk management plan.
INS provided written comments on a draft of this report, which are printed
Agency Comments in full in appendix VI. INS also provided technical comments separately,
and Our Evaluation which we incorporated where appropriate. INS agreed with our
recommendation that it should evaluate its improvements to the
deployment planning process to help ensure that the agency’s information
needs are being met.
On the issue of INS’ plans for implementing a new financial management
system, INS stated that we failed to recognize its urgent need for a
replacement financial system. To the contrary, we have long recognized
this need. We believe our report and many past reports by us and others
fully recognize the problems in INS’ financial management systems and the
need to replace them. Thus, our primary focus in this report was on
expressing our concerns about INS’ plans for implementing a new system.
In this regard, INS disagreed with a recommendation in our draft report
that it analyze financial management processes prior to acquiring a new
financial management system and stated that it thought we relied too
much on the NAPA findings and did not follow up appropriately with
additional field work on the steps INS had taken after the NAPA report was
issued. We disagree that we relied primarily on the NAPA findings. Although
our report discusses the NAPA findings as they related to INS’ efforts to
acquire a new system, our recommendation was based in addition on our
analysis of agency documents, INS consultant reports, and our long history
of work on the implementation of major new information technology
systems. For example, our May 1994 guide, which we used in assessing INS’
approach, stated that information systems projects that do not focus on
process improvements typically fail or reach only a fraction of their
potential. To better clarify the basis for our observations, we have added
some information to the report about our previous work in this area.
Although we continued to discuss these and other matters in this report
with INS as the report was being developed and reviewed, we wanted to be
sure that we had fully considered all of the most recent developments in
its plans for a new financial system that were raised by INS in its comment
letter. Accordingly, we met with the Assistant Commissioner for the Office
of Financial Management and other finance officials in May 1997 to
discuss actions that INS plans to take to mitigate the risks associated with
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implementing its new financial management system. In addition to
establishing an Executive Steering Committee and obtaining the
contractual support described in INS’ comments, these officials told us that
they were working with or preparing to work with consultants on
(1) analyzing INS’ financial management processes, (2) developing a
comprehensive implementation plan that would include how the system is
to be evaluated, and (3) developing a risk management plan. They also
stated that the entire system will not be in place by October 1, 1997, as
originally intended; rather, core functions will be implemented and tested
at some, but not all, locations.
In the time since our audit work was largely completed, INS’ strategy for
implementing a new financial management system has evolved further,
and INS is currently taking steps to plan for a phased implementation and
other actions that should help to mitigate the risks we observed. These
actions, if carried out effectively, are more consistent with the approach
that our work in this area has indicated would mitigate risk. For that
reason, we have revised our recommendation to focus more on actions the
Commissioner needs to take to fully develop and implement the plans that
were discussed with us in concept.
Page 85 GAO/GGD-97-132 INS Management Problems
Appendix I
Roles and Responsibilities for the Offices of
the Executive Associate Commissioners and
Regional Directors for Field Operations
• Serve as principal advisor to the Commissioner and Deputy Commissioner
Executive Associate on matters of policy and planning.
Commissioner, Office • Formulate, review, integrate, codify, and disseminate national INS policy.
of Policy and Planning • Serve as a clearinghouse for the coordination and dissemination of
program-specific policy, regulations, guidelines, and directives.
• Develop strategic plans, annual priorities, and statistical data.
• Research and develop cross-program initiatives.
• Establish an administration position on broader-than-INS immigration
policy questions and examine broad policy questions.
• Analyze new legislative proposals and regulatory and procedural changes.
• Perform organizational analysis to assist in the allocation of resources,
identify structural deficiencies, and avoid duplication of functions.
• Implement governmentwide initiatives, such as quality management and
the Vice President’s National Performance Review.
• Provide high-quality agencywide statistical information for use in
decisionmaking.
• Improve and expand technology assessment and research.
• Participate with the Executive Staff in the budget formulation and
execution processes.
• Serve as principal advisor to the Commissioner and the Deputy
Executive Associate Commissioner on field operations.
Commissioner, Office • Plan, direct, and manage field operations through the three regional
of Field Operations directors and the Director, International Affairs.
• Provide general guidance and supervision to the regional directors and the
Director, International Affairs.
• Ensure that the annual operating plans of the regional directors and the
Director, International Affairs, are developed in accordance with the
Commissioner’s priorities.
• Allocate resources to the regional directors and the Director, International
Affairs.
• Authorize the transfer of resources that cross regional boundaries.
• Monitor the implementation of approved plans by the regional directors
and the Director, International Affairs.
• Recommend INS policies in areas related to field operations.
• Respond to field office needs and provide a single point of contact at
headquarters for field issues.
• Ensure policy consistency and program effectiveness in the work of the
districts and sectors.
Page 86 GAO/GGD-97-132 INS Management Problems
Appendix I
Roles and Responsibilities for the Offices of
the Executive Associate Commissioners and
Regional Directors for Field Operations
• Represent the Commissioner with other agencies, Members of Congress,
interest groups, law enforcement officials, and the general public in
matters related to field operations.
• Serve as action officer on projects or special activities requiring executive
direction and high-profile leadership.
• Participate with the Executive Staff in the budget formulation and
execution processes.
• Serve as the principal advisor to the Commissioner, Deputy
Executive Associate Commissioner, and the Executive Associate Commissioner for Field
Commissioner, Office Operations on enforcement and examinations program resources.
of Programs • Strengthen INS policy and planning capabilities by providing a cohesive
framework for enforcement and examinations to function as integrated
elements of INS.
• Establish a programmatic structure that will empower program managers
to develop program plans that anticipate demands on the agency, build
communications capabilities, and concentrate on program integration.
• Develop INS program policy and ensure policy consistency and program
effectiveness in the work of INS’ districts and sectors.
• Provide general guidance and supervision to the Associate Commissioners
for Enforcement and Examinations.
• Ensure that program objectives are developed in accordance with the
Commissioner’s priorities.
• Represent the Commissioner and Deputy Commissioner with other
agencies, Members of Congress, interest groups, law enforcement officials,
and the general public in matters related to INS program policy.
• Participate with the Executive Staff in the budget formulation and
execution processes.
• Serve as the principal advisor to the Commissioner and INS management
Executive Associate on financial, human resources, administrative, and information resource
Commissioner, Office management issues.
of Management • Manage all INS management support services at headquarters, regions, and
field locations.
• Develop policies related to all administrative functions.
• Serve as action officer on projects or special activities requiring executive
direction and high-profile leadership.
• Direct personnel management, facilities development, procurement, and
other administrative functions through the Associate Commissioner,
Human Resources and Administration.
Page 87 GAO/GGD-97-132 INS Management Problems
Appendix I
Roles and Responsibilities for the Offices of
the Executive Associate Commissioners and
Regional Directors for Field Operations
• Direct the affirmative employment and discrimination complaints
programs through the Director, Equal Employment Opportunity.
• Direct budget, finance, and resource management through the Associate
Commissioner, Financial Management.
• Direct data systems and systems integration through the Associate
Commissioner, Information Resource Management.
• Direct regional management and administrative activities through the
regional administrators.
• Direct all security and suitability activities through the Director, Security.
