oversight

Alien Applications: Processing Differences Exist Among INS Field Units

Published by the Government Accountability Office on 1997-05-20.

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

                United States General Accounting Office

GAO             Report to the Attorney General




May 1997
                ALIEN APPLICATIONS
                Processing Differences
                Exist Among INS Field
                Units




GAO/GGD-97-47
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      General Government Division

      B-275114

      May 20, 1997

      The Honorable Janet Reno
      The Attorney General
        of the United States

      Dear Madam Attorney General:

      The Immigration and Naturalization Service (INS) collects fees for
      processing aliens’ applications (and petitions) for such immigration
      benefits as naturalization and adjustment of status (to become permanent
      residents).1 Eighteen percent ($566 million) of INS’ fiscal year 1997 budget
      of $3.09 billion is allocated for processing applications.

      The number of applications received by INS has been growing and there are
      indications that some INS field units are faster than others at application
      processing. In fiscal year 1996, INS received almost 5.4 million new
      applications and completed about 5.6 million total applications, which is
      about a 115 percent increase over the number of applications received and
      completed in fiscal year 1989. At the end of fiscal year 1996, INS had a
      pending caseload inventory of about 1.7 million applications to be
      processed. This represented an increase of about 2.5 times the pending
      caseload at the end of fiscal year 1989. A recent INS report2 indicated
      differences in application production rates and projected processing times
      among its district offices.

      Because of the large volume of applications and indications of differences
      in processing times across INS field units, we initiated a review under our
      basic legislative authority to determine if significant differences in
      production rates and processing times existed among field units in




      1
       Until recently, INS was to deposit the revenue from all of these fees into the Immigration Examination
      Fee Account. The 1989 Department of Justice Appropriation Act established the account to be used to
      reimburse any appropriation for expenses in providing immigration and naturalization services. P.L.
      100-459, 102 Stat. 2186, 2203 (1988). In the fall of 1996, the Illegal Immigration Reform and Immigrant
      Responsibility Act established a new account, the Immigration Detention Account, into which certain
      additional fees for adjustment of status are now deposited. P.L. 104-208, 110 Stat. 3009, 3009-648,
      3009-649 (1996).
      2
       INS Benefits Division Production Report, Fiscal Years 1996-1997.



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                       application processing.3 Because we found differences, we also asked
                       officials at the nine district offices and two service centers that we visited
                       what factors they believed could have caused the differences. We did not
                       attempt to do the more detailed analyses that would be necessary to
                       determine actual causes. This report presents the results of our work.


                       Our analyses of INS data for the 25-month period of June 1994 through
Results in Brief       June 1996 showed that statistically significant differences existed in the
                       production rates for the five predominant types of applications processed
                       by INS’ district offices and the three predominant types of applications
                       processed by its service centers. For example, the district offices’ average
                       production rates for naturalization applications for that period ranged
                       from 0.35 completions per hour to 1.83 completions per hour. The service
                       centers’ average production rates for employment authorization
                       applications ranged from 3.11 completions per hour to 5.79 completions
                       per hour.

                       Large differences also existed in the projected processing times for the
                       two types of applications for which these data were readily available. The
                       data showed that INS district offices’ projected processing times ranged
                       from 112 to 678 days to process naturalization applications and from 36 to
                       799 days to process adjustment-of-status applications. We found no
                       significant statistical relationship between production rates and projected
                       processing times among the district offices.

                       While we did not determine directly what caused the differences, the wide
                       range in rates and times suggests that opportunities may exist to improve
                       the production and timeliness of some of the INS field units. To that end,
                       we asked INS officials what factors they believed could potentially have
                       caused the differences in the production rates and processing times. They
                       suggested a number of potential factors, including the following:

                   •   differences in the way the field units reported the data we used to
                       calculate the production rates and processing times;


                       3
                        We analyzed the production rates and projected average processing times for each of 25 months in 33
                       INS districts. We did a Pearson correlation coefficient analysis to determine if statistical relationships
                       between production rates and projected average processing times existed (e.g., was an increase in
                       production rates statistically related to an increase in projected average processing times). We
                       calculated “production rates” as the number of completed applications divided by the productive
                       processing staff hours for each field unit (district office and service center). We calculated monthly
                       projected average processing times by dividing the number of applications pending at month’s end by
                       the number of applications completed for the month and multiplying this product by the number of
                       calendar days in the month.



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             •   assistance provided by community-based service organizations in some
                 districts to aliens when filling out their applications;
             •   the use of outside agencies for conducting naturalization testing by some
                 district offices;
             •   the authorization of increased overtime for some districts’ employees;
             •   the varying experience levels and degrees of specialization of district
                 office and service center adjudications officers; and
             •   differences in the staffing levels among some district offices (e.g., some
                 offices were staffed above their authorized levels, while other offices
                 temporarily lost staff to larger offices).

                 We did not attempt to determine whether or to what degree the factors
                 suggested by the officials may have affected the individual field units’
                 production rates and processing times. We note, however, that differences
                 in processing times mean that aliens in different INS districts have had to
                 wait disparate amounts of time for their applications to be processed.
                 Thus, the need to treat applicants fairly and use government resources
                 efficiently makes both determining the causes of the production and
                 timing differences and, if feasible, improving production and timeliness,
                 important goals for INS.


                 INS processes applications for aliens seeking immigration benefits—such
Background       as naturalization and adjustment of status—within its 33 district offices’
                 jurisdictions and 4 service centers located in cities throughout the United
                 States.

                 INScollects fees for processing applications. The fees are generally set on
                 the basis of the approximate cost that INS determines it incurs to process
                 the type of application filed.4 The revenue from the fees is to be used for
                 expenses incurred in (1) processing applications and (2) collecting,
                 safeguarding, and accounting for the fees. In general, INS processes
                 applications that require aliens to be interviewed (i.e., those for
                 naturalization and adjustment of status) at its district offices. However, at
                 four of its largest district offices, the service centers perform preliminary
                 processing of applications that require aliens to be interviewed.
                 Applications that do not require aliens to be interviewed (e.g., those for




                 4
                  An exception is the adjustment-of-status application fee, which is set by statute at $1,000 for certain
                 aliens.



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                                     employment authorization) are processed at its service centers and district
                                     offices.5


Increased Volume of                  While experiencing some fluctuations, the overall number of applications
Applications                         received, completed, and remaining in INS’ ending inventory significantly
                                     increased between fiscal years 1989 and 1996, as shown in table 1.

Table 1: Number of Applications
Received, Completed, and Remaining                                                          Applications
in Inventory, Fiscal Years 1989                                                                                       Fiscal year ending
Through 1996                         Fiscal year                          Received                 Completed                   inventory
                                     1989                                 2,510,015                  2,585,478                     658,399
                                     1990                                 2,963,428                  2,971,300                     540,830
                                     1991                                 3,359,869                  3,379,383                     568,189
                                     1992                                 4,234,980                  4,207,968                     656,067
                                     1993                                 4,498,208                  4,288,643                     679,982
                                     1994                                 4,137,660                  3,911,697                     987,485
                                     1995                                 4,976,716                  4,265,463                   1,765,999
                                     1996                                 5,393,501                  5,557,102                   1,673,163
                                     Source: INS budget data for fiscal years 1989 to 1991 and INS G-22.2 and G-22.3 reports for
                                     fiscal years 1992 to 1996, dated January 1997.



