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entitled 'Information Technology: Near-Term Effort to Automate Paper-
Based Immigration Files Needs Planning Improvements' which was released 
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United States Government Accountability Office:

GAO:

Report to Congressional Requesters:

March 2006:

Information Technology:

Near-Term Effort to Automate Paper-Based Immigration Files Needs 
Planning Improvements:

GAO-06-375:

GAO Highlights: 

Highlights of GAO-06-375, a report to congressional requesters.

Why GAO Did This Study: 

The United States Citizenship and Immigration Services (USCIS) relies 
on about 55 million paper-based files to adjudicate applications for 
immigration status and other benefits. Ensuring the currency and 
availability of these manual files, referred to as alien files, or A-
Files, is a major challenge. To address this challenge, USCIS has 
initiated efforts, both long and near term, to automate the A-Files. 
The long-term effort is now being re-examined within the context of a 
larger USCIS organizational transformation initiative. In the near 
term, USCIS has begun a digitization program, which it estimates will 
cost about $190 million over an 8-year period to electronically scan 
existing paper files and store and share the scanned images. GAO was 
asked to determine whether USCIS was effectively managing its A-Files 
automation efforts.

What GAO Found: 

USCISís effectiveness in managing its long-term effort for automating 
the A-Files cannot yet be determined because the scope, content, and 
approach for moving from paper-based to paperless A-Files has yet to be 
defined. Nevertheless, GAO believes that USCISís recent decision to re-
examine prior agency plans for a strategic A-Files automation solution 
within the context of an agencywide transformation strategy 
appropriately recognizes the integral support role that information 
technology plays in organizational and business transformation. GAO 
also believes that the success of USCISís organizational transformation 
depends on other key supporting practices, such as having a 
comprehensive and integrated transformation plan (goals and schedules) 
and results-oriented performance measures. With respect to USCISís near-
term A-Files automation effort, known as the Integrated Digitization 
Document Management Program, effective planning is not occurring. In 
particular, USCIS has not developed a plan governing how it will manage 
this program and its contractors, and it has not developed an 
evaluation plan for its ongoing digitization concept of operations 
pilot test, even though it has either awarded or plans to award 
contracts totaling about $20 million for this pilot. In addition, USCIS 
officials told us they do not yet know which A-Files immigration forms 
will be scanned. Without a defined scope and adequate planning, this 
program is at risk of falling short of expectations. 

Image: A-Files Storage at National Records Center in Lee's Summit, 
Missouri. 

[See PDF for Image]	

Source: DHS.

[End of Image]

What GAO Recommends: 

GAO is making recommendations to the Secretary of Homeland Security to 
help ensure that USCISís long-term organizational transformation 
initiative is effectively managed and that improvements are made to 
USCISís planning for its near-term A-Files digitization and document 
management effort. In written comments on a draft of this report, the 
Department of Homeland Security agreed with our recommendations and 
described actions that are planned and under way to address them. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-375].

To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Randolph C. Hite at (202) 512-3439 or 
hiter@gao.gov. 

[End of Section]

Contents:

Letter:

Results in Brief:

Background:

USCIS Effectiveness in Managing Long-Term A-Files Automation Efforts 
Remains to Be Seen, but Near-Term Document Digitization Program Is Not 
Being Effectively Managed:

Conclusions:

Recommendations for Executive Action:

Agency Comments:

Appendixes:

Appendix I: Objective, Scope, and Methodology:

Appendix II: Comments from the Department of Homeland Security:

Appendix III: GAO Contact and Staff Acknowledgments:

Figures Figures:

Figure 1: Family-Based Adjustment of Status Application (Form I-485) 
Process:

Figure 2: A-Files Storage at National Records Center in Lee's Summit, 
Missouri: 

Abbreviations:

A-Files: alien files:

CBP: Customs and Border Protection:

CIS: Central Index System:

CLAIMS 3: Computer Linked Application Management System 3:

DHS: Department of Homeland Security: 

FBI: Federal Bureau of Investigation:

ICE: Immigration and Customs Enforcement:

IDDMP: Integrated Digitization Document Management Program:

IG: inspector general:

IT: information technology:

NBC: National Benefits Center:

NFTS: National File Tracking System:

OCIO: Office of the Chief Information Officer:

USCIS: U.S. Citizenship and Immigration Services:

US-VISIT: U.S. Visitor and Immigrant Status Indicator Technology:

United States Government Accountability Office:
Washington, DC 20548: 

March 31, 2006:

The Honorable Susan M. Collins: 
Chairman: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate:

The Honorable Charles E. Grassley: 
Chairman: 
Committee on Finance: 
United States Senate:

The United States Citizenship and Immigration Services (USCIS) within 
the Department of Homeland Security (DHS) relies on more than 55 
million paper-based files, each containing between one and hundreds of 
pages of immigration information, to adjudicate applications for 
immigration status and other benefits. These alien files (A-Files) are 
kept for 75 years, and the data contained in these files are also used 
by federal, state, and local agencies.

Ensuring the currency and availability of these paper files to support 
a range of agency mission needs is a major challenge for USCIS. To 
address this challenge, USCIS plans to pursue both long-term and near- 
term A-Files automation efforts. While the scope, content, and approach 
to its long-term efforts have not yet been defined, in the near-term, 
USCIS has begun the Integrated Digitization Document Management Program 
(IDDMP), which it estimates will cost about $190 million over an 8-year 
period. This program provides for electronically scanning paper forms 
and associated documents contained in the A-Files, storing the 
resulting electronic images, and providing user access to the images. 
Thus far, USCIS has either awarded, or plans to award, five contracts 
to pilot test a digitization concept of operations. These contracts are 
being funded primarily with funds that were set to expire by the end of 
September 2005.