• Develop policies for the records program and Freedom of Information Act
through the Director, Files and Forms Management.
• Plan, direct, and manage field operations in their respective regional areas.
Regional Director, • Provide general guidance and supervision to district directors and Border
Regional Offices for Patrol’s chief Patrol agents.
Field Operations • Develop and recommend annual operating plans for the region.
• Allocate and manage resources within the region.
• Monitor the districts’ and sectors’ implementation of approved plans.
• Serve as the Commissioner’s spokesperson in the geographic area.
• Participate in the budget formulation and execution processes for the
region.
Note: These are INS’ definitions of the roles and responsibilities.
Page 88 GAO/GGD-97-132 INS Management Problems
Appendix II
Objective, Scope, and Methodology
The objective of this review was to follow up on our past INS management
report to determine whether INS had taken steps to correct some of the
most significant management problems identified. Specifically, we
reviewed whether INS had
• developed goals and priorities to guide planning and resource allocation;
• revised its organizational structure;
• improved internal communications and updated its field and
administrative manuals;
• improved the process of allocating budgetary resources;
• improved its capability to monitor its financial status; and
• generated accurate, complete, and consistent data to monitor budget
execution.
Because this review was limited in its scope, we did not investigate
whether INS had better defined the roles of the two key enforcement
divisions—Border Patrol and Investigations. Also, we did not examine
how much progress INS had made in addressing all the goals and objectives
of the reorganization or whether all the newly created offices had
accomplished their new missions. With respect to the process for notifying
Congress of the need for additional spending authority, we reviewed only
the Examinations Fee Account. This is the largest of the fee accounts, and
we wanted to determine if INS’ reprogramming process enabled it to
provide timely services to aliens applying for benefits such as
naturalization and adjustment-of-status.
We used a variety of techniques to determine whether INS had taken steps
to address management problems. To obtain an understanding of INS
management issues, we reviewed our prior management studies, INS
management studies by the Committee on Government Operations and the
National Academy of Public Administration, agency documents, budget
materials, congressional testimonies, and transcripts of congressional
hearings. The reorganization structure was put in place at the beginning of
fiscal year 1995, and our review was conducted during fiscal years 1995
and 1996. Information in this report is on the first year and a half of the
reorganization.
To obtain the perceptions of current INS management, we sent a survey to
3,676 career and appointed INS managers and senior staff. Survey
recipients included all INS managers and senior staff at or above the grade
13 level, as well as all other individuals designated as managers or
supervisors by INS at grades 11 and 12. All organizational units within INS
Page 89 GAO/GGD-97-132 INS Management Problems
Appendix II
Objective, Scope, and Methodology
were represented in our survey. The response rate for our targeted
population was 69 percent.1 Further details of the survey are presented in
appendix III.
We conducted interviews with the four Executive Associate
Commissioners (EACs); the three regional directors; assistant regional
directors, district office program managers, and Border Patrol chiefs in
Los Angeles, California; El Paso, Texas; and Buffalo, New York, locations
judgmentally selected with one from each of the regions; and other
headquarters and regional managers responsible for budget activities,
program planning, and operational activities to obtain more detailed
information than was obtained through the survey regarding the new
structure and the budget execution process during fiscal year 1995. We
also interviewed budget officials at the Justice Department and the Office
of Management and Budget (OMB) to obtain information on INS’ procedures
for proposing the reprogramming of funds from the Examinations Fee
Account. In addition, we conducted a joint interview with the INS
Commissioner and Deputy Commissioner to discuss management issues
related to the new organizational structure and budget execution during
fiscal year 1995.
To determine whether INS had developed goals and priorities, we reviewed
INS documents to determine whether INS had a mission statement, priority
goals, strategies to attain the goals, and performance measures. We also
used information from interviews and the survey data to ascertain
management support for and use of the priority goals. To determine
whether INS’ current organizational structure achieved its major
management goals, we reviewed INS documents articulating the purpose
and goals of the latest reorganization; and we interviewed top
headquarters officials, regional directors, and headquarters and field
managers concerning their perceptions of the reorganization. We also
obtained information on the reorganization through the survey. To
determine whether INS had updated its policy handbooks and manuals, we
interviewed managers at headquarters and in the field offices and used
survey data on managers’ perceptions of these and other communication
issues. We also reviewed policy documents and interviewed managers on
the status of efforts to update written communication through guidance
materials.
1
See appendix III sections “Problems with INS Mailing List” and “Survey Response Rate” for
clarification of this response rate.
Page 90 GAO/GGD-97-132 INS Management Problems
Appendix II
Objective, Scope, and Methodology
To determine whether INS had taken steps to improve its resource
allocation process, we collected and analyzed information on INS’ budget
development, budget execution, and financial review processes for fiscal
years 1994 through 1996. We also collected copies of workload models and
resource allocation plans that INS developed and used to assist in its
decisionmaking process. Our examination of INS’ use of workload
information was limited to determining which program areas had
workload analysis models or used workload information in planning
resource allocation needs and which ones did not. For program areas that
had workload models, we relied on interviews with program and budget
officials to determine if they used the information to allocate resources. To
assess the relationship between INS’ resource allocation process and its
management of alien applications, we examined INS’ process for obtaining
congressional approval for increased funding authority from the
Examinations Fee Account and how well the process worked during fiscal
years 1995 and 1996. To determine whether INS had complete and
consistent data to monitor budget execution, we reviewed budget
documents and financial status reports and interviewed resource
managers and budget officials.
Page 91 GAO/GGD-97-132 INS Management Problems
Appendix III
Survey Methodology
In an effort to obtain a broad spectrum of views on INS management issues,
Overview we developed and pretested a survey that included questions on the
relationship between headquarters and the field, organization changes,
communication, budget execution, and other management-related areas.
Our target population was all INS managers. For our survey, we defined a
“manager” as any INS employee at grade GS-13 or above as well as persons
designated by INS as managers or supervisors at grades GS-11 and 12. INS
provided us a list of employees who met our definition of manager.
To obtain managers’ candid opinions and insights about INS’ management,
we promised anonymity to the survey recipients. To ensure anonymity, no
identification numbers were included on the survey. A postcard containing
an identification number was included in the package sent to our target
population. The postcard was to be mailed back to us separately from the
survey. Receipt of the postcard allowed us to remove names from our
follow-up mailing list. In September 1995, we mailed the survey to 3,676 INS
employees whom INS told us were managers. In late October 1995, we sent
out a follow-up mailing containing another survey and postcard to those
who did not respond to our first mailing.
During the course of the survey, a number of INS employees who were
Problems With INS’ mailed surveys called or wrote to us indicating that they were not
Mailing List managers. This led us to ask INS whether the list of managers that it
provided us may have included persons who should not have been in our
target population. The results of this follow-up inquiry showed that we
sent surveys to 714 INS employees who were in grades GS-11 and 12 but
were not designated by INS as managers or supervisors. These individuals
should not have been sent surveys to complete.
In the course of our investigation, we also found that our mailing list did
not include a number of INS employees who should have been included in
our target population. We found that approximately 400 employees at
grade GS-13 and above who should have received surveys did not because
INS did not include them on the mailing list it provided us. One reason that
we were concerned about this omission is that if these employees were
located in one or a few locations, this could introduce a systematic bias
into our results. However, we were able to determine that these particular
employees were located throughout INS.
