INS User Fee Revisions:

INS Complied With Guidance but Could Make Improvements

GGD-98-197: Published: Sep 28, 1998. Publicly Released: Oct 8, 1998.

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Pursuant to a congressional request, GAO reviewed the Immigration and Naturalization Service's (INS) fee increase proposal, focusing on: (1) the extent to which INS' methodology for computing the proposed application fees complied with federal user fee requirements and used generally accepted statistical sampling procedures; and (2) whether INS recognized implemented and proposed changes to the naturalization process in its application fees.

GAO noted that: (1) on the basis of its user fee study, INS revised the fees it charges for 30 types of immigration and naturalization applications; (2) GAO believes, on the basis of its discussions with Office of Management and Budget (OMB) staff and its review of INS' efforts to identify the costs associated with processing applications, that INS complied, to the extent it was able, with OMB user fee guidance; (3) OMB guidance requires agencies to recover, whenever possible, the full cost of providing their services; (4) however, according to its 1997 fee study report, INS was unable to determine its full cost for processing applications because: (a) INS' financial management information system does not provide actual cost data, including items such as depreciation and support service costs from other INS functions; and (b) INS excluded certain cost items because INS said it lacked guidance on how to treat them; (5) had INS been able to determine these costs and include them in its fee computation, the revised fees could have been set at a higher level; (6) INS' initial plan for sampling the processing of applications at regional service centers and selected district offices and by selected personnel to determine how long it took to process various applications incorporated generally accepted statistical sampling procedures; (7) however, some of the changes INS made for operational reasons to its planned statistical sample during implementation undermined scientific sampling principles and adversely affected INS' ability to project the study's results to all application processing sites; (8) GAO is unable to determine the impact of these changes on the revised user fees; (9) INS is reengineering the way it processes naturalization applications; (10) changes to the naturalization process are intended to improve the integrity of the process and make it more efficient and customer oriented; (11) since these changes took place after INS' fee study, the fee revisions do not recognize these changes; and (12) INS officials said INS is planning to initiate the next Immigration Examination Fee Account user fee review early in fiscal year 1999 and, at that time, the study will recognize any naturalization process or other process changes that have taken place.

Recommendation for Executive Action

  1. Status: Closed - Implemented

    Comments: INS agreed with the recommendation and will ensure that sampling methodologies are consistent with generally accepted social science techniques.

    Recommendation: To improve confidence in the sampling methodologies used to determine future immigration and naturalization fees, the Commissioner of INS should ensure that future samples are consistent with generally accepted social science techniques and that the statistical integrity of the sampling plans is maintained throughout the study.

    Agency Affected: Department of Justice: Immigration and Naturalization Service

 

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