oversight

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)

                 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.



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                                         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.



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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.



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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




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                           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.




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                           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




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                                       managers who expressed an opinion said that the process aided budget
                                       execution decisions.4


Figure 2.3: Many INS Managers
Perceived That the Fiscal Year 1995
                                       Extent aided (as a percent)
Strategic Planning Process That
Identified Nine Priorities Aided
                                       100
Headquarters, Regional, and Budget
Execution Planning and
Decisionmaking
                                       80




                                       60




                                       40




                                       20




                                           0




                                                                                                                  13 s
                                                                                           81
                                           = n




                                                                                40
                                                02
                                           = s




                                                                                                               = ing
                                                                            = s




                                                                                                                     98
                                               52




                                                                                       = n




                                                                                                                     82
                                                                                                            n sion
                                          n gio
                                          n rter




                                                                           n rter



                                                                                      n gio
                                                                                         10
                                                                              12
                                             12



                                             10




                                                                                                                  13
                                                                                                                   n
                                             e




                                                                                                               an
                                                                                        e
                                            a




                                                                            ua




                                                                                                                 i
                                           R




                                                                                       R




                                                                                                              ec
                                                                                                               =
                                          qu




                                                                                                             Pl
                                                                           q




                                                                                                                n


                                                                                                            D
                                        ad




                                                                         ad
                                      He




                                                                       He




                                      Planning                           Decisions                           Budget execution


                                                 Some, moderate, great, very great extent
                                                 Little or no extent



                                       Source: Analysis of GAO 1995 survey responses.




                                       These responses showed that progress had been made toward using
                                       annual priorities to plan and make decisions. However, 19 to 33 percent of

                                       4
                                        For survey responses on whether the priorities had aided INS, we have deviated from the usual
                                       presentation by combining the response scales “to some extent” through “to a very great extent” and
                                       kept the response scale “to little or no extent” separate. We did this to measure whether the strategic
                                       planning process has had an impact, not to measure the degree of the impact. Figure 2.2 shows the
                                       extent to which priorities were perceived to be helpful. We did not include respondents who answered
                                       “no basis to judge” in our analysis.



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                          the INS managers responded that priorities had marginally, i.e. to little or
                          no extent, aided planning and decisionmaking. This indicated that some
                          managers believed that more could be done in this area.


INS Priority Management   The Results Act was passed in 1993 to, among other things, improve the
Process Included Some     effectiveness and efficiency of federal programs by establishing a system
Tasks Required for        to set performance goals and measure results. The Act is to improve the
                          performance of governmental programs through a set of integrated
Implementation of the     activities that include strategic planning, setting annual performance
Government Performance    targets, measuring progress toward reaching those targets, and reporting
and Results Act           on results. INS took some early steps consistent with the goals of the Act’s
                          requirements with the establishment of its strategic plan in 1994 and the
                          implementation of the Commissioner’s Annual Priorities Program in fiscal
                          year 1995. INS officials told us that during the development of the fiscal
                          years 1996 and 1997 implementation plans, increased attention was given
                          to establishing and tracking performance measures that would align with
                          the Results Act. INS officials said that they recognized that additional
                          efforts are still required to fine-tune performance measurement, reporting,
                          and coverage of appropriate program activities. In April 1997, INS officials
                          told us that both the Office of Planning and the Office of Budget were
                          combining efforts to review the Act’s measures. GAO’s past work at INS and
                          at other agencies indicates that to be successful, such initiatives require
                          continued top management attention and commitment to continuously
                          improve program performance.


                          The 1994 reorganization restored regional directors into the chain of
Reorganization            command to supervise district directors and Border Patrol chiefs. As a
Restored Regional         result, according to some managers, district directors and Border Patrol
Directors to Manage       chiefs received more supervision. Prior to the 1994 organization, the EAC
                          for Operations was responsible for directly supervising 33 district
Field Units               directors and 21 Border Patrol chiefs. Some managers told us that district
                          directors and Border Patrol chiefs were often able to operate
                          independently of headquarters direction. The current Commissioner
                          considered this span of control too large and supervision too far removed.

                          Under the current organization, the EAC for Field Operations is to provide
                          headquarters direction to the field by supervising the three regional
                          directors. Each regional director in turn is to supervise an average of 18
                          district directors and Border Patrol chiefs. According to INS managers,
                          with the smaller span of control, regional directors can be more



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                     responsive to field needs and provide more oversight than the EAC for
                     Operations could under the previous structure. According to a
                     headquarters Field Operations manager, an assistant district director, and
                     a deputy regional director, the strength of the regional structure lies in the
                     direct, personal contact between regions and districts. This is reportedly
                     better than the former structure, because headquarters does not have the
                     resources to respond to all the districts and sectors and is too far removed
                     from the field to know the problems that the field is having.

                     In addition to reestablishing a regional structure with oversight
                     responsibility for field units, INS’ reorganization delegated resource
                     allocation authority to regional directors to provide consistency in field
                     operations and improve the delivery of services. According to regional
                     directors, they had gradually begun to exercise their new authorities. For
                     example, one regional director told us of having taken the unprecedented
                     act of moving a couple of positions from one district to another.
                     Furthermore, regional offices began to manage personal services and
                     benefits (PS&B) funds for district offices and Border Patrol sectors
                     beginning in fiscal year 1996. PS&B funds are payroll costs and represent
                     the majority of INS’ budget. The allocation and management of PS&B funds
                     were being maintained at the district and sector levels during fiscal year
                     1995. Two regional directors told us that the district directors were no
                     longer able to act independently.

                     Managers responding to our survey were divided in their perceptions of
                     the success of the reorganization. Generally, 35 to 40 percent of managers
                     responding to our survey believed that the reorganization was somewhat
                     or very unsuccessful in clarifying lines of authority, delegating authority to
                     persons geographically closer to locations where work was being done,
                     and decentralizing decisionmaking. About 20 percent of the managers
                     responding believed that the reorganization had been very or somewhat
                     successful in achieving these goals.5 More information on the survey
                     results and our interpretation of them is presented later in this chapter.
                     Probing the reasons behind these survey responses was beyond the scope
                     of our study.


                     At the time of our review, INS had not fully defined the responsibilities and
Reorganization Not   authorities of the offices of Field Operations and Programs, nor had it
Fully Implemented    determined staffing levels for these offices on the basis of their new

                     5
                      This survey question listed 11 goals and had 8 response categories. For more details, see appendix IV,
                     question 34.



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                             responsibilities. Also, INS had not improved communications and
                             coordination among offices or updated field manuals and the policy
                             manual, as we previously recommended. We recognize that the
                             Commissioner did not expect the reorganization to correct all problems
                             immediately and that adjustments are needed as a new organizational
                             structure is implemented. However, we believe that fully implementing the
                             reorganization as soon as possible would help INS work more efficiently
                             and help achieve the goals of the reorganization.

                             Our survey and interviews with managers indicated that headquarters and
                             field managers were confused and frustrated because INS’ implementation
                             of its new organizational structure left unclear the differences in
                             responsibility and authority between the Office of Field Operations and
                             the Office of Programs. Also, INS did not determine the staffing levels that
                             would be needed for the Office of Field Operations to carry out its new
                             functions, did not determine the staffing levels for the Office of Programs
                             to meet its changed responsibilities, and did not move all operational
                             activities to the Office of Field Operations. Some INS managers told us that
                             they were having difficulty determining whom to coordinate with, when to
                             coordinate, and how to communicate with each other because they were
                             unclear about headquarters offices’ responsibilities and authority. Some
                             managers also said that they believed resources in the Office of Field
                             Operations were insufficient to meet field needs.


Responsibilities and         In December 1994 INS published an organizational chart and general
Authority of the Office of   description of the roles and responsibilities of the Office of Field
Field Operations and         Operations and the Office of Programs in the Federal Register (see ch. 1).
                             However, we were told by headquarters and field managers that INS had
Office of Programs Were      not clearly delineated the respective roles and responsibilities of these two
Unclear                      offices. As stated by an INS field manager, “Neither [office] seems to know
                             the limits of its responsibilities nor the parameters of its authority.” INS
                             managers whom we interviewed also said that because the authority of the
                             EACs was not clear, decisions that should have been made at the EAC level
                             often had to go to the Deputy Commissioner for resolution.

                             In our interviews with INS managers and in comments written on our
                             survey, some managers indicated that they felt frustrated by a lack of clear
                             understanding of responsibilities and authority at headquarters. As one INS
                             manager stated on our survey:




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“With respect to the whole reorganization of 1994, there seemed to be little thought given
to its implementation and actual practical working[s] beyond just an organizational chart.
Overnight the [re]organization was implemented with virtually no transition, leaving . . .
each office [to] themselves to figure out what to do. Rather than plan for this organization
in some detail, it was left to personal ideas of the top management who gained the new
positions in the new structures to determine what would happen.”


INS managers whom we interviewed provided examples to demonstrate the
lack of clear delineation of responsibility between the Office of Field
Operations and the Office of Programs. One example related to the
development of the deployment plan for interior enforcement for fiscal
year 1996. The Office of Programs drafted the deployment plan because it
does the program planning for allocating resources to meet the
Commissioner’s priorities. It sought input from the field units and
subsequently provided a draft to the other EACs. When the EAC for Field
Operations received the Program Office’s subsequent draft, he determined
that the revised draft did not adequately consider or incorporate field
concerns. The EAC for Field Operations sent his own draft proposal for a
deployment plan to the field units with assumptions different from those
in the plan prepared by the Office of Programs. The field units provided
input to the second draft proposed by the Office of Field Operations.
Subsequently, the Deputy Commissioner intervened and instructed the
two EACs to develop a single proposal that they could agree upon.

Another example provided to us involved the selection of employees from
the field to train as instructors for firearms courses. A district manager
said that headquarters Field Operations staff asked the region to provide a
list of employees to attend instructor training for new firearms that were
being issued. The district manager provided a list to headquarters of
employees that the district wanted to recommend for instructor training.
The headquarters Field Operations staff selected employees from the list
to attend the training.

Subsequently, the headquarters Programs office staff asked the district
manager to provide a list of employees to be trained as instructors for the
firearms training. The district manager provided the Office of Programs
the same list of employees recommended for instructor training, and the
staff in the Programs office selected from it. The Office of Programs and
the Office of Field Operations selected different employees from the lists
provided. It was initially unclear to the district manager who was
responsible and had the authority to select employees for instructor
training. The Office of Programs ultimately made the decision on who




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                           would take the instructor training but, according to the district manager
                           who provided this example, field staff were confused and frustrated by the
                           situation.

                           Some headquarters and field managers whom we interviewed told us that
                           it is difficult to separate program planning activities and operational
                           activities. For example, some headquarters managers said it is clear that
                           the Office of Programs is responsible for such things as planning where
                           resources should be allocated and that the Office of Field Operations is
                           then responsible for implementing the use of resources as planned. But, as
                           stated by an INS official, it is unclear where planning ends and
                           implementation begins. This had implications for where responsibilities
                           and authorities should begin and end and where coordination is needed.

                           An example that illustrates the difficulty in separating program planning
                           and implementation was the development of a new automated system for
                           allowing people to enter the United States at remote locations along the
                           northern border.6 According to INS officials, the headquarters program
                           office was working with staff in the district office in Montana to test the
                           use of new systems for the northern border. The headquarters Program
                           Office manager and the staff in Montana proceeded to develop the new
                           systems without including the region or the Office of Field Operations
                           until they needed staff for the project. The region did not know that it
                           would have to provide a staff position to the Montana office in order to
                           implement the new technology until the Program Office contacted the
                           Field Operations office when the resource was needed. The region was not
                           involved in the program planning for this initiative but was eventually
                           responsible for providing the district resources to support it. This started
                           out as a planning activity but became an operational one.


Communication Processes    In a February 1994 memo to INS employees, the Commissioner stated that
Within the New Structure   the new organizational structure would build communication capabilities.
Had Not Been Clearly       As one of its new responsibilities, the Office of Programs was to develop
                           communication capabilities. However, under the reorganization, it had
Defined and                difficulty developing new communication paths with the rest of the
Communicated               agency. Managers in the Investigations Office of Programs told us they
                           initially thought that their chain of command for communicating with the
                           districts was through the Office of Field Operations. This reportedly

                           6
                            At selected remote ports-of-entry that are not open 24 hours, local residents on both sides of the
                           border are to be able to apply for a permit allowing them to cross the border during the hours when
                           the port is closed using new technology for identification. Montana piloted the use of computerized
                           voice recognition and video conference by inspectors located at the nearest 24-hour port-of-entry.



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became too burdensome over time. Consequently, according to these
headquarters program managers, the EAC for Field Operations provided
oral guidance to the field units on when it was appropriate for the
headquarters Programs Office to contact the field directly and when the
Programs Office should go through the Office of Field Operations.
However, headquarters program managers told us that in practice, some
headquarters Field Operations staff continued to require that all
communications go through their office. Also, field units continued to
consider their appropriate channel of communication to be through the
regions and the Office of Field Operations. At the time of our review, INS
had not provided any written guidance on what needs to be communicated
and coordinated and when it should happen.

In March 1996 we met with the Commissioner and Deputy Commissioner
to obtain their perspectives on particular problems that managers in the
agency had described to us. During this meeting they told us that it would
be appropriate for field managers to communicate with headquarters
program managers without going through the Office of Field Operations
when program managers are seeking information or getting the field’s
input. The Commissioner told us that headquarters program managers
need to talk with the field to develop policies and assess the effectiveness
of policies. According to the Deputy Commissioner, the headquarters
program managers should go through the Office of Field Operations and
regional directors when they are tasking the field to do something that will
involve consumption of operational resources.

Nonetheless, according to headquarters program managers, some staff in
the Office of Field Operations continued to require program staff to go
through their office before contacting the field. This was reportedly the
case regardless of the purpose of the contact. Some headquarters program
managers reported that they have received mixed messages from the
Office of Field Operations on the circumstances under which they can
communicate directly to the field.

Another example of problems with the channels of communication
pertained to who had responsibility for a priority and the lack of
coordination between offices. We were told by some INS managers that
communication problems had occurred between the Office of Policy and
Planning and the Office of Programs. Headquarters program managers in
the investigations program area believed that the Office of Policy and
Planning had developed a priority objective for antismuggling but had not
consulted with the headquarters investigation managers even though the



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                          headquarters investigations program area has an antismuggling branch
                          that has a role in planning for the area. The investigations program
                          managers responsible for antismuggling activities said they would have
                          liked to have been involved. According to one official, it was unclear
                          whether the Office of Policy and Planning did not see a need for their
                          involvement or if there were not enough people in the Office of Policy and
                          Planning to coordinate the sharing of products. However, according to an
                          Office of Policy and Planning official, the EAC for Field Operations—not
                          Policy Planning—was the lead official for a priority that included this
                          objective. The official said that the Office of Field Operations did not
                          include the Office of Programs Investigations Division staff in the process
                          and, thus, was not employing the proper approach to priority management
                          by involving appropriate offices.


Survey Responses          INS managers responding to several questions in our September 1995
Reflected Problems With   survey indicated that there were problems coordinating and
Communication and         communicating, particularly between headquarters and field units.
                          Sixty-three percent of the managers indicated that poor communications
Coordination              was a problem to a great and very great extent.7 Ninety-two percent of the
                          managers responded that headquarters should consult more with the field
                          when developing policy. Seventy-three percent of the managers responded
                          that headquarters was not in touch with events, problems, and concerns of
                          the field. Fifty-nine percent of the managers responded that coordination
                          and cooperation among INS units needed improvement to a great or very
                          great extent. Although field managers were more likely to respond that
                          headquarters should consult the field more and that headquarters was not
                          in touch with events and concerns of the field, a majority of both
                          headquarters and field managers responded that there was a problem.
                          Table 2.2 presents these survey results for all managers combined and for
                          headquarters managers and field managers separately.




                          7
                           The analysis of survey data in this paragraph does not include respondents who answered “no basis to
                          judge.”



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Table 2.2: Survey Responses Indicate Communication and Coordination Problems
                                                                                                        Percent of
                                                                                                All     Headquarters          Field
Question                         Statement                      Response category          managers        managers       managers
Thinking about the               Headquarters should            Agree or strongly agree          92                  83         95
implementation of INS            consult more with the field
internal policy, would you       when developing policy.
agree or disagree with the
following statements as they
apply servicewide?