Page 92 GAO/GGD-97-132 INS Management Problems
Appendix III
Survey Methodology
Because we inadvertently mailed surveys to 714 grade GS-11 and 12
Survey Response nonmanagers, our survey response rate was adversely affected. This is
Rates because individuals receiving our management survey who were not
managers were much less likely to return the survey than were managers.
Because of this, we are providing two separate response rates for our
survey, one response rate for the managers who correctly received our
survey and another for the nonmanagers who incorrectly received our
survey. These response rates are shown in table III.1.
Table III.1: Survey Response Rates
Number of
Postcards returned Percent
INS employees indicating that a survey Response
receiving surveys was returned rate
INS managers
(correct target population) 2,962 2,034 69%
Grade 11 and 12 nonmanagers
(should not have received surveys) 714 295 41
a
Total 3,676 2,329
a
We actually received 2,321 completed surveys. This discrepancy may be due to the lack of a
perfect match between those who returned the survey and those who returned the postcard.
Source: GAO analysis.
From the postcards we received, the survey results used in this report
contain data from approximately 295 grade GS-11 and 12 nonmanagers
who completed and returned our survey. Therefore, responses received
from INS employees who should not have been in our survey population
represent about 13 percent of the data used throughout the report. We
were not able to remove these data from our database because the surveys
were anonymous and, therefore, did not contain any identifying
information about the respondents.
Throughout this report, the percentages presented do not include
Reporting Survey respondents who skipped a question. For some questions the percentages
Results presented do not include respondents who answered “no basis to judge.”
When this occurs, we indicated this in a footnote.
In general, when we report responses to five-point scales, we report the
combination of the percentages of respondents selecting the top two
response categories and the combination of the percentages of
Page 93 GAO/GGD-97-132 INS Management Problems
Appendix III
Survey Methodology
respondents selecting the bottom two response categories. Occasionally,
we deviate from this practice. When this occurs, we indicate this in a
footnote.
Respondents to our survey provided numerous written comments dealing
with management issues. We did not analyze all of the written comments
in a systematic manner. We used a number of these comments in our
report to illustrate some of the management issues discussed in the report.
The practical difficulties of conducting any survey may introduce errors,
Nonsampling Errors commonly referred to as nonsampling errors. For example, differences in
how a particular question is interpreted, in the sources of information that
were available to respondents, or in the types of people who did not
respond can introduce unwanted variability into the survey results. We
included steps in the development of the survey, the data collection, and
the data analysis for minimizing such nonsampling errors. These steps
include practices, such as extensive pretesting of the survey, procedures
to ensure that respondents remain anonymous, and the inclusion of
various edit checks in the analysis program.
Page 94 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
Page 95 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
I. Background Information 5. What position do you currently hold at INS?
(Include acting positions.) (Check one.)
1. To which of the following are you
currently assigned? (Check one.) n = 2,300
n=2,275 0.9% 1. Commissioner, Deputy
Commissioner, Executive
25% 1. Headquarters Associate Commissioner, or their
immediate staffs
25% 2. Eastern Region
2.3% 2. Regional Director, Deputy
24% 3. Central Region Regional Director, or their
immediate staffs
27% 4. Western Region
2.5% 3. District Director, Deputy District
Director, or their immediate staffs
2. Please indicate if you are assigned to any
of the following offices. (Check one.) 2.3% 4. Chief Patrol Agent, Deputy Chief
Patrol Agent, or their immediate
n=2,274 staffs
24% 1. Border Patrol Sector 1.2% 5. General, Regional, or District
Counsel
26% 2. District Office
0.1% 6. Associate Commissioner
3% 3. Service Center
0.7% 7. Assistant Commissioner
3% 4. Administrative Center
3.1% 8. Assistant District Director
5% 5. International Affairs/Asylum
Offices/Foreign Offices 2.3% 9. Assistant Chief Patrol Agent
39% 6. None of the above 14.7% 10. Second line supervisor (Port
Director, officer-in-charge, etc.)
3. How long have you been at this physical location? 43.4% 11. First line supervisor
Mean = 9 years 16.7% 12. Non-supervisory staff
_____ Years _____ Months
9.7% 13. Other - Please specify:
_________________
4. How long have you worked at INS?
Mean = 16 years
_____ Years _____ Months
2
Page 96 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
Page 97 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
Neither
Strongly agree nor Strongly No basis
agree Agree disagree Disagree disagree to judge
(1) (2) (3) (4) (5) (6)
a. My unit can recruit qualified employees
n =2,292 17% 38% 12% 16% 9% 8%
b. My unit can fill vacancies in a timely fashion
n =2,296 5% 16% 10% 30% 32% 8%
c. My unit can retain quality employees
n =2,265 9% 34% 15% 25% 13% 3%
d. My unit currently has adequate staff to
do its work n =2,290 3% 16% 6% 33% 42% 0.5%
e. Adequate funding for training is available for
my unit n =2,294 3% 22% 15% 31% 25% 4%
f. Adequate time for training is allocated for
those in my unit n =2,299 4% 25% 14% 32% 23% 1%
g. Staff in my work unit are provided the types
of training courses they need n =2,296 3% 24% 19% 34% 19% 1%
h. I am provided with the types of training
courses I need n =2,293 4% 28% 17% 33% 17% 0.7%
i. My unit plans for its future staffing needs
n =2,291 6% 32% 17% 22% 17% 6%
j. The staff in my unit have the needed skills to
do their jobs well n =2,301 10% 49% 18% 17% 6% 1%
k. My unit currently has adequate clerical staff
to do its work n =2,301 3% 18% 8% 30% 40% 2%
8. In general, how clear or unclear to you are the following? (Check one box in each row.)
Very Somewhat Somewhat Very
clear clear unclear unclear
(1) (2) (3) (4)
a. Your current duties and responsibilities
n =2,303 59% 28% 8% 4%
b. Your unit's goals and objectives
n =2,304 47% 32% 14% 7%
c. INS' priorities
n =2,306 26% 35% 24% 15%
d. INS' overall mission
n =2,306 31% 35% 20% 14%
Page 98 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
9. In your opinion, how positive or negative an impact, if any, have the following factors had on morale at INS?
(Check one box in each row.)
Very Positive No Negative Very No basis
positive impact negative to judge
(1) (2) (3) (4) (5) (6)
a. Leadership provided by top management at INS
n =2,297 3% 19% 16% 35% 26% 2%
b. Operational/program funding levels n =2,296 2% 20% 11% 37% 23% 7%
c. Communications between Headquarters
and the regions n =2,305 1% 10% 15% 27% 14% 34%
d. Communications between Headquarters and
administrative centers n =2,307 0.3% 6% 14% 15% 8% 56%
e. Communications between the regional offices
and the administrative centers n =2,307 1% 8% 15% 12% 6% 59%
f. Communications between regional offices
and the districts/sectors n =2,307 3% 23% 16% 19% 7% 33%
g. Level of cooperation among units at INS
n =2,293 3% 29% 13% 37% 15% 3%
h. Availability of training/development opportunities
n =2,302 2% 21% 16% 43% 14% 4%
i. Physical work environment (office space,
facilities, outdoor work, etc.) n =2,312 6% 29% 14% 32% 19% 1%
j. Availability/quality of equipment
(computers, cars, etc.) n =2,308 6% 36% 8% 33% 17% 1%
k. Amount of time required for duties
unrelated to primary work n =2,302 1% 12% 27% 39% 17% 4%
l. Staffing level n =2,292 2% 14% 12% 41% 29% 3%
m. Anything else - Please specify: _____________
n =537 2% 2% 2% 21% 70% 5%
10. Currently, how would you characterize the general level of morale in your unit? (Check one.)
n=2,238
1. Very high 3%
2. Fairly high 21%
3. Neither high nor low 25%
4. Fairly low 31%
5. Very low 19%
------------------
6. No basis to judge 0%
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III. Budget
11. Thinking about the budgeting and financial management process in INS as a whole and in your unit, would you
agree or disagree with the following statements? (Check one box in each row.)