As part of your request that we review USCIS's management and use of 
the A-Files, we agreed to determine whether USCIS was effectively 
managing its A-Files automation efforts. To accomplish this objective, 
we reviewed available plans and contractor statements of work 
pertaining to the automation efforts. We conducted our review from 
August 2005 through February 2006 in accordance with generally accepted 
government auditing standards. Details on our objective, scope, and 
methodology are provided in appendix I.

Results in Brief:

It is too early to determine how effectively USCIS's long-term A-Files 
automation effort is being managed because the scope, content, and 
approach for moving from paper-based to paperless A-Files have yet to 
be defined. The agency recently decided to re-examine this long-term 
effort within the context of an agencywide organizational and business 
transformation initiative, but it has not formally documented this 
transformation initiative. Nevertheless, we support the concept of 
aligning strategic automation of the A-Files with a transformation of 
USCIS business operations, as this concept recognizes and reflects the 
support role of information technology (IT) in organizational 
transformation. As USCIS moves forward with what it is calling its 
Transformation Strategy, it will be important for the agency to 
leverage a number of interdependent transformation enablers that we 
have previously reported as keys to success, such as having strong 
executive leadership; establishing a comprehensive and integrated 
transformation plan (e.g., goals and schedules); adopting effective 
management processes, information systems, and related best practices 
(e.g., use of an enterprise architecture); and employing results- 
oriented performance measures.

USCIS is not effectively managing key planning activities associated 
with its near-term A-Files automation effort, known as the Integrated 
Digitization Document Management Program (IDDMP). In particular, it has 
not yet developed a plan governing how it will manage this program and 
the contractors working on it, and it has not yet developed a plan for 
measuring and evaluating the results of a pilot test of a document 
scanning and storage capability. According to USCIS officials, these 
plans do not exist because the program is just getting started. 
Nonetheless, USCIS has already awarded, or plans to award, contracts 
totaling more than $20 million for this pilot. In addition, USCIS 
officials told us they do not yet know which of the roughly 50 types of 
A-Files-related forms will be scanned as part of the program. Without a 
defined program scope and adequate program planning, IDDMP is at risk 
of falling short of expectations.

To assist USCIS in its future transformation efforts, we are making 
recommendations to the Secretary of Homeland Security aimed at ensuring 
that certain keys to successful organizational transformation are 
employed. We are also making recommendations to the Secretary for 
improving IDDMP planning.

In written comments on a draft of this report, the Department of 
Homeland Security agreed with our recommendations. In its letter, which 
is reprinted in appendix II, the department described actions it is 
taking, and plans to take, to address our recommendations. It also 
provided technical comments that we have incorporated, as appropriate.

Background:

A mission of USCIS is to provide timely and accurate information and 
services to immigrant and nonimmigrant aliens as well as to federal 
employees who make informed decisions about, for example, granting 
citizenship and approving immigration benefits. To perform this 
mission, staff dispersed among approximately 89 of USCIS's field 
offices[Footnote 1] require, among other things, access to an alien 
applicant's case history information. Currently, this information 
resides primarily in the paper-based A-Files.

To improve the reliability and currency of the A-Files, as well as 
their accessibility to geographically and organizationally dispersed 
users, USCIS intends to automate the A-Files, beginning with scanning 
certain forms contained in the A-Files and storing the resulting 
electronic images. While these automation efforts were to be part of 
their IT Transformation Program, both A-Files automation and the IT 
Transformation Program were recently incorporated into an agencywide 
organizational and business transformation effort referred to as the 
USCIS Transformation Strategy.

A-Files Are Important to Mission Operations of USCIS and Other Agencies:

A-Files are a critical component of the USCIS mission of ensuring the 
integrity of the immigration system. These files are used by USCIS 
staff to make immigration and citizenship decisions. Maintaining the 
currency of these files and distributing them in a timely manner has 
been a long-standing challenge.

An A-File is the set of records USCIS maintains on certain individuals 
to document their interaction with USCIS in actions prescribed by the 
Immigration and Nationality Act and other regulations. The single most 
important set of records kept by USCIS are A-Files. An A-File contains 
between one and hundreds of pages of documents and forms, such as 
submitted benefits and naturalization forms, photographs, fingerprints, 
and correspondence from family members or third-party sponsors. 
According to USCIS, A-File information is used to:

* grant or deny immigration-related benefits,

* capture subsequent status changes,

* prosecute individuals who violate immigration law,

* document chain of custody for enforcement,

* provide immigrant statistics,

* control and account for records in compliance with the code of 
federal regulations, or:

* certify the existence or nonexistence of records.

USCIS estimates that it currently has more than 55 million of these 
paper-based files, each of which is to be maintained for a 75-year 
period.[Footnote 2]

Generally, USCIS processes for adjudicating alien benefit requests vary 
by type of application or form, and may involve creating, searching, 
transporting, obtaining, examining, updating, or storing the A-File. 
Figure 1 is an example of one such process: the Family-Based Adjustment 
of Status, also referred to as the Application to Register Permanent 
Residence, or Form I-485.[Footnote 3] The process of submitting this 
form involves both manual and automated steps.

Figure 1: Family-Based Adjustment of Status Application (Form I-485) 
Process:

[See PDF for image] 

Source: GAO analysis of USCIS data. 