Do you agree or disagree         Headquarters is in touch       Disagree or strongly             73                  64         76
with the following statements    with events, problems, and     disagree
concerning INS as an             concerns in the field.
organization?


In your opinion, to what         Coordination and               To a great or very great         59                  70         56
extent, if at all, do you feel   cooperation among INS          extent
the following areas need         units.
improvements servicewide?


                                                 Source: Analysis of GAO 1995 survey.



                                                 The following written comments from INS managers in our survey further
                                                 illustrated the perceived problems with communication and coordination
                                                 in the fall of 1995:

                                             •   “The Commissioner’s reorganization has created so many layers of
                                                 oversight that it delays all communications to the field. Even on routine
                                                 program or operational matters, all communications must go through the
                                                 EAC for Field Operations.”
                                             •   “Since the reorganization, the lines of authority and communication
                                                 between Programs and Field Operations have become more complex. We
                                                 need better understanding and cooperation among all INS functions.”
                                             •   “The reorganization has created lots of confusion in our office. Many areas
                                                 do not know if they report to the regional office or headquarters . . . .
                                                 There is no clear definition of who reports where.”




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INS Attempted to Clarify   INShas taken actions to try to solve some of the concerns about roles,
Responsibilities and       responsibilities, and communications. In April 1995, the EAC for Field
Communication Processes,   Operations sent an electronic mail message to the western region
                           requesting feedback on the reorganization and suggestions for
but Problems Had Not Yet   communication mechanisms. The Western Regional Director forwarded
Been Resolved              the request to the districts and sectors under his jurisdiction and then
                           provided their comments to the Office of Field Operations. Several district
                           directors and Border Patrol chiefs reported many of the same
                           coordination and communication problems that were reported to us from
                           the cross-section of managers whom we interviewed. We could not
                           determine whether a message had been sent to the other regional offices,
                           but the regional managers for the eastern and central region told us that
                           they did not remember such a request.

                           In August 1995, the EACs and staff from the headquarters Field Operations
                           and Programs offices met and discussed their roles, responsibilities, and
                           communication issues. The EAC for Field Operations summarized the
                           results of the meeting and communicated them to the regional and
                           international affairs directors. The summary defined the roles of each of
                           the offices.

                           The summary said that Field Operations was looking to the Office of
                           Programs to develop plans, conduct analysis, and devise tools for tracking
                           progress in the field. In addition, according to the EAC’s summary, the
                           group agreed that the Office of Programs would conduct an inventory of
                           reports that it prepares that could be shared with the Office of Field
                           Operations. The summary also stated that the group agreed there would be
                           more active sharing of information between the two offices.

                           The EAC’s summary listed actions to be taken by the Office of Field
                           Operations and the Office of Programs. These included developing
                           mechanisms for Field Operations to provide input to the Office of
                           Programs and clarifying Field Operations organizational structure for
                           liaison purposes. The summary also recommended that the Office of
                           Programs and the Office of Field Operations set up regular meetings at the
                           assistant commissioner level with structured agendas. Furthermore, the
                           summary presented other ideas that the group discussed, such as
                           (1) having an 800 number for the reporting of problems and incidents,
                           (2) including managers from the Office of Management in a later meeting,
                           and (3) discussing at a later meeting where the Office of Policy and
                           Planning fits in.




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                             According to an INS official in the Office of Field Operations, the summary
                             was provided to the regional directors but was not shared with the Office
                             of Programs. The Office of Programs did not prepare a summary of the
                             meeting, according to officials in that office.

                             In the spring of 1996, we interviewed several headquarters investigations
                             and detention and deportation program managers about problems
                             between headquarters and field managers. We also recontacted some field
                             managers in the central and western regions about problems described to
                             us earlier in the review. According to several headquarters program
                             managers, some improvements had occurred, but communication
                             problems continued. The weekly meetings between the managers in the
                             individual program offices and the Office of Field Operations provided a
                             mechanism for sharing some information on routine operations, but the
                             participating officials did not have the authority to make major decisions.
                             Several field managers that we recontacted told us that there was still
                             confusion in the field regarding responsibilities and communication. A
                             recent example of continuing communication problems was reported by a
                             consultant to the Justice Department who was reviewing INS’
                             naturalization procedures. The consultant reported that three different
                             versions of guidance on naturalization procedures had been distributed
                             throughout INS and that some offices were using the wrong version. One
                             version was a copy of the memorandum signed by the Commissioner,
                             another was an unsigned electronic version of the memorandum with
                             different attachments, and the third was an early version drafted for the
                             Deputy Commissioner’s signature.


Staffing Level for the       Several managers whom we interviewed stated that the Office of Field
Office of Field Operations   Operations had not been sufficiently staffed to accomplish its function and
Was Perceived to Be          duties. According to the EAC for Field Operations, the initial plan for the
                             reorganization intended that the Office of Field Operations have a
Insufficient                 relatively small staff and that the regional office staff be an extension of
                             the headquarters office. The expectation was that regional offices would
                             be more involved with the districts and sectors and would respond to their
                             needs. However, as the reorganization evolved, the headquarters office
                             found that it needed more staff at headquarters to accomplish its
                             functions. A June 1994 organization chart provided for 29 positions in the
                             Office of Field Operations. According to an INS official in the Office of
                             Field Operations, as of March 1996, the Office of Field Operations had 41
                             authorized positions, of which 32 were filled. No analysis had been done to




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                           determine what the staffing levels should be in relation to the
                           responsibilities of the headquarters Office of Field Operations.

                           Headquarters investigations managers in the Office of Programs provided
                           an example of the problem of insufficient staffing level in the Office of
                           Field Operations. Within the Field Operations office, three people handled
                           field issues for investigation activities; and in each of the three regions,
                           three or four staff were dedicated to investigations work. According to the
                           headquarters program managers in investigations, the investigations staff
                           in the Field Operations Office were overwhelmed because there were
                           about 2,000 investigators in the field units seeking assistance from the few
                           staff in the regional office and headquarters Field Operations. Several
                           managers told us in interviews and through written comments on our
                           September 1995 survey that the headquarters field operations office was
                           not sufficiently staffed to handle the workload.

                           Some Office of Programs managers told us that they felt that they had to
                           respond to field inquiries and assist the Office of Field Operations because
                           that office was unable to handle the numerous calls and accompanying
                           heavy workload. According to these headquarters program officials, field
                           managers called them for assistance because they were unable to reach
                           headquarters Field Operations staff. However, some staff in the
                           headquarters Office of Field Operations perceived that headquarters
                           program officials were unwilling to relinquish the authority they formerly
                           had over field operations.


Staffing Level for the     According to managers in headquarters, the regional offices, and field
Office of Programs Had     units, staffing levels for the Office of Programs were not changed as a
Reportedly Not Been        result of the reorganization even though the responsibilities of the office
                           had changed.
Reassessed After
Responsibilities Changed   Some managers outside of the Office of Programs perceived that there was
                           an imbalance between resources in the Office of Programs and the Office
                           of Field Operations, and some survey respondents commented that the
                           personnel resources of the Office of Programs remained the same despite
                           the change in its role and responsibilities. For example, at headquarters,
                           the Office of Programs had 531 authorized positions compared to the 41
                           authorized positions in the Office of Field Operations in March 1996.
                           Further, the investigations program in the Office of Programs had 46 staff
                           and, as mentioned previously, the Office of Field Operations’
                           investigations staff consisted of 3 people, according to INS officials. It



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                              would seem logical that with changed responsibilities, INS would need to
                              reassess its staffing of this office.


Leaving Operational           One of the objectives of the reorganization was to separate program
Activities in the Office of   planning and operational activities so that headquarters program
Programs Caused Some          managers could focus on program planning and not be involved in the
                              day-to-day operations. However, INS management decided that some
Confusion                     operational activities should remain in the Office of Programs. According
                              to the headquarters program managers whom we interviewed in the
                              Investigations and Detention and Deportation Offices, some operational
                              activities were left in the headquarters Office of Programs because the
                              workload needed to be done at headquarters and was too large for the
                              Office of Field Operations to take over. These program managers also told
                              us that another reason operational activities were left in the headquarters
                              Programs office was that the staff had particular expertise in a particular
                              program area that was relevant to both planning and operations.
                              According to the Commissioner and Deputy Commissioner, INS needed the
                              mix in expertise of staff left in the Programs Office to do the program
                              planning functions. However, headquarters program managers told us that
                              because they continued to do operational activities, they did not feel that
                              they were able to devote enough time to planning activities.

                              We did not identify all the operational activities that continued to be the
                              responsibility of the Office of Programs, but through interviews we were
                              able to identify a sample of the kinds of operational activities that
                              remained there. Management of the Mariel Cubans8 and juveniles in
                              detention facilities are two activities that were left in the Office of
                              Programs. According to INS officials, the caseload for processing Mariel
                              Cubans was too large for the newly created Office of Field Operations to
                              handle. In the case of juveniles, headquarters program managers told us
                              that they had the expertise to contract for juvenile bed space. Until the
                              reorganization, the Office of Programs’ detention and deportation staff
                              handled both the planning and operational aspects of detaining juveniles.
                              Since they had the experience, INS management decided to have the staff
                              in Programs continue handling both planning and operations for juveniles.
                              Other operational activities that remained in the Office of Programs
                              included processing of applications for immigrant benefits through INS’
                              four service centers, oversight of the witness security program, and review
                              and approval of requests for authority to conduct undercover operations.


                              8
                               Mariel Cubans are Cuban nationals who were allowed to enter the United States as refugees in 1980.



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                       We found no evidence that field units were unable to accomplish their
                       missions because some operational functions remained in the Office of
                       Programs. However, several headquarters and regional managers told us
                       that having operational functions remain in the Office of Programs
                       contributed to the confusion regarding when and how to coordinate with
                       the Office of Field Operations.


                       Through the reorganization, INS sought to create a structure that would
Field and Policy       enable it to reengineer major processes, such as those that develop and
Manuals Still Have     disseminate organizational policy and guidelines. We reported in 1991 that
Not Been Updated       policy information was outdated, and we found in this review that policy
                       information still has not been updated. INS was in the process of updating
                       manuals in some program areas but not in others. Sections of the manuals
                       are to be issued as they are completed, but no revised manuals or sections
                       of manuals had been issued as of February 1997.9


INS Was Beginning to   Six program areas10 are to have field manuals containing policies and
Update Field Manuals   procedures on how to implement the immigration laws. These field
                       manuals are basic reference tools for managers. For example, INS
                       managers rely on the inspector’s field manual to explain the procedures
                       for inspecting cruise ships and cargo vessels and the necessary forms for
                       each of these inspections. If a stowaway is found, the field manual also
                       explains the procedures INS employees are expected to follow.

                       According to an INS official, until 1995, no work had been done on the
                       manuals for about 5 years. To help alleviate this problem, in November
                       1995, INS assigned a project officer specifically responsible for updating
                       manuals.11 The project officer told us that in the past and at the time of our
                       review, completion of field manuals had been delayed because staff
                       assigned to develop them had been sidetracked to develop regulations to
                       implement legislation. In a briefing report used in March 1996, INS stated
                       that the lack of updated field manuals had created a burden for employees
                       because they had to search out too many sources of information on


                       9
                        In commenting on a draft of this report, INS officials said that agreement had been reached with INS
                       unions that 51 of the 295 chapters of the administrative manual needed only minor modifications and
                       did not affect work practices. INS staff were notified in April 1997 that those chapters were issued in
                       computerized form.
                       10
                         The six program areas are inspections, adjudications and nationality, detention and deportation,
                       investigations, Border Patrol, and intelligence.
                       11
                           This excludes the Border Patrol manual, which is being updated by the Border Patrol Program Office.



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                            immigration laws or regulations. This had reportedly made it difficult for
                            employees to follow INS procedures because they received conflicting
                            information on procedures. The briefing report said that the lack of
                            current manuals also led to field officers creating policy locally, and this
                            compounded the confusion and the difficulties in coordination.

                            INS was in the process of updating the Inspections Field Manual and
                            expected that parts of the revised manual would be issued in May 1997. INS
                            began updating the Adjudications and Nationality Field Manual in March
                            1996. The project officer said that in the spring of 1996 he had also held
                            preliminary meetings with the detention and deportation and
                            investigations program area officials to discuss updating their manuals.
                            However, according to the project officer, as of February 1997, nothing
                            more had been accomplished on these manuals because he had to respond
                            to a higher priority to develop legislatively mandated regulations. The
                            intelligence program area is to have a chapter in each of the other five
                            program area field manuals in addition to having its own general manual
                            on procedures to follow for reporting intelligence information. The
                            Intelligence Program Office is to develop the general Intelligence Field
                            Manual.


INS Had Drafted a Revised   INS staff rely on the administrative manual to provide information on
Administrative Manual but   internal technical policies that are not related to immigration law. The
Was Not Sure When It        administrative manual includes information on procedures, such as cash
                            collection, disciplinary actions, firearms, uniforms, personnel issues, and
Would Be Issued             financial management. INS took about 2 years to revise the manual, and
                            several additional years have passed as changes were being negotiated
                            with the employee unions.

                            According to an INS official, as part of the partnership agreement that INS
                            has with its employee unions, the unions can review changes to the
                            administrative manual and field manuals. When INS completed a draft of
                            the administrative manual in 1993, the two unions were given the draft to
                            review. According to INS’ labor relations manager and a union president,
                            the changes made to the administrative manual were voluminous, and the
                            unions were unable to review it expeditiously. As a result, negotiations
                            with the unions on the changes have gone on for more than 3 years. In the
                            spring of 1996, INS management and the unions agreed on a list of sections
                            in the draft manual that needed to be reviewed with the unions and have
                            prioritized the list to expedite the process. The section on use and storage
                            of firearms is the first item on the priority list.



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    Due to the negotiations between INS and the unions, INS had not yet
    established a timeline for completing the revised administrative manual as
    of February 1997. According to the INS official directing the field manuals
    project, sections of the administrative manual may be issued when they
    are finalized with the unions. To avoid similar delays with the field
    manuals, INS management was seeking agreement with the unions on small
    sections of each manual as they are approved by INS management. This
    was done with the draft section of the Inspections Manual and worked
    well, according to the project officer.

    The following written comments by respondents to our survey illustrate
    INS’ problems communicating policies and procedures in the fall of 1995:


•   “The Administrative Manual is extremely out-of-date. There have been
    numerous times that I have researched an issue and arrived at a
    conclusion, only to be told by [the] Region that, ‘That’s so old; we don’t
    follow that anymore.’ If it’s still ‘on the books’ then I should be able to use
    it as a tool for completing my work. Of course, the alleged current policy
    or procedure is rarely validated by a written issuance.”
•   “With regard to . . . policy implementation, field personnel all do their own
    thing. There is not one place an officer can go for direction. The . . .
    operating instructions are out of date and policy wires often don’t make it
    to the field.”
•   “The reorganization was recent, and it is understandable that policies and
    procedures may still be in the process of being developed, but
    headquarters should at least communicate that guidance is in process and
    provide interim guidance. As an example, legislation effective October 1,
    1995 calls for charging fees for some services at the land border. No policy
    guidance for collecting the fees has been issued. Over $50,000 was
    collected in San Diego the first week. Apparently, there was a disconnect
    between the Office of Programs and the Office of Field Operations about
    who is responsible for implementing the program. It should be a
    coordinated effort. Even if headquarters is still in the process of
    developing the policies and procedures, interim guidelines, such as ‘follow
    the district’s cash collection procedures’ would have been fine.
    Headquarters does not see the urgency. They do not see the people lining
    up with applications.”
•   “I was recently told by a regional staff employee that it was not the policy
    to put things out in writing. How are employees suppose[d] to know what
    to do if they are not told. I believe the word is ‘chaos.’ (confusion)
    [Headquarters] needs to know [and] understand the needs of district [and]
    sectors. [Headquarters] needs to establish written policies in a multitude



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                          of areas using input from field office personnel. [Headquarters] must
                          communicate with regional personnel as well as field offices when
                          establishing procedures.”
                      •   “Dissemination of policies in my unit is sometimes through hearing instead
                          of in writing . . . execution of policies differ greatly . . .”