Strongly Agree Neither Disagree Strongly No basis
agree agree nor disagree to judge
disagree
(1) (2) (3) (4) (5) (6)
Budget Process in INS
a. The INS budget directs resources to
where they are most needed n =2,314 1% 11% 13% 41% 24% 10%
b. The distribution of funding among INS
programs is appropriate n =2,313 1% 7% 13% 41% 24% 14%
c. The distribution of personnel among
INS programs is appropriate n =2,314 0% 9% 13% 42% 25% 11%
d. The distribution of funding among
geographic areas is appropriate n =2,313 0% 8% 18% 26% 17% 31%
e. The distribution of personnel among
geographic areas is appropriate n =2,312 0% 11% 17% 28% 18% 26%
f. Decisions about how to allocate funds in
INS are made by the right people n =2,315 1% 4% 13% 27% 34% 21%
Budget Process in Y our Unit
g. My unit has financial problems that affect
its ability to carry out its mission n =2,313 22% 32% 15% 21% 5% 6%
h. My unit receives its fair share of
financial resources n =2,314 2% 23% 19% 33% 16% 8%
i. My unit receives the financial resources
it needs to operate in a timely fashion n =2,316 3% 21% 16% 35% 19% 6%
j. My unit uses the financial resources
it receives efficiently n =2,315 22% 46% 12% 9% 5% 6%
k. My unit has the necessary number of people
on board to carry out its mission n =2,317 3% 15% 6% 38% 38% 1%
l. My unit has the necessary equipment to meet
its goals, objectives, and mission n =2,318 4% 26% 11% 34% 24% 1%
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IV. M anagem ent Information
12. In your opinion, how adequate or inadequate is management information provided to you for the following?
(Check one box in each row.)
More Generally Neither Generally Very No basis
than adequate adequate inadequate inadequate to judge
adequate nor (6)
inadequate
(1) (2) (3) (4) (5)
a. Information on personnel and staffing
allocation n =2,306 2% 25% 16% 31% 19% 9%
b. Information on budget and financial
management n =2,307 1% 18% 16% 30% 23% 11%
c. Measures of workload (e.g., number of
arrests, etc.) n =2,303 4% 36% 19% 19% 12% 9%
d. Measures of productivity (e.g., number of cases
adjudicated per work hour, etc.) n =2,302 4% 31% 21% 20% 14% 11%
e. Information on policies and procedures
n =2,297 3% 37% 14% 25% 17% 3%
If you checked box 4 or 5 for any item in question 12 → Continue with Question 13.
If you checked box 1, 2, 3, or 6 for all items in question 12 → Skip to Question 15.
13. For which of the following reasons, if any, do you have inadequate management information?
(Check all that apply.)
n=699 1. Information systems (automated or manual) are not providing reliable management information
n=841 2. Information systems (automated or manual) are not providing timely management information
n=866 3. Information systems (automated or manual) are not providing complete management information
n=770 4. Most of the information I need to manage my unit is not readily available in electronic format
n=437 5. Other - Please describe: ________________________________________________
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14. Which of the following describes how this 16. Given the following options, how would you
inadequate management information impacts your characterize the current setting of priorities at INS
unit? (Check all that apply.) between enforcement and service functions?
(Check one.)
n=851 1. Impedes the accomplishment of my
program's goals and objectives n=2,297
n=803 2. Makes it necessary to keep 13% 1. Much heavier emphasis on
supplemental records enforcement than on service
n=535 3. Hinders my ability to adequately 14% 2. Somewhat heavier emphasis on
measure performance enforcement than on service
n=762 4. Hinders my ability to make well- 21% 3. About equal priority
thought-out decisions
19% 4. Somewhat heavier emphasis on
n=520 5. Prevents holding employees service than on enforcement
accountable
26% 5. Much heavier emphasis on service
n=1,025 6. Results in wasting scarce resources than on enforcement
(e.g., people, time, or money) -------------------------
8% 6. No basis to judge
n=175 7. Other - Please describe:
_____________________________
17. In your opinion, how should enforcement vs.
service priorities be set at INS? (Check one.)
V. Priority Setting and Planning n=2,285
25% 1. Should be much heavier emphasis
15. To what extent, if at all, are INS-wide goals and on enforcement than on service
objectives clear enough to assist you in carrying
out your planning responsibilities? (Check one.) 25% 2. Should be somewhat heavier
emphasis on enforcement than on
n=2,281 service
4% 1. To a very great extent 43% 3. Should have about equal priority
15% 2. To a great extent 2% 4. Should be somewhat heavier
emphasis on service than on
33% 3. To a moderate extent enforcement
26% 4. To some extent 1% 5. Should be much heavier emphasis
on service than on enforcement
22% 5. To little or no extent -------------------------
4% 6. No basis to judge
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The following question refers to the Commissioner's strategic planning process.
This includes the following priorities:
· Strengthen Border Protection
· Expedite Removal of Criminal Aliens
· Reduce Incentives for Unlawful Migration
· Implement Asylum Reform Regulations
· Improve Customer Service
· Promote and Streamline Naturalization
· Improve Professionalism
· Provide Innovative Immigration Policy Leadership
· Broaden and Integrate INS Systems Infrastructure
18. In your opinion, to what extent, if at all, has the strategic planning process, which identifies nine priorities, aided
INS in the following areas? (Check one box in each row.)
To little To To a To a To a very No basis
or no some moderate great great to judge
extent extent extent extent extent
(1) (2) (3) (4) (5) (6)
a. Headquarters planning n =2,272 11% 17% 13% 9% 3% 47%
b. Regional planning n =2,273 9% 15% 14% 7% 2% 54%
c. Headquarters decision-making n =2,267 14% 16% 13% 9% 3% 45%
d. Regional decision-making n =2,262 10% 15% 15% 6% 2% 52%
e. Unit planning n =2,255 24% 25% 23% 11% 4% 14%
f. District or sector ability to carry
out their missions n =2,262 18% 23% 20% 8% 2% 30%
g. Budget execution planning n =2,269 20% 19% 14% 7% 2% 38%
h. Budget execution decisions n =2,269 20% 18% 14% 7% 2% 39%
i. Personnel planning n =2,270 23% 21% 16% 9% 3% 27%
j. Personnel decisions n =2,264 25% 21% 17% 7% 2% 28%
k. Immigration policy planning n =2,268 17% 19% 15% 9% 3% 37%
l. Providing agency-wide perspective
on programs n =2,265 20% 20% 18% 8% 3% 31%
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VI. Client Service
19. Is your unit (See Glossary on page 1) directly involved with adjudications and nationality; legalization; refugees,
asylum; outreach; or information services (i.e., does it deal directly with the public)? (Check one.)
n=2,255
38% 1. Yes → Continue with Question 20.