[A] Computer Linked Application Management System 3. 

[B]Central Index System. 

[C]National File Tracking System.

[End of figure]

As illustrated in figure 1, the alien submits the I-485, along with the 
required fee and supporting information, to a USCIS "lock box" in 
Chicago that is operated by the Department of the Treasury on behalf of 
USCIS.[Footnote 4] Treasury then captures the form electronically and 
creates an extract file containing selected I-485 data elements that it 
sends in an electronic format to the USCIS National Benefits Center 
(NBC), along with the original paper form and supporting information. 
NBC prepares a daily upload file of all cases that need biometric 
appointments. This information is used to schedule an interview and 
direct the applicant to the Application Support Center, where 
biometrics, such as fingerprints, will be captured. NBC obtains the 
paper application and the selected electronic data elements, and inputs 
the data elements into the Computer Linked Application Management 
System 3 (CLAIMS 3).[Footnote 5] In addition, NBC searches a USCIS 
electronic index system, known as the Central Index System (CIS), to 
determine whether an A-File already exists for the individual. If an A- 
File does not exist, one is created. If one does exist, NBC determines 
its location by accessing an additional system called the National File 
Tracking System (NFTS), which tracks the physical location of the A- 
File. When NBC obtains the requested A-File, it merges the Form I-485 
into the A-File. NBC then performs an initial name check using the 
Interagency Border Inspection System and the Federal Bureau of 
Investigation (FBI) National Name Check Program, and updates the A-File 
with the results.

While NBC is processing the application, the Application Support Center 
is collecting the applicant's biometrics and sending the data 
electronically to the FBI, where a criminal background check is 
performed on the applicant. When the FBI has completed the background 
check, it sends the results to NBC, which then prints the results and 
adds them to the A-File.

When the A-File contains the I-485 application, biometrics, and 
background check results, it is transported to the USCIS local office 
closest to the applicant for a ruling on the applicant's request. The 
local office reviews the file, interviews the applicant, and makes a 
decision on the permanent residence request. The A-File is then 
transported to the National Records Center in Missouri for storage (see 
fig. 2).

Figure 2: A-Files Storage at National Records Center in Lee's Summit, 
Missouri:

[See PDF for image] 

Source: DHS.

[End of figure] 

According to a recent report by the DHS Inspector General (IG), this 
paper-based process is costly.[Footnote 6] For example, the estimated 
costs for copiers and copy paper for one USCIS service center is more 
than $400,000 per year. Further, according to senior USCIS officials, 
the agency spends approximately $13 million each year transporting A- 
Files within USCIS and to other bureaus and agencies.

Besides USCIS's need for A-Files, DHS's Immigration and Customs 
Enforcement (ICE), Customs and Border Protection (CBP), and U.S. 
Visitor and Immigrant Status Indicator Technology (US-VISIT) need 
access to either the data in the A-Files or the A-Files themselves, as 
do agencies external to DHS, including the FBI, the Department of 
State, and state and local governments. For example, USCIS officials 
told us that the FBI uses A-Files data in performing law enforcement 
activities. In addition, USCIS documentation shows that ICE uses A- 
Files as the principle source of information for prosecuting aliens who 
have committed crimes and for immigration removal proceedings; CBP uses 
A-Files when it interviews and arrests aliens; and the Department of 
State uses data within the A-Files when issuing visas to alien 
visitors. According to USCIS officials, obtaining access to these A- 
Files has been a long-standing problem.

USCIS Intends to Address Limitations in Its IT and Data-Sharing 
Environments:

The limitations in the USCIS IT and data-sharing environments are not 
confined to the A-Files. According to a recent report by the DHS 
IG,[Footnote 7] USCIS uses duplicative, nonintegrated, and inefficient 
data systems that have limited information sharing, resulting in data 
integrity and reliability problems. For example, adjudicators may need 
to access more than a dozen systems using between 5 and 17 passwords, 
and may have to restart these systems multiple times to process a given 
application. In addition, the IG reported that the networks and 
hardware platforms across USCIS offices are outdated and inconsistent. 
The IG also reported that past problems in this IT environment have led 
to small, disparate business process re-engineering initiatives that 
were narrowly focused and were not sufficiently coordinated across the 
organization to enable standardized processes.

To address these limitations, USCIS began an IT Transformation Program 
in March 2005 that was led by the agency's Office of the Chief 
Information Officer (OCIO) and was intended to move USCIS progressively 
toward a paperless environment that facilitates information sharing. In 
January 2006, USCIS reported that this IT transformation effort was 
being subsumed into a new, long-term organizational and business 
transformation effort, referred to as the USCIS Transformation 
Strategy. Under this strategy, according to USCIS officials, long-term 
solutions to its A-Files automation needs will be pursued within the 
context of business process re-engineering.

In the interim, however, USCIS still intends to reduce the volume of 
paper associated with its existing A-Files through a program called the 
Integrated Digitization Document Management Program (IDDMP). According 
to USCIS, the goals of the IDDMP are to:

* comply with laws governing electronic information storage and access 
and information sharing;

* reduce the backlog of immigration benefit requests, ensure timely 
access to files, and reduce paper-based file storage and transportation 
costs; and:

* respond to a statement in The 9/11 Commission Report that all points 
in the border system--from consular offices to immigration services 
offices--will need appropriate electronic access to an applicant's 
file.[Footnote 8]

To accomplish these objectives, IDDMP is to convert paper forms and 
documents in existing A-Files to electronic images and manage the 
retrieval, movement, retention, and disposition of these images. The 
program is not intended to change existing USCIS core business 
processes, but rather to merely reduce the amount of paper associated 
with these business processes and improve user access to these scanned 
forms and documents. The program is estimated to cost about $190 
million over 8 years, which includes planning, acquisition of hardware 
and software products and services, and operations and maintenance.