                                     According to INS officials, the significant increase in the number of
                                     applications INS has received since fiscal year 1989 can be attributed to
                                     (1) aliens’ reactions to proposed changes in state and federal laws that
                                     would have denied aliens benefits (e.g., proposals to prohibit children of
                                     illegal aliens from attending public schools); (2) aliens having to replace
                                     their alien registration receipt cards; and (3) legal aliens becoming eligible
                                     to become naturalized and having an incentive to do so because of the
                                     benefits that could be derived from their status as citizens. INS officials
                                     said that naturalization and adjustment-of-status applications reached
                                     record levels in fiscal year 1996. For example, naturalization applications
                                     rose from about 423,000 in fiscal year 1989 to over 1.2 million in fiscal year
                                     1996. The officials also said that the level of applications is expected to
                                     remain high.

                                     According to INS officials, the waiting time needed to process an
                                     application in fiscal year 1995 had increased. For example, the projected

                                     5
                                      In addition, INS processes applications for asylum at eight offices nationwide. Because such
                                     applications are not processed at the district offices or the service centers, we excluded them from our
                                     review.



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                         processing time for naturalization applications exceeded 2 years in several
                         of INS’ largest districts. INS added that this increase in processing time was
                         due to (1) the tremendous growth in application receipts, combined with
                         the speed at which the increase occurred; and (2) the lag time to obtain
                         additional resources through the reprogramming process.


Changes in Application   In 1986, INS began requiring that some applications, other than those
Processing               requiring interviews (e.g., those for naturalization and adjustment of
                         status), be mailed directly to service centers for processing, rather than to
                         the district offices.6 INS called this the “Direct Mail Program.” Under a
                         change to the Direct Mail Program, which was effective February 1996,
                         aliens who would have mailed their naturalization applications to one of
                         INS’ four largest district offices (Chicago, Los Angeles, Miami, and New
                         York) are required to mail their naturalization applications directly to a
                         designated service center. The service centers are to perform the
                         preliminary processing of the applications in support of these four district
                         offices.7 The district offices are to complete the processing of these
                         applications by doing additional work (e.g., interviewing the aliens).
                         According to INS officials, INS expects to continue with its plan to expand
                         the Direct Mail Program to include other district offices and application
                         types. The officials added that the Direct Mail Program has greatly assisted
                         these district offices in reducing the large pending workload of
                         naturalization applications.

                         In addition to expanding its Direct Mail Program, during fiscal year 1996
                         INS directed more resources to processing naturalization applications. It
                         concentrated its additional staff and other resources primarily in Los
                         Angeles, San Francisco, Miami, Chicago, and New York. These district
                         offices’ workloads together comprised 75 percent of pending
                         naturalization applications in fiscal year 1995 and, according to INS
                         officials, this was the reason they were chosen for the Direct Mail
                         Program.

                         According to INS officials, as a result of these efforts, the number of
                         naturalization applications completed increased by about 166 percent
                         between fiscal years 1995 and 1996, and the pending balance was reduced


                         6
                          The applications were to be mailed to designated remote adjudications centers, which have since
                         been replaced by the four service centers.
                         7
                          Under the Direct Mail Program, the California Service Center supports the Los Angeles District Office,
                         the Nebraska Service Center supports the Chicago District Office, the Texas Service Center supports
                         the Miami District Office, and the Vermont Service Center supports the New York District Office.



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                                          by about 13 percent over the same time period. The officials said that INS
                                          received more applications but its capacity to handle applications
                                          increased at the same time. However, its pending balance of
                                          adjustment-of-status applications increased by about 37 percent. The
                                          pending balance for all types of applications decreased by 17 percent. (See
                                          table 2.)


Table 2: Changes in Receipts, Completions, and Pending Balances for Adjustment-of-Status, Naturalization, and All
Application Types for Fiscal Years 1995 and 1996
                                                                  Percent                  Percent                                     Percent
Application type                         Fiscal year Receipts      change Completed        change       Pending                        change
Naturalization                                   1995   1,057,759                        505,913                       803,062
                                                 1996   1,220,517             15.4     1,344,412           165.7       701,487            (12.6)
Adjustment of status                             1995     577,759                        357,567                       320,770
                                                 1996     649,792             12.5       541,867            51.5       438,546             36.7
All types                                        1995   3,341,198                      3,401,983                       642,167
                                                 1996   3,523,192              5.4     3,670,823              7.9      533,130            (17.0)
                                          Source: INS G-22.2 and G-22.3 reports for fiscal years 1995 and 1996, dated January 1997.




INS Application Processing                INS’goal is that the application process will be timely, consistent, fair, and
Goals                                     of high quality. In addition, INS officials stated that a quality decision
                                          includes a timely decision. During fiscal year 1996, INS made processing
                                          naturalization and adjustment-of-status applications among its highest
                                          priorities and INS’ Commissioner set 6-month and 4-month goals,
                                          respectively, for processing these two types of applications.8 According to
                                          INS officials, INS has not established production rate goals.



                                          To determine the production rates and projected processing times for
Scope and                                 selected application types at INS’ district offices and service centers, we
Methodology                               collected and analyzed INS application processing workload summary data
                                          and projected processing time reports by application type and by month
                                          for the 25-month period ending June 1996. We then compared the
                                          production rates and projected processing times for applications among
                                          district offices and the production rates for applications among service
                                          centers. After identifying differences, we attempted to identify possible
                                          reasons for the differences in production rates and processing times. We
                                          did this by asking INS officials in headquarters and 11 selected field units

                                          8
                                           A processing time frame of 90 days for interim employment authorization applications also exists.



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what factors they believed could have caused the differences.9 On the
basis of our analyses of production rates and projected processing times,
we chose the nine district offices and two service centers we visited
because they had a range of production rates, processing times, and
application volumes.10 At these field units and INS headquarters, we
discussed application processing procedures, staffing changes, production
rates, and application processing times for the period of June 1994 through
June 1996. Their comments are not generalizable to other field units. Also,
we reviewed an INS report that showed differences in production rates and
projected processing times among its field units.11

Using INS’ methodology, we calculated “production rates” as the number of
completed applications divided by the productive processing staff hours
for each field unit (district office and service center).12 This is a measure
of how many applications were completed per hour. According to INS
guidance, the projected processing time for a particular month is to be
calculated by dividing the number of applications pending at month’s end
by the number of applications completed for the month and multiplying
this product by the number of calendar days in the month. This is a
projection of how long INS will take to complete action on an application
received on the last day of the month if the current month’s completion
rate is maintained. This is a proxy measure of how long the “wait time”
would be from receipt of an application to the completion of its
processing, per month. INS used this methodology to calculate projected
processing times for selected application types by month over the
25-month period of June 1994 through June 1996.

