oversight

Higher Education: Verification Helps Prevent Student Aid Payments to Ineligible Noncitizens

Published by the Government Accountability Office on 1997-08-06.

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

                  United States General Accounting Office

GAO               Report to Congressional Committees




August 1997
                  HIGHER EDUCATION
                  Verification Helps
                  Prevent Student Aid
                  Payments to Ineligible
                  Noncitizens




GAO/HEHS-97-153
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division

      B-277450

      August 6, 1997

      The Honorable James M. Jeffords
      Chairman
      The Honorable Edward M. Kennedy
      Ranking Minority Member
      Committee on Labor and Human Resources
      United States Senate

      The Honorable William F. Goodling
      Chairman
      The Honorable William L. Clay
      Ranking Minority Member
      Committee on Education and the Workforce
      House of Representatives

      The Honorable Spencer Abraham
      Chairman
      The Honorable Edward M. Kennedy
      Ranking Minority Member
      Subcommittee on Immigration
      Committee on the Judiciary
      United States Senate

      The Honorable Lamar Smith
      Chairman
      The Honorable Melvin L. Watt
      Ranking Minority Member
      Subcommittee on Immigration and Claims
      Committee on the Judiciary
      House of Representatives

      The Department of Education administers a federal student financial aid
      structure that in academic year 1997-98 will provide about $47 billion in
      grants, loans, and other aid to 8.1 million recipients. Grants are provided
      mainly through the Federal Pell Grant Program, under which a student
      may receive up to $2,700 a year, depending on the demonstrated financial
      need. Loans come from a number of programs, the largest of which are the
      Federal Family Education Loan Program (the government guarantees
      loans provided by private sector lenders) and the William D. Ford Federal
      Direct Loan Program (the government makes loans directly to borrowers).




      Page 1                       GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
    B-277450




    Student eligibility criteria spelled out in title IV of the Higher Education
    Act of 1965, as amended, require that only U.S. citizens and eligible
    noncitizens receive federal student financial aid. Students who do not fall
    into either of these two categories are considered ineligible noncitizens
    and do not qualify for federal student financial aid. “Ineligible noncitizens”
    is a broad category that includes illegal aliens (persons who are in the
    United States in violation of U.S. immigration laws) as well as individuals
    legally in the United States. They include entrants whose applications for
    permanent residence are still pending, tourists, foreign students or
    exchange visitors with temporary visas, and individuals with visas
    pertaining to international organizations.

    The fiscal year 1997 Department of Defense Appropriations Act contains
    several immigration and welfare reform provisions, including a
    reaffirmation of the citizenship-related eligibility criteria contained in the
    Higher Education Act. A companion provision of the law requires us to
    report to the appropriate committees of the Congress on the extent to
    which illegal aliens are receiving postsecondary federal student financial
    assistance. This report responds to that mandate.

    In discussing the mandate with committee staff, we agreed to expand our
    analysis to all “ineligible noncitizens” because information is not readily
    available on specifically illegal aliens, a subcategory of this larger group. In
    addition, we agreed to focus our work on describing Department of
    Education processes intended to prevent applicants who are ineligible
    noncitizens from receiving aid rather than on conducting an independent
    audit of those who already received aid in order to determine their
    eligibility. We therefore focused our work on the following questions:

•   What processes ensure that ineligible noncitizens do not receive federal
    student financial aid under title IV?
•   How many potentially ineligible noncitizen applicants were identified
    through these processes?
•   What are the indications, if any, of the degree to which ineligible
    noncitizens are receiving student financial aid despite these processes?

    To answer these questions, we obtained information from the Department
    of Education, which administers federal student aid programs; other
    federal agencies involved in checking students’ eligibility for aid; and four
    college financial aid administrators. Our methodology is explained in
    detail in the appendix.