As part of the IDDMP, USCIS initiated a digitization and storage pilot 
to scan approximately 1 million A-Files that include adjudicated I-485 
forms and supporting documents (each containing about 100 
pages).[Footnote 9] The purpose of the pilot is to validate that the 
digital format satisfies user needs, to identify network storage 
requirements, and to provide insight into potential scanning and 
storage problems. According to USCIS program officials, the pilot 
involves five separate contracts, three of which are primarily funded 
from $20 million that Congress had designated for "the historical 
records project to convert immigration records into an electronic, 
digitally-accessible format."[Footnote 10] The other contracts were 
awarded using other USCIS funding. Officials told us that they needed 
to move quickly to obligate these funds before they were due to expire 
at the end of September 2005, so they awarded four of the contracts in 
September 2005. A description of each of the contracts follows.

Records digitization facility. According to program officials, this 
contract is intended to set up a facility for scanning the piloted 
number of A-Files and for scanning future A-Files. The contract is to 
cover preparing the documents for scanning, scanning the documents, and 
performing quality assurance checks on the captured images. It also is 
to cover indexing the scanned images using the meta-data standards 
defined in the requirements definition contract portion of the 
digitization pilot and temporarily storing the images in a staging 
server until they are accessed under the enterprise document management 
service contract. According to officials, this contract was originally 
awarded in September 2005, and a protest was filed in October 2005. 
During the course of the protest, the agency took corrective action, 
which included re-evaluation of the proposal; the protest was 
dismissed, the original award was vacated, and a new award is expected 
in March 2006.[Footnote 11] The estimated value of the new contract is 
$14 million.

Enterprise document management service. This contract, awarded in 
September 2005, is to gather technical requirements for the design and 
implementation of a system to electronically manage the scanned images 
created by the records digitization process. In addition, the 
contractor is to design and implement a system capable of ensuring 
image and data quality and compliance with the DHS document management 
standard. It also includes development of a Web infrastructure and 
implementation of user interface software components. The value of this 
contract is about $2.3 million.

Storage facility infrastructure. Under this contract, awarded in 
September 2005, the contractor is to provide hardware, software, and a 
wide area network for the digitization and storage process. The value 
of this contract is about $7.2 million.

Records business process re-engineering. This contract, which was 
awarded in September 2005, includes determining how I-485 A-Files are 
currently used for adjudicating permanent residence requests and 
documenting the process for compilation, movement, digitization, and 
lockdown of I-485 A-Files. The contractor is also to determine how to 
effectively relocate the I-485 forms to the records digitization 
facility. The estimated value of this contract is $487,400.

Requirements definition. This contract, which was awarded in October 
2005 using fiscal year 2006 funds, covers gathering and documenting non-
USCIS stakeholder digitization and document management requirements, 
including the meta-data requirements for indexing the scanned 
documents. As of December 2005, the first draft of requirements had 
been reviewed by USCIS and some of the external stakeholders, including 
ICE, CBP, and the Department of State. The contractor's next steps are 
to refine the requirements and develop, among other things, the plans 
of action and a concept of operations for the digitization and document 
management processes. The value of this contract is about $451,000.

USCIS Effectiveness in Managing Long-Term A-Files Automation Efforts 
Remains to Be Seen, but Near-Term Document Digitization Program Is Not 
Being Effectively Managed:

It is not yet possible to determine the effectiveness of USCIS's 
management of its long-term A-Files automation effort because this 
effort is not yet under way. However, USCIS currently has a near-term A-
Files automation effort under way (IDDMP) that it is not effectively 
managing. Specifically, USCIS has not developed a program management 
plan to guide program execution and provide the basis for reliable cost 
and schedule estimates, and it does not have a plan for evaluating its 
IDDMP concept of operations pilot test of a document scanning 
capability. According to USCIS officials, these plans do not exist 
because the program is just getting started. Nevertheless, five 
contracts have either been awarded or are to be awarded under this 
program, a pilot test is under way, and significant program costs are 
anticipated. Without effective planning, IDDMP is at risk of falling 
short of expectations and its funding requests cannot be justified.

Long-Term A-Files Automation Effort Is Being Re-evaluated; It Is Too 
Early to Determine Whether It Is Being Effectively Managed:

As we have previously reported,[Footnote 12] technology alone cannot be 
relied on to solve long-standing and fundamental business problems, 
such as USCIS's dependence on paper-laden A-Files. Instead, our work 
has shown that such organizational and business transformation requires 
a number of key, interdependent elements working collectively to effect 
meaningful and long-lasting institutional change and mission 
improvement. These elements begin with strong, sustained executive 
leadership to direct and oversee organizational reforms. Other elements 
include a comprehensive and integrated business transformation plan, 
strategic management of human capital, effective processes and related 
tools (such as an enterprise architecture to provide a business and 
technology blueprint and associated road map), and results-oriented 
performance measures that link institutional, unit, and individual 
personnel goals, measures, and expectations.

