Immigration Management:

Strong Leadership and Management Reforms Needed to Address Serious Problems

GGD-91-28: Published: Jan 23, 1991. Publicly Released: Jan 23, 1991.

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GAO conducted a general management review of the Immigration and Naturalization Service (INS) to assess its overall role and performance and identify ways to meet the challenges it faces while experiencing unprecedented growth and change.

GAO found that INS management: (1) was constrained by such environmental factors as the diversity of its mission, unpredictable and changing world conditions, negative perceptions of its abilities, and difficulty in coordinating its work with various agencies and outside interest groups; (2) failed to provide effective leadership, resulting in the development of a group of autonomous, segmented programs; (3) failed to address critical strategic issues facing its enforcement mission and did not delineate responsibilities among the various programs, resulting in program overlaps, inconsistent implementation, and ineffective personnel use; (4) failed to address the increase in convicted aliens and unauthorized aliens in its detention program, resulting in inadequate and understaffed facilities; (5) lacked an overall enforcement strategy to integrate interrelated programs, clearly delineate responsibilities, determine appropriate staff for those responsibilities, and assess detention needs; (6) failed to fully utilize new revenue sources to improve service delivery problems and alleviate substantial delays in adjudication processing; (7) failed to resolve problems involving delays at land border crossings and excessive overtime costs within its inspection program; (8) had a chaotic approach toward budget development and weak controls over revenue and expenditures; and (9) had a decentralized organizational structure that increased geographic fragmentation of program operations. GAO also found that the INS Commissioner, in early 1990, centralized budget control and personnel functions and developed a reorganization proposal, but failed to provide stronger accountability systems or adequately address serious geographic and program fragmentation in its enforcement program.

Matters for Congressional Consideration

  1. Status: Closed - Implemented

    Comments: The House Judiciary Subcommittee on Immigration held hearings on April 24, 1991, as recommended in the GAO report. It also held hearings on October 5, 1994.

    Matter: To ensure continued attention to solving INS problems, the Senate and House Committees on the Judiciary should hold oversight hearings on the recommendations in this report, as well as the recommendations of the management group appointed by the Attorney General.

  2. Status: Closed - Implemented

    Comments: The Senate Judiciary Subcommittee on Immigration held hearings on June 24, 1991, as recommended in the GAO report.

    Matter: To ensure continued attention to solving INS problems, the Senate and House Committees on the Judiciary should hold oversight hearings on the recommendations in this report, as well as the recommendations of the management group appointed by the Attorney General.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: This recommendation is being closed because there are no specific plans to address the overlap issue on an agency-wide basis.

    Recommendation: To address the overlap and duplication in the enforcement program, the Commissioner, INS, should assess the enforcement mission and determine the appropriate units and personnel needed to carry out the various roles. As a general rule, the Border Patrol should concentrate its efforts at the borders, and Investigations Division agents should be assigned tasks commensurate with their training and grade level.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  2. Status: Closed - Not Implemented

    Comments: Current detention issues were addressed by GAO/GGD-92-85 and its attendant recommendations.

    Recommendation: To deal with problems in the detention program, the Attorney General and the Commissioner, INS, should work together to determine the level of funds needed to fill all required detention positions and address the security problems at detention facilities. The Commissioner should take steps to immediately address the dangerous situations at the El Centro and Krome detention facilities. INS should initially attempt to resolve those staffing and security shortages within existing resource constraints. In the long term, the Commissioner should develop a detention plan that not only determines the detention space needed, but also specifically outlines the level of security required for the increasing number of aliens detained. The Commissioner should also ensure that staff requirements, both in terms of number and funds needed, become an integral part of detention planning so that new facilities are not only built, they are also adequately staffed.

    Agency Affected: Department of Justice

  3. Status: Closed - Not Implemented

    Comments: Current detention issues were addressed by GAO/GGD-92-85 and its attendant recommendations.

    Recommendation: To deal with problems in the detention program, the Attorney General and the Commissioner, INS, should work together to determine the level of funds needed to fill all required detention positions and address the security problems at detention facilities. The Commissioner should take steps to immediately address the dangerous situations at the El Centro and Krome detention facilities. INS should initially attempt to resolve those staffing and security shortages within existing resource constraints. In the long term, the Commissioner should develop a detention plan that not only determines the detention space needed, but also specifically outlines the level of security required for the increasing number of aliens detained. The Commissioner should also ensure that staff requirements, both in terms of number and funds needed, become an integral part of detention planning so that new facilities are not only built, they are also adequately staffed.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  4. Status: Closed - Not Implemented

    Comments: INS has implemented a Direct Mail Program that employs a two-prong processing structure, the service centers and the district offices, to expedite the adjudication process. All adjudications that do not involve personal interviews will be directed to the service centers. The district offices can then place their resources in areas such as naturalization, adjustment of status, and employment authorizations to enhance quality in adjudication and service. Implementation of CLAIMS, a fully automated adjudication system, has dramatically increased the four service centers' productivity. CLAIMS is now being installed in the district offices. INS eased asylum adjudication delays by diverting the initial processing of asylum applications from the field offices to the service centers where data entry and mail services can be efficiently provided. INS will continue to conduct regular analyses on workload and resource management to ensure efficiency and quality in adjudications.