                          INSidentified goals for the reorganization to help it manage better. We
Survey Results on         asked a question on our survey about the success of the reorganization in
Gains Made as a           accomplishing INS’ goals, and respondents to the survey had mixed
Result of                 opinions. Concerning the reorganization’s success in clarifying lines of
                          authority, for example, 20 percent of the managers responded that the
Reorganization Were       reorganization was very successful or somewhat successful, 21 percent
Mixed                     responded that the reorganization was as successful as unsuccessful, and
                          41 percent responded that the reorganization had been somewhat or very
                          unsuccessful. Another 15 percent of the managers responded that they had
                          no basis to judge. Table 2.3 presents the question that we asked managers
                          and responses by INS’ managers on the success of the reorganization in
                          achieving some of the goals. A complete list of the goals and managers’
                          responses can be found in appendix IV.




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Table 2.3: Managers’ Responses to the
Question: Generally, How Successful
or Unsuccessful Do You Think the
Reorganization Has Been in Achieving
the Following Goals?                    Goals
                                        Clarifying lines of authority
                                        Delegating authority to persons geographically closer to locations where work is being
                                        done
                                        Decentralizing decisionmaking authority
                                        Improving processes to develop and disseminate organizational policy and guidelines




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                                          Managers responding
   Very or
 somewhat    As successful as    Somewhat or very          Goal achieved prior to         Too early to   No basis to
successful      unsuccessful        unsuccessful                  reorganization                  say         judge
       20%                21%                      41%                             2%               3%           15%
       22                 18                       36                              1                4            20

       22                 18                       35                              1                5            20
       17                 21                       44                              1                4            13
                                Note: Percentages may not add to 100 percent due to rounding.

                                Source: Analysis of GAO 1995 survey.



                                There were several possible reasons cited by various INS managers as to
                                why the percentage of managers who thought the reorganization had been
                                unsuccessful in achieving certain goals was roughly twice as great as the
                                percentage who thought the reorganization had been successful. First,
                                they said overlaps in the roles and responsibilities of the Offices of
                                Programs and Field Operations may have led managers to believe that
                                lines of authority were unclear. Second, we were told that regional
                                directors did not assume all of their new authority immediately, and the
                                agency was going through a transition phase the first year. Thus, some
                                managers could have perceived that the reorganization had not
                                accomplished its goal for delegating authority closer to where the work is
                                performed or decentralizing authority. A third reason given was that not
                                enough time had passed for significant changes to occur. For example,
                                some of the goals of the reorganization, such as developing planning
                                capability, improving the delivery of services, and establishing quantitative
                                performance measures, could take several years to accomplish.
                                Furthermore, INS had not begun to implement some of the strategies to
                                achieve its goals. For example, in March 1996, the Commissioner told us
                                that the agency has not formalized processes to disseminate information
                                and procedures.

                                In April 1996, INS’ Office of Policy and Planning began a review of the 1994
                                reorganization. According to an INS official, the review was an ongoing
                                effort, and, as the need for organizational changes or refinements are
                                identified, changes can be included in future INS plans and budgets.




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              INShas taken some steps to address long-standing management problems.
Conclusions   INSdeveloped a strategic plan and initiated an annual priorities
              management process—initial steps in the Results Act process. We believe
              that such efforts are important components of effective planning and
              decisionmaking. The priorities process had top management support, had
              been linked with planning and decisions for resource allocations, and had
              been clearly communicated throughout the organization. The long-term
              impact is yet to be determined and will require that top management
              persist in its commitment to using priority management for planning and
              decisionmaking.

              INSachieved some of its management goals for the reorganization, but, as
              can be expected in the first years of implementing a new structure, not all
              management goals were achieved. INS reestablished a regional structure
              with oversight responsibility of district directors and Border Patrol chiefs;
              and regional directors have been delegated authority to manage the field
              resources, which places responsibility closer to where the work is
              performed. It is too soon to determine whether the organizational changes
              will improve customer services and enforcement activities.

              According to many managers we interviewed, the lack of delineation of
              responsibilities and authority between the Office of Programs and the
              Office of Field Operations had caused confusion for headquarters and field
              managers. For example, separate requests to a field manager from each of
              the offices to identify trainers resulted in a duplication of effort and in
              different employees being selected as potential trainers from the same list.
              Furthermore, headquarters and field managers perceived that too many
              decisions that should be resolved at the EAC levels had to go to the Deputy
              Commissioner for resolution because lines of responsibility and authority
              were not clear. The agency had not clearly defined the responsibilities and
              authority of the Office of Field Operations and the Office of Programs in
              relation to each other and to other INS units and had not clearly defined
              how and when these offices should coordinate with each other.

              INS’new structure and the Commissioner’s Priority Program had created
              new ways of communicating. Managers reported to us that they were
              confused and frustrated about when and how to communicate with each
              other. INS’ new structure and the Commissioner’s Priority Program
              required that communication and coordination cut across the agency. The
              EAC for Field Operations had reportedly provided oral guidance on
              communications between the Office of Programs and the field units and
              had taken some actions to address communication problems. However,



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these efforts did not appear to have provided a clear understanding of
what communication is needed and when it should occur. INS had not
provided any written guidance on what needs to be communicated and
coordinated and when it should happen for this new way of working.

The agency reorganized in 1994 and created a new Office of Field
Operations, created new Regional Director offices, and changed the role of
the previous EAC for Operations to EAC for Programs. However, the agency
did not determine what resources would be needed for these offices to
carry out their new responsibilities. One of INS’ goals for the reorganization
was to enhance program planning capabilities by relieving headquarters
program managers of responsibility for day-to-day operations. Yet, some
operational activities remained with the Office of Programs. According to
headquarters program managers, they did not have any more time for
program planning as a result of the reorganization. Although INS provided
reasons for some activities remaining in the Office of Programs, this may
be counterproductive to accomplishing an intended goal of the
reorganization to create a clearer sense of mission by separating policy
planning, program planning, and field operations.

INS’field and administrative manuals had not been updated since we
reported the lack of policies and procedures as a problem in 1991. One of
the goals of the reorganization was to improve the processes for
dissemination of organizational policy and guidelines. The lack of current
manuals made it difficult for employees to carry out their mission-related
activities and led to field officers creating policy locally. The agency was in
the process of revising some of the field manuals and finalizing approval of
the revised administrative manual. In the past and at the time of our
review, completion of field manuals had been delayed because staff
assigned to develop them had been sidetracked to develop regulations to
implement legislation. The administrative manual had not been issued
because of negotiations between INS and its two unions. INS had not
established milestones for issuing manuals or parts of manuals. Having
milestones could help INS management to recognize when slippage occurs
and focus the need to remain vigilant with respect to issuing current
guidance.

Overall, we found that the reorganization had addressed some of the
management problems identified in past reports, but the reorganization
had not been fully implemented. INS was beginning to evaluate the 1994
reorganization as we concluded our review.




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                      We recommend that the INS Commissioner take the following actions to
Recommendations       help achieve the reorganization goals:

                  •   provide written guidance to all INS managers on the responsibilities and
                      authority of the EACs for Field Operations and Programs in relation to each
                      other;
                  •   provide written guidance on the appropriate coordination and
                      communication methods and channels between offices to include
                      (1) when and how Field Operations and Programs should coordinate and
                      communicate with each other, (2) when and how the Office of Programs
                      should coordinate and communicate with the regional offices and the
                      districts and sectors, and (3) when and how the Office of Policy and
                      Planning should coordinate and communicate with the other offices;
                  •   determine whether staffing levels need to be adjusted for Programs, Field
                      Operations, and regional offices to accomplish their prescribed roles and
                      responsibilities consistent with the respective mission and workloads for
                      each office;
                  •   establish milestones for issuance of manuals or parts of manuals that can
                      stand alone; and
                  •   incorporate into INS’ current evaluation of the reorganization the issues
                      raised in this report so that they can be addressed as INS attempts to fully
                      achieve the goals of the reorganization.


                      INS provided written comments on a draft of this report, which are printed
Agency Comments       in full in appendix VI. INS said that it agreed with our assessment that some
                      objectives of the reorganization had not been achieved and stated that it
                      has proposed changes to improve lines of responsibility that address many
                      of the concerns raised in the report.

                      INSprovided technical comments separately, which we incorporated
                      where appropriate. INS also provided updated information on the
                      administrative manual. According to INS officials, INS and the unions
                      reviewed 85 of the 295 chapters of the administrative manual to identify
                      ones that needed only minor modifications and did not constitute changes
                      in working conditions. Following this review, 51 chapters were issued in a
                      computerized format in December 1996, and the EAC for Management sent
                      a memo to field offices in April 1997 to inform staff that these new
                      chapters were available for their use. We added this information to our
                      report. INS was to meet with union representatives again in June to review
                      another group of 70 to 80 chapters to identify ones that require minor
                      modifications and do not constitute changes in working conditions so that



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more chapters can be issued. Chapters that need further negotiation are to
be handled at a later date.




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                    In 1991, we reported that INS’ budget allocations had not been based on
                    agencywide priorities, INS had not adequately used workload information
                    as a factor in making budget allocations, and budget management and
                    resource allocation problems perpetuated backlogs for processing aliens’
                    applications for naturalization and adjustment of status. We also reported
                    that INS’ primary accounting system was outmoded and had weak internal
                    controls, and the use of unreliable financial information had resulted in INS
                    inadequately monitoring its budgetary resources.

                    During our review of INS’ fiscal year 1995 budget execution process, we
                    found that INS (1) had improved its management of budget resources by
                    using annual priorities to help make budget allocation decisions and using
                    workload information for planning to some extent in four of its six
                    program areas,1 and (2) was seeking to improve its capability to use
                    workload information in each of its program areas. However, problems
                    persisted because INS continued to (1) experience resource allocation
                    problems that caused field offices to have backlogs in processing alien
                    applications and (2) lack accurate, complete, and consistent data to
                    efficiently monitor budgetary resources.

                    INShas been taking steps intended to improve workload analysis, improve
                    the data it uses to monitor the budget, and implement a new financial
                    management system. Although these steps, if fully implemented, should
                    move INS in a positive direction toward resolution of the problems we
                    identified, continued top management attention to monitoring progress
                    and reducing the risks associated with these initiatives will be necessary.


                    For several years, INS acknowledged the need to make better use of the
INS Made            agency’s financial resources. Accordingly, INS took several steps intended
Improvements in     to improve its allocation of budgetary resources. INS sought to find ways to
Planning Resource   better match resources to workload demands and performance at each
                    field location and to more strongly link program activities to strategic
Allocations         planning. As discussed in chapter 2, INS initiated a strategic planning
                    process that tied annual priorities and performance measures to resource
                    allocation. In addition, steps were taken to improve the use of workload
                    data in deciding how to allocate resources in the six major INS program




                    1
                     Adjudications and nationality, Border Patrol, detention and deportation, inspections, intelligence, and
                    investigations are the six major INS program areas.



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                       areas. Also, for the first time, INS developed a table of organization2 to
                       assist the various field and program units in planning and managing
                       personnel resources. In addition, deployment plans were being used in
                       fiscal year 1996 to allocate new resources. Finally, INS developed a
                       long-range growth management plan to assist the agency in accomplishing
                       its resource allocation goals of directing the additional resources provided
                       by Congress to priorities and workload demands.


Resource Allocations   As discussed in chapter 2, in 1995 INS began implementing a priorities
Linked to Priorities   management process to establish annual priorities in support of, among
                       other things, its strategic plan. The purpose of these priorities was to
                       provide a means of monitoring crosscutting program initiatives important
                       to the agency’s mission. They provided a mechanism to tie agency
                       resources to annual priority activities. Under this approach, senior INS
                       executives were required to make recommendations to the Commissioner
                       on priorities for budget formulation, allocations for budget execution, and
                       other resource issues that have an agencywide effect. The goal was to
                       ensure that allocation of budgetary resources supports the
                       Commissioner’s annual priorities.

                       INS receives funding through the appropriations process from several
                       sources. These sources include: (1) general revenues, (2) the Violent
                       Crime Reduction Trust Fund3 (VCRTF), and (3) various fees paid by users of
                       immigration services. INS linked its allocation of additional resources from
                       these funds to program initiatives and annual priorities. At the beginning
                       of fiscal year 1995, INS instituted a priorities implementation review
                       process that established connections among the strategic plan, priorities,
                       budget initiatives, and program requirements. Extending this effort, INS
                       then linked the priorities implementation review sessions to its quarterly
                       financial review process. The quarterly financial reviews helped identify
                       needs for additional funding and the availability of resources that had not
                       been obligated and that could be reallocated to other priorities or agency
                       needs. The intended outcome of the linkage was to ensure that resource
                       allocation decisions were consistent with the agency’s annual priorities.




                       2
                        A table of organization is a document prepared by INS’ Office of Budget in conjunction with the
                       various field and program units. It provides detailed information to unit managers on authorized
                       funded staffing levels.
                       3
                        A separate account in the Treasury, the Violent Crime Reduction Trust Fund was created by the
                       Violent Crime Control and Law Enforcement Act of 1994 (P.L. 103-322, 42 U.S.C. 14211). Amounts in
                       the Fund are to be used for the purposes authorized in that act.



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Steps Taken to Better    INS has taken steps to better use and incorporate workload
Incorporate the Use of   models—referred to in INS as workload analysis models (WAMs)—into its
Workload Information     budget allocation decisions. The purpose of WAMs is to help determine the
                         distribution of current personnel resources and to base projected future
                         staffing needs on operational priorities and cross-cutting programmatic
                         needs. WAMs were designed as a management tool to assist INS officials in
                         basing program resource allocation decisions on workload distribution
                         while maintaining flexibility to respond to changing events, circumstances,
                         and emerging priorities. Under the reorganized management structure
                         created in 1994, the role of INS’ program offices was to shift away from
                         managing field resources. The new focus of these offices was to be on
                         program development and integration that anticipate growing workloads
                         and demands on the agency. Program offices were to be primarily
                         responsible for developing, maintaining, and utilizing WAMs that provide INS
                         managers with information to enable them to respond to changes in
                         workload demands. Much of the information included in the workload
                         models relies on workload data from the various INS field and service
                         units.

                         We interviewed cognizant officials and found that the type and use of
                         workload information varied among the six major INS program areas. As
                         table 3.1 shows, during fiscal years 1995 and 1996, four of the six program
                         areas used workload data to some extent for planning and allocation
                         purposes. Inspections used a WAM; adjudications used WAMs for service
                         centers, but not for district offices; investigations had a WAM in place, but it
                         was not used; intelligence had no model but utilized workload
                         information; and neither Border Patrol nor detention and deportation had
                         WAMs or used workload data to project how to allocate budgetary
                         resources.




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Table 3.1 INS’ Use of WAMs and Workload Data in Planning Fiscal Year 1995 and 1996 Resource Allocations
                             WAM in place?      Workload data used?
INS Program                 Yes      No             Yes        No           Brief description of situation
Adjudications and                                                           WAM was used to recommend allocation of resources
Nationality                                                                 among adjudication service centers.
—Service Centers            •                       •                       No evidence that WAM was used for planning and
—District Offices                    •                         •            projecting allocation of resources in district offices.

Border Patrol                        •                         •            According to an INS official, allocation of resources in this
                                                                            program area in fiscal year 1995 was decided primarily
                                                                            by program initiatives and agency and congressional
                                                                            priorities, which continued into fiscal year 1996.
Detention and Deportation            •                         •            INS had entered into a contract to develop a WAM for this
                                                                            program area. No evidence of the use of workload data in
                                                                            planning and projecting resource allocations.
Inspections                 •                       •                       Detailed WAM and automated workload data collection
                                                                            system were in place and were used in planning and
                                                                            projecting resource allocations.
Intelligence                         •              •                       No WAM existed. An INS official said that INS utilized
                                                                            workload information in making resource allocation
                                                                            decisions in fiscal years 1995 and 1996.
Investigations              •                       •                       Detailed WAM was in place. However, it had not been
                                                                            used in planning and projecting resource allocations
                                                                            since 1992. Workload information was considered in
                                                                            making some of the resource allocation decisions in fiscal
                                                                            years 1995 and 1996.
                                          Source: INS documents and interviews with cognizant officials.