Until recently, USCIS had high-level, technology-focused plans for 
modernizing its information systems environment, including plans for 
automating its A-Files. These plans were part of the OCIO's IT 
Transformation Program, which included four components: (1) 
establishing and evolving a mature CIO organization; (2) improving the 
IT infrastructure; (3) implementing an information-based architecture 
to facilitate information standardization, security, and sharing; and 
(4) providing new business capabilities. However, agency officials told 
us in January 2006 that the IT Transformation Program has been 
reconsidered and will now be incorporated into a broader effort 
referred to as the USCIS Transformation Strategy. While this broader 
organizational and business transformation strategy has yet to be 
formally documented, officials told us that the strategy will, among 
other things, align IT modernization with broader organizational and 
business process changes. Restated, the IT modernization will be 
neither separate from nor the driver of organizational transformation. 
Rather, it will support and enable organizational transformation. To 
illustrate, one approach to long-term A-Files automation could 
potentially involve doing away with both paper forms and electronic 
images of these forms and instead provide for the electronic capture of 
data when the applications are filed using Web-based services and 
management of the captured data via corporate data warehouses to 
facilitate data access and sharing.

USCIS's more broadly based organizational and business transformation 
concept, in which IT modernization will be treated as an enabler rather 
than an independent undertaking or a driver, is more consistent with 
effective transformation practices employed by successful 
organizations. However, our experience has shown that successful 
organizations also perform other key elements related to organizational 
and business transformation. As we have previously reported,[Footnote 
13] these elements are as follows:

* Ensure top leadership drives the transformation. Leadership must set 
the direction, pace, and tone and provide a clear, consistent rationale 
that brings everyone together behind a single mission.

* Establish a coherent mission and integrated strategic goals to guide 
the transformation. Together, these define the culture and serve as a 
vehicle for employees to unite and rally around.

* Focus on a key set of principles and priorities at the outset of the 
transformation. A clear set of principles and priorities serves as a 
framework to help the organization create a new culture and drive 
employee behaviors.

* Set implementation goals and a timeline to build momentum and show 
progress from day one. Goals and a timeline are essential because the 
transformation could take years to complete.

* Dedicate an implementation team to manage the transformation process. 
A strong and stable team is important to ensure that the transformation 
receives the attention needed to persevere and be successful.

* Use the performance management system to define responsibility and 
assure accountability for change. A "line of sight" shows how team, 
unit, and individual performance can contribute to overall 
organizational results.

* Establish a communication strategy to create shared expectations and 
report related progress. The strategy must effectively communicate with 
employees, customers, and stakeholders.

* Involve employees to obtain their ideas and allow them to participate 
in the transformation. Employee involvement strengthens the process and 
allows them to share their experiences and shape policies.

* Build a world-class organization. Building on a vision of improved 
performance, the organization adopts the most efficient, effective, and 
economical personnel, system, and process changes and continually seeks 
to implement best practices. One such practice is the use of an 
enterprise architecture.[Footnote 14]

The degree to which USCIS incorporates each of these key elements into 
its current transformation efforts will help to determine the success 
of its efforts, including the automation of its A-Files.

USCIS Is Not Effectively Managing Its Near-Term A-Files Automation 
Effort:

Industry best practices and information technology program management 
principles[Footnote 15] stress the importance of effective planning in 
the management of programs, such as IDDMP. Inherent in such planning is 
the development and use of program management plans, which define, 
among other things, program goals and major milestones, delineate work 
tasks and products and the associated schedules and resources for 
achieving them, define management processes and structures (e.g., 
processes and structures for tracking and overseeing contractors), 
identify key players and stakeholders and their roles and 
responsibilities, and specify performance measures and reporting 
mechanisms. They also require plans for testing and evaluating program 
products and capabilities, including plans for evaluating the results 
of pilot-testing efforts. Pilot evaluation plans include goals and 
objectives, tasks, time frames, resource needs, roles and 
responsibilities, and evaluation criteria and results measures. Such 
plans are essential to ensuring, among other things, that programs are 
executed properly and that funding requests are reliably derived.

USCIS has yet to develop either an IDDMP management plan or a pilot 
evaluation plan. According to USCIS OCIO officials, the IDDMP is only 
now being initiated, and the program office, including program staff, 
is not fully in place. Thus, they said it is too early to expect these 
plans to exist. Nevertheless, USCIS has awarded four contracts and is 
in the process of awarding a fifth related to the program; these 
contracts total about $20 million, including an ongoing digitization 
and storage technology pilot test, and it estimates that it will spend 
$190 million over an 8-year period on the program. At the same time, 
officials told us they do not yet know which of the roughly 50 types of 
forms associated with A-Files will be scanned and stored or the 
sequence in which form types will be scanned. If all forms are scanned, 
information provided by USCIS shows that scanning and storage could 
cost as much as $550 million.

The absence of program planning was also noted in a December 2005 
workshop by one of the digitization and storage pilot contractors. 
Discussion points during this workshop included IDDMP's lack of a clear 
vision and business objectives, critical gaps in the digitization 
approach, confusion regarding terminology and roles and 
responsibilities, and the lack of a management plan. Restated, this 
means that large sums of resources are being invested, and much larger 
sums are likely to be invested, on a program that lacks plans for 
ensuring that the resources are invested effectively and that resource 
estimates are valid. According to OCIO officials, while the funding 
estimates are a "guess," $20 million in funds were designated in fiscal 
year 2005 for converting historical immigration records into a 
digitally accessible format, and they needed to move quickly to 
obligate these funds before they expired at the end of September 2005. 
These officials also told us that, while they did not have time to 
fully establish and staff a program office that would have pre-empted 
the contractor's concerns, they are now taking steps to deal with the 
concerns. However, we have yet to receive documentation from USCIS as 
to the scope and nature of the steps they are taking.