Since the fall of 1996, reports by us and others and congressional oversight
hearings have provided evidence that INS’ efforts to reduce backlogs in
naturalization application processing resulted in serious internal control
and other weaknesses that led to improper naturalization actions in some
cases.13 Reviews of these problems, by ourselves and others, are currently

9
 We met with Assistant District Directors for Examinations and Service Center Directors, except when
they suggested that we speak with someone else on their staff.
10
    See app. I for a list of locations we visited.
11
 The data source for this report was the same source that we used for our analysis. INS’ report
excluded data on returned applications, while we included these data.
12
  Productive processing staff hours do not include staff time spent on any administrative functions
(e.g., training, travel, supervision, and record keeping).
13
 Naturalization of Aliens: Assessment of the Extent to Which Aliens Were Improperly Naturalized
(GAO/T-GGD-95-51, Mar. 5, 1997); KPMG Peat Marwick LLP. Naturalization Quality Procedures
Implementation Review (Washington, D.C.: Apr. 17, 1997); Naturalization of Aliens: INS Internal
Controls (GAO/T-GGD-97-57, Apr. 30, 1997); Naturalization of Aliens: INS Internal Controls
(GAO/T-GGD-97-98, May 1, 1997).
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                            ongoing. The scope of the work that was undertaken to address our
                            objectives for this report—to determine whether significant differences in
                            production rates and processing times existed among INS’ field units—did
                            not include an assessment of whether INS’ naturalization processes were
                            being carried out in accordance with INS’ policies and procedures.

                            We conducted our review from March 1996 to April 1997 in accordance
                            with generally accepted government auditing standards. We provided the
                            Attorney General and the INS Commissioner with a draft of this report for
                            their review and comment. The Commissioner provided written comments
                            for the Attorney General, which are discussed and evaluated at the end of
                            this letter. The INS comment letter is reprinted in appendix III. Appendix I
                            provides a more detailed description of our objectives, scope, and
                            methodology. INS also provided separately some technical comments. We
                            discussed these comments with INS officials and agreed on appropriate
                            changes.


                            Our analyses of INS monthly workload summary data for the period of
Variances in                June 1994 through June 1996 showed that statistically significant
Production Rates            differences existed in production rates for each of the five predominant
                            types of applications among INS district offices and service centers. This is
                            consistent with the INS report that also showed differences in production
                            rates among its district offices and among its services centers for fiscal
                            years 1994, 1995, and 1996. In discussing our analyses with INS officials,
                            they pointed out that anomalies in some district offices explain some of
                            the differences. However, INS did not provide any examples of these
                            anomalies.


Production Rates Differed   Our analyses of the production data for district offices and service centers
Significantly               showed that statistically significant differences existed in average
                            production rates by application type (as measured by applications
                            completed per productive hour) for the 25-month period ending June 1996.
                            (See table 3.) See appendix II for a schedule by field unit and application
                            type.14




                            14
                              In our analyses, we compared monthly production rates (completed applications divided by
                            productive hours) by application type for each district office and service center. In this report, we used
                            the 25-month average by application type for each unit. This was done for presentation purposes
                            because of the complexity of the data for 33 district offices and 4 service centers by month, for 25
                            months, for 5 separate application types.



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Table 3: Range of Average Per Hour
Production Rates for INS District                                             District offices’ range            Service centers’ range
Offices and Service Centers for Five   Application type                               Low              High              Low              High
Application Types, June 1994 Through
                                       I-90                                           0.04              3.94             3.17              6.69
June 1996
                                       I-130                                          0.32              1.26             2.85              4.20
                                                                                                                              a                  a
                                       I-485                                          0.32              1.28
                                       I-765                                          0.76              4.55             3.11              5.79
                                                                                                                              a                  a
                                       N-400                                          0.35              1.83
                                       Legend:
                                       I-90 = replacement of alien registration card
                                       I-130 = immigrant visa for alien relative
                                       I-485 = registration for permanent residency or adjustment of status
                                       I-765 = employment authorization
                                       N-400 = naturalization
                                       a
                                        Generally, the service centers do not adjudicate the I-485 and N-400 applications.

                                       Source: GAO analyses of INS data.



                                       In comparing production rates among district offices for the five
                                       application types, some district offices tended to be more productive for
                                       all application types, others were comparatively less productive for all
                                       application types, while other district offices’ production rates varied by
                                       application type. For example, one district office had one of the highest
                                       production rates for one application type but the lowest production rate
                                       for two other application types. Another district office had one of the
                                       highest production rates for two application types but the next to lowest
                                       rate for another application type.

                                       We also analyzed the production data to determine if either the proportion
                                       of naturalization applications and adjustment-of-status applications or the
                                       volume of naturalization and adjustment-of-status applications completed
                                       by district offices was related to their production rates for these two
                                       application types.15 We did not find a statistically significant relationship.
                                       We did find, however, a statistically significant, positive relationship
                                       between the production rate for naturalization applications and the
                                       production rate for adjustment-of-status applications.16 That is, district
                                       offices with high production rates for naturalization applications also
                                       tended to have high production rates for adjustment-of-status applications.

                                       15
                                        Naturalization and adjustment-of-status applications accounted for about one-half of all completed
                                       applications in fiscal year 1996.
                                       16
                                         For the average production rate for the 33 districts, the Pearson correlation coefficient between the
                                       two application types was 0.58 (the probability that the relationship was due to chance was less than
                                       5 percent).



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                         In other words, we found a tendency for some district offices to have more
                         completions per hour than others for these two application types.


INS’ Report Containing   According to the INS Benefits Division Production Report, average
Production Data Also     production rates agencywide for all application types decreased from 1.67
Showed Variances         completions per hour in fiscal year 1995 to 1.45 in fiscal year 1996. Across
                         INS, during the same time period, average naturalization application
                         completions increased from 0.66 to 0.84 per hour, while completions of
                         adjustment-of-status applications decreased from 0.74 to 0.70 per hour.
                         The report further stated that, in fiscal year 1996, field units’ average
                         production rates ranged from 0.42 to 2.11 completions per hour for all
                         application types combined, from 0.21 to 2.30 completions per hour for
                         naturalization applications, and from 0.30 to 1.88 completions per hour for
                         adjustment-of-status applications. The INS report did not include a
                         statistical analysis of the differences in production rates.

                         We compared the results of our analyses with the data in INS’ report and
                         found that our results were similar to INS’ results. Differences in how we
                         aggregated data for analyses caused our figures to differ somewhat from
                         INS’ figures, but the overall pattern of differences across district offices is
                         evident in both analyses.17 INS excluded returned applications, while our
                         analyses of the data included returned applications. According to INS
                         officials, this inclusion would not significantly affect our analyses.

                         According to INS officials, although INS had not compared the reasons or
                         studied the causes for differing production rates, it has been working to
                         address differences in processing times.


                         Our analyses of INS workload summary and projected processing time data
Variation in Projected   for the 25-month period ending June 1996 showed that differences existed
Processing Times         among district offices concerning projected processing times for the two
                         predominant types of applications.18 Furthermore, INS’ report also showed
                         variances in projected processing times among its district offices.

                         17
                          INS’ report provided data from 65 units, including district offices and suboffices within the district
                         offices. Naturalization data for two units were zero. The data were for fiscal years 1994, 1995, and
                         1996. For fiscal years 1995 and 1996, INS also reported the data by quarters. Our analyses were done by
                         month for the 25-month period ending June 1996 for the same two application types as well as for the
                         other three major application types.
                         18
                          As with production rates, we used the 25-month average for projected processing times for
                         naturalization and adjustment-of-status applications. This was done for presentation purposes because
                         of the complexity of displaying the data for 33 district offices by month for the 25 months for 2
                         application types.



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Projected Application                   Our analyses of projected processing time data for adjustment-of-status
Processing Times Differed               and naturalization applications showed that significant differences existed
Significantly Among INS                 among INS district offices.19 For example, the projected average processing
                                        time for adjustment-of-status applications from June 1994 to June 1996
District Offices                        was 357 days for all district offices combined, with a low of 36 days and a
                                        high of 799 days20 (see table 4).