    Page 2                         GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                   B-277450




                   The processes for preventing ineligible noncitizens from obtaining federal
Results in Brief   student financial aid focus on identifying applicants whose eligibility is
                   questionable and referring their names to financial aid administrators at
                   postsecondary institutions (hereafter referred to as colleges) for
                   follow-up. The Department of Education uses two main screening
                   techniques to determine which applicants may be ineligible. It checks all
                   financial aid applicants for U.S. citizenship, using records of the Social
                   Security Administration (SSA). In addition, for applicants who are not U.S.
                   citizens, the Department checks the records of the Immigration and
                   Naturalization Service (INS) to determine if these applicants meet eligibility
                   criteria. Names of applicants who fail either of these screenings are sent to
                   financial aid administrators at colleges in which the applicant is interested
                   in enrolling. No federal student aid can be released until the applicant
                   provides proof of eligibility to the administrator. The Department’s
                   processes for verifying the citizenship status of all financial aid applicants
                   appear to be working reasonably well, as departmental monitoring has
                   found few implementation problems.

                   The INS and SSA screening techniques identified over 500,000 potentially
                   ineligible noncitizens in award year 1996-97 (July 1, 1996, through June 30,
                   1997), but it is possible that many of them ultimately provided proof of
                   their eligibility. According to the Department, of the 9.6 million financial
                   aid applicants in award year 1996-97, almost 460,000 (about 5 percent)
                   initially failed SSA screening—SSA could not confirm that an applicant was
                   a U.S. citizen—and another approximately 108,000 (1 percent) were
                   flagged for follow-up because INS could not confirm that they were eligible
                   noncitizens. The Department does not know how many of the flagged
                   applicants were subsequently found ineligible, because financial aid
                   administrators are required to neither inform the Department of the results
                   of their follow-up nor centrally maintain such information themselves. To
                   shed some light on the final outcome concerning an applicant’s eligibility,
                   we contacted financial aid administrators at four colleges with high
                   numbers of noncitizens in attendance. They estimated that virtually all the
                   applicants flagged through SSA and INS screening were ultimately able to
                   demonstrate their eligibility for student aid.

                   No one knows whether or how many ineligible noncitizens are
                   nonetheless managing to qualify for student financial aid. The
                   Department’s Office of Inspector General (OIG) has not opened and
                   resolved any investigations of applicants who falsified their citizenship
                   status and received aid since the SSA verification process was implemented
                   in 1996. However, OIG did, primarily in response to allegations of



                   Page 3                        GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                                        B-277450




                                        citizenship fraud, identify 26 cases in which ineligible noncitizens received
                                        aid between 1993 and 1995, totaling about $332,000. Illegal aliens
                                        constituted almost half of these recipients. The Department referred the
                                        cases to the Department of Justice for prosecution.


                                        From the Department’s perspective, all applicants for financial aid fall into
Background                              one of three categories of citizenship status: U.S. citizen, eligible
                                        noncitizen, or ineligible noncitizen, as shown in figure 1. By law, only the
                                        first two categories of applicants are eligible for title IV student financial
                                        aid. The third category, which includes illegal aliens and others, is
                                        ineligible for aid.1 An applicant who is ineligible for federal student aid
                                        may still be eligible for state or college aid.


Figure 1: Categories of Applicants by
Citizenship Status




                                        An applicant uses the Free Application for Federal Student Aid form to
                                        indicate whether he or she is a citizen, eligible noncitizen, or ineligible
                                        noncitizen. The application form also notifies applicants that information
                                        provided on the application is subject to computer matching programs
                                        with other federal agencies to verify eligibility and to prevent fraud, waste,

                                        1
                                         An illegal alien is a person who may have entered the United States illegally (that is, without INS
                                        inspection, undocumented, or by using fraudulent documentation) or legally (under a nonimmigrant
                                        visa or other temporary conditions but subsequently violated the terms of the visa or other terms of
                                        entry).