Without effective planning, including a clearly defined program scope, 
IDDMP is at risk of falling short of expectations and its future 
funding needs are not adequately justified.

Conclusions:

While it is too early to determine how effectively USCIS is managing 
its long-term A-Files automation effort, USCIS's recent decision to 
reconsider its long-term IT modernization plans--including the role of 
IT in the agency's broader organizational and business transformation 
efforts--was both warranted and appropriate. As USCIS defines and 
pursues these strategic transformation efforts, it is important that 
the agency adequately incorporate the keys to successful organizational 
transformation discussed in this report.

With respect to management of its near-term A-Files automation efforts, 
key IDDMP planning activities are not being performed effectively. 
Given the contractual commitments being made on IDDMP, as well as the 
potential for the cost of this program to reach well into the hundreds 
of millions of dollars, it is critical that USCIS expeditiously develop 
an effective program management plan and pilot evaluation plan to guide 
the execution of the program and the pilot test, respectively. Without 
these plans, IDDMP is at risk of not meeting expectations and its 
funding needs are not adequately justified.

Recommendations for Executive Action:

To better ensure the success of USCIS's long-term transformation 
efforts, to include A-Files automation, we recommend that the Secretary 
of Homeland Security direct the Director of USCIS to implement the 
following two recommendations:

1. Ensure that the key elements to successful organizational and 
business transformation cited in this report are employed.

2. Ensure that both a program management plan and a pilot evaluation 
plan are expeditiously developed and approved for IDDMP, along with a 
reliable estimate of funding requirements.

Agency Comments:

In commenting on a draft of this report, the Department of Homeland 
Security agreed with our recommendations and described actions that are 
planned and under way to address them. It also provided technical 
comments that we have incorporated, as appropriate. The department's 
comments are reprinted in appendix II.

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from the report date. At that time, we will send copies to the 
Secretary of Homeland Security, the Director of the United States 
Citizenship and Immigration Services, and appropriate congressional 
committees. We will also make copies available to others on request. In 
addition, this report will also be available at no charge on GAO's Web 
site at [Hyperlink, http://www.gao.gov].

If you or your staff have any questions about this report, please 
contact me at (202) 512-3439 or [Hyperlink, hiter@gao.gov]. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III.

Signed By:

Randolph C. Hite: 
Director: 
Information Technology Architecture and Systems Issues:

[End of section]

Appendix I: Objective, Scope, and Methodology:

Our objective was to determine whether the United States Citizenship 
and Immigration Service (USCIS) is effectively managing its alien files 
(A-Files) automation efforts. To accomplish this objective, we reviewed 
and analyzed USCIS's information technology (IT) strategic plan, IT 
Transformation Program planning documents, and IT Transformation 
Program mission needs statement, as well as available documentation for 
the Integrated Digitization Document Management Program (IDDMP). In 
addition, we reviewed the A-Files budget submission to the Office of 
Management and Budget, the digitization and storage contractor 
statements of work, and requirements meeting minutes. Among other 
things, we interviewed program officials, including the USCIS chief 
information officer and the IDDMP manager. We also interviewed 
officials from Immigration and Customs Enforcement and met with 
officials at the Department of Homeland Security (DHS) Office of 
Inspector General to discuss program management activities for the 
IDDMP.

We conducted our work at DHS headquarters offices in Washington, D.C., 
from August 2005 through February 2006 in accordance with generally 
accepted government auditing standards.

[End of section]

Appendix II: Comments from the Department of Homeland Security:

U.S. Department of Homeland Security: 
Washington, DC 20528:

Homeland Security:

March 22, 2006:

Mr. Randolph C. Hite: 
Director:
Information Technology Architecture and Systems Issues:
U.S. Government Accountability Office: 
441 G Street, N.W.
Washington, D.C. 20548:

Dear Mr. Hite:

Thank you for the opportunity to comment on draft report GAO-06-375, 
Information Technology: Near-term Effort to Automate Paper-based 
Immigration Files Needs Planning Improvements. Technical comments have 
been provided under separate cover.

We appreciate the Government Accountability Office's (GAO's) statement 
that U.S. Citizenship and Immigration Services' (USCIS') recent 
decision to reexamine prior agency plans for a strategic A-Files 
automation solution within the context of an agency-wide transformation 
strategy appropriately recognizes the integral support role that 
information technology plays in organizational and business 
transformation. USCIS is committed to transforming the way it does 
business in support of its operations and customers.

We further appreciate the GAO's review of our near-term A-File 
automation efforts. The GAO concluded that effective planning has not 
been occurring. While USCIS is still in the early stages of this 
effort, we agree that robust planning and management will help ensure 
success. USCIS established a Digitization Requirements Steering 
Committee that has gathered high-level technical requirements from key 
external stakeholders that use the immigration file. USCIS has 
developed a high-level project approach/time-line that included 
establishing a team of functional managers that developed requirements, 
plans-of-action, and a working group charter through facilitated 
sessions. The managers identified eight components that are key to the 
success of the Digitization Pilot; Policy and Process, Security and 
Privacy, Personnel, Organization and Communication, Facility, 
Training, Technology, and Quality Assurance. USCIS provided GAO a copy 
of the Digitization Dependency Plan with a high level road map of its 
process and progress to follow. The plans-of-action for each functional 
area are now incorporated into the Digitization Integrated Plan. The 
GAO will be provided a copy of the final Integrated Plan.