Table 4: Average Projected Processing
Times for Adjustment-of-Status          INS district office                                                                  Number of days
Applications at 32 District Offices,    St. Paul, MN                                                                                          36
June 1994 Through June 1996
                                        Portland, ME                                                                                          69
                                        Buffalo, NY                                                                                           102
                                        Cleveland, OH                                                                                         107
                                        Honolulu, HI                                                                                          110
                                        Denver, CO                                                                                            141
                                        Anchorage, AK                                                                                         147
                                        Baltimore, MD                                                                                         151
                                        Helena, MT                                                                                            163
                                        Philadelphia, PA                                                                                      180
                                        Detroit, MI                                                                                           197
                                        Dallas, TX                                                                                            208
                                        Boston, MA                                                                                            209
                                        Miami, FL                                                                                             221
                                        Seattle, WA                                                                                           228
                                        New Orleans, LA                                                                                       237
                                        Kansas City, MO                                                                                       244
                                        Atlanta, GA                                                                                           273
                                        San Antonio, TX                                                                                       311
                                        Portland, OR                                                                                          316
                                        Newark, NJ                                                                                            347
                                        Omaha, NE                                                                                             348
                                        San Francisco, CA                                                                                     353
                                        Washington, D.C.                                                                                      359
                                        Chicago, IL                                                                                           424
                                                                                                                                    (continued)

                                        19
                                         Because staff at INS service centers generally did not adjudicate naturalization and
                                        adjustment-of-status applications, we did not analyze the processing times for INS’ four service
                                        centers. Also, data on processing times for other types of applications were not readily available.
                                        Therefore, we only analyzed naturalization and adjustment-of-status applications.
                                        20
                                          We eliminated the Harlingen District Office (Texas) from our computation of INS’ average because
                                        its reported projected processing time appeared to be an anomaly. Doing further analyses to determine
                                        whether the time reported was an anomaly or an error was not practical.



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                                        INS district office                                                                 Number of days
                                        New York, NY                                                                                       456
                                        San Diego, CA                                                                                      504
                                        San Juan, PR                                                                                       521
                                        Phoenix, AZ                                                                                        608
                                        El Paso, TX                                                                                        669
                                        Los Angeles, CA                                                                                    770
                                        Houston, TX                                                                                        799
                                        INS average                                                                                        357

                                        Note: According to INS officials, as part of a pilot of the Direct Mail Program, the Vermont Service
                                        Center has been performing the preliminary processing of adjustment-of-status applications in
                                        support of the Baltimore District Office. The officials added that this initiative could affect the
                                        district office’s projected processing times and production rates for this application type.

                                        Source: GAO analyses of INS data.



                                        For naturalization applications, the average projected processing time
                                        from June 1994 to June 1996 was 373 days across all district offices, with a
                                        low of 112 days and a high of 678 days. (See table 5.)

Table 5: Average Projected Processing
Times for Naturalization Applications   INS district office                                                                 Number of days
at 32 District Offices, June 1994       Portland, ME                                                                                       112
Through June 1996
                                        Buffalo, NY                                                                                        130
                                        Baltimore, MD                                                                                      138
                                        Washington, D.C.                                                                                   140
                                        Anchorage, AK                                                                                      159
                                        Cleveland, OH                                                                                      167
                                        St. Paul, MN                                                                                       170
                                        Helena, MT                                                                                         171
                                        Kansas City, MO                                                                                    185
                                        Philadelphia, PA                                                                                   188
                                        San Antonio, TX                                                                                    196
                                        Portland, OR                                                                                       196
                                        Honolulu, HI                                                                                       218
                                        New Orleans, LA                                                                                    259
                                        New York, NY                                                                                       261
                                        Atlanta, GA                                                                                        265
                                        Omaha, NE                                                                                          265
                                        Boston, MA                                                                                         274
                                        Denver, CO                                                                                         287
                                                                                                                                  (continued)


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INS district office                                                                     Number of days
San Diego, CA                                                                                           294
El Paso, TX                                                                                             295
Harlingen, TX                                                                                           308
Newark, NJ                                                                                              331
San Juan, PR                                                                                            339
              a
Seattle, WA                                                                                             344
Los Angeles, CA                                                                                         369
Detroit, MI                                                                                             379
Dallas, TX                                                                                              455
Chicago, IL                                                                                             526
San Francisco, CA                                                                                       552
Miami, FL                                                                                               578
Houston, TX                                                                                             615
Phoenix, AZ                                                                                             678
INS average                                                                                             373

a
 An official in the Seattle District Office said that its processing time for naturalization applications
did not exceed 196 days. According to the official, the difference between the average data INS
and we used and its data resulted from the fact that INS and we used a formula (which is a proxy
on the basis of the aggregate flow of applications) to calculate average projected processing
times, whereas the Seattle District Office used the actual processing times spent to complete
individual naturalization applications each month. We did not verify Seattle’s calculation.

Source: GAO analyses of INS data.



To determine whether a statistical relationship existed between
production rates and projected processing times, we analyzed data for
adjustment-of-status and naturalization applications for all district offices
that completed at least 100 of either type of application per month during
the 25-month period ending June 1996.21 We found no significant
relationship between production rates and projected processing times
among the district offices.22




21
  To detect a possible relationship between the two application types, we needed a sufficient number
of completed applications. On the basis of our review of the data, 100 completed applications per
month were adequate for our purpose—29 and 30 district offices had completed an average of 100
naturalization and 100 adjustment-of-status applications per month, respectively. At the time of our
review, data from the New York District Office were not available. Because of data problems, we
excluded the Harlingen District Office (Texas).
22
  The Pearson correlation coefficient was less than 0.1 (with a probability greater than 0.8).



Page 13                                       GAO/GGD-97-47 INS Processing of Alien Applications
                             B-275114




INS’ Report Containing       According to the INS Benefits Division Production Report, during fiscal
Timeliness Data Showed       year 1996, the average projected processing times of reporting field units
Variances                    for completing all types of applications ranged from 45 days to 296 days.
                             The average projected processing time for naturalization applications
                             ranged from 22 days to 383 days. According to the INS report, 53 percent of
                             its reporting field units had average projected processing times for their
                             naturalization applications of less than or equal to 183 days (6 months),
                             which was INS’ processing goal. The projected processing times for the
                             field units to complete adjustment-of-status applications ranged from 38
                             days to 998 days. Twenty-eight percent of the field units completed
                             processing of adjustment-of-status applications within 122 days (4
                             months), which was INS’ processing goal. As in the case of INS’ production
                             data, its projected processing time data were consistent with our
                             analyses.23


                             To identify factors that may have contributed to the differences in
Possible Reasons for         production rates and processing times, we met with officials at INS
Differences in               headquarters, nine district offices, and two service centers.24 Generally,
Production Rates and         these officials’ comments focused on the data used to compare the field
                             units’ rates and times, as well as on other factors that may have affected
Processing Times             the units’ production and timeliness. With the exception of comparability
                             of data issues, we were not able to gain insight into the extent to which
                             these factors actually affected the production rates and processing times.
                             Such an assessment would require a more thorough review and analysis of
                             the field units’ procedures and practices for processing applications than
                             we could complete within a reasonable period of time.

                             In our discussions about factors that the officials said could have affected
                             differences in production rates and processing times, the issues they
                             identified tended to be interrelated. Therefore, in the following discussion,
                             we do not separate production rate and processing time issues.