                                        Page 4                                  GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                         B-277450




                         and abuse. If information on the application indicates that the applicant is
                         a citizen or eligible noncitizen, the Department verifies that the applicant
                         is eligible for aid. If the information indicates that the applicant is an
                         ineligible noncitizen, the Department does not continue processing the
                         application and the applicant is rendered ineligible for federal student
                         financial aid, although he or she may be eligible for state or college aid.

                         OIG reported in 1994 that, while the Department verified the eligibility of
                         applicants claiming to be eligible noncitizens, it did not verify eligibility for
                         the vast majority of applicants who claimed U.S. citizenship.2 As a result of
                         weak internal controls over the citizenship verification process, OIG
                         concluded that the Department awarded 45,000 potentially ineligible
                         noncitizens nearly $116 million in federal grants and loans in award year
                         1992-93. Although OIG did not verify that the financial aid recipients were
                         ineligible noncitizens, it recommended that the Department initiate a data
                         matching agreement with SSA to verify citizenship status for all federal
                         student aid applicants who claim U.S. citizenship. OIG also recommended
                         that the Department identify all applicants who fail the citizenship
                         verification process and notify them that their application has been
                         suspended until they can provide proof of U.S. citizenship to the
                         Department. The Department implemented both recommendations in
                         award year 1996-97.


                         During a given school year, all federal student financial aid applications
Responsibility for       (about 10 million annually) go through the Department’s automated
Identifying Ineligible   Central Processing System. The system’s functions include matching
Applicants Is Shared     applicants against SSA and INS databases to make a preliminary
                         determination of an applicant’s eligibility as a U.S. citizen or eligible
by the Department        noncitizen and producing the Student Aid Report (SAR). SARs are sent to the
and Colleges             applicant as well as all colleges he or she listed on the application. College
                         financial aid administrators use SARs to determine the type and amount of
                         federal financial aid the student is eligible to receive, as well as aid from
                         state, college, and other sources. The Department also monitors, through
                         its program reviews and independent audits, the procedures that college
                         financial aid administrators used to determine whether applicants were
                         citizens or eligible noncitizens.




                         2
                         Department of Education, Office of Inspector General, Ineligible, Non-U.S. Citizens Received $70
                         Million in Federal Pell Grants, ACN: 11-40000 (Washington, D.C.: Sept. 9, 1994).



                         Page 5                                  GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                          B-277450




The Department Uses Two   To verify that an applicant is either a U.S. citizen or eligible noncitizen, the
Types of Matches to       Department conducts an electronic match in conjunction with SSA and INS,
Identify Potentially      in which citizenship information on a student’s application is matched
                          against SSA and INS databases. Applicants who pass the appropriate
Ineligible Applicants     matches are eligible for aid. Those who do not pass are flagged and must
                          provide satisfactory proof of their citizenship status to the college
                          financial aid administrator before eligibility can be determined.

                          All aid applicants who claim they are U.S. citizens or eligible noncitizens
                          undergo the SSA match to confirm their status. Applicants claiming eligible
                          noncitizenship must simultaneously undergo the INS match for
                          confirmation of their status, as shown in figure 2.3 The SSA match,
                          implemented in 1996 in response to OIG’s recommendations, and the INS
                          match, implemented in 1989, are conducted each time a student applies for
                          aid. SSA and INS are responsible for providing match results to the
                          Department within 24 hours of its request for verification of an applicant’s
                          citizenship status.




                          3
                           Department officials stated that it is more efficient for the Central Processing System to submit all
                          applications for the SSA match, whether an applicant claims to be a citizen or eligible noncitizen. Since
                          applicants claiming to be eligible noncitizens are subject to both the SSA and INS matches, results of
                          the INS match take precedence over those of the SSA match.