62% 2. No → Skip to Question 22.
20. How would you rate your unit's performance in the following areas? (Check one box in each row.)
No
Excellent Very Fair Poor Very basis
good poor to judge
(1) (2) (3) (4) (5) (6)
a. Quality of service provided to the public
n=892 24% 42% 24% 7% 2% 0%
b. Timeliness of service provided to the public
n=892 18% 37% 27% 12% 6% 1%
c. Efficiency of service provided to the public
n=893 17% 40% 29% 10% 3% 1%
d. Quantity/volume of service provided
to the public n=892 26% 38% 25% 7% 4% 1%
21. In your opinion, to what degree does INS commit the necessary resources for quality service?
(Check one.)
n=891
4% 1. Very high commitment
14% 2. High commitment
37% 3. Moderate commitment
26% 4. Low commitment
16% 5. Very low commitment
---------------------------
3% 6. No basis to judge
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VII. Organizational/Accountability Issues
22. In general, over the past 5 years, would you say that the quality of leadership in the following INS top
management positions has improved, stayed about the same, or has gotten worse? (Check one box in each row.)
Improved Improved Stayed Gotten Gotten No
greatly somewhat about somewhat much basis
the same worse worse to judge
(1) (2) (3) (4) (5) (6)
a. Top Headquarters management positions
(Commissioner, Deputy Commissioner,
Executive Associate Commissioners) n =2,308 11% 22% 26% 16% 17% 9%
b. Top regional office management positions
(Regional Director, Deputy Director) n =2,302 10% 22% 32% 11% 8% 17%
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23. Do you agree or disagree with the following statements concerning INS as an organization?
(Check one box in each row.)
Strongly Agree Neither Disagree Strongly No basis
agree agree nor disagree to judge
disagree
(1) (2) (3) (4) (5) (6)
a. Overall, the current organizational structure of
INS works well n =2,298 2% 18% 17% 35% 26% 2%
b. Headquarters should have more control over INS'
field operations n =2,308 8% 15% 14% 33% 27% 4%
c. INS' regional offices should have more input into
national policy setting n =2,309 14% 48% 15% 11% 4% 9%
d. Districts/sectors should have more input into
national policy setting n =2,309 29% 48% 10% 6% 2% 6%
e. The regional offices should have greater input
into how their districts/sectors are managed
n =2,302 13% 35% 20% 19% 7% 7%
f. Regional offices should have more autonomy
n =2,297 8% 27% 26% 24% 8% 8%
g. Districts/sectors should have more autonomy
n =2,293 14% 31% 20% 22% 7% 5%
h. There should be more coordination among INS
regions and the districts/sectors under their
jurisdiction n =2,309 32% 48% 11% 2% 1% 6%
i. Headquarters is in touch with events/
problems/concerns in the field n =2,311 2% 11% 13% 33% 37% 5%
j. The regional offices are in touch with
events/problems/concerns in the districts/sectors
n =2,309 4% 27% 21% 23% 13% 13%
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24. Listed below are problems which may occur in an organization. In your opinion, to what extent, if at all, are
these problems present at INS? (Check one box in each row.)
To little To some To a To a To a very No basis
or no extent moderate great great to judge
extent extent extent extent
Extent these may be problems at INS (1) (2) (3) (4) (5) (6)
a. Unclear lines of authority n=2,302 24% 24% 19% 14% 18% 2%
b. Chain-of-command is not followed n=2,307 24% 22% 19% 15% 16% 3%
c. Unclear lines of accountability n=2,302 15% 19% 20% 20% 23% 3%
d. Lack of central decision-making authority
n=2,279 23% 20% 18% 14% 16% 9%
e. Too much central decision-making authority
n2,260 27% 20% 17% 13% 13% 11%
f. Unclear decision-making authority at
the local level n=2,293 28% 22% 17% 13% 11% 9%
g. Duplication of effort n-2,302 10% 20% 18% 23% 25% 4%
h. Poor communications n=2,311 4% 16% 17% 24% 38% 1%
i. Poor dissemination of information n=2,311 5% 16% 18% 22% 37% 1%
25. Given your experiences, would you say that at 26. Consider the work performed in your unit. How
least some of the work performed in your unit is rarely or often would you say that tasks
duplicated by some other office in INS (e.g., a performed in your unit are duplicated in some
Border Patrol unit working the same or related other office? (Check one.)
case as an Investigations unit)? (Check one.)
n=1,114
n=2,307
8% 1. Rarely → Skip to Question 28.
48% 1. Yes → Continue with Question
26.
48% 2. Occasionally
43% 2. No 10% 3. As often as not Continue with
Skip to Question 28. Question 27.
9% 3. No basis 22% 4. Often
to judge
12% 5. Very often
1% 6. No basis to judge →Skip to
Question 28.
13
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27. Which of the following groups in INS 28. To your knowledge, how often, if ever, does the
unnecessarily duplicate at least some of the work field carry-out programs differently than
that your unit does? (Check all that apply.) Headquarters may have originally intended?
(Check one.)
n=26 1. None of the duplication is
unnecessary n=2,293
n=20 2. Office of the Commissioner or
Office of the Deputy Commissioner 13% 1. Very often
n=73 3. Office of the Executive Associate
Commissioner for Programs 18% 2. Often
n=82 4. Office of the Executive Associate
Commissioner for Policy and 30% 3. Sometimes
Planning
n=127 5. Office of the Executive Associate 12% 4. Rarely
Commissioner for Field Operations
n=59 6. Office of the Executive Associate 7% 5. Very rarely, if ever
Commissioner for Management --------------------
n=89 7. Office of the Regional Director 21% 6. No basis to judge
n=73 8. Office of the District Director
n=57 9. General Counsel, Regional
Counsel, or District Counsel
n=83 10. Congressional Relations
n=83 11. Public Affairs
n=31 12. Asset Forfeiture
n=300 13. Border Patrol
n=436 14. Investigations
n=234 15. Intelligence
n=62 16. International Affairs/Asylum
Offices
n=203 17. Detention and Deportation
n=86 18. Adjudications and Nationality
n=106 19. Service Center
n=148 20. Inspections
n=88 21. Records
n=12 22. Administrative Appeals
n=39 23. Equal Employment Opportunity,
Security, Files and Forms
Management
n=88 24. Budget and Financial Management
n=84 25. Human Resources and
Administration
n=44 26. Information Resources
Management
n=50 27. Internal Audit
n=99 28. Administrative Centers
n=58 29. Other - Please specify:
________________________
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29. In your opinion, service-wide, how consistent or inconsistent is the actual implementation of policies,
procedures, directives, and regulations by the various offices at INS? (Check one box in each row.)