Data May Affect              INSofficials in certain field units said that our comparisons of field units’
Comparisons of Field Units   production rates and projected processing times could be affected by two
                             data-related factors.



                             23
                               The same previously discussed reasons explain the differences between INS’ report and our analyses.
                             24
                              Before meeting with these officials, we provided them with our analyses of production rates and
                             projected processing times.



                             Page 14                                    GAO/GGD-97-47 INS Processing of Alien Applications
                                             B-275114




                                         •   The first factor was the possibility of inaccuracies in the data reported by
                                             other field units. For example, officials in two field units were concerned
                                             that other field units may not have accurately reported their production
                                             data. However, none of the field units we visited identified problems
                                             associated with its own production data. Furthermore, many of the
                                             officials told us that they reviewed and corrected their units’ production
                                             data before sending the data to their respective regional offices or INS
                                             headquarters.
                                         •   The second factor, which was cited by several district offices at the time of
                                             our visit, was inconsistency in defining the point when approved
                                             naturalization applications were considered completed. For example, five
                                             of the nine district offices we visited considered an approved
                                             naturalization application completed after the naturalization interview,
                                             and at that point, the district offices would approve the application. The
                                             other four district offices considered an approved naturalization
                                             application completed only after the alien was sworn in as a naturalized
                                             citizen.25 We agree with INS that the differences in production rates and
                                             processing times could be partly attributed to this inconsistent definition.
                                             However, as shown in table 6, our analyses indicated that differences
                                             existed in the production rates of the four districts that considered the
                                             naturalization ceremony the point of completion, as well as among the five
                                             district offices that considered the interview the point of completion.

Table 6: Ranges of Average
Production Rates and Projected                                                                                                    Projected
Processing Times for the Nine INS                                                                Per hour production          processing time in
District Offices Broken Out by When in                                                                  rate                        days
the Process Naturalization                   Naturalization complete                                   High           Low          High           Low
Applications Were Considered                 After ceremony                                             1.34          0.82           615           185
Completed, June 1994 Through
June 1996                                    After interview                                            1.83          0.56           455           130
                                             Source: GAO analyses of INS data.



                                             As shown in table 7, wide variances also existed among these district
                                             offices’ per hour production rates for the four types of applications, other
                                             than those for naturalization.




                                             25
                                               According to INS officials, INS now requires its field units to consider a naturalization application
                                             completed after the naturalization ceremony. The five district office officials said that they are now
                                             following this requirement.



                                             Page 15                                      GAO/GGD-97-47 INS Processing of Alien Applications
                                            B-275114




Table 7: Range of Average Per Hour
Production Rates for the Nine INS                                                                                  District offices’ range
District Offices for Four Application       Application type                                                             Low                 High
Types, June 1994 Through June 1996
                                            I-90                                                                         0.10                3.94
                                            I-130                                                                        0.32                1.26
                                            I-485                                                                        0.37                1.28
                                            I-765                                                                        0.76                3.78
                                            Legend:
                                            I-90 = replacement of alien registration card
                                            I-130 = immigrant visa for alien relative
                                            I-485 = registration for permanent residency or adjustment of status
                                            I-765 = employment authorization

                                            Source: GAO analyses of INS data.



                                            Regarding the nine district offices’ projected processing times, data were
                                            readily available for adjustment-of-status applications but not for other
                                            application types. The nine district offices’ projected processing times for
                                            adjustment-of-status applications also varied widely, ranging from 102
                                            days to 799 days.

                                            INSheadquarters officials were aware of concerns that field units had
                                            about the data we used for our analyses. However, they pointed out that
                                            the data were the best available and were used by INS for budgeting and
                                            management purposes, such as in INS’ previously mentioned Benefits
                                            Division Production Report. In addition, INS uses the same data for its
                                            report to Congress on the status of adjudications and naturalization
                                            processing.


Other Factors That May                      During our visits to field units, INS officials identified several factors that
Affect Production Rates                     they believed may affect production rates and processing times. They
and Processing Times                        pointed out that, in any such work process, an interrelationship exists
                                            among many factors that may affect both production rates and processing
                                            times. We agree and generally did not verify whether or to what extent the
                                            following factors actually affected production rates or processing times.

                                        •   An official from one district office said that it must rely on the courts to
                                            conduct naturalization ceremonies, which can delay the naturalization
                                            dates and, therefore, increase the time spent to complete applications. An
                                            official from another district office said that his office conducted the
                                            naturalization ceremony on the same day the application was approved,
                                            thereby shortening processing times.



                                            Page 16                                    GAO/GGD-97-47 INS Processing of Alien Applications
                  B-275114




              •   According to officials in two district offices, aliens’ naturalization
                  applications tended to be more accurately completed when aliens received
                  assistance from community-based service organizations. As a result,
                  according to these officials, INS officers were able to process these
                  applications more quickly.
              •   According to eight field unit officials, district offices have varying degrees
                  of automation. For example, one district office developed a computerized
                  tracking system to enhance the recording and processing of
                  adjustment-of-status applications. According to officials in this district,
                  other districts have requested and started to use this system to enhance
                  their adjustment-of-status application processing.26
              •   According to district office officials, in four district offices, adjudications
                  staff specialized in certain application types, while in the other five district
                  offices, adjudications staff performed as generalists, processing all types
                  of applications.
              •   According to INS officials at one field unit, the mix of applications (i.e., the
                  proportion of application types) that field units receive affects their
                  processing times. These officials added that, if a field unit receives a larger
                  percentage of applications that take longer to process, its average
                  processing times for all types of applications would be longer relative to
                  other field units.
              •   According to INS officials we visited, staffing at the district offices has
                  varied. While some district offices have been staffed at or above their
                  authorized levels, other offices have lost staff on a temporary basis to
                  larger offices. These officials added that the experience level of the
                  adjudication staff differs across INS. They said INS had recently hired new
                  staff, and the new hires are generally not as efficient as the more
                  experienced staff.
              •   According to officials we visited, some INS district offices rely on outside
                  testing agencies to conduct naturalization examinations, while other
                  offices conduct their own examinations. According to the officials, the use
                  of outside testing agencies may improve timeliness.
              •   According to officials in three district offices, authorized increases in
                  overtime hours above their budget enabled their offices to reduce
                  processing times.


                  Our analyses showed that the production rates among the district offices
Conclusions       and among service centers varied significantly for the five application
                  types we analyzed. We did not find a relationship between production
                  rates and the mix of applications received or the volume of completed

                  26
                    At the time of our review, this system was not being used agencywide.



                  Page 17                                    GAO/GGD-97-47 INS Processing of Alien Applications
B-275114




applications. Furthermore, the projected processing times of
naturalization and adjustment-of-status applications differed among the
district offices. We found no significant relationship between production
rates and projected processing times among the district offices. An INS
report covering approximately the same time period also showed
variations in projected production rates and projected processing times
among its district offices. INS has not identified reasons for these
variations.

We did not attempt to assess the extent to which specific practices or
circumstances caused the differences in production rates and processing
times among field units. However, our analyses of production rates and
projected processing times for the nine district offices we visited, along
with the fact that the field officials also provided other reasons, seem to
indicate that factors other than data quality problems, at least in part, may
have contributed to the variation. Data quality, specifically definitional
issues, however, could have contributed to differences across field units.