                          Page 6                                   GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                                            B-277450




Figure 2: Overview of the SSA and INS
Matches




SSA Confirmation of                         During the SSA match, the Department sends the student’s financial aid
Citizenship                                 application to SSA, which then compares the applicant’s Social Security
                                            number, name, and date of birth with its data base. All three fields must
                                            match SSA’s records before U.S. citizenship can be confirmed. If SSA
                                            confirms that the applicant’s information matches that of a U.S. citizen, the
                                            applicant is eligible to receive federal student financial aid. If SSA cannot
                                            determine whether the applicant is a U.S. citizen—that is, if there is a
                                            discrepancy in the applicant’s Social Security number, name, or date of
                                            birth—the applicant must provide the college with proof of citizenship,
                                            such as a birth certificate, passport, or naturalization certificate. The
                                            financial aid administrator uses this additional information to decide what
                                            action to take based on the applicant’s citizenship status. If the additional
                                            information indicates that the applicant

                                        •   is a U.S. citizen (for example, the applicant was born abroad to U.S. citizen
                                            parents and could be a U.S. citizen), no further match is performed and the
                                            applicant qualifies for federal student financial aid;
                                        •   is an eligible noncitizen, he or she undergoes the INS match, remaining
                                            ineligible for federal financial aid until INS confirms eligibility; or




                                            Page 7                        GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                                   B-277450




                               •   is an ineligible noncitizen, he or she does qualify for federal student
                                   financial aid.

INS Confirmation of Eligible       The INS match has two components: primary and secondary confirmation.
Noncitizenship                     During primary confirmation, the Department sends the noncitizen
                                   student’s application to INS, which then compares the applicant’s alien
                                   registration number with its data base to confirm that the applicant is an
                                   eligible noncitizen as claimed.4 Applicants failing primary confirmation
                                   must provide the college’s financial aid administrator proof of their
                                   eligibility, such as an alien registration receipt card (commonly known as
                                   a “green card”) or passport and must generally undergo secondary
                                   confirmation.

                                   A college initiates the secondary confirmation process by sending an
                                   applicant’s documentary evidence (obtained during primary confirmation),
                                   along with a completed Document Verification Request (INS Form G-845S)
                                   to the local INS District Office to certify the authenticity of the documents.
                                   The college must wait up to 15 business days for INS secondary
                                   confirmation before determining the applicant’s eligibility.5

                                   If secondary confirmation indicates that the applicant’s documents have
                                   expired, appear to be counterfeit, or otherwise fail to support the
                                   applicant’s citizenship eligibility, colleges notify the applicant that unless
                                   he or she corrects the discrepancy with INS, the case will be submitted to
                                   the Department’s OIG for investigation. Secondary confirmation is not
                                   required if the college has no conflicting information on the applicant and
                                   if the applicant provides the same documents that were used to pass
                                   secondary confirmation in a prior award year, as long as the documents
                                   are current.


College Financial Aid              If the Department questions an applicant’s eligibility as a result of an SSA or
Administrators Required to         INS match, the Department identifies this information on an SAR to call it to

Resolve Eligibility of             the college financial aid administrator’s attention for follow-up. Once
                                   financial aid administrators make the final eligibility determination, they
Flagged Applicants                 are required to note it in the applicant’s file and keep copies of evidence

                                   4
                                    INS assigns an alien registration number to each noncitizen alien legally residing in the United States
                                   and those illegal alien who it identified.
                                   5
                                    If the college does not receive a determination from INS within 15 business days, the financial aid
                                   administrator may review the file to determine whether the applicant is still eligible based on his or her
                                   documentary evidence. As long as the college has no conflicting information on the applicant, the
                                   applicant may be eligible for federal student financial aid. The administrator must note in the
                                   applicant’s file that INS did not respond in 15 days.



                                   Page 8                                    GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                               B-277450




                               they used in making their determination where these can be reviewed by
                               program reviewers and auditors. The administrators are not required to
                               report this information to the Department or to maintain it centrally at the
                               college.