                                          Inspections, investigations, and the adjudications service centers had
                                          mathematical workload analysis models. Inspections’ model seemed to be
                                          the most sophisticated because it took baseline information from ports of
                                          entry and did computer simulations to estimate personnel resource needs
                                          under different scenarios and changing priorities. The investigations
                                          workload model used data to estimate a weighted workload based on the
                                          relative size of work among districts and the priority of the work area, e.g.,
                                          removal of criminal aliens and proactive investigations of major alien
                                          smuggling organizations to project future workload allocations. The
                                          adjudications service centers’ workload information was based on
                                          incoming receipts and the productivity per employee, among other things,
                                          to project resources needed to meet workload demands.

                                          Despite not having WAMs, the adjudications district offices and intelligence
                                          used workload information to decide how to allocate resources in fiscal
                                          years 1995 and 1996. Border Patrol resource allocations were based on



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                         priorities and program initiatives that among other things, sought to
                         increase the number of agents on the border to deter illegal entry into the
                         United States. The detention and deportation program area has a contract
                         with a firm to develop mathematical workload analysis models that are
                         intended to identify the most effective distribution of current personnel
                         resources and to project future staffing needs.

                         We did not attempt to evaluate how effectively the units were using WAMs
                         or workload data to help them allocate resources. We also did not attempt
                         to verify the quality of the workload data being utilized by the INS
                         programs. However, INS’ efforts to improve workload information and the
                         use of models to make resource decisions are steps in the right direction.


Other Steps Taken in     INS has taken further steps intended to improve the linkage between
Fiscal Year 1996 to      workload and the way it allocates and tracks the deployment of its
Improve Resource         resources. In fiscal year 1996, INS began providing tables of organization to
                         its various resource managers, developed deployment plans to manage the
Allocation               allocation of additional resources that were being provided by Congress,
                         and developed a long-range plan for growth management.

Tables of Organization   Tables of organization are a management tool intended to assist managers
                         with resource allocation planning. The information in the tables of
                         organization allows INS managers to compare the existing staff distribution
                         to funded personnel levels. According to INS headquarters officials, INS
                         tries to ensure that the tables of organization are updated quarterly to
                         reflect changes in authorized funded staffing levels. Prior to the use of the
                         tables of organization, INS resource managers did not have information
                         readily available on authorized funding levels to use in making hiring plans
                         and resource allocation decisions.

                         To alleviate this problem, INS began drafting tables of organization with its
                         resource managers starting with the fourth quarter of fiscal year 1995. The
                         first table of organization drafted was for the Border Patrol Program. In
                         April 1996, INS provided a draft consolidated table of organization to all
                         headquarters and field locations for review. The final version was
                         distributed in July 1996. The tables of organization are intended to help INS
                         manage staffing for the various INS units, including regional offices, Border
                         Patrol sectors, adjudications service centers, and district offices.

Deployment Plans         In fiscal year 1996, INS formalized the use of deployment plans with the
                         intent of ensuring that additional resources received during the year were



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                         allocated in a way that was consistent with priorities, program initiatives,
                         and identified workload needs. Deployment plans are management tools
                         intended to specify when and where to distribute new positions. These
                         deployment plans had generally been developed through an iterative
                         process that included statistical analysis and field input. For example, an
                         INS official responsible for managing the development of the deployment
                         plan for the interior border enforcement initiative said that WAMs and the
                         table of organization have served as a base of information for developing
                         deployment plans. INS’ Interior Enforcement Deployment Plan outlines
                         specific steps to be taken in fiscal year 1996 for the deployment of new
                         resources to key geographic locations in support of established priorities,
                         program initiatives, and workloads for fiscal year 1996.

Growth Management Plan   INSalso took steps in fiscal year 1996 to implement a growth management
                         plan that included long-range deployment planning and a management
                         process that tied into budget formulation and priorities planning,
                         incorporated congressional requirements, and projected general plans for
                         growth, by location. As part of this effort, INS had developed a long-range
                         plan that was intended to assist the agency in managing planned growth in
                         the size of its officer workforce and support staff through fiscal year 1998.
                         The growth management plan called for INS to implement its deployment
                         plans by building sound multiyear staffing models and to redesign its
                         deployment plans to incorporate projected growth. The growth
                         management plan outlined goals for recruiting, hiring, and training officers
                         and support staff and for ensuring field readiness to absorb planned
                         growth. INS intended to monitor these plans to ensure that any required
                         adjustments could be made in a timely manner.

Independent Study        In April 1996, INS hired a consultant to do an independent analysis of how
                         INS deploys its personnel resources, including an assessment of the
                         strengths and weaknesses of WAMs and deployment planning processes.
                         The results of the May 1996 independent study indicated that INS’
                         processes tended to be reactive rather than prospective and were driven
                         more by resources that were available than by a determination of actual
                         requirements. The consultant concluded in part that (1) workload was not
                         adequately captured and reflected in the processes that were intended to
                         recommend staff allocations and (2) WAMs currently in use needed to be
                         updated to better serve as forecasting tools. Among other things, the
                         consultant recommended that INS develop a minimum 5-year, rolling
                         strategic planning process; develop an INS-wide requirements-based model
                         to assist planners at all levels that builds on the strengths of existing




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                        stand-alone tools, such as WAMs; and conduct further analyses to formulate
                        a more integrated INS deployment planning process.

                        In response to these recommendations, INS hired another consultant to
                        identify deployment planning process improvements that were needed;
                        assess INS’ deployment planning requirements; develop a stand-alone,
                        automated deployment planning tool for INS, which included design,
                        installation, implementation, and testing of a prototype software program;
                        and train selected INS personnel on the implementation of the software
                        program. The prototype software program is to initially help plan for
                        deploying personnel resources by service locations and is to be capable of
                        expanding to include planning for training, equipment, and facilities. The
                        prototype is also to be compatible with existing automated staffing
                        models. The contractor was to accomplish its tasks by June 1997. INS
                        intends to contract for enhancements to the model for other resource
                        needs, such as equipment and facilities.


                        Approximately one-third of INS’ funds in fiscal year 1995 were derived from
Process for Notifying   fees, with the Immigration Examinations Fee Account being the largest.
Congress of Need for    The demand for examinations fee services, and therefore funding levels,
Additional Funds        fluctuates more than for other INS fee activities. Consequently,
                        examination fee levels are more likely to require adjustments after the
From Fee Account        current year budget has been enacted. If INS anticipates a need for a
Contributed to          change in funding authority as a result of higher or lower-than-expected
                        fee collections, then INS is to prepare a reprogramming proposal for
Application Backlogs    transmittal by the Department of Justice to the Office of Management and
                        Budget (OMB) and, subsequently, to the appropriation subcommittees with
                        jurisdiction over the Department of Justice.

                        INSstarted fiscal year 1995 with a higher-than-expected adjudications
                        workload. An amendment adding subsection 245(i) to the Immigration and
                        Nationality Act of 1952 and California’s Proposition 187, passed in
                        November 1994, led to a dramatic surge in the demand for adjudication
                        benefits in 1995. INS also experienced a tremendous growth in its
                        examinations fee account receipts because of (1) a new
                        adjustment-of-status application process under the 245(i) amendment and
                        increased fees from that provision, and (2) increases in the number of
                        naturalization applications received. When INS determined that the
                        increase in the number of applications was likely to persist and that it
                        needed to respond to the additional demand for services, it took steps to
                        notify Congress of the need to use additional funds from the Immigration



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                    Examinations Fee Account.4 A proposal for additional spending authority
                    was submitted to Congress in the third quarter of the fiscal year.
                    According to INS officials, INS wanted to determine the extent to which the
                    number of applications would rise after the passage of the 245(i)
                    amendment and whether the growth would continue. Therefore, it
                    monitored data on application rates for the first 3 months of fiscal year
                    1995. After INS determined that there was a need for additional funding, the
                    internal and external processes for planning, preparing, and reviewing the
                    proposal for reprogramming of funds consumed another 4 months before
                    the proposal could go to Congress. As a result, backlogs and average wait
                    times for processing applications continued to grow in the field units.


INS Reprogramming   During most of fiscal year 1994, INS experienced a lower-than-normal level
                    of receipts. Consequently, INS proposed several reprogrammings to
                    decrease spending for activities funded by the Examinations Fee Account.
                    However, INS experienced a surge in applications in the final 2 months of
                    fiscal year 1994 and had a large pending workload going into fiscal year
                    1995. This workload was compounded by a further increase in the
                    applications filed during the first quarter of fiscal year 1995. As a result, INS
                    determined that it needed additional funding to hire people to process the
                    applications. According to an INS budget official, other fee accounts are
                    more predictable, which enables INS to project revenues more reliably.
                    Because the Examinations Fee Account has “peaks and valleys,”
                    reprogrammings are used to address the uncertainty of the workload in
                    this program area. But, according to INS officials, the reprogramming
                    process does not respond quickly enough to the need for additional funds.

                    As part of the 1995 congressional action, INS’ spending level authority for
                    the Examinations Fee Account was $291.1 million. In establishing this
                    funding level, the Conference Report acknowledged that it might not cover
                    INS’ full cost of inflation increases. The report directed that if INS realized
                    examination fee receipts in fiscal year 1995 that were higher than the
                    current estimate, INS should use those funds for base inflation costs, as
                    necessary, and to the extent possible, to provide additional resources for
                    the processing of naturalization applications. The conferees stated that
                    they expected to be notified of changes in spending plans as delineated by




                    4
                     INS’ Examinations Fee Account derives revenue from fees collected for processing 59 types of
                    applications, petitions, hearings, and appeals forms for immigration benefits, such as naturalization
                    and permanent resident status. INS collects fees and processes applications at 4 regional service
                    centers and 33 district offices.



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                        the reprogramming requirements of the appropriation bill.5 Under these
                        requirements, which are found in section 605 of the Appropriation Act,
                        notification to the Appropriation Committees of both Houses of Congress
                        must be provided 15 days in advance of reprogramming of funds.

                        In accordance with section 605 of the 1995 Appropriation Act and section
                        8 of the Department of Justice Appropriation Authorization Act, 1980, P. L.
                        96-132, the Department of Justice notified the House and Senate
                        Committees on Appropriations and the Judiciary of proposed
                        reprogramming actions for INS’ Examinations Fee Account, the
                        Legalization account, and the VCRTF in April 1995. The reprogramming
                        provided additional spending authority of $76.6 million.


Process for Proposing   The Department of Justice requires INS and its other department
Reprogramming Actions   components to prepare and submit a report containing a justification for
                        the reprogramming proposal. Justice also requires INS and its other
                        components to obtain congressional response to the reprogramming
                        action before expending any of the additional funds being sought. Several
                        internal and external layers of review and approval were required before a
                        reprogramming proposal could be forwarded to Congress. These layers
                        contributed to the time it took to process a reprogramming proposal.

                        INS officials said that before proceeding with a reprogramming proposal in
                        fiscal year 1995, INS managers decided that they needed data on the
                        aftermath of the 245(i) and proposition 187 legislation. INS officials said
                        that the agency decided to wait until 3 months of trend data on
                        applications were available before reacting to any increases in workload
                        demands. INS officials said that they took this approach because they
                        wanted to be certain that the increases in workload trends were not a
                        temporary surge in response to the passage of the new legislation.

                        Examinations fees collected in the first 2 months of fiscal year 1995
                        increased substantially and exceeded expectations. INS officials said they
                        assumed this increase was a temporary reaction in response to the new
                        legislation and not a trend that would continue. However, after the results
                        from the third month in the first quarter showed a continuing increase in
                        fees, INS officials determined it was not a short-term rush but a growing
                        demand that would require additional resources. Once a decision was
                        made to proceed in January 1995, officials said that internal discussions

                        5
                        Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies 1995
                        Appropriations and 1994 Supplemental Appropriations, P.L. 103-317; H.R. Rep. No. 103-708, 103d
                        Cong., 2d Sess at 35 (1994).



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                                        were held to decide whether additional resources should be for permanent
                                        or temporary personnel, given that the 245(i) amendment would expire in
                                        October 1997. This discussion and development of the resource needs,
                                        along with other internal reviews of reprogramming documents by INS
                                        budget officials, EACs and their staffs, the Office of the General Counsel,
                                        the Deputy Commissioner, and the Commissioner, took about 2 months.

                                        External layers of review and approval also contributed to the amount of
                                        time it took to obtain congressional response to the reprogramming
                                        proposal. Justice and OMB reviewed the proposal before it was submitted
                                        to Congress. Because INS waited 3 months before starting to draft the
                                        reprogramming proposal and then the internal development and external
                                        reviews took another 4 months, a reprogramming proposal was not
                                        submitted to Congress until April 1995. Figure 3.1 shows the timeline of
                                        key activities for INS’ reprogramming of funds in fiscal year 1995 to
                                        respond to increasing adjudication workload demands.


Figure 3.1 Timeline of Key Activities
for INS’ Fiscal Year 1995               Year      Month          Activity
Reprogramming
                                        1994      October 1-     INS collected information on receipts from applications to adjust status
                                                  December 31    and naturalization petitions.

                                                  December       An INS fee analysis group met to decide what to do in response to
                                                                 increasing workload demands and to make projections of future
                                                                 revenue receipts.

                                        1995      January-       Documentation requesting additional spending authority was prepared
                                                  March          and reviewed internally.

                                                  March 3        Request for additional spending authority was forwarded to Justice for
                                                                 approval.

                                                  March 3-28     Justice added an $11 million request for Community Relations Services
                                                                 to carry out Operation Safe Haven to assist Cubans and Haitians.

                                                  March 28       Justice forwarded the request to Office of Management and Budget.

                                                  March 28-      Office of Management and Budget reviewed, approved, and returned
                                                  April 11       request to Justice.

                                                  April 13       Justice forwarded request to Congress for House and
                                                                 Senate review.

                                                  April 13-      Congressional review period and communication with INS about use
                                                  June 6         of additional funds.

                                                  June 7         Congress responded in writing with formal approval and a few
                                                                 modifications.


                                                                                                             (Figure notes on next page)


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                            Source: Justice, INS, and OMB officials.




Average Wait Times for      The time spent in the preparation and review of the fiscal year 1995
Adjudication Applications   reprogramming proposal contributed to an increase in average projected
Grew During Fiscal Year     waiting times for processing certain adjudication applications. For fiscal
                            year 1995, INS’ self-designated acceptable time for processing all I-485
1995                        adjustment-of-status and N-400 naturalization applications was 4 months.6
                            Our analysis of applicant waiting times revealed that the average projected
                            agencywide waiting time for processing adjustment-of-status applications
                            during fiscal year 1995 grew from about 5 months as of September 30,
                            1994, to about 10 months as of September 30, 1995. The average projected
                            waiting time for the processing of naturalization applications grew from
                            about 8 months to about 17 months.

                            At the beginning of fiscal year 1995, 8 of the 33 INS districts exceeded INS’
                            acceptable processing time of 4 months by 1 month or more for
                            adjustment-of-status applications. At the end of fiscal year 1995, 18 of the
                            33 INS districts exceeded INS’ acceptable processing time of 6 months by 1
                            month or more. Twenty-one of the 33 INS districts exceeded the acceptable
                            processing time for processing naturalization applications by 1 month or
                            more at the beginning of the fiscal year compared to 26 of the 33 INS
                            districts at the end of the fiscal year.

                            During fiscal year 1995, average projected wait times for
                            adjustment-of-status applications more than doubled in 19 of the 33 INS
                            districts, as shown in table 3.2. In the Harlingen, Texas, District Office,
                            average projected wait times increased from an average of 27 months to an
                            average of 53 months.7 Average projected wait times for naturalization
                            applications more than doubled in 11 of the 33 districts. The average
                            projected wait time for naturalization in the Chicago District Office
                            increased from an average of 8 months to an average of 40 months and in
                            Miami from an average of 9 months to an average of 49 months.




                            6
                             INS set a priority for fiscal year 1996 to complete the processing of naturalization applications within
                            6 months and, in September 1996, revised the adjustment-of-status goal to 5 months.
                            7
                             The average projected wait times for adjustment-of-status applications for the Harlingen district
                            appear anomalous. We do not know if these wait times are correct or are due to an error.