The production rates of district offices and service centers are important
because of the significant growth in the number of applications that INS
has received over the past several years. This growth has placed greater
demands on INS as it attempts to process these applications within
reasonable time frames. Our comparisons among field units show that
significant differences exist in their production rates; thus, opportunities
may exist to improve the production rates of some of the units.

Aliens pay the same fees for the various applications at all INS offices;
however, the length of time that aliens wait for their applications to be
completed has varied widely from field unit to field unit. This raises a
fairness issue in that the length of time aliens have to wait for their
applications to be processed varies according to the INS office at which
they apply.

Determining the reasons for the differences in, or methods for improving,
production or timeliness were outside the scope of this review. Because
INS has in-depth knowledge of its field operations and its application
processing procedures, it is in the best position to pursue the causal
factors that may be contributing to higher production in some field units.
The identification of these factors can be important because they may
relate to opportunities for improved efficiencies at all field units.




Page 18                          GAO/GGD-97-47 INS Processing of Alien Applications
                       B-275114




                       We recommend that you direct the INS Commissioner to periodically
Recommendations to     determine and assess the production rates and processing times in the INS
the Attorney General   field units. The Commissioner should first ensure that the field units are
                       consistently reporting the data used to calculate the rates and times. After
                       ensuring that data are consistently reported, including using the same
                       definitions, the Commissioner should (1) analyze the production rates and
                       processing times for each field unit by application type, (2) identify factors
                       that contribute to making the field units more or less productive and
                       timely, (3) determine whether and what changes could be made to make
                       individual field units more productive and timely, and (4) follow up with
                       the field units to ensure that appropriate changes are implemented.


                       In an April 22, 1997, letter, the INS Commissioner provided comments on a
Agency Comments        draft of this report (see app. III). Although not specifically commenting on
and Our Evaluation     our recommendations in its letter, INS officials, including the Associate
                       Commissioner for Examinations, in a meeting on March 18, 1997, said that
                       they agreed with our recommendations.27 However, the Commissioner
                       said that our draft led the reader to believe that our overall conclusions
                       were based on scientific analyses when, in her view, they were based
                       simply on unvalidated testimonial and anecdotal information.

                       We disagree with INS that our analyses and conclusions were not
                       scientifically based. We analyzed the production rates using standard
                       statistical techniques to determine if the differences between field units by
                       application type were significant. Our analyses showed that significant
                       differences existed. We then examined other factors that might be related
                       to the differences in the production rates such as processing times, mix of
                       application types, and volume of application types. However, we
                       recognized as a result of INS’ comment that additional information about
                       our methodology would be beneficial to a reader. Accordingly, we added
                       additional information to this report to clarify the statistical analyses we
                       performed.

                       INS also said that the data in our draft were suggestive and not conclusive
                       and that the report provided very little information to help it better
                       understand the problem. Therefore, INS believes that our work further
                       demonstrates the need for it to continue its efforts to improve data
                       integrity. INS added that one of its priorities is to revise its workload



                       27
                        At this meeting, INS provided technical comments, which were incorporated in this report where
                       appropriate.



                       Page 19                                   GAO/GGD-97-47 INS Processing of Alien Applications
B-275114




reporting process, including standardizing the definitions and methods of
data collection.

As discussed in this report, we agree that the data we analyzed do not
provide conclusive reasons for the differences in production rates and
processing times within the nine field offices. Our objectives for this
review did not include determining actual causes for the differences.


This report contains recommendations to you. As you know, 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 Chairmen and Ranking
Minority Members of interested congressional committees; the INS
Commissioner; the Director, Office of Management and Budget; and other
interested parties. Copies will also be made available to others upon
request.

Major contributors to this report are listed in appendix IV. If you have any
questions about this report, please contact me on (202) 512-8777.

Sincerely yours,




Norman J. Rabkin, Director
  Administration of Justice Issues




Page 20                         GAO/GGD-97-47 INS Processing of Alien Applications
Page 21   GAO/GGD-97-47 INS Processing of Alien Applications
Contents



Letter                                                                                                  1


Appendix I                                                                                             24

Objectives, Scope,
and Methodology
Appendix II                                                                                            28

INS Field Units’
Average Production
Rates and Average
Completions by
Application Type for
the 25-Month Period
Ending June 1996
Appendix III                                                                                           31
                         GAO’s Comments                                                                33
Comments From the
Commissioner,
Immigration and
Naturalization Service
Appendix IV                                                                                            34

Major Contributors to
This Report
Tables                   Table 1: Number of Applications Received, Completed, and                       4
                           Remaining in Inventory, Fiscal Years 1989 Through 1996
                         Table 2: Changes in Receipts, Completions, and Pending Balances                6
                           for Adjustment-of-Status, Naturalization, and All Application
                           Types for Fiscal Years 1995 and 1996
                         Table 3: Range of Average Per Hour Production Rates for INS                    9
                           District Offices and Service Centers for Five Application Types,
                           June 1994 Through June 1996




                         Page 22                        GAO/GGD-97-47 INS Processing of Alien Applications
Contents




Table 4: Average Projected Processing Times for                               11
  Adjustment-of-Status Applications at 32 District Offices,
  June 1994 Through June 1996
Table 5: Average Projected Processing Times for Naturalization                12
  Applications at 32 District Offices, June 1994 Through June 1996
Table 6: Ranges of Average Production Rates and Projected                     15
  Processing Times for the Nine INS District Offices Broken Out by
  When in the Process Naturalization Applications Were
  Considered Completed, June 1994 Through June 1996
Table 7: Range of Average Per Hour Production Rates for the                   16
  Nine INS District Offices for Four Application Types, June 1994
  Through June 1996
Table II.1: INS District Office Average Per Hour Production Rates             28
  and Average Monthly Completions by Application Type for the
  25-Month Period Ending June 1996
Table II.2: INS Service Center Average Per Hour Production                    30
  Rates and Average Monthly Completions by Application Type for
  the 25-Month Period Ending June 1996




Abbreviations

INS        Immigration and Naturalization Service


Page 23                        GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I

Objectives, Scope, and Methodology


              Because of the large volume of applications and indications of differences
              in processing times across INS field units, we initiated a review under our
              basic legislative authority to determine if significant differences in
              production rates and processing times existed among INS’ field units in
              application processing. Because we found differences, we also asked
              officials at the nine district offices and two service centers that we visited
              what factors they believed could have caused the differences. We did not
              attempt to do the more detailed analyses that would be necessary to
              determine actual causes.

              To determine the production rates for each type of application in the INS
              district offices and service centers, we obtained the monthly adjudications
              workload summary reports (G-22.2 and G-22.3 reports, dated January 31,
              1997) from INS headquarters covering the 25-month period from June 1994
              through June 1996. These monthly reports provided information, by
              district office and application type, on (1) the number of applications
              received and completed, as well as the ending (pending) balances; and
              (2) the productive hours of the adjudications staff. For each office, we
              then calculated average monthly production rates for each application
              type by dividing the applications completed by the productive hours spent
              on adjudications.

              The reports do not include contractor hours for processing applications
              and records management at the field units. During our discussions with
              field unit officials, they did not mention contractor hours as a factor
              affecting the differences in production rates or processing times. Since the
              INS reports did not contain contractor hours, we could not analyze the
              effect that contractor hours may have had on production rates or
              processing times.