The immediate focus for the plans-of-action is the Pilot Project and 
the Records Digitization Facility that will be established upon award 
of the contract. The initial concept was to scan one million I-485 A-
Files. After further discussion, however, USCIS expects modifications 
to the initial approach to reflect: the need to integrate the present 
digitization efforts with the future envisioned for newer electronic 
files under the Business Transformation Initiative; the need to 
determine the feasibility and cost benefits of digitizing a wider range 
of files with varying degrees of indexing; and, the need to collaborate 
more effectively with U.S. Immigration and Customs Enforcement and U.S. 
Customs and Border Protection. Accordingly, USCIS is considering a plan 
to also select a wider range of A-file types and to put them through 
rigorous testing from beginning to end of the digitized process, 
including scanning, access, storage, retrieval and further file 
manipulation. This plan will explore digitization's effectiveness for 
use by adjudicators and law enforcement personnel. At the same time, 
USCIS will engage in the larger policy and operational issues discussed 
above to assess the effectiveness of the approach and new system 
components, adjusting as indicated by the experiences of this pilot. 
USCIS anticipates the pilot will provide insight into potential 
scanning and storage challenges and mitigation strategies for a long-
term A-file implementation solution.

In response to the two recommendations, USCIS offers the following:

Direct the Director of USCIS to ensure that the key elements to 
successful organizational and business transformation cited in this 
report are employed.

USCIS has been modeling its transformation efforts after best practices 
and believes the relevant suggestions by the GAO are being covered as 
follows:

* Ensure Top Leadership Drives the Transformation. The USCIS Director 
and the Acting Deputy Director have immersed themselves in this project 
to ensure its success. They assembled an Integrated Transformation 
Leadership Team consisting of officials from all disciplines within 
USCIS.The Acting Deputy Director and Chief of Staff hold regular team 
meetings ensuring that both long-and short-term goals are accomplished 
as well as stressing the importance of the goals' various components. 
The Manager of the Transformation Program reports directly to the 
Acting Deputy Director.

* Establish a Coherent Mission and Integrated Strategic Goals to Guide 
the Transformation. The mission of the USCIS Transformation Program is, 
"USCIS will deliver a new business identity, fresh tools, and 
dependable information to enable its people as confident and proud 
stewards of America's promise."In order to accomplish this, USCIS will 
focus improvements on three areas: national security and integrity, 
customer service, and administrative economy and efficiency.USCIS will 
ensure the integrity of the immigration system and the security of the 
country by effectively collecting, analyzing, and sharing information 
used to identify eligibility and status. USCIS will deliver world-class 
customer service by providing timely and accurate information and 
promoting civic values. USCIS will be an innovative, flexible, and 
accountable organization that invests in its people and infrastructure 
to ensure cost-effective and consistent results.

* Focus on a Key Set of Principles and Priorities at the Outset Of 
Transformation. Transformation established four principal priorities 
that will help create a new culture and drive employee behavior while 
allowing USCIS to reach its business goals. These include:

- Ensuring the security and integrity of the system;

- Providing efficient and customer-oriented immigration benefit and 
immigration services;

- Strengthening the infrastructure necessary to achieve USCIS' mission; 
and:

- Operating as a high-performance organization and position USCIS as an 
employer of choice.

* Set Implementation Goals and a Timeline to Build Momentum and Show 
Progress From Day One. As currently planned, the USCIS Transformation 
Program is developing a pilot that will test end-to-end electronic 
processing of a limited selection of benefits with incremental, phased 
national rollout once the concept is proven. The program will start in 
25 field offices with five users per office, all located in the Western 
Region. There will be five benefit types tested: international 
adoptions, applications for certificates of citizenship, replacement of 
naturalization certificates, locally produced employment authorization 
documents, and non-immigrant religious workers and cultural 
representatives. The pilot also has outlined specific milestones and 
their anticipated completion in line with DHS investment requirements. 
Interlacing with these milestones will be business and IT metrics. The 
pilot awaits departmental approval and could be changed.

* Dedicate an Implementation Team to Manage the Transformation Process. 
USCIS has dedicated several teams and management groups in order to 
ensure and maintain focus on the goals that USCIS has set out to do. 
The individuals participating in this transformation process come from 
several different disciplines. At the head of this organization is the 
Milestone Decision Authority (MDA). The MDA is the senior approval 
authority and decides when it is appropriate to move onto the next 
phase of the acquisition life cycle.Working hand in hand with the MDA 
is the Leadership Team. The Leadership Team is responsible for 
approving program direction, policy decisions, investment strategy, 
acquisition strategy, and program scope. The Leadership Team is 
assembled from USCIS Senior Executive Service Officials whose branches 
will be the most affected by Transformation.

A member of the Leadership Team is the USCIS Transformation Program 
Office (TPO) Program Manager. The Program Manager serves as a liaison 
between the: Leadership Team and the four other parts of the 
transformation team. These four remaining team components are 
Acquisition and Program Support Team, Integrated Design Team, 
Technology Solutions Team, and Communications and Change Management 
Team. Each one of these last four teams is highly specialized and 
focuses on a narrower topic within Transformation.

* Use the Performance Management System to Define Responsibility and 
Assure Accountability For Change. USCIS has identified its current 
business metrics and laid out new goals and goal metrics. These goal 
metrics will incorporate a combined effort from every single aspect of 
USCIS. At the conclusion of the Transformation Program, processes will 
be standardized and immigration services will have defined measurable 
parameters. For example, one of USCIS' goals is operational efficiency. 
At this time the number of applications that are initially processed 
correctly varies. Once transformation is concluded, less than 10 per 
cent of applications submitted will require a second review.