Very Consistent As consistent Inconsistent Very No
consistent as inconsistent basis
inconsistent to judge
(1) (2) (3) (4) (5) (6)
a. Implementation of policies
n =2,313 4% 24% 27% 27% 11% 9%
b. Implementation of procedures
n =2,313 3% 20% 26% 30% 13% 8%
c. Implementation of directives
n =2,311 4% 24% 27% 26% 10% 9%
d. Implementation of regulations
n =2,312 6% 29% 24% 22% 10% 9%
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VIII. INS Internal Policy Development and Implem entation
30. Thinking about the implementation of INS internal policy (e.g., personnel practices, budget processes, etc.), would
you agree or disagree with the following statements as they apply service-wide? (Check one box in each row.)
Strongly Agree Neither Disagree Strongly No basis
agree agree nor disagree to judge
disagree
(1) (2) (3) (4) (5) (6)
a. INS policy is clearly defined by Headquarters
n =2,301 3% 23% 22% 34% 15% 5%
b. Headquarters provides adequate policy guidelines
to the field n =2,301 2% 17% 20% 38% 18% 6%
c. Field offices can voice opposition concerning a
policy to Headquarters if they feel the policy is
misguided or inappropriate n =2,305 3% 24% 13% 27% 19% 15%
d. Headquarters should consult more with the field
when developing policy n =2,305 48% 41% 6% 1% 1% 4%
e. Advice from the field is heeded by Headquarters
when developing policy n =2,303 8% 14% 19% 28% 18% 13%
f. INS policy is clearly communicated by
Headquarters to the field n =2,301 2% 17% 23% 37% 17% 5%
g. Policy is communicated to the field in a formal
(standardized) manner n =2,304 2% 29% 24% 26% 13% 6%
h. Changes in policy are promptly disseminated
n =2,300 1% 13% 17% 43% 22% 4%
i. Changes in policy are disseminated to everyone
who needs them n =2,300 1% 13% 18% 39% 22% 6%
j. Field offices should have discretion in
implementing INS policy n =2,300 8% 26% 17% 29% 16% 4%
k. Headquarters ensures that policies are
consistently implemented service-wide n =2,298 2% 8% 21% 40% 21% 10%
l. Written policies are kept up-to-date n =2,304 1% 9% 16% 39% 31% 5%
m. Instructions on carrying out policy are complete
n =2,304 1% 10% 20% 39% 26% 5%
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IX. Overall M anagem ent Concerns
31. In your opinion, to what extent, if at all, do you feel the following areas need improvement service-wide?
(Check one box in each row.)
To little To some To a To a To a very No basis
or no extent moderate great great to judge
extent extent extent extent
(1) (2) (3) (4) (5) (6)
a. Financial management n =2,307 2% 10% 13% 24% 40% 12%
b. Budget development/formulation n =2,307 1% 10% 14% 27% 34% 15%
c. Budget execution process n =2,300 1% 9% 14% 26% 35% 16%
d. Distributed Budget Module System (DBM)
(i.e., system used to allocate and move funds)
n =2,303 2% 7% 11% 16% 31% 33%
e. Quality of service to the public n =2,295 10% 23% 23% 18% 17% 9%
f. Quality of information services to the public
n =2,306 9% 19% 20% 21% 21% 10%
g. Record and data management n =2,297 3% 13% 21% 26% 26% 11%
h. Workload/productivity measures n =2,300 7% 17% 25% 22% 21% 7%
i. Employee morale n =2,309 1% 7% 13% 25% 53% 1%
j. Lines of authority n =2,303 12% 20% 24% 19% 23% 2%
k. Coordination and cooperation among INS units
n =2,309 4% 16% 19% 24% 34% 2%
l. Agency-wide planning n =2,300 2% 12% 22% 25% 31% 8%
m. Oversight and evaluation of INS programs
n =2,297 3% 15% 24% 23% 27% 8%
n. Development of managers n =2,306 2% 11% 18% 26% 41% 3%
o. Training of staff n =2,307 3% 12% 22% 27% 33% 2%
p. Quality of staff n =2,307 6% 20% 26% 19% 28% 2%
q. Personnel process n =2,305 3% 12% 19% 24% 37% 6%
r. Quality of INS leadership at Headquarters
n =2,303 5% 14% 19% 17% 37% 8%
s. Quality of INS leadership at the regional offices
n =2,309 8% 19% 22% 14% 20% 16%
t. Quality of leadership in districts/sectors n =2,307 11% 23% 22% 13% 20% 11%
u. Other - Please specify:__________ n =275 1% 2% 2% 16% 72% 7%
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32. In your opinion, how effectively or ineffectively is INS carrying out the following activities?
(Check one box in each row.)
Very Somewhat Neither Somewhat Very No basis
effectively effectively effectively ineffectively ineffectively to judge
nor
ineffectively
(1) (2) (3) (4) (5) (6)
a. Timely processing of international travelers
at ports-of-entry n=2,297 15% 24% 4% 8% 3% 46%
b. Screening immigrants at ports-of-
entry for admissibility n=2,293 10% 25% 5% 14% 6% 41%
c. Apprehending noncriminal aliens
n=2,283 5% 22% 8% 22% 28% 15%
d. Detaining noncriminal aliens n=2,287 3% 13% 8% 20% 41% 15%
e. Apprehending criminal aliens n=2,288 6% 30% 8% 24% 18% 15%
f. Detaining criminal aliens n=2,283 6% 24% 7% 24% 24% 15%
g. Controlling the border between
ports-of-entry n=2,293 3% 21% 8% 24% 24% 21%
h. Deporting aliens in a timely manner
n=2,295 2% 10% 6% 21% 43% 18%
i. Adjudicating resident status and
naturalization cases in a timely manner
n=2,293 2% 14% 8% 17% 16% 43%
j. Adjudicating legalization cases in a timely
manner n=2,293 2% 10% 9% 13% 16% 50%
k. Adjudicating asylum cases in a timely
manner n=2,295 4% 10% 7% 14% 18% 48%
l. Adjudicating other benefit cases in a timely
manner n=2,291 2% 14% 11% 16% 10% 48%
m. Adjudicating cases across the country in a
consistent manner n=2,289 1% 8% 8% 19% 16% 48%
n. Identifying fraud n=2,293 3% 19% 10% 25% 26% 17%
o. Enforcing employer verification
of work eligibility n=2,293 1% 10% 10% 23% 31% 26%
p. Fining employers who hire illegal aliens
n=2,292 1% 10% 8% 23% 33% 26%
q. Collecting breached bonds n=2,288 1% 6% 6% 14% 21% 53%
r. Providing accurate and complete
information to clients and the general public
n=2,293 2% 18% 17% 22% 17% 25%
s. Managing seized assets n=2,292 1% 10% 11% 12% 12% 54%
t. Stopping the flow of illegal narcotics
into the United States n=2,288 1% 15% 9% 17% 35% 23%
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X. Reviewing the Past Two Years
33. In your opinion, over the past two years, have the following improved, worsened, or stayed about the same
in your unit? (Check one box in each row.)