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Table 3.2: Average Projected Wait Times for INS Processing of I-485 Adjustment-of-Status and N-400 Naturalization
Applications at the Start and End of Fiscal Year 1995
                                   I-485 Applications to adjust status               N-400 Naturalization applications
                                          Average projected                                 Average projected
                                         wait time (in months)                             wait time (in months)
                                            As of                    As of                      As of                  As of
INS District Offices           September 30, 1994       September 30, 1995         September 30, 1994     September 30, 1995
Servicewide                                     4.5                       9.5                     8.2                    17.3
Eastern region districts
Atlanta                                         1.6                       5.1                     5.1                      7.7
Baltimore                                       9.7                       1.6                     3.9                      6.8
Boston                                          2.2                       7.6                     2.8                      7.9
Buffalo                                         2.3                       2.2                     5.6                      4.5
Cleveland                                       1.2                       4.3                     3.7                      9.9
Detroit                                         1.8                       3.5                     5.7                    13.0
Miami                                           6.7                       9.0                     8.6                    48.6
Newark                                          5.6                      19.6                     2.5                      8.9
New Orleans                                     2.2                       9.7                     7.5                      4.0
New York City                                   8.6                      18.5                     4.8                    23.7
Philadelphia                                    1.7                       4.7                     6.1                      5.4
Portland, Maine                                 2.1                       1.6                    10.3                      1.5
San Juan, Puerto Rico                           2.7                       9.6                     6.2                    16.6
Washington, D.C.                                4.1                       7.9                     3.5                      6.5
Central region districts
Chicago                                         3.3                       2.7                     7.9                    39.7
Dallas                                          2.4                       4.2                    12.7                    11.0
Denver                                          2.2                       3.6                     3.9                      5.2
El Paso                                         1.7                       9.3                     6.6                      9.4
Harlingen, Texasa                              26.5                      52.8                    11.9                    11.2
Helena                                          6.8                       3.8                     5.6                      3.9
Houston                                         4.7                      16.8                     8.6                    16.0
Kansas City, Missouri                           3.0                       2.0                     5.1                      4.2
Omaha                                           1.8                       7.3                     1.5                    10.2
San Antonio                                     3.5                      11.8                     4.6                      5.4
St. Paul                                         .1                        .6                     2.6                      3.8
Western region districts
Anchorage                                       4.9                       3.7                     3.2                      4.8
Honolulu                                        4.0                       4.3                     5.7                      7.3
Los Angeles                                     9.7                      19.6                    12.6                    26.3
Phoenix                                         6.1                      12.9                     9.7                    10.5
                                                                                                                   (continued)

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                         I-485 Applications to adjust status                         N-400 Naturalization applications
                                Average projected                                            Average projected
                               wait time (in months)                                        wait time (in months)
                                    As of                      As of                          As of                         As of
INS District Offices   September 30, 1994         September 30, 1995             September 30, 1994            September 30, 1995
Portland, Oregon                       0.5                           10.1                            4.1                              9.5
San Diego                              3.2                           12.6                           13.7                              7.5
San Francisco                          2.8                           10.2                           18.2                          21.5
Seattle                                2.0                            4.4                            9.2                              7.4

                                 Note: INS computed the processing wait times by dividing the number of applications pending at
                                 month’s end by the number of applications completed for the month and multiplying by the
                                 number of calendar days in the month. This method computes how long it would take to complete
                                 all cases pending at the end of the month if the rate of completions remained constant.
                                 a
                                  The average projected wait times for adjustment-of-status applications for the Harlingen district
                                 appear anomalous. We do not know if these wait times are correct or are due to an error.

                                 Source: INS data.



                                 INS officials attributed delays in the processing of adjudication applications
                                 to the lack of authority to spend funds to hire additional personnel to
                                 address increased workload demands.


INS Submitted Fiscal Year        For fiscal year 1996, INS began drafting a reprogramming proposal in
1996 Reprogramming               August 1995. The reprogramming proposal was submitted to the Justice
Proposal to Congress             Department in September 1995, to OMB in October 1995, and to Congress in
                                 November 1995. Congress responded in January 1996. The reprogramming
Earlier in the Fiscal Year       provided additional spending authority for the Examinations Fee Account
                                 to expedite the processing of naturalization applications and 245(i)
                                 applications and to expand direct mail services and cover mandatory
                                 expenses. An INS budget official said that this reprogramming action was
                                 less complex than that of fiscal year 1995.

                                 The fiscal year 1995 reprogramming was more complex because it
                                 included several proposed actions within different sources of funds. INS’
                                 fiscal year 1995 reprogramming proposed actions within its Examinations
                                 Fee Account, Legalization Account, and VCRTF. It sought increased
                                 resources for processing naturalization applications and
                                 adjustment-of-status applications under the section 245(i) amendment;
                                 disseminating information on the naturalization process; staffing and
                                 contract support for Ask Immigration, which is INS’ public information




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                         system; supplementing operational and support components; and
                         increasing positions for the Institutional Hearing Program.


                         INS continued to experience problems in fiscal year 1995 with monitoring
Monitoring of Budget     its budgetary resources because of inaccurate and incomplete data in its
Resources Suffered       financial management system and inconsistencies in data available to and
From Inadequate Data     provided by headquarters and field units. For example, INS experienced
                         problems monitoring its resources because the Budget Office did not have
                         the information it needed on commitments made by field units, staff
                         attrition, and hiring plans.


Long-standing Problems   A financial management system is to integrate accounting, budget,
With INS’ Financial      personnel, and procurement systems, as well as other information
Management System        systems.8 Inaccurate financial data; an unreliable and antiquated financial
                         management system; and insufficient internal controls over allocation,
                         obligation, and expenditure of funds have made it difficult for managers in
                         INS headquarters to readily determine the financial status of INS’ field units.
                         These serious financial management problems are not new at INS. They
                         have long affected INS’ ability to effectively manage and accurately report
                         the results of its program and administrative operations. The Department
                         of Justice’s Office of the Inspector General and Justice Management
                         Division (JMD) and we have issued several reports on the serious
                         weaknesses in INS’ internal controls and accounting system.

                         In 1991, we reported that INS’ primary accounting system —Financial
                         Accounting and Control System (FACS) —was outmoded and had weak
                         internal controls.9 These 1991 reports stated that weaknesses had existed
                         for many years and would require a commitment by INS leadership across
                         succeeding administrations to correct. We reported again in 1993 and 1995
                         about these problems.10

                         Furthermore, JMD assessments of problems identified with FACS in fiscal
                         years 1993, 1994, and 1995 revealed that actions had not been taken to

                         8
                           Framework for Federal Financial Management Systems, Joint Financial Management Improvement
                         Program (FFMSR-O, Jan. 1995).
                         9
                          Financial Management: INS Lacks Accountability and Controls Over Its Resources (GAO/AFMD-91-20,
                         Jan. 24, 1991); and Immigration Management: Strong Leadership and Management Reforms Needed to
                         Address Serious Problems (GAO/GGD-91-28, Jan. 23, 1991).
                         10
                          Immigration Issues: Making Needed Policy and Management Decisions on Immigration Issues
                         (GAO/T-GGD-93-18, Mar. 30, 1993); and INS: Update of Management Problems and Program Issues
                         (GAO/T-GGD-95-82, Feb. 8, 1995).



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                           address recommended improvements. Specifically, the JMD audits
                           concluded that FACS (1) lacked reliable information, (2) failed to comply
                           with administrative policies and procedures in regard to funds control, and
                           (3) contained significant weaknesses in internal controls over payments
                           and obligations. Managers within INS also perceived the need for
                           improvements in financial management. Seventy-two percent of the
                           respondents to our 1995 survey on INS management issues said that
                           servicewide improvements were needed to a great or very great extent in
                           INS’ financial management. The INS Commissioner told us that in the past,
                           INS was required to use Justice’s financial management information system
                           because Justice wanted all of its components on the same system. She said
                           that INS has always maintained that the Justice system would not meet INS’
                           management needs. In the spring of 1994, Justice reached an agreement
                           with INS that enabled the agency to develop its own financial management
                           system. However, INS did not receive funding to pursue a new financial
                           system until May 1995.

                           Since fiscal year 1992, quarterly financial reports have generally been
                           prepared for INS nationwide, encompassing every program and field office.
                           INS quarterly reports are intended to enable INS managers to better monitor
                           expenditures and availability of funds, make accurate end-of-year financial
                           projections of obligations, and allow for the timely preparation of requests
                           for changes in spending authority. Further, these quarterly reports are to
                           provide managers with the information that INS believes is necessary to
                           detect and address potential problems in a timely manner by comparing
                           budget allocations with obligations and projected spending. In addition, in
                           November 1994, INS appointed the EAC for Management as its Chief
                           Financial Officer, responsible for overseeing all of INS’ financial
                           management activities. The Chief Financial Officer’s responsibilities
                           include, among other things, overseeing the integration of budgeting and
                           accounting information; the preparation of financial statements; and the
                           production of complete, reliable, timely, and consistent financial
                           information.


Data From INS’ Financial   During our review of INS’ fiscal year 1995 budget execution process, we
Accounting and Control     found that adequate financial information was neither readily available nor
System Continued to Be     being maintained in INS’ FACS. Consequently, INS budget officials and
                           managers did not have the requisite information in FACS to determine the
Inadequate                 amount of funds available in specific INS units or to prepare accurate
                           financial status reports. Consistent with what we found in 1991, INS’
                           financial accounting system in fiscal year 1995 still failed to provide INS



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                             managers with the financial management information they needed to
                             adequately control funds and evaluate program operations in an efficient
                             manner.

                             The information in FACS did not provide management with accurate and
                             complete financial information on its program and administrative
                             operations. Also, because much of the financial information that FACS
                             produced was not a correct reflection of the financial status of INS field
                             units, it was unreliable. In addition, INS’ financial management system did
                             not adequately integrate information that INS managers needed, such as
                             information on commitment of funds, attrition of staff, and hiring plans in
                             the field. For example, FACS had generally maintained data on commitment
                             of funds only at the INS headquarters level, which did not provide
                             headquarters or regional managers with detailed information on the
                             commitment of funds at specific INS field units. Commitments had
                             generally been tracked directly by the individual INS field locations.


INS Did Not Have             FACS  was not able to provide accurate data to INS managers on the financial
Complete Financial and       status of each field unit. Also, the Office of Budget in headquarters did not
Personnel Information        have ready access to personnel data that would have enabled it to identify
                             current and planned staffing levels in INS field units. To obtain the
Needed to Manage Its         necessary accounting and personnel information for an accurate picture of
Budget Execution             the financial status of its field units, managers in INS headquarters had to
                             rely on information obtained from each of INS’ 33 districts and 21 sectors.
                             For example, the Office of Field Operations, which is responsible for
                             managing resources in INS field units, had to obtain information on, among
                             other things, attrition of personnel, commitment of funds, and hiring plans
                             from INS’ 33 districts and 21 sectors to be able to project what funds would
                             be available for reallocation during quarterly financial reviews for fiscal
                             year 1995. In fiscal year 1995, the allocation and management of PS&B
                             funds, including information on financial commitments and vacant
                             positions associated with these funds, were being maintained at the
                             district and sector levels. Accurate information on spending in PS&B funds
                             in INS field units was not consistently available to managers at INS
                             headquarters or being readily maintained in INS’ financial accounting
                             system.


Inconsistencies Existed in   Inconsistencies in the financial data being used by INS managers in
the Data Provided by INS     headquarters and in the field resulted in very different projections of the
Resource Managers            financial status of the various INS units. During fiscal year 1995, field unit



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    projections of funds expected to be used and funds available to reallocate
    differed significantly from initial projections that the Office of Budget had
    developed from data in INS’ financial accounting system.

    For example, relying on FACS data as of March 31, 1995, the Office of
    Budget projected that the field would have about $115 million in surplus
    funds through the end of the fiscal year.11 This was a baseline projection
    that the Office of Budget used as a starting point to obtain input from the
    field offices on the status of finances as part of the normal financial review
    process. Subsequently, the Office of Field Operations, relying on data
    provided by the INS regional offices and the 33 districts and 21 sectors,
    projected that the INS field units would experience a $5 million shortfall in
    funding for the remainder of fiscal year 1995.

    Managers in INS headquarters and field units said that they spent a great
    deal of time attempting to reconcile the $120 million difference in fiscal
    year 1995 projections. Ultimately, the Office of Budget based and revised
    its initial mid-year estimate on data provided by INS field units. After
    incorporating field data on attrition of staff, commitment of funds, and
    hiring plans, and reconciling other differences, the Office of Budget
    indicated in its Prospective Financial Status report for the period ending
    March 31, 1995, that about $25 million in surplus funds would be available
    to Field Operations through the remainder of the fiscal year. This was
    about $90 million less than the Office of Budget’s initial estimate of
    $115 million in surplus funds.

    Office of Budget officials said that the process of determining the financial
    status of INS units was impeded by several factors. These officials said that
    the following factors contributed to the problems:

•   various officials responsible for collecting information to be used in the
    financial reports used different data sources,
•   various officials responsible for reporting financial data did not
    consistently use formats that the budget office provided, and
•   data provided by the field had errors.




    11
     INS uses the term surplus funds to refer to funds that were not used during the fiscal year for PS&B
    and therefore become available for other purposes.



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INS Has Taken Interim   INS has acknowledged that FACS is old and labor-intensive and has had
Steps Until New         difficulty accounting for and controlling its resources in an accurate and
Accounting System Is    timely manner. To work toward having more complete, accurate, and
                        useful information, in October 1996, INS decided to use a competitive
Available               selection process to acquire a new financial management system through
                        an interagency agreement with a federal agency that could best meet its
                        user needs. The Office of Management and Budget endorses the use of
                        cross-servicing with other federal agencies as a cost effective and efficient
                        way to obtain services. In January 1997, a letter of interest and a
                        solicitation to acquire a system were sent to the Treasury Department, the
                        Commerce Department, and the Department of the Interior’s U.S.
                        Geological Survey. INS had identified these agencies as having the potential
                        for meeting its needs. Proposals were to be provided to INS by January 31,
                        1997; however, as of the beginning of February 1997, INS had one proposal
                        that it was evaluating and was negotiating an extension for proposals from
                        another agency. INS evaluated the proposals during February and
                        March 1997 and selected a vendor on March 31. INS’ solicitation for a
                        financial management system specified that the agency expected to have a
                        core financial management system implemented by October 1, 1997, to
                        meet the deadline agreed upon with the Department of Justice.

                        In the meantime, INS officials said that starting with the first quarter of
                        fiscal year 1996, PS&B resources were allocated and managed at the
                        regional level instead of at the district and sector levels. This change was
                        undertaken to alleviate, among other things, the need to collect
                        information from the 33 districts and 21 sectors. As previously presented,
                        INS developed a table of organization, which provided information to field
                        units and headquarters’ managers on authorized funded staffing levels.
                        This document was intended to help INS managers better monitor and
                        control personnel resources in the various INS units. According to an INS
                        official, the tables of organization data were manually compared to
                        on-board staffing level data to derive vacancy levels by office and major
                        occupations. This manual reconciliation process is a temporary measure,
                        which is to be eventually automated through implementation of a new
                        Position Tracking System (POSTS).

                        INS’implementation of the new Position Tracking System is to address the
                        lack of information on current staffing levels, staff attrition, vacancies, and
                        hiring plans. POSTS is to contain both the tables of organization control data
                        and data on occupied positions. When fully operational, POSTS is to provide
                        INS managers with an up-to-date summary of filled and vacant positions.
                        Additionally, POSTS is to interface with the new Hiring Tracking System



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                            (HITS) to provide INS managers with, among other things, an account by
                            location of all vacancies in INS. Neither of these systems was sufficiently
                            implemented as of April 1997 to provide useful data to support the
                            activities of the Office of Budget, but INS expects the systems to be
                            available throughout the agency by the end of fiscal year 1997.