                               The Department does not hold the college liable for an error in an
                               eligibility determination if, in making that determination, the college had
                               no conflicting data on that applicant and relied on

                           •   the SAR indicating the applicant met the eligibility requirements for federal
                               student aid,
                           •   INS’ determination that the applicant was an eligible noncitizen, or
                           •   documents from the applicant proving that he or she is an eligible
                               noncitizen if INS did not provide a determination within 15 business days.

                               If the financial aid administrator determines an applicant’s eligibility
                               without relying on one of these types of documents, the college could be
                               held responsible for repaying federal financial aid funds to the
                               Department; otherwise, the applicant is held responsible. For example,
                               applicants who fraudulently filled out the application would be held
                               responsible.


Department Monitoring          The Department monitors both the financial aid administrators’
Finds Few Implementation       determinations of applicants’ eligibility and the two automated match
Problems                       processes. The Department has found few problems in its monitoring of
                               financial aid administrators’ determinations to help ensure that they were
                               made in accordance with established Department procedures.

                               This monitoring includes an evaluation of the college’s procedures for
                               determining student eligibility. For example, the reviewer or auditor
                               checks a sample of student financial aid files to determine whether
                               financial aid administrators initiated and documented subsequent
                               verification of student applicants who were flagged by the INS match. In
                               reviewing a sample of student financial aid files since 1989, when matching
                               was first implemented, independent auditors and program reviewers found
                               that financial aid administrators made erroneous student eligibility
                               decisions at about 3 percent of colleges audited or reviewed. The
                               Department held these colleges liable for any federal financial aid
                               inappropriately awarded to the students.




                               Page 9                        GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                         B-277450




                         The Department’s annual evaluations of computer programs used to
                         perform the automated SSA and INS matches indicate that they are working
                         as intended. In evaluating the matches, the Department recognized that
                         their value is dependent on, and possibly limited by, the accuracy of SSA
                         and INS data bases. To illustrate, according to the computer matching
                         agreement between the Department and SSA, information in the SSA data
                         base may be less than 50 percent current.

                         The Department’s evaluations attempt to ensure that the matches are
                         properly identifying potentially ineligible applicants. The Department’s
                         Central Processing System performs routine edits on all applications to
                         identify incomplete, invalid, or inconsistent citizenship-related
                         information. The edits check to determine, for example, if citizenship is
                         indicated, if a numerically valid alien registration number has been
                         provided, or if the reported Social Security number is found in SSA’s data
                         base. The Department evaluates citizenship-related edits for a sample of
                         applications by examining how frequently they occur and how frequently
                         applicants correct the information.


                         The SSA and INS matches flag potentially ineligible noncitizens, but the
Match Processes          Department does not—and is not required to—know how many of these
Identify Applicants as   applicants were subsequently found by financial aid administrators to be
Potentially Ineligible   ineligible for aid. However, financial aid administrators we interviewed
                         estimated that, based on their experience in resolving flagged cases,
Noncitizens              almost no flagged applicants were found to be ineligible noncitizens.

                         Department statistics show that as of March 15, 1997, about 460,000 of the
                         9.6 million financial aid applications (nearly 5 percent) received in award
                         year 1996-97 were flagged by the SSA match. SSA was generally unable to
                         confirm that these applicants were either U.S. citizens or eligible
                         noncitizens because of a discrepancy in an applicant’s reported Social
                         Security number, name, or date of birth. The most common discrepancy
                         was in the applicant’s name, occurring in about 83 percent of cases,
                         followed by date of birth (12 percent) and Social Security number (5
                         percent). Further, the Department does not know how many of these
                         applicants claimed to be eligible noncitizens and therefore also underwent
                         an INS match. Approximately 108,000 of the 9.6 million applicants (about
                         1 percent) were flagged by INS’ match because they failed primary
                         confirmation.