Improved Improved Stayed Worsened Worsened No basis
greatly somewhat about somewhat greatly to judge
the same
(1) (2) (3) (4) (5) (6)
a. Information on personnel and
staffing allocation n =2,301 3% 17% 45% 16% 11% 9%
b. Information on budget and
financial management
n =2,300 2% 12% 42% 18% 14% 13%
c. Measures of workload
(e.g., number of arrests)
n =2,295 5% 19% 45% 13% 8% 10%
d. Productivity n =2,294 10% 33% 32% 13% 7% 5%
e. Measures of productivity
(e.g., number of cases adjudicated
per work hour) n =2,296 5% 21% 42% 11% 6% 16%
f. Information on policies and
procedures n =2,297 2% 16% 48% 19% 10% 5%
g. Quality of work n =2,294 6% 31% 38% 14% 8% 3%
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XI. 1994 INS Reorganization
The following questions refer to the reorganization that began in July 1994.
The reorganization established four Executive Associate Commissioner
positions, changed the number of regional offices from four to three, and
had administrative centers report to Headquarters rather than to the regions.
34. Generally, how successful or unsuccessful do you think the reorganization has been in achieving the following
goals? (Check one box in each row. If goal had been achieved prior to the reorganization, check box 1.)
Goal achieved Very Somewhat As Somewhat Very Too No
prior to the success- successful successful unsuccess-ful unsuc- early basis
reorganization ful as cessful to say to judge
Goals
unsuccess-ful
(4) (5) (8)
(1) (2) (3) (6) (7)
a. Creating a clearer sense
of mission by
combining INS' major
functions
n =2,293 2% 3% 18% 20% 17% 18% 7% 16%
b. Decentralizing
decision-making
authority n =2,292 1% 3% 19% 18% 17% 18% 5% 20%
c. Empowering the field
operational units to
improve the delivery of
services to customers
n =2,292 1% 3% 18% 18% 16% 15% 4% 25%
d. Developing planning
capability n =2,287 1% 3% 16% 20% 16% 17% 5% 23%
e. Setting customer service
standards
n =2,288 1% 3% 19% 19% 12% 12% 4% 30%
f. Establishing quantitative
performance measures
n =2,288 1% 2% 15% 21% 17% 17% 4% 23%
g. Clarifying lines of
authority n =2,289 2% 3% 17% 21% 16% 24% 3% 15%
Question 34 continued on next page.
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Question 34 (Continued)
In your opinion, how successful or unsuccessful has the reorganization been at achieving the following goals?
(Check one box in each row. If goal had been achieved prior to the reorganization, check box 1.) (74-77)
Goal achieved Very Somewhat As Somewhat Very Too No
prior to the success- successful successful unsuccess-ful unsuc- early basis
Goals reorganization ful as cessful to say to judge
unsuccess-ful
(1) (2) (3) (4) (5) (6) (7) (8)
h. Focusing on overall
INS effectiveness rather
than individual program
objectives n =2,297 1% 4% 22% 20% 17% 15% 6% 17%
i. Building an atmosphere
of trust between the
field and Headquarters
n =2,299 1% 2% 11% 15% 22% 34% 3% 13%
j. Improving processes to
develop and disseminate
organizational policy
and guidelines
n =2,298 1% 2% 15% 21% 21% 23% 4% 13%
k. Delegating authority to
persons geographically
closer to locations
where work is being
done n =2,298 1% 3% 19% 18% 17% 19% 4% 20%
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35. In your opinion, has the reorganization improved, worsened, or had no effect on the following in INS?
(Check one box in each row.)
Improved Improved Had no Worsened Worsened Too No basis
greatly somewhat effect somewhat greatly early to
to say judge
(1) (2) (3) (4) (5) (6) (7)
a. Quality of leadership provided by
top management n =2,303 3% 18% 33% 16% 17% 4% 9%
b. Level of cooperation among
INS units n =2,307 1% 17% 43% 17% 10% 3% 9%
c. Communication between
Headquarters and the regions
n =2,311 1% 13% 17% 12% 9% 2% 46%
d. Communication between
Headquarters and administrative
centers n =2,309 1% 8% 13% 7% 6% 2% 63%
e. Communication between the
regions and the administrative
centers n =2,311 1% 7% 13% 8% 6% 2% 64%
f. Communication between the
regional offices and the
districts/sectors n =2,313 3% 19% 26% 10% 5% 2% 36%
g. Level of effort involved in
obtaining administrative services
n =2,307 1% 10% 25% 18% 14% 2% 29%
h. Quality of decision-making
n =2,300 1% 16% 33% 20% 14% 3% 13%
i. Timeliness of decision-making
n =2,307 1% 14% 31% 21% 18% 2% 13%
j. Consistency of policies among
units/programs n =2,307 1% 14% 36% 20% 13% 3% 14%
k. Timeliness of work n =2,309 1% 15% 41% 18% 11% 3% 11%
l. Efficiency of work n =2,309 1% 16% 40% 18% 11% 3% 11%
m. Review process (layers of
review needed) n =2,305 1% 11% 31% 18% 19% 2% 19%
Page 116 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
36. In your opinion, has the reorganization improved, worsened, or had no effect on the following in your unit?
(Check one box in each row.)
Improved Improved Had no Worsened Worsened Too No basis
greatly somewhat effect somewhat greatly early to
to say judge
(1) (2) (3) (4) (5) (6) (7)
a. Effectiveness of program
operations n =2,308 1% 17% 43% 19% 11% 3% 7%
b. Staff morale n =2,313 1% 9% 37% 26% 22% 2% 5%
c. Quality of decision-making
n =2,309 2% 14% 46% 19% 12% 2% 6%
d. Timeliness of decision-making
n =2,309 2% 13% 44% 20% 13% 2% 6%
e. Accountability n =2,308 2% 13% 46% 16% 13% 2% 7%
37. In your opinion, what would be the best organization for INS' administrative functions? (Check one.)
n=2,287
16% 1. Current administrative center structure
(i.e., administrative centers that support regional offices and report to Headquarters)
29% 2. Previous administrative structure
(i.e., administrative offices that supported regional offices and reported to the regional offices)
18% 3. Administrative centers with specialized centers that report to Headquarters
(i.e., specialized centers located outside of Headquarters, such as finance in one location and
personnel at another location, etc. )
10% 4. Other organization - Please specify: _______________________________________________
28% 5. No opinion
Page 117 GAO/GGD-97-132 INS Management Problems
Appendix IV
GAO Survey on INS Management Issues
XII. Comments
38. If you have any additional comments regarding any previous question or comments concerning INS' managerial
practices, internal control weaknesses, or specific problems that need to be addressed, please use the space
provided below. If necessary, you may add additional sheets.
974 respondents included written comments.
Thank you for your assistance.
Please return your questionnaire in the pre-addressed envelope. Also, please return the postcard separately.
GGD-SMK 9/95
Page 118 GAO/GGD-97-132 INS Management Problems
Appendix V
INS’ Fiscal Years 1995 and 1996 Priorities
Table V.1: INS’ Fiscal Year 1995 Priorities
Prioritya INS statement of priority
1. Strengthen border protection INS will continue to improve border protection by facilitating travel and commerce while
ensuring border integrity. This will be accomplished by employing a strategy of
prevention through deterrence, concentrating resources at key transit and entry points
(foreign and domestic), and employing resource-multiplying technology. Activities will
include continued implementation of a comprehensive Southwest land border strategy,
improvement in the use of lookout systems through better integration of data, and
continued development of automated inspections processes.