              To better understand how production compared across INS field units, we
              analyzed the production rates for the five major types of applications
              separately. According to INS data, the five application types that were
              processed most frequently were the replacement of alien registration card
              (I-90), immigrant visa for alien relative (I-130), registration for permanent
              residency or adjustment of status (I-485), employment authorization
              (I-765), and naturalization (N-400). These five application types accounted
              for about 97 percent of all completed applications for June 1996. We
              compared the rates for each application type only with those for the same
              type of field unit. For example, the production rates for employment
              authorization applications at district offices were compared with those at
              other district offices but not with those at service centers. According to



              Page 24                          GAO/GGD-97-47 INS Processing of Alien Applications
    Appendix I
    Objectives, Scope, and Methodology




    INS,the application review processes are different in the two types of field
    units.

    To determine whether a relationship existed between production rates and
    projected processing times, we analyzed data for adjustment-of-status and
    naturalization applications for all district offices that completed at least
    100 of either type of application per month during the 25-month period
    ending June 1996. To determine whether a relationship existed between
    the two application types, we needed a sufficient number of completed
    applications. On the basis of our review of the data, 100 completed
    applications per month was adequate for our purpose. We also analyzed
    the production data to determine whether the mix of naturalization and
    adjustment-of-status applications received (i.e., proportion of application
    types at a district office) or the volume of naturalization and
    adjustment-of-status applications completed by district offices, was
    related to their production rates.1 Specifically, we performed three
    statistical analyses.

•   Our analysis of the variation in monthly production rates showed a
    statistically significant difference (probability that the relationship was
    due to chance was less than 5 percent) between district office average
    production rates. We analyzed data from June 1994 through June 1996 for
    the 33 districts for the 5 predominant types of applications processed by
    the district offices and 3 types for service centers. This result led to several
    other analyses to attempt to determine what factors might be related to
    production rates.
•   We compared production rates and projected average processing times to
    see if a statistically meaningful relationship existed between the two. That
    is, we wanted to know if districts with high production rates also generally
    had shorter projected average processing times than districts with lower
    production rates, or whether the inverse was true. We analyzed data for
    adjustment-of-status and naturalization applications for all district offices
    that completed an average of at least 100 applications per month during
    the 25-month period. We did not find a significant relationship (the
    Pearson correlation coefficient was less than 0.1 with a probability due to
    chance greater than 80 percent).
•   We also analyzed adjustment-of-status and naturalization applications to
    see if either the volume of applications processed or the mix of
    applications processed was related to the production rate. Volume was
    measured by the average number of completions per month for the two

    1
     Naturalization and adjustment-of-status applications accounted for about one-half of all completed
    applications in fiscal year 1996.



    Page 25                                    GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I
Objectives, Scope, and Methodology




application types, and mix was measured by the ratio of applications
completed for one application type divided by applications completed for
all other application types. We did not find a statistically meaningful
relationship among these factors. We did, however, find a statistically
significant, positive relationship between the production rate for
naturalization applications and the production rate for
adjustment-of-status applications (Pearson correlation coefficient equaled
0.58, with a probability that the relationships was due to chance of less
than 5 percent). That is, districts with high production rates for one
application type tended to have high production rates for the other
application type.

Finally, while we did not verify the accuracy of the adjudications data
received from INS, we obtained the comments of INS officials in field units
and headquarters on how data for the monthly adjudications workload
summary reports and productive hours are accumulated, as well as what
checks are performed to ensure the quality and accuracy of the data.
These officials raised questions about the reporting of productive hours
and the definition of naturalization application completions. Accordingly,
we performed additional analyses of the data in an effort to determine
their validity.

To analyze applications’ processing times, we gathered processing time
reports (also called “aging reports”) from INS headquarters covering each
district office for the same 25-month period—June 1994 through
June 1996. Processing time data were not readily available for the service
centers. We focused our analyses on the naturalization and
adjustment-of-status applications because these were the only applications
for which INS collects timeliness data. Further, INS has made these
application types its highest priority for adjudication and the INS
Commissioner has set specific processing time goals for these two types of
applications. As with the production rate data, at each INS office we visited
we also obtained the comments of INS field and headquarters officials on
the accuracy of the processing time data and what factors affect the
usefulness of the data.

To determine the reasons for the differences in production rates and
projected processing times, we selected and visited 9 of INS’ 33 district
offices and 2 of its 4 service centers. On the basis of our analyses of the
production data provided by INS, we selected five of the relatively more
productive district offices—Dallas, TX; El Paso, TX; Houston, TX; Omaha,
NE; and Seattle, WA—and four of the relatively less productive district



Page 26                              GAO/GGD-97-47 INS Processing of Alien Applications
Appendix I
Objectives, Scope, and Methodology




offices—Baltimore, MD; Buffalo, NY; Kansas City, MO; and Los Angeles,
CA—to visit. In addition, as part of our selection criteria, we factored in
the relative volume of applications received and applications’ projected
processing times. The service centers we visited were the California
Service Center (Laguna Niguel, CA) and the Texas Service Center (Irving,
TX). These two service centers were chosen primarily on the basis of their
proximity to the selected district offices we visited.

At each field unit, we gathered data on how production and processing
time data were collected and what checks were in place to ensure the
data’s accuracy. Generally, we met with Assistant District Directors for
Examinations and Service Center Directors, except when they suggested
that we meet with someone else on their staff. We discussed the unique
characteristics of the various field units we visited and what role these
characteristics may have played in affecting production rates and the
timeliness of adjudications. Finally, we discussed the policies and
procedures used by the field units we visited. Their comments are not
generalizable to other field units.

INSprocesses asylum applications at eight offices nationwide. Because
they are not processed at the district offices and service centers, we
excluded these applications from our review.

In the report, we present average processing and timeliness data for the
25-month period. This was done for presentation purposes. Our analyses
were done for each application type, by unit, and by month. We did the
analyses by month because using averages over 25 months could hide
differences. We performed our work between March 1996 and April 1997
in accordance with generally accepted government auditing standards.




Page 27                              GAO/GGD-97-47 INS Processing of Alien Applications
Appendix II

INS Field Units’ Average Production Rates
and Average Completions by Application
Type for the 25-Month Period Ending June
1996
Table II.1: INS District Office Average
Per Hour Production Rates and                                                          I-765
Average Monthly Completions by            District office          I-765 rate    completions         N-400 rate
Application Type for the 25-Month         Anchorage, AK                 2.74                20             0.57
Period Ending June 1996
                                          Atlanta, GA                   4.55              587              0.84
                                          Baltimore, MD                 0.76                96             1.09
                                          Boston, MA                    4.39             1,358             0.73
                                          Buffalo, NY                   2.10              260              0.56
                                          Chicago, IL                   3.81             1,541             0.74
                                          Cleveland, OH                 1.95              338              0.94
                                          Dallas, TX                    3.09              634              0.97
                                          Denver, CO                    2.22              351              0.86
                                          Detroit, MI                   1.51              289              0.94
                                          El Paso, TX                   3.06              337              1.83
                                          Harlingen, TX                 3.00              310              0.66
                                          Helena, MT                    1.43                67             0.40
                                          Honolulu, HI                  1.99              261              0.45
                                                                             c
                                          Houston, TX                   2.78              437              1.18
                                          Kansas City, MO               1.96              326              0.82
                                          Los Angeles, CA               2.04              896              1.12
                                          Miami, FL                     2.29             4,174             0.88
                                          New Orleans, LA               2.04              354              0.65
                                          New York, NY                  2.59             4,385             0.74
                                          Newark, NJ                    1.81             1,143             1.59
                                          Omaha, NE                     3.23              289              1.10
                                          Philadelphia, PA              2.51              447              0.65
                                          Phoenix, AZ                   3.77              740              0.60
                                          Portland, ME                  1.34                43             0.35
                                          Portland, OR                  1.89              277              0.93
                                          San Antonio, TX               3.24              556              0.78
                                          San Diego, CA                 2.06              713              0.74
                                          San Francisco, CA             2.63             2,832             0.57
                                          San Juan, PR                  1.80              238              0.37
                                          Seattle, WA                   3.78              501              1.34
                                          St. Paul, MN                  4.11              294              0.53
                                          Washington, D.C.              3.14              911              0.79