* Establish a Communication Strategy to Create Shared Expectations and 
Report Related Progress. The Communications and Change Management Team 
will be responsible for developing and executing the communications 
strategy plan; conceptualizing, organizing, and rolling out content for 
Intranet sites and other communication mechanisms; coordinating, 
tracking, and updating communications; and planning, coordinating, and 
guiding content development for key communications events with 
stakeholders and the end-user community.

* Involve Employees to Obtain Their Ideas and Gain Their Ownership For 
Transformation. Transformation will take a proactive approach to 
strategizing and planning this area. There will be ongoing, targeted 
site visits to establish Training and Change Management needs. This 
will allow feedback to occur and appropriate measures in response to 
this feedback to take place. Employees will have the opportunity to be 
heard and impact the way the program will be shaped.

* Build a World-Class Organization. USCIS wants to change for the 
better, and also become "best-in-class" in the government arena. USCIS 
believes this will be possible through Transformation. It plans on 
doing this by examining other benchmark best practices, as well as 
constantly striving to improve in its core competencies.

Direct the Director of USCIS to ensure that both a program management 
plan and pilot evaluation plan are expeditiously developed and approved 
for Integrated Digitization Document Management Program (IDDMP), along 
with a reliable estimate of funding requirements.

USCIS is in the process of establishing a Project Management Office to 
manage the Digitization effort. This office will manage progress 
against the existing program management plan and develop a pilot 
evaluation plan, as well as reliable funding estimates, as the program 
moves forward in development. It will also address the likely 
modifications to the initial approach to reflect: the evolution of 
USCIS' Business Transformation Initiative; the need to integrate the 
present digitization efforts with the future envisioned for newer 
electronic files under the Business Transformation Initiative; and, the 
need to determine the feasibility and cost benefits of digitizing 
certain files. At the same time, USCIS will analyze the larger policy 
and operational issues discussed above to assess the effectiveness of 
the approach and new system components, adjusting as indicated by the 
experiences of this pilot.

Thank you again for the opportunity to comment on this draft report and 
we look forward to working with you on future homeland security issues.

Sincerely, 

Signed By: 

Steven J. Pecinovsky: 

Director:

Departmental GAO/OIG Liaison Office:

[End of section]

Appendix III: GAO Contact and Staff Acknowledgments:

GAO Contact: Randolph C. Hite, (202) 512-3439 or [Hyperlink, 
hiter@gao.gov] 

Staff Acknowledgments:

In addition to the contact named above, the following staff made key 
contributions to this report: Michael Marshlick, Assistant Director; 
Elena Epps; Kate Feild; and Nancy Glover.

(310610): 

[End of Section]

FOOTNOTES

[1] According to agency officials, of USCIS's approximately 250 
offices, 89 are considered file control offices. A file control office 
is an office that is authorized to create, store, transfer, receive, 
maintain, and retire A-Files.

[2] According to USCIS program officials, the 75-year storage period is 
a National Archive and Records Administration requirement.

[3] Form I-485 is one of the more complex forms and business processes 
that USCIS uses. It is used by adjudicators to make decisions on 
granting permanent residency to alien applicants.

[4] The purpose of the lock box is to provide a single mailing location 
for applications and a capability for accepting and depositing fees. 

[5] CLAIMS 3 is a customer repository designed to provide funds control 
for fees collected with applications, record the results of 
adjudications for each benefit, and provide case status information to 
applicants. This system became operational in 1993.

[6] DHS, Office of Inspector General, USCIS Faces Challenges in 
Modernizing Information Technology, OIG-05-41 (Washington, D.C., 
September 2005).

[7] OIG-05-41.

[8] The National Commission on Terrorist Acts Upon the United States, 
The 9/11 Commission Report (Washington, D.C., July 2004), 388.

[9] USCIS officials stated that they are now considering modifying the 
scope of the pilot.

[10] House of Representatives Conference Report 108-774 to accompany 
H.R. 4567 (Oct. 9, 2004).

[11] Fiscal year 2005 funds remain available for this contract pursuant 
to 31 U.S.C. ß 1558, which generally provides that funds available to 
an agency for a contract at the time a protest is filed shall remain 
available for obligation for 100 days after the date a final ruling is 
made on the protest.

[12] See, for example, GAO, National Aeronautics and Space 
Administration: Long-standing Financial Management Challenges Threaten 
the Agency's Ability to Manage Its Programs, GAO-06-216T (Washington, 
D.C.: Oct. 27, 2005).

[13] GAO, Highlights of a GAO Forum: Mergers and Transformation: 
Lessons Learned for the Department of Homeland Security and Other 
Federal Agencies, GAO-03-293SP (Washington, D.C.: Nov. 14, 2002).

[14] An enterprise architecture provides a clear and comprehensive 
picture of an entity--whether an organization (e.g., federal department 
or agency) or a functional or mission area--that cuts across more than 
one organization. This picture consists of snapshots of both the 
enterprise's current "as is" operational and technological environment 
and its target or "to be" environment, as well as a capital investment 
road map for transitioning from the current to the target environment. 
These snapshots further consist of "views," which are basically one or 
more architecture products that provide conceptual or logical 
representations of the enterprise. 

[15] Institute of Electrical and Electronics Engineers, IEEE/EIA Guide 
for Information Technology, IEEE/EIA 12207.1 - 1997 (April 1998).

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