2. Expedite removal of criminal aliens INS will broaden its programs to identify and apprehend criminal aliens and expedite
their removal from the United States. Activities will include responding to federal, state,
and local law enforcement officers’ requests on alienage and immigration status;
completing implementation of the five-state Institutional Hearing Program model;
completing development of a national alien transportation plan; expanding the use of
technology, including the use of electronic fingerprinting and teleconferencing; and
completing a comprehensive review of the legal and regulatory processes for removal.
3. Reduce incentives for unlawful migration INS will decrease the “pull factors” for illegal migration and simultaneously support
benefit providers with information on alienage of individuals. Strategies include making it
easier for employers to verify employment eligibility and increasing efforts to educate
employers about their responsibility to comply with the law, focusing enforcement efforts
on industries that have traditionally relied on unauthorized labor and employers who
knowingly violate the law, and increasing the security of employment authorization
documents.
4. Implement asylum reform regulations INS will implement a more timely asylum processing and decision system. New
procedures, coupled with additional resources, will enable the Service to keep up with
incoming applications and begin to handle backlogged cases. This effort will also focus
enforcement on fraudulent applications, reducing incentives for asylum abuse.
5. Improve customer service INS will enhance delivery of services to its customers. This will be accomplished by
improving the current systems being used to obtain and apply customer service
feedback; implementing all components of the Executive Order on “Setting Customer
Service Standards”; and applying benchmarking to programs, where applicable, to
achieve best-in-the-business practices and standards.
6. Promote and streamline naturalization INS will encourage and promote naturalization through public education programs by
establishing cooperative agreements with community-based organizations, ethnic group
networks, and educational institutions to assist in preparation of applications and study
for civics and language tests; and by seeking ways to streamline the naturalization
process.
7. Improve professionalism INS will pursue professionalism at all levels of the agency. This will be accomplished by
maintaining high standards of conduct fostered through proper training and career
development and hiring and promotion practices—as reflected in the Service’s new
Equal Employment Opportunity plan—that result in a workforce that reflects the diversity
of America and our clientele.
8. Provide innovative immigration policy INS will inform and shape immigration policy through production of timely, high-quality
leadership information and policy analysis. The Service will take a proactive role in creating a better
understanding of immigration issues and in advancing new initiatives, including
legislation, to improve administration of U. S. immigration law and policy.
9. Broaden and integrate INS’ systems INS will improve management information systems by developing accurate, timely,
infrastructure integrated databases that upgrade operational effectiveness and productivity. The INS
“information highway” will lead to paperless work processes and national automated
immigration data repositories for both INS and relevant non-INS users.
(Table notes on next page)
Page 119 GAO/GGD-97-132 INS Management Problems
Appendix V
INS’ Fiscal Years 1995 and 1996 Priorities
a
According to INS officials, these priorities were not ranked in their order of importance.
Source: INS.
Page 120 GAO/GGD-97-132 INS Management Problems
Appendix V
INS’ Fiscal Years 1995 and 1996 Priorities
Table V.2: INS’ Fiscal Year 1996 Priorities
Prioritya INS statement of priority
1. Strengthen the INS workforce INS will rapidly increase the size of its officer workforce and support staff. To accomplish
the goal of hiring over 4,000 new, productive employees, INS will (1) streamline and
target recruitment, (2) expand training, (3) increase retention of experienced employees,
and (4) deploy new employees with proper equipment.
2. Strengthen border enforcement and INS will regulate entry to the United States in a manner that facilitates lawful travel and
facilitation commerce while ensuring border integrity against unlawful entry. Efforts in fiscal year
1996 will consolidate and expand progress achieved at and between ports-of-entry in
the primary corridors of illegal immigration. To pursue these strategic targets, INS will (1)
enhance control between ports-of-entry along the Southwest Border, especially in San
Diego, Tucson, McAllen, and El Paso; (2) tighten control at ports-of-entry in anticipation
of the impact from beefed-up Border Patrol activities; (3) facilitate traffic by adding new
inspectors, opening lanes, and redesigning signs; (4) establish a proactive intelligence
program to support field managers in anticipating and responding to shifts in illegal alien
crossing patterns; (5) develop overseas deterrence activities, particularly in Mexico City,
to support border control efforts; and (6) expand antismuggling operations.
3. Increase removal of deportable aliens INS will increase removal of criminal and noncriminal illegal aliens, focusing especially
on aliens convicted of aggravated felonies. To increase removals, INS will (1) increase
criminal alien removals through expanded Institutional Hearing Programs and county jail
projects; (2) expand noncriminal alien removals with final orders of deportation of aliens
who have absconded, been rejected for asylum, or are in the workforce illegally; (3)
improve functioning of primary components of removal system, including the national
transportation system; and (4) enhance cooperative efforts with other law enforcement
agencies.
4. Enhance worksite enforcement and INS will reduce opportunities for illegal employment through enhanced worksite
verification systems investigations, document improvements, and automated status verification services. To
increase control at the worksite, INS will (1) target the worst violators of immigration and
employment standards laws and coordinate investigations with the Department of Labor,
(2) increase worksite operations to remove unauthorized workers and make jobs
available for authorized workers, and (3) test and expand pilot programs to assist
employers in complying with the law.
5. Improve immigration services INS will continue to improve services to its various customers, including petitioners for
immigration benefits, other law enforcement agencies, its own front-line employees, and
the local communities within which the Service works. To improve services, INS will (1)
reorganize service delivery to applicants for immigration benefits by improving forms,
reducing waiting periods, and accelerating processing times; (2) increase coordination
with other local law enforcement agencies to improve sharing of information, response
times, and joint operations; and (3) expand outreach to local communities through
citizen advisory groups, coordination with consulates, and participation in public events,
including expanded public affairs activities and communication with local congressional
offices.
6. Implement citizenship U.S.A. INS will respond to the tremendous growth in naturalization applications by reducing
naturalization processing times to 6 months. It will greatly increase the efficiency, quality
control, and convenience of the process and work with a variety of local organizations to
meet the increase in applications while maintaining examination standards.
a
According to INS officials, these priorities were ranked in their order of importance.
Source: INS.
Page 121 GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service
Page 122 GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service
Page 123 GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service
Page 124 GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service
Page 125 GAO/GGD-97-132 INS Management Problems
Appendix VII
Major Contributors to This Report
Evi L. Rezmovic, Assistant Director, Administration of Justice Issues
General Government Linda R. Watson, Evaluator-in-Charge
Division, Washington, Charity J. Goodman, Senior Evaluator
D.C. Charles Michael Johnson, Senior Evaluator
Stuart M. Kaufman, Senior Social Science Analyst
Katherine M. Wheeler, Publishing Consultant
Pamela V. Williams, Communications Analyst
Ann H. Finley, Senior Attorney
Office of the General
Counsel, Washington,
D.C.
Michael P. Dino, Senior Evaluator
Los Angeles Field Leah G. Riordan, Senior Evaluator
Office
(183594) Page 126 GAO/GGD-97-132 INS Management Problems
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Address Correction Requested
INS Management: Follow-up on Selected Problems
Published by the Government Accountability Office on 1997-07-22.
Below is a raw (and likely hideous) rendition of the original report. (PDF)