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defined priorities, (2) lacked management control over regional commissioners, (3) had poor internal communications and outdated policies and procedures, (4) did not use workload data to allocate resources and had budget management and resource allocation problems that perpetuated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. Page 3 GAO/GGD-97-132 INS Management Problems 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 Page 4 GAO/GGD-97-132 INS Management Problems 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 Page 9 GAO/GGD-97-132 INS Management Problems 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 Page 17 GAO/GGD-97-132 INS Management Problems 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 Chapter 2 INS Made Progress Toward Some Management Goals of the Reorganization, but Others Continue to Be Problematic 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. Page 38 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 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 Page 39 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 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. Page 40 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 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: Page 41 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 “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 Page 42 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 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. Page 43 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 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 Page 44 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 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.” Page 45 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 2.2: 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.” Page 46 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 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. Page 47 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 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 Page 48 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 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 Page 49 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 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. Page 50 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 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. Page 51 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 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. Page 52 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 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 Page 53 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 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. Page 54 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 Page 55 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 2.3: 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 Page 56 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 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. Page 57 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 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, Page 58 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 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. Page 59 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 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 Page 60 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 more chapters can be issued. Chapters that need further negotiation are to be handled at a later date. Page 61 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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. Page 62 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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. Page 63 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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. Page 64 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 65 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 66 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 67 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 68 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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. Page 69 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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). Page 70 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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) Page 71 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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. Page 72 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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) Page 73 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 74 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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). Page 75 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 76 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 77 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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. Page 78 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 79 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist (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. Page 80 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 81 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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.” Page 82 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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, Page 83 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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 Page 84 GAO/GGD-97-132 INS Management Problems Chapter 3 Improvements Made to Management of Budget Resources, but Problems Persist 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% Page 99 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 100 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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: ________________________________________________ Page 101 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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 Page 102 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 103 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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 Page 104 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 105 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 106 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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 Page 107 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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: ________________________ Page 108 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 109 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 110 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 111 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 112 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 113 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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. Page 114 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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% Page 115 GAO/GGD-97-132 INS Management Problems Appendix IV GAO Survey on INS Management Issues 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 Ordering Information The first copy of each GAO report and testimony is free. Additional copies are $2 each. Orders should be sent to the following address, accompanied by a check or money order made out to the Superintendent of Documents, when necessary. VISA and MasterCard credit cards are accepted, also. Orders for 100 or more copies to be mailed to a single address are discounted 25 percent. 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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)