                            Concerning inconsistencies in the data provided by the various INS units,
                            little was done to correct the problem until the beginning of fiscal year
                            1996. At that time, INS officials in the Office of Budget, Office of Field
                            Operations, and other INS units began working together to establish
                            mutually agreed-upon data sources and time frames and to develop
                            consistent and reliable reporting mechanisms to be used for the first
                            quarterly financial review of fiscal year 1996. On the basis of lessons
                            learned from prior financial reviews, a revised financial review process
                            and policy was developed with the intent to, among other things:

                        •   ensure that all organizational components are using the same financial
                            data for review, projections, and adjustments;
                        •   guarantee that all organizational components utilize the same automated
                            tools, algorithms, and methodologies to perform analyses and adjustments
                            to projections, thereby providing consistency and confidence in the
                            results, particularly the determination of available surplus funds; and
                        •   maximize the effectiveness of planning the use of resources by utilizing
                            not only actual to-date surplus funds, but also projected surplus.


                            In April 1996, INS contracted with the National Academy of Public
INS Contracted for          Administration (NAPA) to assist it with developing a framework to change
Assistance to               its budget and financial management process and execution. INS stated in
Strengthen Its Budget       the contract that it had taken steps to address problems in the budget and
                            financial management areas, but it believed it needed to further clarify and
Process and Improve         strengthen the budget process at all levels of the organization. NAPA’s
Its Financial               January 1997 report12 made 40 recommendations related to such issues as
                            budget account structure, budget formulation, budget execution, and
Management System           organizational issues affecting budgeting. In addition, as part of the
                            process of developing recommendations to clarify and strengthen the INS
                            budget process at all levels of the organization, the NAPA project included
                            an analysis of how the INS budget process connected to the financial
                            management system and agency efforts to develop a new core financial
                            management information system.

                            12
                             Report by a Panel of the National Academy of Public Administration for the Immigration and
                            Naturalization Service, Budgeting for Performance: Strategy, Flexibility, and Accountability to Meet a
                            Demanding Mission, January 1997.



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The NAPA report raised concerns regarding (1) the quality of systems
requirements that INS developed; (2) the need to analyze and document
current “as is” business processes and develop targeted “to be” processes;
and (3) the need for systems integration analyses, among other things.
According to the NAPA report, INS’ acquisition of a new core financial
management information system will not resolve the long-standing
deficiencies in the agency’s financial management system because the root
cause of its problems lies in the domain of INS’ business processes and
procedures. The report stated that although a new financial information
system is needed, improvements in agency processes and procedures must
come first. NAPA also reported that various offices within INS were engaged
in activities that could be construed as process analysis activities, but
these activities were independent and were not part of an overall
systematic process improvement strategy, plan, and program. In a briefing
to the Justice Department in January 1997 on NAPA’s findings and
recommendations, INS recognized the need to address major process
problems and provided information on activities that it had undertaken
through its contract with a financial management consultant to identify
requirements and begin prioritizing options for business process
reengineering. However, NAPA questioned the quality of INS’ planning
efforts and was concerned about INS’ expectation to implement a new
financial system by October 1, 1997. According to an INS official, as of
January 1997, the agency was committed to implementing a new system by
October 1, 1997, because it wanted to meet the agreed-upon deadline
established with the Justice Department and because problems have been
long-standing, and the agency wanted to show that it is making progress
toward addressing them.

In July 1996, INS contracted with a financial management consultant to
(1) assist it with reviewing and revising processes and procedures in
anticipation of converting to a new financial system and (2) review
requirements for selected functional areas of the system to optimize
process improvements to be derived from the new system. INS’ financial
management consultant also suggested to INS that it should first define
business processes and clarify functional requirements before selecting a
new system. Specifically, the consultant stated that its experience and best
practices model incorporated the concept of defining and improving
business processes as an antecedent to the selection and use of
technology and software. The consultant made several recommendations,
one of which was for INS to establish a risk management plan to allow for
timely management action so that quality, schedule, and cost objectives
are achieved. Both NAPA and INS’ consultant raised concerns about the



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              adequacy of INS’ planning efforts to acquire its new system and the
              feasibility of implementing a core financial management system by
              October 1, 1997.

              Our previous and current work highlights how important it is for INS to
              address the issues raised by NAPA and the consultant. Our May 1994 guide,13
              which identified information and technology management best practices,
              described how information systems initiatives must be focused on process
              improvement and guided by an organizational architecture.14 The guide
              also stated that information systems projects that do not focus on process
              improvement typically fail or reach only a fraction of their potential. Our
              February 1997 guide,15 which provides a structure for evaluating and
              assessing how well a federal agency is selecting and managing its
              information technology resources, stated that a key hazard in acquiring
              information technology is that the new system will automate outmoded,
              inefficient business processes. Another guide that we issued in April 199716
              stated that technology is an enabler of process reengineering, not a
              substitute for it. This guide also stated that acquiring technology in the
              belief that its mere presence will somehow lead to process innovation is a
              root cause of bad investments in information systems. The Clinger-Cohen
              Act of 199617 requires executive agencies to conduct analyses of work
              processes before making significant investments in information
              technology. The act sought to remedy the dilemma of using technology to
              correct process problems by insisting that process redesign drive the
              acquisition of information technology, and not the other way around.
              Thus, an assessment of current processes (process mapping, baselining,
              benchmarking) should be completed before a decision is made about
              acquiring technology.


              Since fiscal year 1995, some, but not all, program areas used WAMs and
Conclusions   workload information in deciding how to deploy resources. INS contracted

              13
               Executive Guide: Improving Mission Performance Through Strategic Information Management and
              Technology; Learning From Leading Organizations (GAO/AIMD-94-115, May 1994).
              14
               Architectures explicitly define common standards and rules for both data and technology, as well as
              mapping key processes and information flows.
              15
               Assessing Risks and Returns: A Guide for Evaluating Federal Agencies’ IT Investment
              Decision-making (GAO/AIMD-10.1.13, February 1997 Version 1).
              16
                Business Process Reengineering Assessment Guide (GAO/AIMD-10.1.15, April 1997 Version 3).
              17
               The Omnibus Consolidated Appropriations Act of 1997 renames both the Federal Acquisition Reform
              Act of 1996 and the Information Technology Management Reform Act of 1996 as the “Clinger-Cohen
              Act of 1996.”



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                      with a consultant to develop a software program that would be compatible
                      with existing staffing models and that is intended to move INS toward
                      better deployment planning. In general, we believe that the use of WAMs
                      can help INS make resource allocation decisions, because INS will be able to
                      consider different factors and changing scenarios. Thus, we support INS’
                      initiative to develop WAMs and use models to improve resource allocation
                      planning.

                      INS has been taking steps to address the weaknesses in its financial
                      management system that have adversely affected financial reporting and
                      management at all levels and that hampered INS’ ability to prepare accurate
                      quarterly financial management reports in fiscal year 1995. The
                      improvements made during fiscal year 1996 address some of the
                      weaknesses associated with INS not having consistent and readily available
                      data but will not remedy the problems. INS selected a new financial
                      management system. Ultimately, the new system is intended to provide
                      consistent and reliable data, integrate information from other systems, and
                      produce accurate and complete information on commitment of funds,
                      attrition of staff, and hiring plans in the field. However, NAPA and INS’
                      financial consultant recommended that INS define its current business
                      processes and define its desired business processes before acquiring a
                      new system. Our guides on information management and the
                      Clinger-Cohen Act also endorse these practices. Problems with the
                      accuracy, completeness, and consistency of data that we identify in this
                      chapter are process issues, not technology issues. INS did not perform a
                      comprehensive analysis of its financial management processes before
                      selecting a new financial management system; therefore, the new financial
                      management system may not address process problems. As a result, INS
                      has incurred a risk that the system may not meet its financial management
                      requirements.


                      We recommend that the Commissioner of INS take the following actions:
Recommendations
                  •   Develop a strategy and schedule for periodically evaluating the new
                      deployment planning process to help ensure that it is compatible with INS’
                      key planning processes and provides information needed by managers to
                      adequately plan for resource needs and make resource decisions.
                  •   Take steps to mitigate the risks associated with INS’ planned approach for
                      acquiring a new financial management system. Such steps should include
                      fully implementing plans to analyze its current financial management
                      processes and determining future financial management process needs,



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                     finalizing a comprehensive implementation plan, and fully developing and
                     implementing a risk management plan.


                     INS provided written comments on a draft of this report, which are printed
Agency Comments      in full in appendix VI. INS also provided technical comments separately,
and Our Evaluation   which we incorporated where appropriate. INS agreed with our
                     recommendation that it should evaluate its improvements to the
                     deployment planning process to help ensure that the agency’s information
                     needs are being met.

                     On the issue of INS’ plans for implementing a new financial management
                     system, INS stated that we failed to recognize its urgent need for a
                     replacement financial system. To the contrary, we have long recognized
                     this need. We believe our report and many past reports by us and others
                     fully recognize the problems in INS’ financial management systems and the
                     need to replace them. Thus, our primary focus in this report was on
                     expressing our concerns about INS’ plans for implementing a new system.

                     In this regard, INS disagreed with a recommendation in our draft report
                     that it analyze financial management processes prior to acquiring a new
                     financial management system and stated that it thought we relied too
                     much on the NAPA findings and did not follow up appropriately with
                     additional field work on the steps INS had taken after the NAPA report was
                     issued. We disagree that we relied primarily on the NAPA findings. Although
                     our report discusses the NAPA findings as they related to INS’ efforts to
                     acquire a new system, our recommendation was based in addition on our
                     analysis of agency documents, INS consultant reports, and our long history
                     of work on the implementation of major new information technology
                     systems. For example, our May 1994 guide, which we used in assessing INS’
                     approach, stated that information systems projects that do not focus on
                     process improvements typically fail or reach only a fraction of their
                     potential. To better clarify the basis for our observations, we have added
                     some information to the report about our previous work in this area.

                     Although we continued to discuss these and other matters in this report
                     with INS as the report was being developed and reviewed, we wanted to be
                     sure that we had fully considered all of the most recent developments in
                     its plans for a new financial system that were raised by INS in its comment
                     letter. Accordingly, we met with the Assistant Commissioner for the Office
                     of Financial Management and other finance officials in May 1997 to
                     discuss actions that INS plans to take to mitigate the risks associated with



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implementing its new financial management system. In addition to
establishing an Executive Steering Committee and obtaining the
contractual support described in INS’ comments, these officials told us that
they were working with or preparing to work with consultants on
(1) analyzing INS’ financial management processes, (2) developing a
comprehensive implementation plan that would include how the system is
to be evaluated, and (3) developing a risk management plan. They also
stated that the entire system will not be in place by October 1, 1997, as
originally intended; rather, core functions will be implemented and tested
at some, but not all, locations.

In the time since our audit work was largely completed, INS’ strategy for
implementing a new financial management system has evolved further,
and INS is currently taking steps to plan for a phased implementation and
other actions that should help to mitigate the risks we observed. These
actions, if carried out effectively, are more consistent with the approach
that our work in this area has indicated would mitigate risk. For that
reason, we have revised our recommendation to focus more on actions the
Commissioner needs to take to fully develop and implement the plans that
were discussed with us in concept.




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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.



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                           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



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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.



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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.




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                                     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



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                     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




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GAO Survey on INS Management Issues




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                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%




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                 Appendix IV
                 GAO Survey on INS Management Issues




9. In your opinion, how positive or negative an impact, if any, have the following factors had on morale at INS?
   (Check one box in each row.)

                                                          Very      Positive      No     Negative    Very      No basis
                                                         positive               impact              negative   to judge
                                                           (1)        (2)         (3)      (4)        (5)         (6)

a. Leadership provided by top management at INS
                                              n =2,297     3%        19%         16%      35%        26%         2%

b. Operational/program funding levels         n =2,296     2%        20%         11%      37%        23%         7%

c. Communications between Headquarters
   and the regions                            n =2,305     1%        10%         15%      27%        14%        34%

d. Communications between Headquarters and
   administrative centers                n =2,307         0.3%        6%         14%      15%         8%        56%

e. Communications between the regional offices
   and the administrative centers         n =2,307         1%         8%         15%      12%         6%        59%

f. Communications between regional offices
   and the districts/sectors               n =2,307        3%        23%         16%      19%         7%        33%

g. Level of cooperation among units at INS
                                              n =2,293     3%        29%         13%      37%        15%         3%

h. Availability of training/development opportunities
                                              n =2,302     2%        21%         16%      43%        14%         4%

i.   Physical work environment (office space,
     facilities, outdoor work, etc.)          n =2,312     6%        29%         14%      32%        19%         1%

j.   Availability/quality of equipment
     (computers, cars, etc.)                  n =2,308     6%        36%         8%       33%        17%         1%

k. Amount of time required for duties
   unrelated to primary work                  n =2,302     1%        12%         27%      39%        17%         4%

l.   Staffing level                           n =2,292     2%        14%         12%      41%        29%         3%

m. Anything else - Please specify: _____________
                                               n =537      2%         2%         2%       21%        70%         5%



10. Currently, how would you characterize the general level of morale in your unit? (Check one.)

     n=2,238

      1.        Very high                       3%

      2.        Fairly high                    21%

      3.        Neither high nor low           25%

      4.        Fairly low                     31%

      5.         Very low                      19%
      ------------------
      6.         No basis to judge              0%




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                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%




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              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: ________________________________________________




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14. Which of the following describes how this            16. Given the following options, how would you
    inadequate management information impacts your           characterize the current setting of priorities at INS
    unit? (Check all that apply.)                            between enforcement and service functions?
                                                             (Check one.)
n=851      1.      Impedes the accomplishment of my
                   program's goals and objectives        n=2,297

n=803      2.      Makes it necessary to keep            13%         1.      Much heavier emphasis on
                   supplemental records                                      enforcement than on service

n=535      3.      Hinders my ability to adequately      14%         2.      Somewhat heavier emphasis on
                   measure performance                                       enforcement than on service

n=762      4.      Hinders my ability to make well-      21%         3.      About equal priority
                   thought-out decisions
                                                         19%         4.      Somewhat heavier emphasis on
n=520      5.      Prevents holding employees                                service than on enforcement
                   accountable
                                                         26%         5.        Much heavier emphasis on service
n=1,025    6.      Results in wasting scarce resources                         than on enforcement
                   (e.g., people, time, or money)                    -------------------------
                                                         8%          6.        No basis to judge
n=175      7.      Other - Please describe:
                   _____________________________
                                                         17. In your opinion, how should enforcement vs.
                                                             service priorities be set at INS? (Check one.)

V. Priority Setting and Planning                         n=2,285

                                                         25%         1.      Should be much heavier emphasis
15. To what extent, if at all, are INS-wide goals and                        on enforcement than on service
    objectives clear enough to assist you in carrying
    out your planning responsibilities? (Check one.)     25%         2.      Should be somewhat heavier
                                                                             emphasis on enforcement than on
n=2,281                                                                      service

4%         1.      To a very great extent                43%         3.      Should have about equal priority

15%        2.      To a great extent                     2%          4.      Should be somewhat heavier
                                                                             emphasis on service than on
33%        3.      To a moderate extent                                      enforcement

26%        4.      To some extent                        1%          5.        Should be much heavier emphasis
                                                                               on service than on enforcement
22%        5.      To little or no extent                            -------------------------
                                                         4%          6.        No basis to judge




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                         The following question refers to the Commissioner's strategic planning process.
                         This includes the following priorities:

                          ·   Strengthen Border Protection
                          ·   Expedite Removal of Criminal Aliens
                          ·   Reduce Incentives for Unlawful Migration
                          ·   Implement Asylum Reform Regulations
                          ·   Improve Customer Service
                          ·   Promote and Streamline Naturalization
                          ·   Improve Professionalism
                          ·   Provide Innovative Immigration Policy Leadership
                          ·   Broaden and Integrate INS Systems Infrastructure




18. In your opinion, to what extent, if at all, has the strategic planning process, which identifies nine priorities, aided
    INS in the following areas? (Check one box in each row.)