    Recommendation: To confront the continuing delays in adjudications processing, the Commissioner, INS, should develop a long-term plan to improve processing of applications. Such a plan should include an annual assessment of adjudications work load and resources, and it should provide more resources to district offices that have historically not been able to process applications in a timely manner. This plan should also consider the impact of significant changes to the adjudications program, such as the establishment of the asylum corps and the role of the service centers in increasing productivity. INS leadership must take full advantage of opportunities to improve service through better resource management and effective use of new sources of revenues provided by the examinations fee account.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  5. Status: Closed - Not Implemented

    Comments: INS has developed three staffing models.

    Recommendation: To enhance INS inspections activities, the Commissioner, INS, should develop an inspection workforce plan that better identifies current staffing requirements and charts out actions for future staffing needs. Such a plan should specifically outline steps necessary to address the shortage of staff at land border crossings and the highly inefficient use of overtime. In addition to better workforce planning, the Commissioner should take a number of other actions to address high overtime costs. Specifically, scheduling procedures at all ports of entry should be examined to minimize unneeded overtime. Also, the Commissioner should reexamine the 1931 act that authorizes overtime to see whether legislative revisions are needed to make the law more consistent with today's environment and prudent business practices.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  6. Status: Closed - Implemented

    Comments: INS has appointed a top management official to oversee finance. Further, INS is implementing the DOJ financial management information system. INS did not, however, establish a group of top experts to assist in designing an effective financial management system. INS has committed to convert to the Department's Financial Management Information System.

    Recommendation: To strengthen the INS budget development process and controls over revenue and expenditures, the Attorney General, in consultation with the Director, Office of Management and Budget (OMB), should establish a group of top experts to work with the INS Commissioner on how best to design and implement an effective financial management system by the end of fiscal year 1991. Those experts should be from both other federal agencies and private organizations. Specifically, the financial management system must comply with applicable accounting principles, standards, and requirements and internal control standards and such policies and requirements as may be prescribed by the OMB Director.

    Agency Affected: Department of Justice

  7. Status: Closed - Implemented

    Comments: INS relies on members of its Executive Staff to make recommendations on major program resource issues.

    Recommendation: In concert with the implementation of a financial management system, INS should put in place an integrated budget formulation process that provides more stability, is based on priorities established in the planning process, and allocates resources on the basis of work load.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  8. Status: Closed - Implemented

    Comments: In 1994, INS implemented a revised organizational structure and a strategic planning process intended to provide direction, improve accountability, and clearly delineate line authority and program development. As part of the reorganization, the Office of Policy and Planning was established to improve long-range planning and policy direction from headquarters. Also, an Executive Associate Commissioner for Field Operations was established to oversee and coordinate the operational aspects of enforcement and service delivery. This recommendation is being closed because INS has taken action on revising its organizational structure without addressing the substance of the recommendation.

    Recommendation: The Commissioner, INS, should continue to take steps to increase headquarters' role in program resource and policy decisions. However, before a revised organizational structure is adopted, the Commissioner should develop an enforcement strategy. Once specific roles and responsibilities of the various enforcement organizations are determined, the Commissioner should develop an organization to carry out those responsibilities. To this end, the Commissioner should consider consolidating all field enforcement functions, including Border Patrol and district enforcement organizations, under a revised field structure that would centralize all INS enforcement functions under a single official within a geographic area.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  9. Status: Closed - Implemented

    Comments: A Strategic Planning Process has been developed. A follow-on Strategic Planning Working Group is developing the initial Strategic Plan to guide overall mission accomplishment through the year 2005. Its recommendations for the Commissioner's FY 1994 priorities to guide FY 1994 program operations have been completed. Input into operations has been completed. Input into FY 1994, 1995, and 1996 budget activities will be provided by this group pending the completion of the plan in FY 1994. Accountability is a key component being built into the Strategic Plan and the various subsidiary plans being developed by individual programs by short-, mid-, and long-range operations.