                                          Page 28             GAO/GGD-97-47 INS Processing of Alien Applications
                                    Appendix II
                                    INS Field Units’ Average Production Rates
                                    and Average Completions by Application
                                    Type for the 25-Month Period Ending June
                                    1996




     N-400                     I-130                        I-90                      I-485        Other      Other forms’
completions I-130 rate   completions   I-90 rate    completions I-485 rate      completions forms’ rate a    completions a
                                                                b
         85       0.88           26          0.31                      0.41              36           0.07                3
      1,212       0.91          336          1.79            33        0.64             772           0.07               42
      1,384       0.32          216          0.28              1       0.37             468           0.05               40
      2,086       0.68          517          0.74              7       0.73           1,010           0.04               45
        415       1.13          556          0.17              7       0.41             192           0.15              201
      3,200       0.74          537          0.24              1       0.74           1,304           0.07               51
        537       0.59          158          0.71              9       0.71             320           0.07               23
      1,153       0.93          249          1.56              8       1.03             894           0.04               17
        565       1.05          210          0.04              1       0.88             506           0.04               15
        721       0.54          152          2.17           132        0.79             398           0.02               16
      1,277       1.26           79          0.48              2       1.28             341           1.11            1,563
        442       0.69           70          0.42           173        0.47             152           0.46              503
         67       0.60          140          0.37              2       0.41              72           0.05               29
        532       0.83          305          2.04            45        0.32             247           0.08               52
      1,383       1.10          186          2.88            31        0.62             630           0.08               31
        416       0.37          118          0.10              1       0.49             226           0.04               15
     13,750       0.55          966          2.19              2       0.51           2,628           0.05              194
      5,048       0.83         1,060         0.25            27        0.47           2,331           0.03               60
        631       0.68          170          0.90            39        0.50             375           0.04               21
      9,575       0.47         1,390         0.26              4       0.59           3,239           0.11              395
      3,086       1.03          429          0.79            40        0.64           1,562           0.04               34
        184       0.99           74          3.94            75        1.06             138           0.02                2
        869       0.79          283          1.27              4       0.52             518           0.09               30
        928       0.71          192          1.51           665        0.47             524           0.39              751
        113       0.43           38          0.10              3       0.43              50           0.01                5
                                                                b
        349       1.14          108          1.50                      0.82             236           0.06                9
        807       0.65          179          0.74           203        0.84             473           0.63              670
      1,495       0.68          101          1.31           356        0.65             343           0.66            1,510
      5,730       0.71          740          0.86           167        0.52           1,836           0.03               48
        321       0.90          187          0.12              2       0.58             237           0.07               21
      1,171       0.79          259          0.42            29        0.85             537           0.06               64
        419       1.03          631          0.41            11        0.50             254           0.04               16
      1,360       0.74          337          1.48            30        0.50             713           0.14               69




                                   Page 29                                GAO/GGD-97-47 INS Processing of Alien Applications
                                            Appendix II
                                            INS Field Units’ Average Production Rates
                                            and Average Completions by Application
                                            Type for the 25-Month Period Ending June
                                            1996




                                         a
                                          The other application types (“other forms”) represented a small volume of applications, and
                                         therefore we did not analyze them separately or as a group.
                                            b
                                            Less than one completion per month on average.
                                         c
                                          The Houston data for March 1996 seemed to contain an error (547 completions per hour). Rather
                                         than attempt to determine the actual number of completions and productive hours for March, we
                                         eliminated the March data. If we had included the March data, Houston’s average production rate
                                         would have been 24.59 completions per hour.

                                         Source: GAO analysis of INS data.




Table II.2: INS Service Center Average Per Hour Production Rates and Average Monthly Completions by Application Type
for the 25-Month Period Ending June 1996
                                       I-765                   I-130                     I-90        Other    Other forms’
Service center I-765 rate       completions I-130 rate completions I-90 rate     completions forms’ ratea     completionsa
California           4.28          15,434             4.20        14,357          5.31              16,009             0.22               1,356
Nebraska             4.02           5,125             2.85         6,349          4.09               5,708             0.41               3,453
Texas                5.79          12,842             4.14        11,218          6.69              10,394             0.72               2,090
Vermont              3.11          14,238             3.07        13,905          3.17              10,697             0.28               2,028
                                            Note: The other application types (“other forms”) represented a small volume of applications, and
                                            therefore we did not analyze them separately or as a group. Generally, the service centers do not
                                            process the N-400 and I-485. The N-400 and I-485 are not included with the other forms.

                                            Source: GAO analysis of INS data.




                                            Page 30                                   GAO/GGD-97-47 INS Processing of Alien Applications
Appendix III

Comments From the Commissioner,
Immigration and Naturalization Service

Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




See comment 1




                             Page 31   GAO/GGD-97-47 INS Processing of Alien Applications
Appendix III
Comments From the Commissioner,
Immigration and Naturalization Service




Page 32                              GAO/GGD-97-47 INS Processing of Alien Applications
                 Appendix III
                 Comments From the Commissioner,
                 Immigration and Naturalization Service




                 The following are GAO’s comments on the Immigration and Naturalization
                 Service’s April 22, 1997, letter.


                 1. INS said that the overall results of our work alluded to problems related
GAO’s Comments   to data. It pointed out that we gathered information on how production
                 and processing time data were collected and what checks were in place to
                 ensure data accuracy but added that we provided little information to help
                 INS understand the problem. To identify what INS believed were the
                 potential causes for the differences in production rates and processing
                 times, we asked field unit officials among other things about any steps that
                 they may have taken regarding the checks that are performed to ensure
                 the quality and accuracy of data. They pointed out that they had concerns
                 that other field units may not have accurately reported their production
                 data, but many of the officials told us they reviewed their unit’s data. We
                 agree that we did not perform any detailed analysis regarding data
                 accuracy.




                 Page 33                              GAO/GGD-97-47 INS Processing of Alien Applications
Appendix IV

Major Contributors to This Report


                        James M. Blume, Assistant Director, Administration of Justice Issues
General Government      David P. Alexander, Senior Social Science Analyst
Division, Washington,   James A. Bell, Assistant Director
D.C.                    James M. Fields, Senior Social Science Analyst
                        Joanne M. Parker, Senior Social Science Analyst
                        Bonita J. Vines, Computer Specialist
                        Michelle D. Wiggins, Issue Area Assistant


                        Christopher H. Conrad, Evaluator-in-Charge
Dallas Field Office     Frederick T. Lyles, Jr., Evaluator


                        Ann H. Finley, Senior Attorney
Office of the General
Counsel, Washington,
D.C.




(183605)                Page 34                          GAO/GGD-97-47 INS Processing of Alien Applications
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