                                                          To little    To          To a      To a    To a very    No basis
                                                           or no      some       moderate    great     great      to judge
                                                           extent     extent      extent    extent    extent
                                                            (1)        (2)          (3)       (4)       (5)         (6)

 a. Headquarters planning                      n =2,272    11%        17%         13%        9%         3%         47%

 b. Regional planning                          n =2,273     9%        15%         14%        7%         2%         54%

 c. Headquarters decision-making               n =2,267    14%        16%         13%        9%         3%         45%

 d. Regional decision-making                   n =2,262    10%        15%         15%        6%         2%         52%

 e. Unit planning                              n =2,255    24%        25%         23%       11%         4%         14%

 f. District or sector ability to carry
    out their missions                         n =2,262    18%        23%         20%        8%         2%         30%

 g. Budget execution planning                  n =2,269    20%        19%         14%        7%         2%         38%

 h. Budget execution decisions                 n =2,269    20%        18%         14%        7%         2%         39%

 i. Personnel planning                         n =2,270    23%        21%         16%        9%         3%         27%

 j. Personnel decisions                        n =2,264    25%        21%         17%        7%         2%         28%

 k. Immigration policy planning                n =2,268    17%        19%         15%        9%         3%         37%

 l. Providing agency-wide perspective
    on programs                                n =2,265    20%        20%         18%        8%         3%         31%




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VI. Client Service

19.   Is your unit (See Glossary on page 1) directly involved with adjudications and nationality; legalization; refugees,
      asylum; outreach; or information services (i.e., does it deal directly with the public)? (Check one.)

n=2,255


38%         1.        Yes   →    Continue with Question 20.

62%         2.        No    →   Skip to Question 22.


20.   How would you rate your unit's performance in the following areas? (Check one box in each row.)


                                                                                                                No
                                                       Excellent    Very      Fair       Poor       Very       basis
                                                                    good                            poor     to judge
                                                          (1)        (2)       (3)        (4)        (5)        (6)

a.    Quality of service provided to the public
                                               n=892     24%        42%       24%        7%         2%          0%

b.    Timeliness of service provided to the public
                                               n=892     18%        37%       27%        12%        6%          1%

c.    Efficiency of service provided to the public
                                               n=893     17%        40%       29%        10%        3%          1%

d.    Quantity/volume of service provided
      to the public                            n=892     26%        38%       25%        7%         4%          1%




21. In your opinion, to what degree does INS commit the necessary resources for quality service?
     (Check one.)

n=891

4%               1.         Very high commitment

14%              2.         High commitment

37%              3.         Moderate commitment

26%              4.         Low commitment

16%              5.         Very low commitment
                 ---------------------------
3%               6.         No basis to judge




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VII. Organizational/Accountability Issues

22. In general, over the past 5 years, would you say that the quality of leadership in the following INS top
    management positions has improved, stayed about the same, or has gotten worse? (Check one box in each row.)


                                                     Improved   Improved     Stayed      Gotten   Gotten      No
                                                      greatly   somewhat     about     somewhat   much      basis
                                                                            the same     worse    worse    to judge
                                                       (1)        (2)          (3)        (4)      (5)        (6)

a.   Top Headquarters management positions
     (Commissioner, Deputy Commissioner,
     Executive Associate Commissioners) n =2,308      11%        22%         26%        16%       17%        9%

b.   Top regional office management positions
     (Regional Director, Deputy Director) n =2,302    10%        22%         32%        11%        8%       17%




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23. Do you agree or disagree with the following statements concerning INS as an organization?
    (Check one box in each row.)

                                                          Strongly   Agree    Neither    Disagree   Strongly   No basis
                                                            agree            agree nor              disagree   to judge
                                                                              disagree

                                                             (1)      (2)       (3)        (4)        (5)        (6)

a. Overall, the current organizational structure of
   INS works well                             n =2,298      2%       18%      17%         35%        26%         2%

b. Headquarters should have more control over INS'
   field operations                       n =2,308          8%       15%      14%         33%        27%         4%

c. INS' regional offices should have more input into
   national policy setting                  n =2,309       14%       48%      15%         11%         4%         9%

d. Districts/sectors should have more input into
   national policy setting                   n =2,309      29%       48%      10%          6%         2%         6%

e. The regional offices should have greater input
   into how their districts/sectors are managed
                                               n =2,302    13%       35%      20%         19%         7%         7%

f. Regional offices should have more autonomy
                                               n =2,297     8%       27%      26%         24%         8%         8%

g. Districts/sectors should have more autonomy
                                               n =2,293    14%       31%      20%         22%         7%         5%

h. There should be more coordination among INS
   regions and the districts/sectors under their
   jurisdiction                               n =2,309     32%       48%      11%          2%         1%         6%

i.   Headquarters is in touch with events/
     problems/concerns in the field            n =2,311     2%       11%      13%         33%        37%         5%

j.   The regional offices are in touch with
     events/problems/concerns in the districts/sectors
                                               n =2,309     4%       27%      21%         23%        13%        13%




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24. Listed below are problems which may occur in an organization. In your opinion, to what extent, if at all, are
    these problems present at INS? (Check one box in each row.)


                                                           To little     To some            To a          To a     To a very       No basis
                                                            or no         extent          moderate       great       great         to judge
                                                            extent                         extent        extent     extent
      Extent these may be problems at INS                    (1)             (2)             (3)           (4)        (5)           (6)


a. Unclear lines of authority                   n=2,302        24%           24%           19%           14%         18%            2%

b. Chain-of-command is not followed             n=2,307        24%           22%           19%           15%         16%            3%

c.    Unclear lines of accountability           n=2,302        15%           19%           20%           20%         23%            3%

d. Lack of central decision-making authority
                                                n=2,279        23%           20%           18%           14%         16%            9%

e. Too much central decision-making authority
                                                 n2,260        27%           20%           17%           13%         13%           11%

f. Unclear decision-making authority at
   the local level                              n=2,293        28%           22%           17%           13%         11%            9%

g. Duplication of effort                         n-2,302       10%           20%           18%           23%         25%            4%

h. Poor communications                          n=2,311        4%            16%           17%           24%         38%            1%

i.    Poor dissemination of information         n=2,311        5%            16%           18%           22%         37%            1%




25.    Given your experiences, would you say that at                   26.     Consider the work performed in your unit. How
       least some of the work performed in your unit is                        rarely or often would you say that tasks
       duplicated by some other office in INS (e.g., a                         performed in your unit are duplicated in some
       Border Patrol unit working the same or related                          other office? (Check one.)
       case as an Investigations unit)? (Check one.)
                                                                       n=1,114
n=2,307
                                                                       8%            1.          Rarely    →      Skip to Question 28.
48%          1.      Yes → Continue with Question
                     26.
                                                                       48%           2.          Occasionally
43%          2.      No                                                10%           3.          As often as not           Continue with
                                        Skip to Question 28.                                                               Question 27.
9%           3.      No basis                                          22%           4.          Often
                     to judge
                                                                       12%           5.          Very often

                                                                       1%            6.          No basis to judge      →Skip to
                                                                                                 Question 28.



                                                                 13




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27.    Which of the following groups in INS                28.   To your knowledge, how often, if ever, does the
       unnecessarily duplicate at least some of the work         field carry-out programs differently than
       that your unit does? (Check all that apply.)              Headquarters may have originally intended?
                                                                 (Check one.)
n=26        1.      None of the duplication is
                    unnecessary                            n=2,293
n=20        2.      Office of the Commissioner or
                    Office of the Deputy Commissioner      13%       1.       Very often
n=73        3.      Office of the Executive Associate
                    Commissioner for Programs              18%       2.       Often
n=82        4.      Office of the Executive Associate
                    Commissioner for Policy and            30%       3.       Sometimes
                    Planning
n=127       5.      Office of the Executive Associate      12%       4.       Rarely
                    Commissioner for Field Operations
n=59        6.      Office of the Executive Associate      7%        5.         Very rarely, if ever
                    Commissioner for Management                      --------------------
n=89        7.      Office of the Regional Director        21%       6.         No basis to judge
n=73        8.      Office of the District Director
n=57        9.      General Counsel, Regional
                    Counsel, or District Counsel
n=83      10.       Congressional Relations
n=83      11.       Public Affairs
n=31      12.       Asset Forfeiture
n=300     13.       Border Patrol
n=436     14.       Investigations
n=234     15.       Intelligence
n=62      16.       International Affairs/Asylum
                    Offices
n=203     17.       Detention and Deportation
n=86      18.       Adjudications and Nationality
n=106     19.       Service Center
n=148     20.       Inspections
n=88      21.       Records
n=12      22.       Administrative Appeals
n=39      23.       Equal Employment Opportunity,
                    Security, Files and Forms
                    Management
n=88      24.       Budget and Financial Management
n=84      25.       Human Resources and
                    Administration
n=44      26.       Information Resources
                    Management
n=50      27.       Internal Audit
n=99      28.       Administrative Centers
n=58      29.       Other - Please specify:
                    ________________________




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29.   In your opinion, service-wide, how consistent or inconsistent is the actual implementation of policies,
      procedures, directives, and regulations by the various offices at INS? (Check one box in each row.)


                                             Very       Consistent   As consistent   Inconsistent      Very           No
                                           consistent                     as                        inconsistent    basis
                                                                     inconsistent                                  to judge
                                              (1)          (2)           (3)             (4)            (5)           (6)

a. Implementation of policies
                                n =2,313     4%           24%           27%             27%            11%           9%

b. Implementation of procedures
                                n =2,313     3%           20%           26%             30%            13%           8%

c. Implementation of directives
                                n =2,311     4%           24%           27%             26%            10%           9%

d. Implementation of regulations
                                n =2,312     6%           29%           24%             22%            10%           9%




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VIII. INS Internal Policy Development and Implem entation

30. Thinking about the implementation of INS internal policy (e.g., personnel practices, budget processes, etc.), would
    you agree or disagree with the following statements as they apply service-wide? (Check one box in each row.)



                                                          Strongly   Agree    Neither    Disagree   Strongly   No basis
                                                            agree            agree nor              disagree   to judge
                                                                              disagree
                                                             (1)      (2)        (3)       (4)        (5)        (6)

a.   INS policy is clearly defined by Headquarters
                                               n =2,301     3%       23%      22%         34%        15%         5%

b.   Headquarters provides adequate policy guidelines
     to the field                           n =2,301        2%       17%      20%         38%        18%         6%

c.   Field offices can voice opposition concerning a
     policy to Headquarters if they feel the policy is
     misguided or inappropriate               n =2,305      3%       24%      13%         27%        19%        15%

d.   Headquarters should consult more with the field
     when developing policy                 n =2,305       48%       41%       6%          1%         1%         4%

e.   Advice from the field is heeded by Headquarters
     when developing policy                 n =2,303        8%       14%      19%         28%        18%        13%

f.   INS policy is clearly communicated by
     Headquarters to the field             n =2,301         2%       17%      23%         37%        17%         5%

g.   Policy is communicated to the field in a formal
     (standardized) manner                    n =2,304      2%       29%      24%         26%        13%         6%

h.   Changes in policy are promptly disseminated
                                               n =2,300     1%       13%      17%         43%        22%         4%

i.   Changes in policy are disseminated to everyone
     who needs them                          n =2,300       1%       13%      18%         39%        22%         6%

j.   Field offices should have discretion in
     implementing INS policy                   n =2,300     8%       26%      17%         29%        16%         4%

k.   Headquarters ensures that policies are
     consistently implemented service-wide     n =2,298     2%       8%       21%         40%        21%        10%

l.   Written policies are kept up-to-date      n =2,304     1%       9%       16%         39%        31%         5%

m. Instructions on carrying out policy are complete
                                               n =2,304     1%       10%      20%         39%        26%         5%




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IX. Overall M anagem ent Concerns

31. In your opinion, to what extent, if at all, do you feel the following areas need improvement service-wide?
    (Check one box in each row.)
                                                             To little   To some       To a      To a    To a very   No basis
                                                              or no       extent     moderate    great     great     to judge
                                                              extent                  extent    extent    extent
                                                               (1)         (2)          (3)       (4)       (5)        (6)

a.   Financial management                         n =2,307     2%         10%         13%       24%        40%        12%

b.   Budget development/formulation               n =2,307     1%         10%         14%       27%        34%        15%

c.   Budget execution process                     n =2,300     1%         9%          14%       26%        35%        16%

d.   Distributed Budget Module System (DBM)
     (i.e., system used to allocate and move funds)
                                                  n =2,303     2%         7%          11%       16%        31%        33%

e.   Quality of service to the public             n =2,295    10%         23%         23%       18%        17%         9%

f.   Quality of information services to the public
                                                  n =2,306     9%         19%         20%       21%        21%        10%

g.   Record and data management                   n =2,297     3%         13%         21%       26%        26%        11%

h.   Workload/productivity measures               n =2,300     7%         17%         25%       22%        21%         7%

i.   Employee morale                              n =2,309     1%         7%          13%       25%        53%         1%

j.   Lines of authority                           n =2,303    12%         20%         24%       19%        23%         2%

k.   Coordination and cooperation among INS units
                                                  n =2,309     4%         16%         19%       24%        34%         2%

l.   Agency-wide planning                         n =2,300     2%         12%         22%       25%        31%         8%

m. Oversight and evaluation of INS programs
                                                  n =2,297     3%         15%         24%       23%        27%         8%

n.   Development of managers                      n =2,306     2%         11%         18%       26%        41%         3%

o.   Training of staff                            n =2,307     3%         12%         22%       27%        33%         2%

p.   Quality of staff                             n =2,307     6%         20%         26%       19%        28%         2%

q.   Personnel process                            n =2,305     3%         12%         19%       24%        37%         6%

r.   Quality of INS leadership at Headquarters
                                                  n =2,303     5%         14%         19%       17%        37%         8%

s.   Quality of INS leadership at the regional offices
                                                  n =2,309     8%         19%         22%       14%        20%        16%

t.   Quality of leadership in districts/sectors   n =2,307    11%         23%         22%       13%        20%        11%

u.   Other - Please specify:__________             n =275      1%         2%           2%       16%        72%         7%




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32. In your opinion, how effectively or ineffectively is INS carrying out the following activities?
     (Check one box in each row.)

                                                         Very       Somewhat         Neither       Somewhat           Very        No basis
                                                      effectively   effectively    effectively    ineffectively   ineffectively   to judge
                                                                                      nor
                                                                                  ineffectively
                                                         (1)            (2)            (3)            (4)             (5)           (6)

 a. Timely processing of international travelers
    at ports-of-entry                   n=2,297         15%           24%             4%              8%              3%           46%

 b. Screening immigrants at ports-of-
    entry for admissibility           n=2,293           10%           25%             5%             14%              6%           41%

 c. Apprehending noncriminal aliens
                                          n=2,283        5%           22%             8%             22%             28%           15%

 d. Detaining noncriminal aliens          n=2,287        3%           13%             8%             20%             41%           15%

 e. Apprehending criminal aliens          n=2,288        6%           30%             8%             24%             18%           15%

 f.   Detaining criminal aliens           n=2,283        6%           24%             7%             24%             24%           15%

 g. Controlling the border between
    ports-of-entry                        n=2,293        3%           21%             8%             24%             24%           21%

 h. Deporting aliens in a timely manner
                                          n=2,295        2%           10%             6%             21%             43%           18%

 i.   Adjudicating resident status and
      naturalization cases in a timely manner
                                          n=2,293        2%           14%             8%             17%             16%           43%

 j.   Adjudicating legalization cases in a timely
      manner                              n=2,293        2%           10%             9%             13%             16%           50%

 k. Adjudicating asylum cases in a timely
    manner                            n=2,295            4%           10%             7%             14%             18%           48%

 l.   Adjudicating other benefit cases in a timely
      manner                              n=2,291        2%           14%            11%             16%             10%           48%

 m. Adjudicating cases across the country in a
    consistent manner                  n=2,289           1%            8%             8%             19%             16%           48%

 n. Identifying fraud                     n=2,293        3%           19%            10%             25%             26%           17%

 o. Enforcing employer verification
    of work eligibility                   n=2,293        1%           10%            10%             23%             31%           26%

 p. Fining employers who hire illegal aliens
                                          n=2,292        1%           10%             8%             23%             33%           26%

 q. Collecting breached bonds             n=2,288        1%            6%             6%             14%             21%           53%

 r.   Providing accurate and complete
      information to clients and the general public
                                          n=2,293        2%           18%            17%             22%             17%           25%

 s. Managing seized assets                n=2,292        1%           10%            11%             12%             12%           54%

 t.   Stopping the flow of illegal narcotics
      into the United States              n=2,288        1%           15%             9%             17%             35%           23%




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X. Reviewing the Past Two Years


33. In your opinion, over the past two years, have the following improved, worsened, or stayed about the same
    in your unit? (Check one box in each row.)