    Recommendation: The Commissioner, INS, should strengthen planning and accountability systems so that all managers are working toward the same goals and can be held accountable for organizational performance.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  10. Status: Closed - Not Implemented

    Comments: In response to GAO's recommendations, as well as those made by others, INS put forth a solicitation in January 1997 to acquire a financial management system that would provide complete, reliable, consistent, and timely information. The system is also to integrate the budget formulation, budget execution, and accounting functions into a common system for use throughout the agency. INS announced a contract award in April 1997 and a phased implementation is planned beginning in fiscal year 1998. This recommendation is being closed because INS has taken steps to respond to the recommendation and because a recommendation in a more recent GAO report (GGD-97-132) provides for following up on the implementation of the new financial management system. The current recommendation will track whether INS has taken steps to mitigate the risks associated with the implementation of its new financial management system.

    Recommendation: The financial management system, as designed by the Attorney General, should provide for complete, reliable, consistent, and timely information that is prepared on a uniform basis and is responsive to the financial information needs of agency management.

    Agency Affected: Department of Justice

  11. Status: Closed - Implemented

    Comments: Selected cost information is available to all DBM users. Cost data include general expenses detailed to the location level and personnel services and benefits aggregated to the regional level. System change requirements have been developed and submitted to the Department for programming that will allow a complete status of resources to be reported to all locations. Delivery of this enhancement is expected during the first quarter of FY 1994.

    Recommendation: The financial management system, as designed by the Attorney General, should provide for the development and reporting of cost information.

    Agency Affected: Department of Justice

  12. Status: Closed - Implemented

    Comments: GAO has no information on the actions taken in response to this recommendation.

    Recommendation: The financial management system, as designed by the Attorney General, should provide for the integration of accounting and budgeting information.

    Agency Affected: Department of Justice

  13. Status: Closed - Implemented

    Comments: INS has also implemented CLAIMS in four of the service centers. Implementation in the district offices is scheduled to be completed in FY 1994. This system automates the adjudication process and provides information on each application, including fee receipt information where applicable. The implementation of CLAIMS in INS service centers accounts for almost all of INS fee receipts.

    Recommendation: The financial management system, as designed by the Attorney General, should provide for controls to ensure that all fees are being collected, deposits of funds are timely and adequately supervised, fee estimates are more accurate, and fees are used for the appropriate purposes.

    Agency Affected: Department of Justice

  14. Status: Closed - Implemented

    Comments: The overall Strategic Plan is being developed with an expected completion date in the fourth quarter of FY 1994. A Commissioner's Planning Conference was held in June 1993 to obtain the input of key service managers. Input will be solicited from other "stakeholders" in the fall of 1993 and from federal agencies with a working interest in INS during FY 1994. Recent and continuing hearings and discussions with Congress, DOJ, and the White House provide clear input on short- and long-range priorities for INS. FY 1994 priorities will be reflected in the FY 1994 Budget Execution Plan and the annual operational plans being developed for operations management programs. In addition, specific programs are developing and refining longer-range plans to guide their operations.

    Recommendation: The Commissioner, INS, with input from DOJ, Congress, and immigration interest groups, should clearly set priorities within the framework of the overall INS mission. Involvement of all those parties is critical, not only because of the additional perspective each brings to the process, but because with their involvement, they will be more committed to the priorities. Once priorities are established, the Commissioner should improve INS operational planning by: (1) developing program and unit operational plans based on agencywide priorities that adequately consider program interrelationships; (2) coordinating and integrating all individual program and administrative function planning; and (3) designing a multiyear staff development program to ensure that appropriate people are properly trained and developed to manage INS and carry out its mission.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  15. Status: Closed - Implemented

    Comments: Annual priorities and goals for FY 1994 are being established with input from the Strategic Planning working group. The priorities and goals will integrate the individual plans being developed by headquarters and field components.

    Recommendation: The Commissioner, INS, should improve communication by: (1) clearly communicating priorities and goals so that program and unit managers can develop action plans that support and are integrated with overall INS priorities; and (2) involving more managers in policy development decisions.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

  16. Status: Closed - Implemented

    Comments: The Performance Analysis System (PAS) is a semiautomated system that provides operations statistics on work units and associated hour expenditures for a broad range of INS programs. PAS statistical reports were designed to provide managers with the capability to determine organizational efficiency and effectiveness and to make decisions with reference to resource deployment and budget preparation. The PAS tactical plan, to continue implementation of the on-line data entry system conversion to a fourth generation database management system with automated data collection, will reduce the data collection process and provide more-accurate and timely information for more-efficient use of resources. PAS will continue as an ongoing system while it is being converted.

    Recommendation: The Commissioner, INS, should establish systems to foster accountability. Most critical to this process is the development of accurate, meaningful, and timely management information.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

 

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