                         Page 10                       GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                         B-277450




                         The SSA and INS matches are the first step in identifying potentially
                         ineligible noncitizens by flagging their applications. The match results do
                         not show whether college financial aid administrators subsequently
                         qualified these applicants for student aid. To provide some indication of
                         what administrators were finding at colleges, we contacted four financial
                         aid officials at colleges that we previously identified with large numbers of
                         eligible noncitizen Pell grant recipients in academic year 1992-93.6
                         Collectively, financial aid administrators at these colleges estimated that
                         virtually all applicants identified by SSA or INS matches are able to prove
                         their eligibility and qualify for aid. They also confirmed that the most
                         common reason for an SSA flag was a discrepancy in the applicant’s name.
                         Estimates provided by financial aid administrators were based on their
                         observations and experience in processing aid applications. None of the
                         financial aid offices we contacted maintains this information centrally.


                         Our literature search did not identify any studies or audits that examined
No Comprehensive         whether federal student financial aid was provided to ineligible
Studies Done on          noncitizens. While OIG’s only audit of student financial aid to ineligible
Financial Aid to         noncitizens was in award year 1992-93, it also investigates cases brought to
                         its attention by colleges and others suspecting citizenship fraud.
Ineligible Noncitizens
and No OIG Findings      As a result of these investigations, all OIG cases resolved to date involve
                         ineligible noncitizens who received financial aid before the SSA citizenship
of Aid Disbursed         verification process was implemented in 1996. Responding mainly to
Since 1996               allegations by colleges since award year 1992-93, OIG investigated and
                         resolved 26 cases in which ineligible noncitizens were inappropriately
                         awarded approximately $322,000 in federal student financial aid. Illegal
                         aliens constituted almost half of these 26 recipients and received about
                         $118,000 in aid. For the 6 other cases, it was unclear whether the person
                         was an illegal alien because information was not available to indicate the
                         person’s citizenship status. In all 26 cases, the student applied for and
                         received financial aid before 1996, when the SSA match became
                         operational. Most of the cases occurred in California, the state with the
                         largest population of eligible noncitizen Pell grant recipients, and all cases
                         were referred to the Department of Justice for prosecution.




                         6
                          Colleges with the highest numbers of eligible noncitizen Pell grant recipients are identified in Higher
                         Education: Selected Information on Student Financial Aid Received by Legal Immigrants
                         (GAO/HEHS-96-7, Nov. 24, 1995).



                         Page 11                                   GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
                  B-277450




                  The Department of Education has implemented two automated matches of
Conclusions       student aid applicant citizenship information with SSA and INS to help
                  ensure that ineligible noncitizens do not receive federal student financial
                  aid. The Department’s policy prohibits awarding financial aid unless the
                  applicant furnishes proof of eligibility to the college financial aid
                  administrator.

                  By verifying the citizenship status of all federal student financial aid
                  applicants, the SSA and INS match processes appear to be a reasonable way
                  of helping prevent student financial aid being awarded to ineligible
                  noncitizens. In addition, the notice to student aid applicants that the
                  citizenship status provided on the application is subject to computer
                  matching may deter applicants from seeking to fraudulently receive
                  financial aid.


                  The Department of Education reviewed a draft of this report and had no
Agency Comments   formal comments, although it provided several technical suggestions that
                  we incorporated as appropriate.


                  We are sending copies of this report to the Secretary of Education,
                  Commissioner of INS, Commissioner of SSA, and others who are interested.
                  Please call me at (202)512-7014 if you or your staff have any questions
                  about this report. Major contributors included Joseph J. Eglin, Jr.,
                  Assistant Director; Joan A. Denomme; Charles M. Novak; Meeta Sharma;
                  and Stanley G. Stenersen.




                  Carlotta C. Joyner
                  Director, Education and
                    Employment Issues




                  Page 12                      GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
Page 13   GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
Appendix

Scope and Methodology


             To determine the Department of Education’s policies and processes for
             verifying that only citizens and eligible noncitizens receive federal student
             financial aid, we contacted officials at and reviewed pertinent documents
             from the Department’s Office of Postsecondary Education, SSA, and INS.