                                          Improved   Improved    Stayed     Worsened   Worsened     No basis
                                           greatly   somewhat     about     somewhat    greatly     to judge
                                                                the same
                                            (1)        (2)         (3)         (4)        (5)          (6)

a. Information on personnel and
   staffing allocation       n =2,301       3%         17%       45%          16%        11%          9%

b. Information on budget and
   financial management
                               n =2,300     2%         12%       42%          18%        14%          13%

c. Measures of workload
   (e.g., number of arrests)
                               n =2,295     5%         19%       45%          13%         8%          10%

d. Productivity                n =2,294    10%         33%       32%          13%         7%          5%

e. Measures of productivity
   (e.g., number of cases adjudicated
   per work hour)             n =2,296      5%         21%       42%          11%         6%          16%

f. Information on policies and
   procedures                 n =2,297      2%         16%       48%          19%        10%          5%

g. Quality of work             n =2,294     6%         31%       38%          14%         8%          3%




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XI. 1994 INS Reorganization



                      The following questions refer to the reorganization that began in July 1994.
                      The reorganization established four Executive Associate Commissioner
                      positions, changed the number of regional offices from four to three, and
                      had administrative centers report to Headquarters rather than to the regions.



34.   Generally, how successful or unsuccessful do you think the reorganization has been in achieving the following
      goals? (Check one box in each row. If goal had been achieved prior to the reorganization, check box 1.)



                               Goal achieved        Very     Somewhat          As          Somewhat        Very      Too        No
                                prior to the      success-   successful    successful     unsuccess-ful   unsuc-     early     basis
                               reorganization        ful                        as                        cessful   to say   to judge
           Goals
                                                                          unsuccess-ful
                                                                               (4)             (5)                             (8)
                                    (1)             (2)         (3)                                         (6)      (7)

a. Creating a clearer sense
   of mission by
   combining INS' major
   functions
                   n =2,293        2%               3%         18%           20%             17%          18%        7%       16%

b. Decentralizing
   decision-making
   authority      n =2,292         1%               3%         19%           18%             17%          18%        5%       20%

c. Empowering the field
   operational units to
   improve the delivery of
   services to customers
                   n =2,292        1%               3%         18%           18%             16%          15%        4%       25%

d. Developing planning
   capability     n =2,287         1%               3%         16%           20%             16%          17%        5%       23%

e. Setting customer service
   standards
                   n =2,288        1%               3%         19%           19%             12%          12%        4%       30%

f. Establishing quantitative
   performance measures
                   n =2,288        1%               2%         15%           21%             17%          17%        4%       23%

g. Clarifying lines of
   authority        n =2,289       2%               3%         17%           21%             16%          24%        3%       15%




                                                Question 34 continued on next page.




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Question 34 (Continued)

  In your opinion, how successful or unsuccessful has the reorganization been at achieving the following goals?
  (Check one box in each row. If goal had been achieved prior to the reorganization, check box 1.)                           (74-77)




                               Goal achieved      Very     Somewhat          As          Somewhat        Very      Too        No
                                prior to the    success-   successful    successful     unsuccess-ful   unsuc-     early     basis
          Goals                reorganization      ful                        as                        cessful   to say   to judge
                                                                        unsuccess-ful
                                    (1)           (2)         (3)            (4)             (5)          (6)      (7)       (8)

h. Focusing on overall
   INS effectiveness rather
   than individual program
   objectives      n =2,297        1%             4%         22%           20%             17%          15%        6%       17%

i. Building an atmosphere
   of trust between the
   field and Headquarters
                   n =2,299        1%             2%         11%           15%             22%          34%        3%       13%

j. Improving processes to
   develop and disseminate
   organizational policy
   and guidelines
                   n =2,298        1%             2%         15%           21%             21%          23%        4%       13%

k. Delegating authority to
   persons geographically
   closer to locations
   where work is being
   done             n =2,298       1%             3%         19%           18%             17%          19%        4%       20%




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35.   In your opinion, has the reorganization improved, worsened, or had no effect on the following in INS?
      (Check one box in each row.)

                                        Improved   Improved   Had no    Worsened    Worsened       Too        No basis
                                         greatly   somewhat    effect   somewhat     greatly      early          to
                                                                                                  to say       judge
                                          (1)        (2)        (3)        (4)         (5)          (6)         (7)

a. Quality of leadership provided by
   top management           n =2,303      3%        18%        33%        16%         17%          4%           9%

b. Level of cooperation among
   INS units               n =2,307       1%        17%        43%        17%         10%          3%           9%

c. Communication between
   Headquarters and the regions
                             n =2,311     1%        13%        17%        12%          9%          2%          46%

d. Communication between
   Headquarters and administrative
   centers                 n =2,309       1%         8%        13%         7%          6%          2%          63%

e. Communication between the
   regions and the administrative
   centers                  n =2,311      1%         7%        13%         8%          6%          2%          64%

f. Communication between the
   regional offices and the
   districts/sectors        n =2,313      3%        19%        26%        10%          5%          2%          36%

g. Level of effort involved in
   obtaining administrative services
                             n =2,307     1%        10%        25%        18%         14%          2%          29%

h.     Quality of decision-making
                             n =2,300     1%        16%        33%        20%         14%          3%          13%

i. Timeliness of decision-making
                             n =2,307     1%        14%        31%        21%         18%          2%          13%

j. Consistency of policies among
   units/programs           n =2,307      1%        14%        36%        20%         13%          3%          14%

k. Timeliness of work        n =2,309     1%        15%        41%        18%         11%          3%          11%

l. Efficiency of work        n =2,309     1%        16%        40%        18%         11%          3%          11%

m.     Review process (layers of
       review needed)       n =2,305      1%        11%        31%        18%         19%          2%          19%




               Page 116                                                 GAO/GGD-97-132 INS Management Problems
               Appendix IV
               GAO Survey on INS Management Issues




36.   In your opinion, has the reorganization improved, worsened, or had no effect on the following in your unit?
      (Check one box in each row.)


                                       Improved     Improved     Had no     Worsened    Worsened        Too        No basis
                                        greatly     somewhat     effect     somewhat     greatly       early           to
                                                                                                       to say       judge
                                          (1)          (2)         (3)         (4)          (5)          (6)          (7)

a. Effectiveness of program
   operations               n =2,308     1%           17%         43%         19%          11%          3%           7%

b. Staff morale             n =2,313     1%            9%         37%         26%          22%          2%           5%

c. Quality of decision-making
                            n =2,309     2%           14%         46%         19%          12%          2%           6%

d. Timeliness of decision-making
                            n =2,309     2%           13%         44%         20%          13%          2%           6%

e. Accountability           n =2,308     2%           13%         46%         16%          13%          2%           7%




37.   In your opinion, what would be the best organization for INS' administrative functions? (Check one.)

n=2,287

16%            1.        Current administrative center structure
                         (i.e., administrative centers that support regional offices and report to Headquarters)

29%            2.        Previous administrative structure
                         (i.e., administrative offices that supported regional offices and reported to the regional offices)

18%            3.        Administrative centers with specialized centers that report to Headquarters
                         (i.e., specialized centers located outside of Headquarters, such as finance in one location and
                         personnel at another location, etc. )

10%            4.        Other organization - Please specify: _______________________________________________

28%            5.        No opinion




               Page 117                                                     GAO/GGD-97-132 INS Management Problems
              Appendix IV
              GAO Survey on INS Management Issues




XII. Comments


38.   If you have any additional comments regarding any previous question or comments concerning INS' managerial
      practices, internal control weaknesses, or specific problems that need to be addressed, please use the space
      provided below. If necessary, you may add additional sheets.



              974 respondents included written comments.




                                            Thank you for your assistance.
      Please return your questionnaire in the pre-addressed envelope. Also, please return the postcard separately.
                                                                                                              GGD-SMK 9/95




              Page 118                                                   GAO/GGD-97-132 INS Management Problems
Appendix V

INS’ Fiscal Years 1995 and 1996 Priorities



Table V.1: INS’ Fiscal Year 1995 Priorities
Prioritya                                     INS statement of priority
1. Strengthen border protection               INS will continue to improve border protection by facilitating travel and commerce while
                                              ensuring border integrity. This will be accomplished by employing a strategy of
                                              prevention through deterrence, concentrating resources at key transit and entry points
                                              (foreign and domestic), and employing resource-multiplying technology. Activities will
                                              include continued implementation of a comprehensive Southwest land border strategy,
                                              improvement in the use of lookout systems through better integration of data, and
                                              continued development of automated inspections processes.
2. Expedite removal of criminal aliens        INS will broaden its programs to identify and apprehend criminal aliens and expedite
                                              their removal from the United States. Activities will include responding to federal, state,
                                              and local law enforcement officers’ requests on alienage and immigration status;
                                              completing implementation of the five-state Institutional Hearing Program model;
                                              completing development of a national alien transportation plan; expanding the use of
                                              technology, including the use of electronic fingerprinting and teleconferencing; and
                                              completing a comprehensive review of the legal and regulatory processes for removal.
3. Reduce incentives for unlawful migration   INS will decrease the “pull factors” for illegal migration and simultaneously support
                                              benefit providers with information on alienage of individuals. Strategies include making it
                                              easier for employers to verify employment eligibility and increasing efforts to educate
                                              employers about their responsibility to comply with the law, focusing enforcement efforts
                                              on industries that have traditionally relied on unauthorized labor and employers who
                                              knowingly violate the law, and increasing the security of employment authorization
                                              documents.
4. Implement asylum reform regulations        INS will implement a more timely asylum processing and decision system. New
                                              procedures, coupled with additional resources, will enable the Service to keep up with
                                              incoming applications and begin to handle backlogged cases. This effort will also focus
                                              enforcement on fraudulent applications, reducing incentives for asylum abuse.
5. Improve customer service                   INS will enhance delivery of services to its customers. This will be accomplished by
                                              improving the current systems being used to obtain and apply customer service
                                              feedback; implementing all components of the Executive Order on “Setting Customer
                                              Service Standards”; and applying benchmarking to programs, where applicable, to
                                              achieve best-in-the-business practices and standards.
6. Promote and streamline naturalization      INS will encourage and promote naturalization through public education programs by
                                              establishing cooperative agreements with community-based organizations, ethnic group
                                              networks, and educational institutions to assist in preparation of applications and study
                                              for civics and language tests; and by seeking ways to streamline the naturalization
                                              process.
7. Improve professionalism                    INS will pursue professionalism at all levels of the agency. This will be accomplished by
                                              maintaining high standards of conduct fostered through proper training and career
                                              development and hiring and promotion practices—as reflected in the Service’s new
                                              Equal Employment Opportunity plan—that result in a workforce that reflects the diversity
                                              of America and our clientele.
8. Provide innovative immigration policy      INS will inform and shape immigration policy through production of timely, high-quality
leadership                                    information and policy analysis. The Service will take a proactive role in creating a better
                                              understanding of immigration issues and in advancing new initiatives, including
                                              legislation, to improve administration of U. S. immigration law and policy.
9. Broaden and integrate INS’ systems         INS will improve management information systems by developing accurate, timely,
infrastructure                                integrated databases that upgrade operational effectiveness and productivity. The INS
                                              “information highway” will lead to paperless work processes and national automated
                                              immigration data repositories for both INS and relevant non-INS users.

                                                                                                                  (Table notes on next page)


                                              Page 119                                        GAO/GGD-97-132 INS Management Problems
Appendix V
INS’ Fiscal Years 1995 and 1996 Priorities




a
According to INS officials, these priorities were not ranked in their order of importance.

Source: INS.




Page 120                                             GAO/GGD-97-132 INS Management Problems
                                              Appendix V
                                              INS’ Fiscal Years 1995 and 1996 Priorities




Table V.2: INS’ Fiscal Year 1996 Priorities
Prioritya                                     INS statement of priority
1. Strengthen the INS workforce               INS will rapidly increase the size of its officer workforce and support staff. To accomplish
                                              the goal of hiring over 4,000 new, productive employees, INS will (1) streamline and
                                              target recruitment, (2) expand training, (3) increase retention of experienced employees,
                                              and (4) deploy new employees with proper equipment.
2. Strengthen border enforcement and          INS will regulate entry to the United States in a manner that facilitates lawful travel and
facilitation                                  commerce while ensuring border integrity against unlawful entry. Efforts in fiscal year
                                              1996 will consolidate and expand progress achieved at and between ports-of-entry in
                                              the primary corridors of illegal immigration. To pursue these strategic targets, INS will (1)
                                              enhance control between ports-of-entry along the Southwest Border, especially in San
                                              Diego, Tucson, McAllen, and El Paso; (2) tighten control at ports-of-entry in anticipation
                                              of the impact from beefed-up Border Patrol activities; (3) facilitate traffic by adding new
                                              inspectors, opening lanes, and redesigning signs; (4) establish a proactive intelligence
                                              program to support field managers in anticipating and responding to shifts in illegal alien
                                              crossing patterns; (5) develop overseas deterrence activities, particularly in Mexico City,
                                              to support border control efforts; and (6) expand antismuggling operations.
3. Increase removal of deportable aliens      INS will increase removal of criminal and noncriminal illegal aliens, focusing especially
                                              on aliens convicted of aggravated felonies. To increase removals, INS will (1) increase
                                              criminal alien removals through expanded Institutional Hearing Programs and county jail
                                              projects; (2) expand noncriminal alien removals with final orders of deportation of aliens
                                              who have absconded, been rejected for asylum, or are in the workforce illegally; (3)
                                              improve functioning of primary components of removal system, including the national
                                              transportation system; and (4) enhance cooperative efforts with other law enforcement
                                              agencies.
4. Enhance worksite enforcement and           INS will reduce opportunities for illegal employment through enhanced worksite
verification systems                          investigations, document improvements, and automated status verification services. To
                                              increase control at the worksite, INS will (1) target the worst violators of immigration and
                                              employment standards laws and coordinate investigations with the Department of Labor,
                                              (2) increase worksite operations to remove unauthorized workers and make jobs
                                              available for authorized workers, and (3) test and expand pilot programs to assist
                                              employers in complying with the law.
5. Improve immigration services               INS will continue to improve services to its various customers, including petitioners for
                                              immigration benefits, other law enforcement agencies, its own front-line employees, and
                                              the local communities within which the Service works. To improve services, INS will (1)
                                              reorganize service delivery to applicants for immigration benefits by improving forms,
                                              reducing waiting periods, and accelerating processing times; (2) increase coordination
                                              with other local law enforcement agencies to improve sharing of information, response
                                              times, and joint operations; and (3) expand outreach to local communities through
                                              citizen advisory groups, coordination with consulates, and participation in public events,
                                              including expanded public affairs activities and communication with local congressional
                                              offices.
6. Implement citizenship U.S.A.               INS will respond to the tremendous growth in naturalization applications by reducing
                                              naturalization processing times to 6 months. It will greatly increase the efficiency, quality
                                              control, and convenience of the process and work with a variety of local organizations to
                                              meet the increase in applications while maintaining examination standards.
                                              a
                                              According to INS officials, these priorities were ranked in their order of importance.

                                              Source: INS.




                                              Page 121                                             GAO/GGD-97-132 INS Management Problems
Appendix VI

Comments From the Commissioner of the
Immigration and Naturalization Service




              Page 122      GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service




Page 123                                 GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service




Page 124                                 GAO/GGD-97-132 INS Management Problems
Appendix VI
Comments From the Commissioner of the
Immigration and Naturalization Service




Page 125                                 GAO/GGD-97-132 INS Management Problems
Appendix VII

Major Contributors to This Report


                        Evi L. Rezmovic, Assistant Director, Administration of Justice Issues
General Government      Linda R. Watson, Evaluator-in-Charge
Division, Washington,   Charity J. Goodman, Senior Evaluator
D.C.                    Charles Michael Johnson, Senior Evaluator
                        Stuart M. Kaufman, Senior Social Science Analyst
                        Katherine M. Wheeler, Publishing Consultant
                        Pamela V. Williams, Communications Analyst


                        Ann H. Finley, Senior Attorney
Office of the General
Counsel, Washington,
D.C.
                        Michael P. Dino, Senior Evaluator
Los Angeles Field       Leah G. Riordan, Senior Evaluator
Office




(183594)                Page 126                               GAO/GGD-97-132 INS Management Problems
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