             We requested information on the number of ineligible noncitizens from the
             Department. However, the Department’s information allowed us to report
             only the number of applicants who initially failed SSA and INS matches but
             not the number of applicants who were subsequently disqualified for aid
             by college financial aid administrators. We therefore contacted financial
             aid administrators at colleges with the largest number of eligible
             noncitizen Pell grant recipients for each of the five principal types of
             colleges (as we reported in 1995): public 2-year, public 4-year, private
             2-year, private 4-year, and proprietary.7 We previously identified these
             colleges in our 1995 report on student aid provided to legal immigrants.8
             Four of the five college financial aid administrators responded and
             provided estimates of the number of ineligible noncitizens based on
             anecdotal information. They said that they do not routinely collect such
             statistics.

             We did not independently verify statistics computed by the Department
             using information in INS and SSA data bases or verify information provided
             by college financial aid officials.

             We examined summary reports of Department program reviews and audits
             since 1989 that indicated that 343 colleges had been cited for improperly
             determining that a student was a citizen or eligible noncitizen. The
             summary reports did not contain details on the number of applications or
             students or the amount of financial aid involved. Although a large number
             of colleges were cited for deficiencies, we did not examine individual
             program reviews or audit reports because most were out-of-date in
             relation to the rather recent introduction of the SSA match.

             To determine whether any studies had been done on student financial aid
             provided to illegal aliens, we conducted a literature search, contacted
             immigration research organizations, and spoke with officials at higher
             education boards in the seven states with the most eligible noncitizen Pell


             7
              Higher Education: Selected Information on Student Financial Aid Received by Legal Immigrants
             (GAO/HEHS-96-7, Nov. 24, 1995).
             8
              In 1995, we reported that legal immigrants constituted about 4 million, or 10 percent, of students who
             received Pell grants totaling $662 million, or about 11 percent, of the total $6.2 billion in Pell grant aid
             in school year 1992-93.



             Page 14                                    GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
           Appendix
           Scope and Methodology




           grant recipients. We also contacted OIG offices at the Department of
           Education, SSA, and the Department of Justice. Only the Department of
           Education’s OIG maintained this information. We queried the Department’s
           OIG data base, the Investigative Case Tracking System, and identified 26
           cases involving citizenship fraud that had been opened after award year
           1992-93 and closed as of April 30, 1997, and in which financial aid was
           actually disbursed to the students. We reviewed each case file to obtain
           additional details, including the source of the case, the nature of the
           citizenship fraud, whether the individual involved was an illegal alien, the
           amount of student financial aid and date it was disbursed, and the states in
           which the cases occurred.

           We performed our work between January and May 1997 in accordance
           with generally accepted government auditing standards.




(104877)   Page 15                       GAO/HEHS-97-153 Student Aid to Ineligible Noncitizens
Ordering Information

The first copy of each GAO report and testimony is free.
Additional copies are $2 each. Orders should be sent to the
following address, accompanied by a check or money order
made out to the Superintendent of Documents, when
necessary. VISA and MasterCard credit cards are accepted, also.
Orders for 100 or more copies to be mailed to a single address
are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office
P.O. Box 6015
Gaithersburg, MD 20884-6015

or visit:

Room 1100
700 4th St. NW (corner of 4th and G Sts. NW)
U.S. General Accounting Office
Washington, DC

Orders may also be placed by calling (202) 512-6000
or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and
testimony. To receive facsimile copies of the daily list or any
list from the past 30 days, please call (202) 512-6000 using a
touchtone phone. A recorded menu will provide information on
how to obtain these lists.

For information on how to access GAO reports on the INTERNET,
send an e-mail message with "info" in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov




PRINTED ON    RECYCLED PAPER
United States                       Bulk Rate
General Accounting Office      Postage & Fees Paid
Washington, D.C. 20548-0001           GAO
                                 Permit No. G100
Official Business
Penalty for Private Use $300

Address Correction Requested